3M 2011 Annual Report Download - page 109

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Environmental Matters
As previously reported, the Company has been voluntarily cooperating with ongoing reviews by local, state, national
(primarily the U.S. Environmental Protection Agency (EPA)), and international agencies of possible environmental
and health effects of various perfluorinated compounds (“PFCs”), including perfluorooctanoate or “PFOA” and
perfluorooctane sulfonate or “PFOS” and other perfluorooctanyl compounds. As a result of its phase-out decision in
May 2000, the Company no longer manufactures perfluorooctanyl compounds. The company ceased manufacturing
and using the vast majority of these compounds within approximately two years of the phase-out announcement, and
ceased all manufacturing and the last significant use of this chemistry by 2008. Through its ongoing life cycle
management and its raw material composition identification processes associated with the Company’s policies
covering the use of all persistent and bio-accumulative materials, the Company has on rare occasion identified the
presence of precursor chemicals in materials purchased from suppliers that may ultimately degrade to PFOA, PFOS
or similar compounds. Upon such identification, the Company works to find alternatives for such chemicals.
Regulatory activities concerning PFOA and/or PFOS continue in the United States, Europe and elsewhere, and
before certain international bodies. These activities include gathering of exposure and use information, risk
assessment, and consideration of regulatory approaches. The EPA continues to develop Drinking Water Health
Advisories for PFOS and PFOA, which are expected to be released in 2012. Those advisory levels will supersede the
current provisional advisory levels. In an effort to move toward developing standards under the Safe Drinking Water
Act, the EPA has proposed to have public water suppliers monitor for six PFCs to determine the extent of their
occurrence.
In late 2008 and early 2009, the EPA undertook testing of private wells and soils at certain agricultural sites in
Alabama where wastewater treatment sludge was applied from the municipal wastewater treatment plant in Decatur,
Alabama that received wastewater from numerous sources, including sanitary wastewater from 3M. In this same
timeframe, the EPA also issued provisional health advisory values for drinking water for PFOA of 0.4 parts per billion
(“ppb”) and PFOS of 0.2 ppb. Pursuant to an information request from EPA, a group of local industries, including 3M,
and the Decatur utility have been working to identify and test private wells in the area, and to connect to municipal
water any private wells used for drinking water that exceed the EPA’s provisional health advisory levels. EPA’s and
the industry’s testing of public drinking water supplies in the area indicate that the levels of PFOA and PFOS in
municipal water supplies are well below the provisional health advisories. 3M and other companies have completed a
survey of properties near the sites where Decatur utility’s wastewater treatment sludge was applied to identify any
additional private drinking water wells not already identified by the EPA, and have connected a small number of wells
that exceeded the provisional health advisory levels for PFOS and PFOA to municipal water. 3M and the other
companies have continued to monitor those few private wells that showed levels of PFOS or PFOA above detection
levels but below the EPA’s provisional health advisory levels. EPA has notified 3M that the agency is satisfied that
3M has completed its obligations under the information request and that EPA is closing its request.
The Agency for Toxic Substances and Disease Registry (ATSDR) has completed a bio-monitoring study evaluating
PFC blood levels in volunteers living near the sludge application fields. The Company expects ATSDR to release its
report in 2012.
3M continues its third and final phase of work pursuant to a Memorandum of Understanding with the EPA regarding
an environmental assessment program at the Company’s Decatur manufacturing site. That work includes
groundwater sampling off-site from the Decatur facility (unrelated to the work described above involving the Decatur
utility’s wastewater treatment sludge) as well as at three local landfills used by the facility.
The Company is continuing to make progress in its work, under the supervision of state regulators, to address its
historic disposal of PFC-containing waste associated with manufacturing operations at the Cottage Grove, Minnesota
and Decatur, Alabama plants.
As previously reported, the Company entered into a voluntary remedial action agreement with the Alabama
Department of Environmental Management (ADEM) to address the presence of PFCs in the soil at the Company’s
manufacturing facility in Decatur, Alabama. For approximately twenty years, the Company incorporated its
wastewater treatment plant sludge containing PFCs in fields at its Decatur facility pursuant to a permit issued by
ADEM. After a review of the available options to address the presence of PFCs in the soil, ADEM agreed that the
preferred remediation option is to use a multilayer cap over the former sludge incorporation areas on the
manufacturing site with subsequent groundwater migration controls and treatment. Implementation of that option will
continue throughout the balance of 2012 and is expected to be completed in 2016.