Ward
Penberthy
04/
30/
2003
12:
48
PM
To:
masantoro@
mmm.
com
cc:
(
bcc:
Mary
Dominiak/
DC/
USEPA/
US)
Subject:
Follow­
up
Questions
Regarding
3M
LOI
Commitments
In
the
March
13,
2003
3M
Letter
of
Intent
there
are
commitments
to
environmental
monitoring.
We
would
like
to
understand
precisely
what
work
is
being
undertaken
and
would
appreciate
some
clarification
about
these
LOI
items.
After
we
understand
the
specifics
of
the
LOI
commitments,
we
will
be
in
a
better
position
to
identify
testing
issues
that
are
adequately
dealt
with
in
the
LOIs
vs.
items
that
may
need
to
be
addressed
in
the
ECA
discussions
commencing
on
June
6.

To
that
end,
could
you
please
provide
a
detailed
description
of
the
environmental
monitoring
studies
that
are
described
in
the
LOI?
In
addition,
EPA
requests
clarification
on
the
following
specific
items:

page
7
item
3
Monitoring
of
groundwater,
surface
water
and
other
environmental
media
How
many
samples
will
be
analyzed
from
each
location?

What
is
the
sampling
strategy?

What
test
method
(
standard)
will
be
used
to
analyze
the
samples
(
e.
g.,
ASTM,
EPA,
OECD,
other

specify)?
Has
the
test
method
ever
been
validated?

What
is
the
accuracy
and
precision
of
the
test
method?

Will
PFOA
precursors
and/
or
other
chemicals
be
analyzed
for
in
addition
to
APFO/
PFOA?
If
so,

which
ones?
What
is
the
timing
of
this
work?

Do
you
have
a
consolidated
written
description
of
the
procedures
that
will
be
followed
with
this

testing?
If
so
please
provide
a
copy.
If
these
procedures
have
already
been
identified
in
a
submission
to
the
Agency
(
ie.
to
AR226
or
8(
e)),
please
identify
the
submission.

We
would
appreciate
a
response
by
May
5,
2003.
Please
call
me
at
202
564
­
8171
if
you
have
any
questions
or
need
to
discuss
further.
Thanks
for
your
continued
help
on
these
matters.
