Column: New questions from regulators regarding 3M and PFAS in Wausau’s water

Wausau’s Independent: By Tom Kilian for Wausau Pilot & Review

If 3M Company, as it has stated, does not use or store PFAS-containing substances at its local facilities that produce roofing granules, then why did the EPA send the corporation a letter in August requesting information about the PFAS contamination identified in Wausau city wells?

That seems like a good question.

When I recently learned of this document – which few seem to know even exists – my first thought was that the EPA’s information-request letter was probably just a generic inquiry from the feds based on 3M’s broader history and association with PFAS.

But after reviewing it on the DNR’s website, I realized that was not the case.

In the August 6, 2024 letter to 3M, the EPA addresses the City’s 2019 PFAS testing results from city wells that are part of the federally-regulated Wausau superfund site along the Wisconsin River (that encompasses areas like the former Wausau Chemical property and an old City dump).

The agency writes:

“In 2019, sampling at the Site identified PFAS at concentrations above EPA’s recently finalized maximum contaminant limit (MCL). 3M manufactures PFAS and uses PFAS in products it manufactures. For several decades in the mid to late 1900s, 3M operated two facilities in Wausau, Wisconsin. For purposes of this information request, EPA has identified these facilities as the 3M Greystone Facility located at 410 Decatur Drive and the 3M Downtown Wausau Facility located at 144 West Rosecrans Street. The questions contained in this request pertain specifically to operations at these two facilities.”

The information requested from 3M by the EPA in the letter ultimately gets surprisingly specific and local, focusing on a particular chemical at one point:

“Provide dates for the following events: a. 3M first synthesizes or purchases NEtFOSAA; b. 3M first uses NEtFOSAA commercially or industrially; c. 3M uses NEtFOSAA in any stage of the commercial or industrial process to produce or treat roofing granules; d. NEtFOSAA is first present at the 3M Greystone Facility e. NEtFOSAA is first present at the 3M Downtown Wausau Facility.”

Naturally, the focus and emphasis in this EPA request would raise questions from just about any resident reading it.

What exactly is NEtFOSAA and why is it so darn important to the EPA’s investigation into the PFAS in Wausau’s groundwater?

Information on the Wisconsin Department of Health Services (DHS) website sheds light on what NEtFOSAA is. It is “one of several PFAS that can turn into perfluorooctane sulfonate (PFOS) in the body and environment.” The DHS information also highlights that studies demonstrated high PFOS levels “may affect reproduction, development, cholesterol levels, liver and thyroid function, and immune response.”

In terms of why the contaminant may be important to Wausau, and why the EPA may be asking about it, public records show that NEtFOSAA has been found in the water of city wells in multiple samples that were tested.

Put simply, it looks like NEtFOSAA is a problematic chemical found in Wausau’s groundwater and federal regulators are trying to find out where it is coming from.

But why ask 3M about it in regard to its local facilities?

It might be, in part, because comparing the levels of NEtFOSAA found in the region’s different water samples could be part of the regulators’ investigation.

For example, according to an email from an EPA representative to a DNR representative on April 25, 2024, the only samples to date in the whole DNR Drinking Water System database with NEtFOSAA levels above 2 ng/L were from Wausau Waterworks, Rothschild Waterworks, and the 3M Greystone Plant. Out of the three, the 3M Greystone NEtFOSAA levels were the highest by far at 20 ng/L. The others were in the single digits.

This is the same 3M Greystone plant that garnered public attention last year for very high levels of PFAS identified in the drinking water from its private well.

And the April 2024 email exchange between the EPA and DNR raises additional questions about certain roofing granules, 3M Greystone, and NEtFOSAA.

The EPA representative who is mentioned above wrote to the DNR representative that some information suggests that “roofing granule manufacturing can produce not only PFOA and PFOS in nearby water bodies, but also NEtFOSAA specifically, which is not found in AFFF.” AFFF stands for “Aqueous film-forming foam.” It is more casually referred to as firefighting foam, which can be a common source of PFAS, I have heard.

He also passed along two attachments in that email. One of them is the preliminary report for the PFAS sampling investigation for the 3M Roofing Granule Plant in Corona, California.

Coincidentally, a few years ago, the City of Corona sued 3M Company related to PFAS contamination in the city’s water supply. In that court case, the “complaint specifically points to roofing granules manufactured at [the] 3M facility in Corona as a source of alleged PFAS contamination in the city’s water.”

An email from the DNR representative to the EPA representative on April 29, 2024 relays that the department has had discussion with 3M representatives regarding the Greystone facility “and understand that off-specification roofing granules have been disposed of at this facility.” He references multiple attachments with assorted information in the email.

Later that day, the EPA representative replies, and one of his statements in the email is:

“The communications are incredibly helpful and revealing! The described chemical formula of ‘FC solid’ in ‘FC-129’ in their March 2021 letter is NEtFOSAA. What’s the chance they disposed of solid and liquid waste containing NEtFOSAA at the Greystone Site and it’s not the source of NEtFOSAA that we’re seeing in Wausau’s groundwater?”

Good question. And what exactly is “FC-129”?

FC-129 is apparently a 3M fluorochemical surfactant, according to its material data safety sheet.

And FC-129 was also specifically highlighted in the Minnesota Attorney General’s PFAS lawsuit against 3M in relation to allegations that the corporation misled its own customers about the biodegradability and environmental properties of its chemicals.

It is a lawsuit that could provide some unique insights.

In what was evidently once-confidential 3M internal correspondence from 1988 that became an exhibit for the Attorney General in the lawsuit, a memo about FC-129 biodegradability states, “I don’t think it is in 3M’s long-term interest to perpetuate the myth that these fluorochemical surfactants are biodegradable. It is probable that this misconception will eventually be discovered, and when that happens, 3M will likely be embarrassed, and we and our customers may be fined and forced to immediately withdraw products from the market.”

The memo goes on to state, “If 3M wants to continue to sell and use fluorochemical surfactants …, I believe that 3M has to accurately describe the environmental properties of these chemicals.”

Another document covering 1998 3M internal correspondence used in the lawsuit also mentions FC-129. The document contains a chart marked “draft” that seems to show company viewpoints on what the least desirable type of “uncontrolled exposure” would be. In the chart, “Degradable/Metabolic Precursors of PFOS” is shown as the least desirable type of exposure. One of the two examples listed for this type of exposure in the document: FC-129.

Finally, one record on the Attorney General’s exhibit list in this Minnesota lawsuit was a 1999 resignation letter from one of 3M’s own employees who served in the Environmental Specialist position. The last two sentences of the resignation letter state: “I can no longer participate in the process that 3M has established for the management of PFOS and precursors. For me it is unethical to be concerned with markets, legal defensibility and image over environmental safety.”

Overall, the recent letter from the EPA to 3M, along with information in regulators’ emails, raise questions about whether or not there is a possible connection between any activities at local 3M facilities and specific types of PFAS that have been found in some of our community’s groundwater. Maybe there is and maybe there is not. The questions will, I presume, remain open until such a thing is either ruled out or ruled in by regulators.

It could very well turn out that PFAS-contaminated groundwater identified in different areas of the city each have their own rather unique PFAS profile from the combination of various contributions and sources in those areas. But that would also imply that just because one source may not have caused PFAS contamination in the groundwater of one part of town does not necessarily mean that it did not cause it in another.

Whatever the case, the records and revelations from Minnesota’s lawsuit are at least clear: while 3M’s PFAS chemicals may not degrade, its credibility on PFAS issues certainly has. Hopefully, ongoing environmental investigations will rely on data and common sense to figure out this mess. Not the multinational corporation’s words or word.

Wausau’s Independent is a weekly opinion column by former Wausau Alder Tom Kilian, a founding member of the grassroots environmental group Citizens for a Clean Wausau. Views expressed here are independent of this newspaper and do not necessarily reflect the views of Wausau Pilot. To submit an idea for a future column, email [email protected] or mail to 500 N. Third St. Suite 208-8, Wausau, Wis. 54403.