EPA Sends Letter to 3M Regarding PFAS in Wausau City Wells
- 3M Company, PFAS
- October 7, 2024
While the City of Wausau already sued 3M Company and other manufacturers for PFAS contamination in its municipal water supply, now a federal regulatory agency has submitted a formal information request to 3M regarding PFAS contamination identified in Wausau City Wells as far back as 2019.
High PFAS water levels had been discovered at the 3M Greystone plant last year.
Public records available on the DNR BRRTS website indicate that 3M has received a letter from the EPA regarding PFAS identified in Wausau City Wells in 2019. The EPA letter, dated August 6, 2024, seeks information from 3M relating to PFAS and its two local sites: 3M Downtown in the Thomas Street neighborhood and 3M Greystone farther north. The letter can be accessed via the following link to the DNR’s website, and it is also embedded below this post:
The letter was sent to 3M in relation to a federally-regulated Wausau superfund site. This superfund site involves activities and/or properties of Wausau Chemical, City of Wausau, and Marathon Electric. EPA information about the superfund, which is called “Wausau Groundwater Contamination,” can be found here. The City of Wausau, Wausau Chemical, and Regal Beloit — presumably, the successor on the Marathon Electric property — also received information-request letters from the EPA that can be accessed on the DNR’s page.
Notably and importantly, 3M is evidently the only party to receive an EPA information-request letter that was not involved in the superfund’s Responsible Party group or that does not have a property inside of, or immediately adjacent to, the geographic area of the superfund.
While the EPA points out in the letter that it is seeking the cooperation of 3M, the agency also notes “compliance with the Request for Information is required by law.”
PFAS Identified in 2019 in City Wells
Sampling and testing of water at the site in 2019 identified PFAS contamination in City Wells, such as CW-3 and CW-6, for example. However, the EPA only recently finalized its Maximum Contaminant Level (MCLs) for PFAS. MCLs are the highest level of a contaminant that is allowed in drinking water.
This chart of PFAS sampling, put together by Midwest Environmental Advocates (MEA) some years ago, includes the 2019 sampling results.
In the letter, the EPA states to 3M Company:
“In 2019, sampling at the Site identified PFAS at concentrations above EPA’s recently finalized maximum contaminant limit (MCL). 3M manufacturers 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.”
Examples of some of the many questions and information requests that the EPA makes to 3M in the regulatory agency’s letter are:
- “Have you ever generated at the 3M Downtown Wausau facility by any process or method
wastewater containing PFAS that you then sent to the 3M Greystone facility for storage,
treatment, or disposal?” - “Have you ever generated at the 3M Greystone Facility by any process or method
wastewater containing PFAS that you then sent to the 3M Downtown Wausau facility for
treatment, storage, or disposal?” - “Identify all past and present solid waste units (e.g., waste piles, landfills, surface
impoundments, waste lagoons, waste ponds or pits, tanks, container storage areas) at the 3M
Wausau Greystone facility or 3M Downtown Wausau facility, which may contain PFAS or PFAS bearing substances.” - “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.”
Depending on the ultimate information that the EPA receives from 3M, the PFAS groundwater contamination at the superfund site could raise a variety of important questions for our community.
Red flags regarding the 2019 testing already went up for some in 2022 when the City of Wausau gave its PFAS press conference on February 9, 2022.
In the press conference, the City focused on more recent PFAS water testing without providing any compelling explanation of why it had data showing PFAS water contamination as far back as 2019, along with earlier knowledge of DHS-recommended levels for standards for PFAS in water, and still did not inform the Wausau public in a timely fashion. In fact, in the press conference which was livestreamed, the DNR states that it had not become aware of the City’s 2019 PFAS water results until December 2021. That livestreamed press conference can be viewed below on YouTube, and pertinent questions to the City about the 2019 results begin at roughly 28 minutes and 30 seconds.
This is the first post in a series on this topic from Citizens for a Clean Wausau.
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