Document VJRakL9Gq2bJGJm469zz3eGM4

Dr. Russell H. Susag, P.E. Di rector Environmental Regulatory Activities 3M Company P.0. Box 3331 St. Paul, Minnesota 55133 Dear Dr. Susag: The Mi nnesota Pollution Control Agency (MPCA) is in the process of conducting an investigation of a disposal site that allegedly existed along the Mississippi River at the Chemolite Plant. I am writing this letter to ask for yo ur assistance and cooperation in this particular investigation, as well as to ask that 3M review and report on its overall past hazardous waste disposal practices. The alleged disposal site was utilized by 3M during 1950 to 1955 for the burial of drums containing isocyanates, fluorocarbons, benzenes, acroleins and polymerizable materials. The wastes buried at the site were to have originated from 3M's Central Research and Pilot Plants in Maplewood, Minnesota, the Benz Building on Lafayette Street in St. Paul, Minnesota and the Busch Building just off Highway 35W. The Agency originally became aware of the disposal site as the result of an anonymous co m p l a i n t re ceived on the M P C A 's "hotline." Since the complaint was received, members of the Agency's staff have been reviewing aerial photographs dating back to the time when the disposal site was used and have found sufficient evidence to indicate the presence of a disposal site. The A g e n c y is c o n c er ne d that this dump site m a y have the potential for contaminating the ground water and surface water in the area depending upon the types and volumes of waste material that were disposed of at the site. The A g en cy is therefore requ esting that 3M research its files and interview relevant present and past employees to determine what specific 3M wastes were or were likely to have been disposed of at the afore mentioned burial site; the approximate volume of waste that would have been disposed of at the site; the duration of time the site was utilized; and submit this information in writing to the Agency by May 29, 1981. Phone: 2 9 7 - 3 7 1 7 1935 West County Road B2, Roseville, Minnesota 55113 Regional Offices Duluth/Brainerd/Detroit Lakes/Marshall/Rochester Equal Opportunity Em ployer Dr. Russell H. Susag, P.E. Page Two A point from which 3M may wish to initiate their investigation would be to discuss this matt er with Mr. Irwin Brown, an Executive for 3M. The complaintant alleged that Mr. Brown was in charge of the disposal area during the time of its operation. 3M should also already by in the process of compiling this type of information on all past hazardous waste disposal sites as required under the Federal "Comprehensive Environmental Response, Compensation, and Li ability Act" w h i c h was signed into law in December of 1980. In Section 103(c) of the law it states in part: "(c) Within one hundred and eighty days after the enactment of this Act, any person who owns or operates or who at the time of disposal owned or operated, or who accepted hazardous substances for transport and selected, a facility at which hazardous substances (as defined in section 1 0 1 ( 1 4 ) (c) of this title) are or have been stored, treated, or disposed of shall, unless such facility has a permit issued under, or has been accorded interim status under subtitle C of the Solid Waste Disposal Act, notify the Administrator of the Environmental Protection Agency of the existence of such facility, specifying the amount and type of any hazardous substance to be found there, and any known, suspected, or likely releases of such substances from such facility." With this letter, the A g e n c y is formally requesting that 3M also provide the MP CA with this type of in formation for all of its past hazardous waste disposal other than the already known Oakdale, Woodbury and Kerrick sites. Please do so within the same timeframe you are required to report to the Environmental Protection Agency. The Agency looks forward to 3M's cooperation concerning these matters. If you have any questions, please feel free to contact me at your convenience. Sincerely, VV\vC\ (joajLUl.1 Michael B. Ayers K Regulatory Compliance Section Solid and Hazardous Waste Division MBA/dc cc: Paul Brandt, Washington County Solid Waste Officer