CBIC Control Number 

# 356845
November 4, 2013

VIA Express Mail OPPT Document Control Office (DCO) Attention: Docket ID NumberEPA-HQ-OPPT-2006-0621 1201 Constitution Avenue NW EPA EastBuildingRoom 6428 Washington, DC 20004 RE: 2013 Submission of3M/Dyneonunderthe EPA 2010/2015 PFOA Stewardship Program Dear Sir orMadam: 

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3M Company (3M) is pleased to make our 2013 submission under EPA's 2010115 PFOA Stewardship Program. This submission has been prepared with reference to EPA's "Guidance on Reporting Emissions and Product Content October 2006", the "Reporting Guidance Clarifications for the 2010/15 PFOA Stewardship Program Progress Reports" issued in September 2007, the October 7, 2009 email from your Agency, and to ourMarch 1, 2006letter to former Administrator Johnson committing to the Program. We enclose the paper copy version ofour submission with this letter. We also enclose a CD-ROM containing the public version ofthe submission as requested. There are no CBI versions submitted this year. In 2010, 3M fully integrated the United States-based Dyneon, LLC subsidiary into the 3M Energy and Advanced Materials Division (EAMD), nowthe Advanced Materials Division (AdMD). Thatbusiness, formerly known as Dyneon, is now known as the 3MAdMD fluoropolymers business. The German manufacturing facility and the European business is still referred to as Dyneon. Forthe sake ofsimplicity, the entire fluoropolymer business is referred to in this report as the 3M fluoropolymer business. Reporting for prioryears or reporting of pre-2010 activities will continue to referto the Dyneon subsidiary. In2008 Dyneon was able to meetthe Voluntary PFOA Stewardship Program goal by developing a replacement emulsifier for the fluoropolymers that formerly were made using PFOA. Comparedto PFOA, our new emulsifier has an improved mammalian toxicological profile, a similar environmental toxicological profile and a faster elimination rate in laboratory animals. Dyneon ceased using PFOA for making fluoropolymers atthe end of2008. 2009 was the first full year offluoropolymer productionfor Dyneon using ourreplacement emulsifier. This full year ofproduction demonstrated that Dyneon's new emulsifierwas capable offull scale replacement ofPFOA for every fluoropolymer formerly made using PFOA. We have been using our replacement emulsifier successfully since that time. In 2011, 3Mreported for the year 2010 that a small amount offluoropolymerproduct contained traces ofPFOA. This was due to the sale ofthe final inventory ofproduct made prior to 2009 using PFOA. This inventory was exhausted in 2010, and no fluoropolymer products made using PFOA have been sold since thattime. Accordingly, to streamline this submittal and following the approach used in last year's report, 3M is submitting onlythe Summary TablesOPPT Document Control Office November4, 2013 Page2

(and not all the Reporting Forms) for this year's report. The previouslyrequested Accomplishments Table is appended to the Summary Tables. Dyneon has been using a "capture for recycle" technology at its Gendorf, Germany facility for a number ofyears. As demonstrated bythe 2008 Facility and Summary Emissions Reports, this technology resulted in a 93 percentreduction in PFOA emissions compared to the baseline year. The same technology allows us to recover and reuse the new emulsifier from waste streams and products as efficiently as we were able to recover and reuse PFOA. Dyneon is also using this technology to reduce the new emulsifier content ofour liquid fluoropolymer dispersion products. As the Agency is aware, Dyneon ceased using PFOA at its Decatur, Alabama operations as of the end of2004, although fluoroelastomer production has continued withoutthe use ofany fluorochemical emulsifier during polymerization. 3M continues to have no production related emissions ofPFOA, higher homologues orprecursors from its Decatur fluoropolymer operations. 3M continues to support the 2010115 PFOA Stewardship Program, and as our submission reflects, atthe end of2008 we metthe Program's 2015 emissions and product contentreduction goals. Should you have any questions regarding this submission, please do not hesitate to contactKarl Weilandt or Gary Hohenstein with any questions. ·· Verytrulyyours,

Karl Weilandt Technical Manager 3MAdvanced Materials Division 6744 33rd Street Oakdale, MN 55128 651-575-3722

Enclosures

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# /}:10~ Man'&er Environmental & Regulatory Affairs 3M Building 224-5W-03 St. Paul, MN 55144 651-737-3570

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