CBIC Control Number 

356845 

November 4, 2013 

VIA Express Mail 

OPPT Document Control Office (DCO) 

Attention: Docket ID Number EPA-HQ-OPPT-2006-0621 

1201 Constitution Avenue NW 

EPA East Building Room 6428 

Washington, DC 20004 

RE: 2013 Submission of3M/Dyneon under the EPA 2010/2015 

PFOA Stewardship Program 

Dear Sir or Madam: 

RECEIVED 

OPPT CBIC 

2013 t~OV -6 AH JO: 3 J 

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 our March 1, 2006letter 

to former Administrator Johnson committing to the Program. We enclose the paper copy 

version of our submission with this letter. We also enclose a CD-ROM containing the public 

version of the 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), now the Advanced Materials Division 

(AdMD). That business, formerly known as Dyneon, is now known as the 3M AdMD 

fluoropolymers business. The German manufacturing facility and the European business is still 

referred to as Dyneon. For the sake of simplicity, the entire fluoropolymer business is referred 

to in this report as the 3M fluoropolymer business. Reporting for prior years or reporting of 

pre-2010 activities will continue to refer to the Dyneon subsidiary. 

In 2008 Dyneon was able to meet the Voluntary PFOA Stewardship Program goal by 

developing a replacement emulsifier for the fluoropolymers that formerly were made using 

PFOA. Compared to 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 at the end of 2008. 

2009 was the first full year of fluoropolymer production for Dyneon using our replacement 

emulsifier. This full year of production demonstrated that Dyneon's new emulsifier was 

capable of full scale replacement of PFOA for every fluoropolymer formerly made using 

PFOA. We have been using our replacement emulsifier successfully since that time. 

In 2011, 3M reported for the year 2010 that a small amount offluoropolymer product contained 

traces of PFOA. This was due to the sale of the final inventory of product made prior to 2009 

using PFOA. This inventory was exhausted in 2010, and no fluoropolymer products made 

using PFOA have been sold since that time. Accordingly, to streamline this submittal and 

following the approach used in last year's report, 3M is submitting only the Summary Tables 
OPPT Document Control Office 

November 4, 2013 

Page2 

(and not all the Reporting Forms) for this year's report. The previously requested 

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 of years. As demonstrated by the 2008 Facility and Summary Emissions Reports, 

this technology resulted in a 93 percent reduction 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 of our liquid fluoropolymer 

dispersion products. 

As the Agency is aware, Dyneon ceased using PFOA at its Decatur, Alabama operations as of 

the end of 2004, although fluoroelastomer production has continued without the use of any 

fluorochemical emulsifier during polymerization. 3M continues to have no production related 

emissions of PFOA, higher homologues or precursors from its Decatur fluoropolymer 

operations. 

3M continues to support the 2010115 PFOA Stewardship Program, and as our submission 

reflects, at the end of 2008 we met the Program's 20 15 emissions and product content reduction 

goals. Should you have any questions regarding this submission, please do not hesitate to 

contact Karl W eilandt or Gary Hohenstein with any questions. ·· 

Very truly yours, 

Karl Weilandt 

Technical Manager 

3M Advanced Materials Division 

6744 33rd Street 

Oakdale, MN 55128 

651-575-3722 

Enclosures 

----- IT 1111 

/}:10~ Man'&er 

Environmental & Regulatory Affairs 

3M 

Building 224-5W -03 

St. Paul, MN 5 5144 

651-737-3570 

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