October 30, 2015 

VIA Express Mail 

OPPT Document Control Office (DCO) 

Attention: Docket 1D Number EPA-HQ-OPPT-2006-0621 

1201 Constitution Avenue NW 

EPA East Building Room 6428 

Washington, DC 20004 

HECEI\!ED 

0PP1 Cf!JIC 

20/5 NOV -2 P'' 

n 12 :53 

CBIC Control Number 

366794 

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

PFOA Stewardship Program 

Dear Sir or Madam: 

3M Company (3M) is pleased to make our 2015 submission under EPA's 2010/15 PFOA 

Stewardship Program. This submission has been prepared with reference to EPA's "Guidance 

on Repmting Emissions and Product Content October 2006", the "Reporting Guidance 

Clarifications for the 2010/15 PFOA Stewardship Program Progress Repmts" issued in 

September 2007, the October 7, 2009 email from your Agency, and to our March 1, 2006letter 

to fanner Administrator Johnson committing to the Program. 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 repmt as the 3M fluoropolymer business. Repmting for prior years or repmting of 

pre-20 I 0 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 emuJsifier has an improved mammalian toxicological 

profile, a similar enviroamenta!,toxicologipal profile and a faster elimination rate in laboratory 

animals. Dyneon ceased 'using PFOA for making fluoropolymers at the end of2008. , · 

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 ofPFOA for every fluoropolymer formerly made using 

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

In 2011, 3M repmted for the year 20 I 0 that a small amount of fluoropolymer product contained 

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

using PFOA. This inventmy 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 

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

Accomplishments Table is appended to the Summaty Tables. 
OPPT Document Control Office 

October 30, 2015 

Page2 ,:'• 

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 Suiriillary 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. 

In summary, as a result of its phase-out decision in May 2000, the Company no longer 

manufactures perfluorooctanyl compounds, including PFOA. The company ceased 

manufacturing and using the vast majority of these compounds within approximately two years 

of the phase-out announcement, and ceased all manufacturing and the last significant use of this 

chemistry by 2008. Through its ongoing life cycle management and its raw material 

composition identification processes associated with the Company's policies covering the use 

of all persistent and bio-accumulative materials, the Company identifies on occasion the 

presence oflong-chain perfluoroalkyl substances (long-chain PFASs, including PFOA) or 

precursor chemicals that may ultimately degrade to long-chain PF ASs in materials. Upon such 

identification, the Company works to find alternatives or alternative suppliers for such 

materials. It should be noted, however, that even when PFOA or PFOA-related substances are 

not intentionally manufactured, processed or used in the manufacturing of fluoropolymers, they 

may still be present in trace quantities in some products. 

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

reflects, at the end of2008 we met the Program's 2015 emissions and product content reduction 

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

contact Karl Weiland! or Gary Hohenstein with any questions. 

V ety truly yours, 

Karl Weiland! 

Laboratory Manager 

3M Advanced Materials Division 

6744 33'd Street 

Oakdale, MN 55128 

651-575-3722 

Enclosures 

~~ M~~ai~ Environmental & Regulatory Affairs 

3M 

Building 224-5W-03 

St. Paul, MN 5 5144 

651-737-3570 
· RepoFied Emissions and Prodnct Content 

9th'Year Chemical Emissions 

Dyneon I 

3M 

s 

2014 

Category 

PFOA, 

PFOA salts 

and Higher 

Homologue 

s 

Precursors 

Releases to all 

inec:lia from FP 

and Telomer, 

Manufacturi!lg 

(kg) 

3M no 

longer 

intentionally 

manufactures 

or imports 

any 

LCPFAC 

chemical 

substances 

kg,ofrelease I, 

kg of product 

roc:luced · 

3M no 

longer 

intentionally 

manufactures 

or imports 

any 

LCPFAC 

chemical 

substances 

tiisi)e~si_ons 

(ppm wet', 

Wei ht basis) 

3M no 

longer 

intentionally 

manufactures 

or imports 

any 

LCPFAC 

chemical 

substances 

0 

Other 

Fll!oropolyriters 

(ppm dry-weight 

basis) 

3M no longer 

intentionally 

manufactures 

or imports 

anyLCPFAC 

chemical 

substances 

Telomers 

(Jlpmdryc 

weight 

b~iS; 

wliess 

stated 

otherwise 

No 

Telomer 

Production 
Compa 9th Chemi Emissions ProdnctContent 

ny Yea .cal 

Dyneon 

/3M 

ucti 

ons 

2014 

Categ 

ory 

PFOA, 

PFOA 

salts 

and 

Higher 

Homo! 

ogues 

Pre cur 

sors 

Releas.es to all media 

from FP and Telomer 

Manufachlrin ·. k · 

3M no longer 

intentionally 

manufactures or 

imports any 

LCPFAC chemical 

substances 

imports any 

LCPFAC 

chemical 

substances 

0 

Dispersions 

(ppm wet-weight . 

basis) 

3M no longer 

intentionally 

manufactures 

or imports any 

LCPFAC 

chemical 

substances 

Other, 

Flnoropolymer 

s(ppmdry;-

. wei lit basis 

3M no longer 

intentionally 

manufactures 

or impmts 

any LCPFAC 

chemical 

substances 

e~~'tions 

Telomers 

·(ppm dry' 

weight 

b@SiS~ 

-Unless 

stated 

· . otherwise) 

No 

Telomer 

Production 
, Reported Percent Reductions in Emissions and Product Content 

Table 3. Reported Percent Reductions in Emissions and Product Content ofPFOA, Precursors, and Higher Homologues from 

U.S. 0 erations 

Company 

Dyneon/3M 

9thYear Chelllical' 

Reductions Category 

2014 

PFOA, 

PFOA salts 

and Higher 

Homolo ues 

Precursors 

.% Reductl()n in Enli$sioits . 

%Reductions in.!otal 

quantityofchemical(s)•· 

r<Mased from baseline 

100% 

Fluoropolymers 

100% Not Applicable 

No Precursor Production 

Telomer based 

products 

No Telomer 

Production 
Table 4. Reported Percent Reductions in Emissions and Product Content of PFOA, Precursors, and Higher Homologues from 

Non U.S. 0 erations 

Company 

Dyneon/3M 

9th.¥ ear .. · 

Reductions 

2014 

Chenilcal 

C:ategory 

PFOA, 

PFOA salts 

and Higher 

Homologues 

Precursors 

%Reductions in total 

qullutityofchelllical(s) 

released front baseline 

100% 100% 100% 

No Precursor Production 

No Telomer 

Production 
3M Fluoropolymers Accomplishments Table 

Company Facilities Reductions 

Emissions Product Content 

United States 100% 100% 

Non-United States 100% 100% 

Global 100% 100% 

Please enter a% number for each of the fields in the table below. 

When necessary, please combine PFOA, precursors, and higher homologues into one PFOA-equivalent number. 

In addition, please combine U.S. and non-U.S. reductions into a global reduction, if possible.