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

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## :53 CBIC Control Number 

# 366794

RE: 2015 Submission of3M!Dyneon under the EPA 2010/2015 PFOA Stewardship Program
Dear Sir orMadam:
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 RepmtingEmissions andProduct 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 ourMarch 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 nowknown 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 inthis repmt as the 3M fluoropolymer business. Repmting for prior years or repmting of pre-20I0 activities will continue to refer to the Dyneon subsidiary.
In 2008 Dyneon was able to meettheVoluntary PFOA Stewardship Program goal by developing a replacement emulsifier for the fluoropolymers that formerly were made using PFOA. Compared to PFOA, ournew 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 offluoropolymer production for Dyneon using our replacement emulsifier. This full year ofproduction demonstrated that Dyneon's new emulsifier was capable offull scale replacement ofPFOAfor every fluoropolymer formerly made using PFOA. We have been using our replacement emulsifier successfully since that time.
In 2011, 3Mrepmted for the year 20I0 that a small amount offluoropolymer product contained traces ofPFOA. This was due to the sale ofthe final inventory ofproductmade prior to 2009 using PFOA. This inventmy 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, 3Mis 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.OPPTDocument Control Office October 30, 2015 Page2 ,:'•

Dyneon has been using a "capture for recycle';<technology at its<Gendorf, Germany facility for a number ofyears. As demonstrated by the 2008 Facility and Suiriillary 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 usingthis technology to reduce the newemulsifier 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 without the use ofany fluorochemical emulsifier during polymerization.
In summary, as a result ofits phase-out decision inMay 2000, the Company no longer manufactures perfluorooctanyl compounds, including PFOA. The company ceased manufacturing and using the vastmajority ofthese compounds within approximately two years ofthe phase-out announcement, and ceased all manufacturing and the last significant use ofthis chemistry by 2008. Through its ongoing life cycle management and its raw material composition identificationprocesses associated withthe Company's policies covering the use ofall persistent and bio-accumulative materials, the Company identifies on occasion the presence oflong-chain perfluoroalkyl substances (long-chain PFASs, including PFOA) or precursor chemicals thatmay ultimately degrade to long-chain PF ASs in materials. Upon such identification, the Companyworks 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 offluoropolymers, 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 nothesitate to contact Karl Weiland! or Gary Hohenstein with any questions. 

### Vetytruly yours,

Karl Weiland! Laboratory Manager 3MAdvanced 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 55144 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 Releasesto all inec:liafrom FP

and Telomer, Manufacturi!lg (kg) 

### 3M no longer intentionally manufactures

or imports any LCPFAC chemical substances kg,ofrelease

### I, kg

## ofproduct roc:luced · 

### 3M no longer intentionally manufactures

or imports any LCPFAC chemical substances**tiisi)e~si_ons** (ppmwet', Wei htbasis) 

### 3Mno longer intentionally manufactures

or imports any LCPFAC chemical substances 0 Other Fll!oropolyriters (ppmdry-weight basis) 

### 3Mno longer intentionally manufactures

or imports anyLCPFAC chemical substances Telomers (Jlpmdryc

weight**b~iS;** wliess stated otherwise

No Telomer ProductionCompa 9th Chemi Emissions ProdnctContent ny Yea .cal

Dyneon

/3M ucti ons

2014 Categ ory

PFOA, PFOA

salts and Higher Homo! ogues Precur

sors Releas.es to all media from FPand Telomer

Manufachlrin ·. k ·



### 3Mno longer intentionally manufactures or imports any LCPFAC chemical substances imports any LCPFAC chemical substances 0 Dispersions (ppmwet-weight

. basis) 

### 3M no longer intentionally manufactures or imports any LCPFAC chemical substances Other, Flnoropolymer

s(ppmdry;-

.wei litbasis 

### 3Mno 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 andProduct Content
Table 3. Reported PercentReductions in Emissions and ProductContent 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 frombaseline

100% Fluoropolymers

100% Not Applicable

No Precursor Production Telomer based products

No Telomer ProductionTable 4. Reported Percent Reductions in Emissions and Product Content ofPFOA, 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 intotal qullutityofchelllical(s) released frontbaseline

100% 100% 100%

No Precursor Production No Telomer Production

### 3MFluoropolymers 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 ofthe fields in the table below.
When necessary, please combine PFOA, precursors, and higher homologues into one PFOA-equivalentnumber.
In addition, please combineU.S. and non-U.S. reductions into a global reduction, ifpossible.