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October 28, 2014



### VIA Express Mail 

## RECEIVED OPPT CBIC
2111 1i 

## OCT 29 

## k;II: I

RECEIVED 

# Nnv 1 3 2014

EPA DOCKET CENTER CBIC Control Number 

# 362430

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: 2014 Submission of 3M/Dyneon under the EPA 2010/2015 PFOA Stewardship Program

Dear Sir or Madam:
3M Company (3M) is pleased to make our 2014 submission under EPA's 2010/15 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, 2006 letter 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 of fluoropolymer 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

October 28, 2014 Page 2

(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.

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 the end of 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 has on occasion identified the presence of precursor chemicals in materials received from suppliers that may ultimately degrade to PFOA, PFOS or similar compounds. Upon such identification, the Company works to find alternatives for such materials.

3M continues to support the 2010/15 PFOA Stewardship Program, and as our submission reflects, at the end of 2008 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 Weilandt or Gary Hohenstein with any questions.
Very truly yours, p. 

### 2



# ea-VgeL

Karl Weilandt Gary ohenstein Laboratory Manager Man ger 3M Advanced Materials Division Environmental & Regulatory Affairs 6744 

### 33' Street 3M Oakdale, MN 55128 Building 224-5W-03 651-575-3722 St. Paul, MN 55144 651-737-3570

EnclosuresP. 3



### Reported Emissions and Product Content

Table 1. Re orted Emissions and Product Content of PFOA, Precursors, and Hi her Elomolo ues from U.S. 0 erations Company Eighth

Year Reductions Chemical

Category Emissions Product Content

Releases to all media from FP and Telomer Manufacturing (kg) kg of

release / kg of product produced Dispersions

(ppm wetweight basis) Other

Fluoropolymers (ppm dry-weight basis) Telomers

(ppm dryweight basis, unless stated otherwise)

Dyneon/3M 2013 PFOA, PFOA salts and Higher Homologues 0 0 0 0 No Telomer Production

Precursors 0p. 

### 4

Table 2. Re orted Emissions and Product Content of PFOA, Precursors, and Hi her Homolo ues from Non U.S. 0 erations Company Eighth

Year Reductions Chemical

Category Emissions Product Content

Releases to all media from FP and Telomer Manufacturing (kg) kg of

release / kg of product produced Dispersions

(ppm wetweight basis) Other

Fluoropolymers (ppm dry-weight basis) Telomers

(ppm dryweight basis, unless stated otherwise)

Dyneon/3M 2013 PFOA, PFOA salts and Higher Homologues 0 0 0 0 No Telomer Production

Precursors 0

### P. 5 

### Reported Percent Reductions in Emissions and Product Content

Table 3. Reported Percent Reductions in Emissions and Product Content of PFOA, Precursors, and Higher Homologues from U.S. 0 erations

Company Eighth

Year Reductions Chemical

Category % Reduction in Emissions % Reduction in Product Content

% Reductions in total quantity of chemical(s) released from baseline year Fluoropolymer

Dispersions Other

Fluoropolymers Telomer based

products

Dyneon/3M 2013 PFOA, PFOA salts and Higher Homologues 100% 100% Not Applicable No Telomer Production

Precursors No Precursor Productionp. 6

Table 4. Reported Percent Reductions in Emissions and Product Content of PFOA, Precursors, and Higher Homologues from Non U.S. 0 erations

Company Eighth

Year Reductions Chem l

ica Category % Reduction in Emissions % Reduction in Product Content

% Reductions in total quantity of chemical(s) released from baseline year Fluoropolymer

Dispersions Other

Fluoropolymers Telomer based products

Dyneon/3M 2013 PFOA, PFOA salts and Higher Homologues 100% 100% 100% No Telomer Production

Precursors No Precursor 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.