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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 

Enclosures 
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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 0 
p. 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 Production 
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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 ica l

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.