Appendix C 

3M/Dyneon Gendorf Facility Report on 

Emissions 

for 2010 
2010/15 PFOA Stewardship Program 

3M/Dyneon Gendorf Facility Report on 

Emissions 

I. CHEMICAL IDENTIFICATION

Identify the chemical for which you are submitting information: 

 

 Chemical name:Ammonium Perfluorooctanoate

 

 CAS number: 3825-26-1

II. COMPANY IDENTIFICATION

Identify the company and location of the facility submitting information: 

 

 Company name:___3M/Dyneon__________________ 

 

 Site location:_____Gendorf, Germany______________ 

Identify a company technical contact who can respond to inquiries about the 

information submitted: 

 Technical contact:_George H. Millet___________________

 Phone:_____651-733-5637__________________________ 

 Address:__6744 33rd St N., Oakdale, MN, 55082_________ 
III. ON-SITE ACTIVITIES

Calendar year for which you are reporting: Jan 1, 2010 to Dec 31, 2010

Provide the amount of chemical identified above for the reporting year at specific 

site: 

 

 Imported (virgin) __ 0__ kgs/yr 

 Imported (externally recycled) ___0___ kgs/yr 

 

 Manufactured (virgin) ___0___ kgs/yr 

Estimate the amount of subject chemical distributed off-site: 

_____N/A_____% of manufacture/import

Provide the amount used (including any that was manufactured, imported [virgin 

or externally recycled], or internally recycled) of the subject chemical for the 

reporting year at specific site: 

___0__kgs/yr 

Narrative Description and Process Flow Schematic: 

Provide overall material balance of the chemical being reported, showing releases 

and products (kgs/year). Use the following page to provide a narrative description 

and process flow schematic of on-site activities, and include information that 

gives an understanding of the nature and extent of potential exposures to the 

subject chemical. Attach additional pages if desired. The narrative and process 

flow schematic should cover major unit operations and chemical conversions for 

manufacturing and on-site uses, if applicable. The narrative should provide insight 

into why and how releases are caused by the process. The schematic should show 

the points of release of the subject chemical in the workplace and to the 

environment. In the event the subject chemical is used in many different 

processes, provide information on each major process instead of each individual 
process. 

Narrative Description and Process Flow Schematic for Gendorf: 

At the end of the year 2008, Dyneon eliminated the use of APFO in the manufacture of 

fluoropolymers at our Gendorf, Germany facility. This completed Dyneon’s efforts to 

reduce and then eliminate APFO emissions and product content on a global basis. In 

doing so, we achieved the goal of eliminating Dyneon’s use of APFO, seven years ahead 

of the time set by the EPA’s 2010/15 Voluntary PFOA Stewardship Program. 

 

We were able to meet the Voluntary PFOA Stewardship Program goal by developing a 

new emulsifier for the fluoropolymers that formerly were made using APFO. Compared 

to APFO, our new emulsifier has an improved mammalian toxicological profile, a similar 

environmental toxicological profile and a faster elimination rate in laboratory animals. 

The new emulsifier also can be recovered by the containment technology that Dyneon 

used to recover APFO from waste streams and products. This technology has enabled us 

to recover and reuse the new emulsifier as efficiently as we were able to recover and 

reuse APFO. Dyneon is also using this technology to reduce the new emulsifier content 

of our liquid fluoropolymer dispersion products. 

Since no APFO was used in 2010 to manufacture fluoropolymer products at Gendorf, 

there were no production related emissions of APFO to air, water or land. 

A broad overview of the emulsifier mass flow in at the Gendorf plant for 2010 can be 

found in the 2009 Form C Report for the Gendorf Facility (for the calendar year 2008). 

APFO Mass Balance Table – Gendorf 2010 

Category Amount of APFO (kg) Percent of Total 

Used 0 

Air Release 0 

Water Release 0 

Solid Release 0 

Destroyed 0 

Recycled 0 

In Products 0 
IV. SITE RELEASE AND TRANSFER INFORMATION 

(For manufacturing and on-site processing/use if applicable) 

In this section, estimate the total media-specific releases after on-site 

treatment of the chemical from your facility. You may estimate the releases by 

using monitoring data or any other method you believe appropriate. Estimates 

should be reported in kgs per year for the reporting period. Enter the values as 

whole numbers to no more than two significant figures. For example, if your 

annual releases are estimated to be 12,360 kgs, an estimate of 12,000 kgs should 

be reported. 

Estimate the number of days per year the release occurs. Enter a whole 

number with a maximum of 2 significant figures. 

Insert “NA” for release activities not associated with the chemical or “0” 

for releases of less than 0.5 kgs per year. 

 For all releases, the source of data and/or basis for determination should 

be described in detail. Suggested information about the possible sources/basis 

includes: 

 

 1. If the source/basis is an analytical measurement, then 

• Describe the method (including analytical standards used, 

sampling, sample treatment, analysis). 

• Describe the uncertainties and assumptions made. 

• Give the Level of Detection (LOD)/Level of Quantification 

(LOQ). 

2. If the source/basis is a mass balance, then 

• Show the mass balance calculation. 

• Show that the mass balance closes. 

• If the mass balance does not close, then report the fraction of total 

feedstock that is not accounted for and the assumptions you made 

to correct the balance. Describe the uncertainties. 

3. If the source/basis is other than measurement or mass balance, then 

• Describe the method used. For example, if engineering 

calculations are used, give a general description and state your 

assumptions. Describe the uncertainties. 
Part IV (cont.) 

A. ON-SITE AIR RELEASES 

Estimate the total fugitive or non-point releases to air and the number of 

days per year the releases occur. These releases include equipment leaks from 

valves, pump seals, flanges, compressors, sampling connections, and open-ended 

lines; evaporative losses from surface impoundments and spills; releases from 

building ventilation systems; and, any other fugitive or non-point air emission. 

In addition, estimate the total releases that occur through stacks, vents, 

pipes, or other confined air streams as stack or point source releases. Include 

storage tank emissions and releases from pollution control equipment. 

If desired, you can provide estimates of the accuracies of your release estimates. 

 

Estimated Total Estimated % # Days/year 

 Annual Releases Accuracy Release 

Occurs 

 (kgs) (Optional)

Fugitive (non-point) ___0___ _____ _____ 

Stack (point) ___0___ ___ _ _____ 

Basis for each release estimate: 

(See discussion on source/basis in beginning of Section IV.) 

Comments: 

(This section is available to clarify your responses. Attach additional pages if 

desired.) 

Part IV (cont.) 
B. WATER RELEASES FROM SITE 

Estimate the total releases of the chemical leaving the fence line of your 

facility from all discharge points to all streams or water bodies. Include all 

discharges from process outfalls such as pipes, open trenches, releases from onsite wastewater treatment, and contribution from storm water runoff, if applicable. 

Do not include discharges to a POTW or other off-site wastewater treatment 

facilities. If desired, you can provide an estimate of the accuracy of your release 

estimate. 

 

Estimated Total Estimated % # Days/year 

Annual Releases Accuracy Release Occurs 

 (kgs) (Optional)

Water releases: ___0___ ______ ____

 

 Enter the names of the streams or water bodies to which the facility 

directly discharges the chemical. Also, enter the NPDES permit number for the 

facility. If more than one number is assigned to the facility, list each number for 

the appropriate discharge quantity and receiving water identified. 

Receiving Water Name(s):__Alz River___ 

NPDES number(s):_N/A

Basis for each release estimate: 

(See discussion on source/basis in beginning of Section IV.) 

Waste water releases were calculated by measuring waste water outfall 

concentration routinely, and multiplying by total volume of waste water flow. 
Comments: 

(This section is available to clarify your responses. Attach additional pages if 

desired.) 

Part IV (cont.) 

C. ON-SITE LAND RELEASES 

Estimate the total releases of the chemical for each category of land 

disposal, if applicable. Estimate only on-site releases. Do not estimate leaks from 

landfills separately. This should be accounted for in your estimate of total landfill 

release. 

Releases to land treatment/land amendment include all waste containing 

the chemical that is applied or incorporated into soil on-site. Do not include waste 

that is landfilled. 

Surface impoundments are natural topographic depressions, man-made 

excavations, or diked areas formed primarily of earthen materials designed to hold 

an accumulation of the chemical. 

 Underground injection is the technology of placing fluids underground, in porous 

formations of rocks, through wells or other similar conveyance systems.

Other releases include any amount of the chemical that is released to land 

other than those listed. An example is the accidental release of the chemical from 

an underground pipeline or storage tank. 
Estimated Total Estimated % 

 Annual Releases Accuracy 

 (kgs) (Optional) 

Landfill __0__ _____ 

Land Treatment/Land Amendment __0__ _____ 

 

Surface Impoundments __0__ _____ 

Underground Injection __0__ _____ 

Unknown or Other (DESTROYED) __0__ ___ describe 

Internally Recycled __0__ _____describe 

Basis for each release estimate: 

(See discussion on source/basis in beginning of Section IV.) 

Destroyed amount is based on inventory records of amount sent for incineration. 

Comments: 

(This section is available to clarify your responses. Attach additional pages if 

desired.) 

Part IV (cont.) 

D. OFF-SITE TRANSFERS 

Estimates of off-site transfers should be similar in accuracy and precision 

to previous release estimates. 

Dl. Transfer to Publicly Owned Treatment Works (POTW) 

Number of days/year the release occurs: __0__ 
Estimate the total quantity of the subject chemical, not the waste stream, 

transferred to the POTW. Complete section below for each POTW to which your 

facility discharges wastewater containing the chemical. Enter the POTW’s 

NPDES permit number, if known. 

Annual Transfer (kgs): __0__ 

Estimated % Accuracy of Transfer Estimate (optional) _____ 

POTW Name:____________________________ 

Street Address: ___________________________________________ 

City: ________________ County: ______________ 

State: _____ Zip Code: _____

NPDES number: _______________________ 

Basis for each release estimate: 

(See discussion on source/basis in beginning of Section IV.) 

Comments: 

(This section is available to clarify your responses. Attach additional pages if 

desired.) 
Part IV (cont.) 

D2. Transfers to other off-site locations 

In this section, estimate the quantity of the subject chemical, not the waste 

stream, transferred and the accuracy of the estimate for each category listed. If 

your facility sends the subject chemical in waste to an off-site location where 

some of the chemical will be recycled and the remainder will be treated, estimate 

each amount separately (i.e., waste treatment and recycling activities). 

 

 Estimated Annual 

 Estimated % 

 Transfers (kgs) 

 accuracy 

 

 (Optional) 

 Incineration __0__ _____ 

 Wastewater Treatment 

 (Excluding POTW) __0__ _____ 

 

 Underground Injection __0__ _____ 

 Hazardous Waste (RCRA 

 Subtitle C) Landfill __0__ _____ 

 

 Other Landfill __0__ _____ 

 Recycle or Recovery __0__ _____ 

 (Does not include internally recycled) 

 

Basis for each release estimate: 

(See discussion on source/basis in beginning of Section IV.) 

Comments: 

(This section is available to clarify your responses. Attach additional pages if 

desired.)