## 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 33 rd 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 a bove 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 ch emical distributed off-site:

_____N/A

_____ % of manufacture/import

Provide the amount used (including any th at 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 ch emical being reported, showing releases and products (kgs/year). Use the following page to provide a narrative description and process flow schematic of on-site ac tivities, and include information that gives an understanding of the nature a nd extent of potential exposures to the subject chemical. Attach additional page s if desired. The narrative and process flow schematic should cover major unit operations and chemical conversions for manufacturing and on-site uses, if appli cable. The narrative s hould provide insight into why and how releases are caused by the process. The schematic should show the points of release of the subject ch emical 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 individualprocess.

Narrative Description and Proce ss 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 facilit y. This completed Dyneon’s efforts to

reduce and then eliminate APFO emissions a nd product content on a global basis. In doing so, we achieved the goal of eliminati ng 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 PF OA Stewardship Progra m goal by developing a new emulsifier for the fluoropolymers that fo rmerly were made using APFO. Compared to APFO, our new emulsifier has an improve d mammalian toxicological profile, a similar environmental toxicological profile and a faster elimination rate in laboratory animals.

The new emulsifier also can be recovere d by the containment t echnology that Dyneon

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

to recover and reuse the new emulsifier as e fficiently as we were able to recover and reuse APFO. Dyneon is also using this technology to reduc e the new emulsifier content of our liquid fluoropolym er dispersion products.

Since no APFO was used in 2010 to manuf acture fluoropolymer pr oducts at Gendorf, there were no production related emissi ons of APFO to air, water or land.

A broad overview of the emulsifier mass fl ow 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 0IV. 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 me thod 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 signi ficant 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 info rmation 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 fo r 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. Fo r example, if engineering calculations are used, give a ge neral descripti on 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 chem ical leaving the fence line of your facility from all discharg e points to all streams or water bodies. Include all discharges from process outfalls such as pipes, open trenches , releases from onsite wastewater treatment, and contributi on 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. Als o, enter the NPDES permit number for the facility. If more than one number is a ssigned 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 calculat ed by measuring wa ste 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-si te 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 amen dment include all waste containing the chemical that is applied or incorporat ed into soil on-site. Do not include waste

that is landfilled.

Surface impoundments are natural to pographic depressions, man-made excavations, or diked areas formed primar ily of earthen materials designed to hold

an accumulation of the chemical.

Underground injection is the technol ogy 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) ( Optiona l)

Landfill __ 0_

_ _____

Land Treatment/Land Amendment __ 0_

_ _____

Surface Impoundments __ 0_

_ _____

Underground Injection __ 0_

_ _____

Unknown or Other (DESTROYED) __0__ ___ d escribe

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 r ecords 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 Own ed 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 sec tion below for each POTW to which your facility discharges wastewater cont aining 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 othe r off-site locations

In this section, estimate th e 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 subj ect chemical in waste to an off-site location where some of the chemical will be recycled a nd the remainder will be treated, estimate each amount separately (i.e., waste tr eatment 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.)