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Appendix C 

Dyneon Gendorf Facility Report on Emissions 

for 2008
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2010/15 PFOA Stewardship Program 

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:___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_________ 
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III. ON-SITE ACTIVITIES

Calendar year for which you are reporting: Jan 1, 2008 to Dec 31, 2008

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

site: 

 

 Imported (virgin) SANITIZED kgs/yr 

 Imported (externally recycled) SANITIZED kgs/yr 

 

 Manufactured (virgin) SANITIZED kgs/yr 

Estimate the amount of subject chemical distributed off-site: 

SANITIZED kgs/yr % 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: 

 SANITIZED 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 
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each individual process. 

Narrative Description and Process Flow Schematic for Gendorf: 

2008 was a transition year for Dyneon. We began the year using APFO, the ammonium 

salt of PFOA (CAS # 3825-26-1), as an emulsifier in the polymerization of SANITIZED. 

By the end of the year we eliminated the use of APFO in the manufacture of 

fluoropolymers at Dyneon’s 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 have 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 effectively 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. 

The product families mentioned above are sold as liquid dispersion products and/or dry 

resin products. The processes for making these families of fluoropolymers are similar, 

regardless of which type of fluoropolymer is manufactured, and regardless of whether 

APFO or our new emulsifier is used in the polymerization step, so the following 

description covers all processes, with any variations noted. 

The aqueous emulsion polymerization process is conducted in a stirred, pressurized, 

temperature controlled reactor. Water, emulsifier, and other polymerization ingredients 

(initiators, etc.) are introduced into the reactor and heated to the polymerization 

temperature. Monomers are fed into the headspace of the reactor as gases; the 

polymerization reaction takes place in the aqueous phase as the monomers diffuse into it. 

Monomers continue to be fed into the reactor until the polymerization is complete, as 

judged by the amount of monomer consumed. During normal operations, there are no 

releases or emissions of emulsifier at this stage due to the enclosed nature of the process. 

The resultant emulsion (or dispersion) is transferred through a filter, and the filtered 

solids (“pre-coagulum”) is landfilled in an on-site waste facility. This pre-coagulum is 

estimated to contain <0.1% of the total of the emulsifier charged to the reactor. 

If the fluoropolymer emulsion produced above is destined to be sold as a liquid 

fluoropolymer dispersion product, it is concentrated, stabilized, treated to remove 

emulsifier, and packaged at this point. The process to reduce the emulsifier content of 
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liquid dispersion fluoropolymers consistes of SANITIZED. This process reduces the 

emulsifier content from about 1500 - 2000 ppm to 5 to 50 ppm depending on the 

fluoropolymer. The emulsifier captured by the process is regenerated and purified for 

reuse. There are small releases to waste water from this process. 

If the fluoropolymer emulsion produced above is destined to be sold as a dry 

fluoropolymer product, then the filtered emulsion is transferred to equipment in which it 

is separated into solid polymer particles (“agglomerate”) and an aqueous phase, by 

chemical or mechanical means. The wet agglomerate is then washed with water to 

remove the remaining polymerization ingredients, including emulsifier. 

The majority of the emulsifier used in the polymerization step is contained in these 

aqueous phases. We estimate that more than 90% of the total amount of emulsifier in this 

waste water is recovered, recycled and reused. 

Emulsifier is recovered from waste water streams using an anion exchange resin bed. 

The waste water is filtered to remove particulate matter then run though the bed. 

Emulsifier content entering the bed is an average about 100 ppm, and the water exiting 

contains about 1 ppm emulsifier. This concentration is measured routinely as a process 

control to identify when the resin bed is exhausted and needs to be changed. The analysis 

is done by GC-MS and the LOQ is 1 ppm. The treated waste water then flows to the site 

waste water treatment facility. Not all waste water streams are treated by ion exchange to 

remove emulsifier; some are so low in concentration or volume that they pass directly to 

the waste water treatment system. 

The clean, wet agglomerate is then dried. There are small amounts of emulsifier 

emission to air from drier exhausts. These are point source emissions. The largest drying 

oven exhaust gas stream is passed through a scrubber that removes emulsifier for 

recycling. The scrubber medium is aqueous potassium carbonate; this converts the 

emulsifier in the exhaust gas to the corresponding potassium salt. 

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Because there is little residual emulsifier present in these dry fluoropolymers, one would 

expect there to be no releases or emissions from this stage of the process. 

By the end of 2007, most of our fluoropolymer manufacturing waste water and exhaust 

gas streams were connected to emulsifier removal and recovery systems. Removal, 

recovery and reuse, had grown from about 10% of the AFPO used in Gendorf in 2000 to 

about 83% in 2008. 

Emulsifier is recovered and recycled from the ion exchange resin by SANITIZED. 

Emissions from this process are small, and waste from the process is incinerated on site. 

The amount of APFO reported as “destroyed” was 2,500 kg in 2008. This was less than 

last year due to our reduced usage of APFO compared to last year. 
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The process flow diagram below is a broad overview of the APFO mass flow in 2008. 

Overview of Gendorf Fluoropolymer Manufacturing Process - 2008

APFO Mass Balance Table – Gendorf 2008 

 

Category Amount of APFO (kg) Percent of Total 

Used SANITIZED 

Air Release 300 

Water Release 700 

Solid Release 20 

Destroyed 2,500 

Recycled SANITIZED 

In Products SANITIZED 

Dyneon 

Fluoropolymer 

Manufacturing 

Process 

Emulsifier

Removal / 

Recovery

Emulsifier

Removal / 

Recovery

Dyneon 

Emulsifier

Recycling-Plant

Emulsifier

Removal / 

Recovery

Process Off-Gas

Process Waste 

Water

Product 

(Dispersion) 

Waste Water 

Treatment Gendorf 

Releases to water 

& landfill

Releases to Air

Releases to landfill

Process Solid 

Waste

To Incinerator

To Incinerator

Recycled Emulsifier Reuse

Polymerization 

Ingredients:

Emulsifier, 

Water, 

Monomers, 

Initiator and 
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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. 
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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) _300__ __95_ __360_ 

Basis for each release estimate: 

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

2008 data based on air emission concentration sampling and engineering estimates of 

exhaust air volumes. Stack air emission concentrations measured by impinger bottle 

sampling, followed by extraction and quantitation using liquid chromatography with 

mass spectrometry detection, or GC-MS depending on expected concentration in the 

sampling medium. 
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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: _ 700_ __95___ _360_ 

 

 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.) 
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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. 
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Estimated Total Estimated % 

Annual Releases Accuracy 

(kgs) (Optional) 

Landfill 20__ _____ 

 

Land Treatment/Land Amendment __0__ _____ 

Surface Impoundments __0__ _____ 

Underground Injection __0__ _____ 

Unknown or Other (DESTROYED) _2,500 _____describe 

Internally Recycled _SANITIZED _____describe 

Basis for each release estimate: 

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

Coagulum and scrap was disposed of on site in an inert waste landfill. Leachate 

from the chemical waste landfill is managed by pumping and treatment before 

transfer to the site waste water treatment plant. 

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Destroyed amount is an engineering estimate based on air flow to an on site 

fluorochemical incinerator through the central vacuum system, and the known 

amount of WWT sludge incinerated. 

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. 
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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.) 

Understanding of waste disposal practices at the Gendorf manufacturing site. 

Comments: 

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

desired.) 
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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.)