3IVI 

Advanced Materials Division :~ g:'£u":~uildffig ,::;_~#" ~./{'11 J3 

6744 33'd St. Street North 

Oakdale, MN 55128 

NOV 0 7 2012. 

~ October 29, 2012 -......, 

_,. 

C5 o:;o 

VIA UPS .....:! -ern 

I -o ("") 

-J -If"'"'\ 

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 

Dear Sir or Madam: 

Re: 2012 Submission of3M/Dyneon under the EPA 2010/2015 

PFOA Stewardship Program 

:PI" 

~ 

\9 

~ 

N 

3M Company (3M) is pleased to make our 2012 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, 2006letter 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 will be referred to in this report as the 3M fluoropolymer business, 

from this year forward. Reporting for prior years or reporting ofpre-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 of2008. 

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 ofPFOA 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 offluoropolymer product contained traces of 

PFOA. This was due to the sale ofthe final inventory of product made prior to 2009 using PFOA. This 

inventory was exhausted in 2010, and in 2011 no fluoropolymer product made using PFOA was sold. 

Because 3M used no PFOA in 2011, had no production related releases ofPFOA, higher homologues or 

CONTAINS NO CBI 

. -·11 

("')< -rom 

C)CJ 
precursors into the environment, and sold no fluoropolymer product made using PFOA in 2011, we 

believe that submitting the series of Reporting Forms would not be useful. Instead, 3M will submit only 

the Summary Tables this year and for the rest of the PFOA Stewardship Reporting period going forward. 

The Accomplishments Table requested this year 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 ofPFOA, 

higher homologues or precursors from its Decatur fluoropolymer operations. 

3M continues to support the 2010/15 PFOA Stewardship Program, and as our submission reflects, at the 

end of2008 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 George Millet or Gary 

Hohenstein with any questions. 

George H. Millet 

Manager 

New Business Development 

3M Advanced Materials 

6744 33rd Street 

Oakdale, MN 55128 

651-733-5637 

-·lr 

M~aZir

!,H~~~ 1 

Environmental & Regulatory Affairs 

3M 

Building 224-5W -03 

St. Paul, MN 55144 

651-737-3570