# 3IVI Advanced Materials Division



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6744 33'd St. StreetNorth Oakdale, MN 55128



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**~** October 29, 2012 

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### -o("") -J -If"'"'\ OPPTDocument Control Office (DCO) Attention: Docket ID Number EPA-HQ-OPPT-2006-0621. 1201 ConstitutionAvenue NW EPAEastBuildingRoom 6428 Washington, DC 20004

Dear Sir orMadam: Re: 2012 Submission of3M/Dyneon under the EPA 2010/2015 PFOA Stewardship Program :PI"

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3M Company (3M) is pleasedto 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 October2006", 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, 2006letterto formerAdministrator Johnson committing to the Program. We enclose the paper copy version ofour submission withthis letter. We also enclose a CD-ROM containing the public version ofthe submission as requested. There are no CBI versions submitted this year. In 2010, 3Mfully integrated the United States-based Dyneon, LLC. subsidiary into the 3M Energy and Advanced Materials Division (EAMD), nowtheAdvanced Materials Division (AdMD)

. Thatbusiness, formerly known as Dyneon, is now known as the 3MAdMD fluoropolymers business. The German manufacturing facility and the European business is still referred to as Dyneon. Forthe sake ofsimplicity, the entire fluoropolymer business will be referred to inthis report as the 3M fluoropolymer business, from this year forward. Reporting for prior years orreporting ofpre-2010 activities will continue to refer to the Dyneon subsidiary. In2008 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 mammaliantoxicological profile, a similar environmental toxicological profile and a faster elimination rate in laboratory animals. Dyneon ceased using PFOA for making fluoropolymers atthe end of2008. 2009 was the first full year offluoropolymer production for Dyneon using ourreplacement emulsifier. This full year ofproduction demonstrated that Dyneon's new emulsifier was capable offull scale replacement ofPFOAfor every fluoropolymer formerly made using PFOA. We have been using our replacement emulsifier successfully since that time.
In 2011, 3Mreported for the year 2010 that a small amount offluoropolymerproduct contained traces of PFOA. This was due to the sale ofthe final inventory ofproduct made prior to 2009 using PFOA. This inventory was exhausted in 2010, and in 2011 no fluoropolymer product made using PFOAwas sold. Because 3M used no PFOA in 2011, had no production related releases ofPFOA, higher homologues or 

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## rom C)CJprecursors into the environment, and sold no fluoropolymer product made using PFOAin 2011, we believe that submitting the series ofReporting Forms would not be useful. Instead, 3Mwill submit only the Summary Tables this year and for the rest ofthe PFOA Stewardship Reporting period going forward. TheAccomplishments Table requestedthis year is appendedto the SummaryTables. Dyneon has beenusing a "capture for recycle" technology at its Gendorf, Germany facility for a number ofyears. As demonstrated by the 2008 Facility and Summary Emissions Reports, this technology resulted in a 93 percentreduction in PFOAemissions 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 andreuse PFOA. Dyneon is also using this technology to reduce the new emulsifier content ofour liquid fluoropolymer dispersion products. As theAgency is aware, Dyneon ceased using PFOA at its Decatur,Alabama operations as ofthe end of 2004, although fluoroelastomer production has continued without the use ofany fluorochemical emulsifier during polymerization. 3M continues to have no production related emissions ofPFOA, higher homologues orprecursors from its Decatur fluoropolymer operations. 3Mcontinues to supportthe 2010/15 PFOA Stewardship Program, and as our submission reflects, atthe 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 orGary Hohenstein with any questions.

George H. Millet Manager New Business Development 3M Advanced Materials 6744 33rd Street Oakdale, MN 55128 651-733-5637



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**M~aZir 1**  Environmental & Regulatory Affairs 3M Building 224-5W-03 St. Paul, MN 55144 651-737-3570