. 

Company sanitized 

Does not contain Confidential Business Information 

(CBI) 

Appendix C 

Draft Facility Report on Emissions 
2010/15 PFOA Stewardship Program 

Draft Facility Report on Emissions 

I. CHEMICAL IDENTIFICATION

Identify the chemical for which you are submitting information: 

 

 Chemical name:Ammonium perfluorononanoate

 

 CAS number:___4149-60-4___ 

II. COMPANY IDENTIFICATION

Identify the company and location of the facility submitting information: 

 

 Company name:___ASAHI GLASS CO.,LTD_______ 

 

 Site location:_____Chiba Plant__________ 

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

submitted: 

 Technical contact:__Yoshiteru Sumi_______ 

 Phone:__81-436-23-3146__________________ 

 Address:_10, Goikaigan, Ichihara-shi, Chiba 290-8566, Japan_______ 
III. ON-SITE ACTIVITIES

Calendar year for which you are reporting: Jan 1, 2013 to Dec 31, 2013 

(Normalized data based on year end run rate) 

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

 

 Imported (virgin) __ZERO _kgs/yr 

 Imported (externally recycled) __ZERO __kgs/yr 

 

 Manufactured __ZERO __kgs/yr 

Estimate the amount of subject chemical distributed off-site: 

_____0____% 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: 

 _____ZERO __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: 

The manufacturing process was changed to a process that doesn’t use emulsifier as 

polymerization aid. 
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) Zero Zero_ 

Stack (point) Zero _ _____ Zero

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.) 

The manufacturing process was changed to a process that doesn’t use emulsifier as 

polymerization aid. 
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 on-site 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: Zero Zero

 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):__Tokyo Bay__ _

NPDES number(s):__Not applicable__ ________ 

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.) 

The manufacturing process was changed to a process that doesn’t use emulsifier as 

polymerization aid. 
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 ZERO _____ 

Land Treatment/Land Amendment ZERO _____ 

Surface Impoundments ZERO _____ 

Underground Injection ZERO _____ 

Other (specify): ZERO _____ 

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.) 

No such activity. 
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: _ZERO_ 

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): _____ 

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.) 

The manufacturing process was changed to a process that doesn’t use emulsifier as 

polymerization aid. 
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 ZERO _____ 

 Wastewater Treatment 

 (Excluding POTW) ZERO _____ 

 

 Underground Injection ZERO _____ 

 Hazardous Waste (RCRA 

 Subtitle C) Landfill ZERO _____ 

 

 Other Landfill ZERO 

 Recycle or Recovery ZERO _____ 

 (Does not include internally recycled) 

 Internally Recycled ZERO _____ 

 Unknown or Other ZERO _____ 

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.) 

The manufacturing process was changed to a process that doesn’t use emulsifier as 

polymerization aid. 
Appendix D 

Draft Facility Report on Product Content
2010/15 PFOA Stewardship Program 

Draft Facility Report on Product Content 

I. CHEMICAL IDENTIFICATION

Identify the product (e.g fluoropolymer dispersion) for which you are submitting 

information: 

 

 Product name:__Carboxylate polymer__________________ 

 

 Product description (including concentrations of perfluoroalkyl chemicals 

 identified in Section IV below and year of production): 

The manufacturing process was changed to a process that doesn’t use emulsifier as 

polymerization aid. Accordingly, the polymer contains no residual emulsifier. 

II. COMPANY IDENTIFICATION

Identify the company and location of the facility submitting information: 

 

 Company name:__ASAHI GLASS Co.,LTD__________ 

 

 Site location:________Chiba Plant__________________ 

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

submitted: 

 Technical contact:_Yoshiteru Sumi_______________

 Phone:_81-436-23-3146 ____________________________ 

 Address:_10, Goikaigan, Ichihara-shi, Chiba 290-8566, Japan _ 

III. PRODUCTION

Calendar year for which you are reporting: Jan 1, 2013 to Dec 31, 2013_ 

(Normalized data based on year end run rate) 

Provide the amount of the product for the reporting year at each specific site: 

 

 < Confidential Business Information> 

 Imported ___ZERO ____kgs/yr 

 

 Manufactured ___ZERO ___kgs/yr 
IV. PRODUCT CONTENT

A. CONCENTRATIONS OF RELEVANT PERFLUOROALKYL CHEMICALS 

Please provide the concentrations (ppb) of various perfluoroalkyl chemicals in your 

product. For chemicals for which you do not have actual data, please provide range 

estimates. 

The following is a nonexhaustive list of chemicals that should be included: 

PFOA and its salts 

 Octanoic acid, pentadecafluoro- (CAS 335-67-1) 

 Octanoic acid, pentadecafluoro- ammonium salt (CAS 3825-26-1) 

PFOA precursors 

 Octane, 1,1,1,2,2,3,3,4,4,5,5,6,6,7,7, 8,8-heptadecafluoro-8-iodo- (CAS 507-63-1) 

 1-Decanol, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-heptadecafluoro- (CAS 678-39-7) 

 1-Decene, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-heptadecafluoro- (CAS 21652-58-

4) 

 2-Propenoic acid, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-heptadecafluorodecyl ester 

(CAS 27905-45-9) 

 2-Propenoic acid, 2-methyl-, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-

heptadecafluorodecyl ester (CAS 1996-88-9) 

 2-Decenoic acid, 3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-hexadecafluoro- (CAS 70887-

84-2) 

 Decanoic acid, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-heptadecafluoro- (CAS 27854-

31-5) 

Higher homologues 

 Dodecane, 1,1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,11,11,12,12-

pentacosafluoro-12-iodo- (CAS 307-60-8) 

 Decane, 1,1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10-heneicosafluoro-10-iodo- 

(CAS 423-62-1) 

 Nonanoic acid, heptadecafluoro- (CAS 375-95-1) 

 Decanoic acid, nonadecafluoro- (CAS 335-76-2) 

 1-Decanol, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-heptadecafluoro- (CAS 678-39-7) 

 Decane, 1,1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8-heptadecafluoro-10-iodo- (CAS 2043-

53-0) 

 Dodecane, 1,1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10-heneicosafluoro-12-iodo- 

(CAS 2043-54-1) 

 2-Propenoic acid, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-heptadecafluorodecyl ester 

(CAS 4980-53-4) 

 2-Propenoic acid, 2-methyl-, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,11,11,12,12,12-

heneicosafluorododecyl ester (CAS 17741-60-5) 
Part IV (cont.) 

B. ANALYTICAL METHODS 

Analyses should be conducted using the most accurate instrumentation and procedures 

available as of the time of testing. Please provide detailed information on the methods 

used (including analytical standards used, sampling, sample treatment, analysis), 

assumptions made, uncertainties and detection limits (LOD, LOQ) for the data provided.