COMPANY SANITIZED PUBLIC COPY OCTOBER 30, 2009 

# Appendix D Facility Report on Product Content

Fluorotelomers Company Sanitized Public CopyCOMPANY SANITIZED PUBLIC COPY OCTOBER 30, 2009 

## 2010/15 PFOA Stewardship Program 

# Facility Report on Product Content Company Sanitized Public Copy I. CHEMICAL IDENTIFICATION Identify the product (e.g fluoropo lymer dispersion) for which y ou are submitting information :

Product name: Fluorotelomer- based polymeric and surfactant products Product description (including concentrations of perfluoroalkyl chemicals identified in Section IV below and year of pr oduction): Production year: 2008

[ CBI ] II. COMPANY IDENTIFICATION Identify the company and location of the facility submitting information:

Company name: DuPont Site locations : [ CBI ] Identify a company technical contact who c an respond to inquiries about the information submitted: Technical con tact: Stephen Korzeniowski Phone: 302 - 695 - 8672 Address: DuPont Experimental Station

ESL 402 - 5231 Route 141 and Henry Clay Wilmington, DE 19803COMPANY SANITIZED PUBLIC COPY OCTOBER 30, 2009

III. PRODUCTION Calendar year for which you are reporting: Jan 1, 200 8 to Dec 31, 200 8 Provide the amount of the product f or the reporting year at each specific site: Imported NA kgs /yr Manufactured [ CBI ] 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 - heptadecafluor o - (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, nonadecaf luoro- (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- 1 2 - iodo - (CASCOMPANY SANITIZED PUBLIC COPY OCTOBER 30, 2009 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 ) [ CBI ] B. ANALYTICAL METHODS The general methods used for the analyses reported here have been published in the following article: Larsen, B.S.; Stchur, P.; Szostek, B.; Bachmura, S.F.; Rowand, R.C.; Prickett, K.B.; Korzeniowski, S.H.; Buck, R.C. Met hod development for the determination of residual fluorotelomer raw materials and perfluorooctanoate in fluorotelomer- based products by gas chromatography and liquid chromatography mass spectrometry. Journal of Chromatography A . 2006 (1110), 117 - 124. In general the LOQ was 2 ppm and LOD was 0.7 ppm. Unpublished improvements have been made to the PFOA method providing for an LOQ of 0.5 ppm and an LOD of 0.15 ppm. This improved method was used in 2007 and 2008.COMPANY SANITIZED PUBLIC COPY OCTOBER 30, 2009

SECTION 4 : SUMMARY OF PRODUCT CONTENT - Fluorotelomers Company Sanitized Public Copy Reporting Period (use calendar year - e.g. Jan 1, 2005 to Dec 31, 2005) As of December 31, 2008 ( Year End Run Rate) Product type Fluoropolymer dispersions Other fluoropolymersi ii Fluorot elomer based products 4a Production v olume (kgs/year) iii Concentrationiv % Reduction from baseline year Operations Chemical category Fluoropolymer dispersions v (ppm wetweight ) Other

fluoropolymers 1, vi (ppb dry weight ) Telomer based

p roducts vii (Year End run rate - kgs.) Fluoropolymer

dispersions Other

fluoropolymers 1 Telomer

based p roducts PFOA, PFOA salts 16 9 7% 4b Global Facilities Direct Precursors

C8 Telomer A 8 - 2 - 8 Ester <3 2 <1 9 7% Please provide information on the methods, assumptions , uncertainties and detection limits for the data provided above.

4 d LOQs for analytical methods for impurities in DuPont FT products is 2 ppm. Methods used were as follows: LC/MS/MS - PFOA; GC/MS - all others. Values were obtained by measuring indi vidual products, obtaining the impurity levels in ppm, and then calculating the actual pounds of impurities by multiplying the pounds made times the ppm of impurities. These are the values reported above. If a value was determined to be <LOQ, we used th e standard EPA convention of 1/2 LOQ as the measurement for the yearly pounds calculation. The general methods used for the analyses reported here have been published in the following article: Larsen, B.S.; Stchur, P.; Szostek, B.; Bachmura, S.F .; Rowand, R.C.; Prickett, K.B.; Korzeniowski, S.H.; Buck, R.C. Method development for the determination of residual fluorotelomer raw materials and perfluorooctanoate in fluorotelomer -based products by gas chromatography and liquid chromatography mass spectrometry. Journal of Chromatography A. 2006 (1110), 117 - 124. In general the LOQ was 2 ppm and LOD was 0.7 ppm. Unpublished improvements have been made to the PFOA method providing for an LOQ of 0.5 ppm and an LOD of 0.15 ppm. This improved method was used in 2007 and in 2008 As noted above, the values obtained for this reporting were determined by measurements of actual finished products. Where possible three separate lots of most every major product were analyzed and then averaged.COMPANY SANITIZED PUBLIC COPY OCTOBER 30, 2009 ii Fluoropolymers manufactured with PFOA. iii Use the following ranges: (1) Zero (2) > 0

– 10 kgs; (3) > 10 kgs

– 100 kgs ; ( 4 ) > 10 0 kgs

– 1,000 kgs; (5) > 1,000 kgs

– 10,000 kgs ; (6) > 10,000 kgs

– 100,000 kgs ; ( 7) > 100,000 kgs

– 1,000,00 0 kgs; (8) Over 1,000,000 kgs. iv Concentration should reflect the concentration of chemical in the product as sold by the reporting company. If the reporting company has information concerning the concentration of chemical in the product as used by others

– for example, as incorporated by dilution into a formulation

– that additional information would also be helpful. v This value should be expressed as a weighted average concentration and range. vi This value should be expressed as a maximum concentration. vii This value should be expressed as a simple (not weighted) average and range.COMPANY SANITIZED PUBLIC COPY OCTOBER 30 , 2009 

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