CBIC Control Number 

# 357051 OPPT-2006-0621 

# CLARIANT 4000 Monroe Road Charlotte NC 28205 704.331.7059 Erin.Russell@clariant.com THIS LETTER DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 

# • November 18, 2013 ATTN: EPA-HQ-OPPT-2006-0621 Document Control Office 7407M Mr. Toni Krasnic Office ofPollution Prevention and Toxics (OPPT) US EPA- East 1200 Pennsylvania Avenue NW Washington DC 20460-000I Re: US EPA 2010/15 PFOA Stewardship Program Dear Mr. Krasnic: Please find enclosed Clariant's report for the US EPA 2010/2015 PFOA Stewardship Program. This report includes the numeric results ofprogress in residual reduction and site emissions reduction through 2012. As a fluorotelomer manufacturer, Clariant does not make oruse PFOA in its production processes, nor does it add PFOA to its products. Trace levels ofPFOA are present in fluorotelomer products as an impurity. Despite the extremely low levels offluorinated impurities in fluorotelomers, Clariant has devoted its efforts and resources to further reduce both product content and plant site emissions. As we discussed earlier this month, Clariant recently sold three business lines including the paperand textile groups. The transaction closed at the end ofSeptember. These businesses own the fluorotelomer products. As such, Clariant no longer produces fluorotelomer products or other chemicals that are relevant to the PFOA Stewardship Program. Next year we will file the 2013 report for production during the period ofour ownership. At that point we will have no additional filings as our production and emissions data will be at zero. Should you have any questions regarding this change please feel free to contact me. Best regards,

# ~~ Erin Russell Enclosures Scanned &Processed in CIS by: PAULA

### . DOES NOTCONTAIN CONFIDENTIAL BUSINESS INFORMATION



# Appendix F 

# CompanyAnnual Report 

# 2012 Summary ofReductions


# . Ill 

# Emissions and Product Content PFOA + 

# Direct PrecursorsDOES NOT CONTAIN CONFIDENTIAL

**~USINESS** INFORMATION 2010/15 PFOA Global Stewardship Program Company Report: Summary of Reductions in Emissions and Product Content

1 sEcTioN 1: REPoRT nATE

--- **···-~····-~---~ --;:;z~s-\?"?1**  **oc1:o_ber.20f3-·-·-----~-·---------~** --J

SECTION 2: COMPANYIDENTIFICATIQN Company Name Clariant Produkte (Deutschland) GmbH

2 a . Street Address 84508 Burgkirchen (Germany) SECTION 3: SUl\1l\1ARY OF EMISSIONS Operations

3 a I I

••... f. **cc~o** . **k'~t~~~$J:Rlk~9B~~'~r~'~f·.j\:¥~ff~~!~L~N~IS,xF:blli!**

Not

applicable Not applicable

U.S. facilities Not aoplicable Not aoolicable

Not applicable 70

3b

I Non-U.S.

I I . ·.

. . . .. ·

.... ·

..... ···.·

...**lbir~ct Pre<;ur$or~**  : <I·_·· .. ·_ ..•. _·. <1.5

_ ... _ .·.·.· .. _ .. 1 .... ___ .· **>~otappl~c~ble.** <·_ .• -.1._ .. · __ .· ... · .. ·._··_ .. _····· **-.~,** ...•... <,; J.. >85

Please provide ·information on tl1e- methoc1s,

.. **~~swuptiQ11S, :4119~J1~i!lt!~-~i~n~"tf!§!@£!i.9P.dim!!§JQt~:!h§;;g~tg_:Qt9:.Ri,g~f;l** 

PFOA is analyzed, after derivatisation, by GC or GC-MS; Method LOD 0.1 ppm.

Direct

Precursors are analyzed by GC and/or GC-MS; Method LOD depends on specific fluorotelomer structure 50

- 100 ppm

3cDOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION

4a 4b 4c Product type Production volume (kgs/year) 2 Operations u.s. facilities Chemical category

4d I PFOA is analysed, after derivatisation, by GC or GC-MS; Method LOD 0.1 ppm.

Direct

Precursors are analysed by GC and/or GC-MS; Method LOD depends on specific fluorotelomer structure 50- 100 ppm

1 Fluoropolymers manufactured with PFOA.

2 Use the following ranges: (1) Zero (2) > 0- 10 kgs; (3) > 10 kgs- 100 kgs; (4) > 100 kgs- 1,000 kgs; (5) > 1,000 kgs- 10,000 kgs; (6) > 10,000 kgs-

100,000 kgs; (7) > 100,000 kgs- 1,000,000 kgs; (8) Over 1,000j000 kgs.

3 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.

4 This value should be expressed as a weighted average concentration and range.

5 This value should be expressed as a maximum concentration.

6 This value should be expressed as a simple (not weighted) average and range.COMPANY SANITIZED DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION



# Appendix C 

# Facility Report on Emissions in 2012
for Direct Precursors (CsFt7-J and C7Fts-COOC2H4CsFt7) 

## and Indirect Precursors I 

## Higher Homologues (Rv-C2H-1-l; Rv-C2HrOH; Rv-C2HrOCO-CR=CH2:RrCH=CH2J with RF = C81C8+ CBIC Control Number 

# 357051COMPANY SANITIZED DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 

## 2010/15 PFOA Stewardship Program 

# Facility Report on Emissions

I. CHEMICAL IDENTIFICATION Identify the chemical for which you are submitting information: Chemical names:Direct precursors and indirect precursors/ higherhomologues (Rrl; RrC2Hri:RrC2HrOH; RrC2HrOCO-CR=CH2.- RrCH=CH2J

with RF-chain: C8I C8+ CAS number: not applicable


### II. COMPANY IDENTIFICATION Identify the company and location ofthe facility submitting information: Company name: Clariant Produkte (Deutschland) GmbH Site location: Germany, Burgkirchen/Gendorf Identify a company technical contact who can respond to inquiries about the information submitted: Technical contact: Phone: Address: email Dr. Wolfgang Knaup +49 8679 7 4653 wolfgang.knaup@clariant.com

2COMPANY SANITIZED DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION



### III. ON-SITE ACTIVITIES Calendaryear for which you are reporting: Jan 1, 2012 to Dec31, 2012 Provide the amount ofchemical identified above for the reporting year at specific site: Imported (virgin) Imported (externally recycled)

Estimate the amount ofsubject chemical distributed off-site: Provide the amount used (including any that was manufactured, imported [virgin or externally recycled], or internally recycled) ofthe subject chemical for the reporting year at specific site:

Narrative Description and Process Flow Schematic: Provide overall material balance ofthe chemical being reported, showing releases and products (kgs/year). Use the following page to provide a narrative description and process flow schematic ofon-site activities, and include information that gives an understanding ofthe nature and extent ofpotential exposures to the subject chemical. Attach additional pages ifdesired. The narrative and process flow schematic should cover major unit operations and chemical conversions for manufacturing and on-site uses, ifapplicable. The narrative should provide insight into why and how releases are caused by the process. The schematic should show the points of release ofthe 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 majorprocess instead ofeach individual process. 3COMPANY SANITIZED DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION

Narrative Description and Process Flow Schematic:

4COMPANY SANITIZED DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION



### IV. SITE RELEASE AND TRANSFERINFORMATION (Formanufacturing and on-site processing/use ifapplicable) In this section, estimate the total media-specific releases after on-site treatment ofthe 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 peryear for the reporting period. Enterthe values as whole numbers to no more than two significant figures. Forexample, if your annual releases are estimated to be 12,360 kgs, an estimate of 12,000 kgs should be reported. Estimate the number ofdays peryearthe release occurs. Enter a whole number with a maximum of2 significant figures. Insert "NA" for release activities not associated with the chemical or "0" for releases ofless than 0.5 kgs peryear. For all releases, the source ofdata and/orbasis for determination should be described in detail. Suggested information aboutthe possible sources/basis includes:

Part IV (cont.) 1. Ifthe 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 ofDetection (LOD)/Level ofQuantification (LOQ). 2. Ifthe source/basis is a mass balance, then • Showthe mass balance calculation. • Showthat the mass balance closes. • Ifthe mass balance does not close, then report the fraction oftotal feedstock that is not accounted for and the assumptions you made to correct the balance. Describe the uncertainties. 3. Ifthe source/basis is otherthan measurement ormass balance, then • Describe the method used. Forexample, ifengineering calculations are used, give a general description and state your assumptions. Describe the uncertainties.

5COMPANY SANITIZED DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION



### A. ON-SITE AIRRELEASES Estimate the total fugitive or non-point releases to air and the number ofdays peryear 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 occurthrough stacks, vents, pipes, or other confined air streams as stack or point source releases. Include storage tank emissions and releases from pollution control equipment. Ifdesired, you can provide estimates ofthe accuracies ofyour release estimates. Estimated Total Annual Releases (kgs)

Basis for each release estimate: Estimated% Accuracy (Optional)

6

**~~~------** 

### #Days/year Release OccursCOMPANY SANITIZED DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION


### Part IV (cont.) B. WATER RELEASES FROM SITE Estimate the total releases ofthe chemical leaving the fence line ofyour facility from all discharge points to all streams orwater bodies. Include all_discharges from process outfalls such as pipes, open trenches, releases from on-site wastewater treatment, and contribution from storm water runoff, ifapplicable. Do not include discharges to a POTW orother off-site wastewater treatment facilities. Ifdesired, you can provide an estimate ofthe accuracy ofyour release estimate. Estimated Total Annual Releases (kgs) Estimated % 

### # Days/year Accuracy Release Occurs (Optional)



### Enterthe names ofthe streams or waterbodies to which the facility directly discharges the chemical. Also, enterthe NPDES permit number for the facility. Ifmore than one number is assigned to the facility, list each number for the appropriate discharge quantity and receiving water identified. Receiving WaterName(s): Alz 

### NPDES number(s): not available Basis for each release estimate:

7

**~--'--"---'--~~~-** ------- -----

**~- -~---**  **=~--~--** --

**~~-**COMPANY SANITIZED DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION

Part IV (cont.) 8COMPANY SANITIZED DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION

C. ON-SITE LAND RELEASES Estimate the total releases ofthe chemical for each category ofland disposal, ifapplicable. Estimate only on-site releases. Do not estimate leaks from landfills separately. This should be accounted for in your estimate oftotal 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 ofearthen materials designed to hold an accumulation ofthe chemical. Underground injection is the technology ofplacing fluids underground, in porous formations of rocks, through wells or other similar conveyance systems. Otherreleases include any amount ofthe chemical that is released to land otherthan those listed. An example is the accidental release ofthe chemical from an underground pipeline or storage tank.

Landfill Land Treatment/Land Amendment Surface Impoundments Underground Injection Other (specify): Basis for each release estimate: Estimated Total Annual Releases (kgs)

notapplicable notrelevant not relevant notrelevant not relevant (See discussion on source/basis in beginning ofSection IV.) Comments: Estimated% Accuracy (Optional)

(This section is available to clarify your responses. Attach additional pages ifdesired.) Part IV (cont.) 

### 9COMPANY SANITIZED DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION



### D. OFF-SITE TRANSFERS Not applicable 

### Estimates ofoff-site transfers should be similar in accuracy and precision to previous release estimates. Dl. Transferto Publicly Owned Treatment Works (POTW) Number ofdays/yearthe release occurs: - Estimate the total quantity ofthe 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. Enterthe POTW's NPDES permit number, ifknown. Annual Transfer (kgs): Estimated % 

### Accuracy ofTransferEstimate (optional)- POTW Name: ---------- (on-site wastewater treatment plant InfraServ Gendorf) Street Address: ------- City: ------------- State: ------------ NPDES number: Basis for each release estimate: County: ----------- Zip Code: ----------
(See discussion on source/basis in beginning ofSection IV.)

ments: (This section is available to clarify yourresponses. Attach additional pages ifdesired.)

10COMPANY SANITIZED DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION


### Part IV (cont.) D2. Transfers to other off-site locations In this section, estimate the quantity ofthe subject chemical, not the waste stream, transferred and the accuracy ofthe estimate for each category listed. Ifyour facility sends the subject chemical in waste to an off-site location where some ofthe chemical will be recycled and the remainder will be treated, estimate each amount separately (i.e., waste treatment and recycling activities).
Incineration Wastewater Treatment (Excluding POTW) Underground Injection Hazardous Waste (RCRA Subtitle C) Landfill OtherLandfill Recycle orRecovery (Does not include internally recycled) Internally Recycled Unknown or Other Basis for each release estimate: Estimated Annual Transfers (kgs)

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

11 

### Estimated % 

### accuracyExhibit A



# CBICOMPANY SANITIZED DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION



# Appendix C 

# Facility Report on Emissions in 2012 for Perjluorooctanoic acid (PFOA)COMPANY SANITIZED DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 

## 2010/15 PFOA Stewardship Program 

# Facility Report on Emissions

I. CHEMICAL IDENTIFICATION Identify the chemical for which you are submitting information: Chemical name: Perfluorooctanoic acid (PFOA) CAS number: 335-67-1


### II. COMPANY IDENTIFICATION Identify the company and location ofthe facility submitting information: Company name: ClariantProdukte (Deutschland) GmbH Site location: Germany, Burgkirchen/Gendorf Identify a company technical contact who can respond to inquiries about the information submitted: Technical contact: Phone: Address: email Dr. Wolfgang Knaup +49 8679 7 4653 wolfgang.knaup@clariant.com

2COMPANY SANITIZED DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION



### III. ON-SITE ACTIVITIES Calendaryear for which you are reporting: Jan 1, 2012 to Dec 31, 2012
Provide the amount ofchemical identified above for the reporting year at specific site:

Estimate the amount ofsubject chemical distributed off-site:

Provide the amount used (including any that was manufactured, imported [virgin or externally recycled], or internally recycled) ofthe subject chemical for the reporting year at specific site:

Narrative Description and Process Flow Schematic: Provide overall material balance ofthe chemical being reported, showing releases and products (kgs/year). Use the following page to provide a narrative description and process flow schematic ofon-site activities, and include information that gives an understanding ofthe nature and extent ofpotential exposures to the subject chemical. Attach additional pages ifdesired. The narrative and process flow schematic should covermajor unit operations and chemical conversions for manufacturing and on-site uses, ifapplicable. The narrative should provide insight into why and how releases are caused by the process. The schematic should show the points of release ofthe 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 ofeach individual process. 3COMPANY SANITIZED DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION



### Narrative Description and Process Flow Schematic:

4COMPANY SANITIZED DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION



### IV. SITE RELEASE AND TRANSFERINFORMATION (Formanufacturing and on-site processing/use ifapplicable) In this section, estimate the total media-specific releases after on-site treatment ofthe 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 peryear for the reporting period. Enterthe values as whole numbers to no more than two significant figures. Forexample, if your annual releases are estimatedto be 12,360 kgs, an estimate of 12,000 kgs should be reported. Estimate the number ofdays per yearthe release occurs. Enter a whole numberwith a maximum of2 significant figures. Insert "NA" for release activities not associated with the chemical or "0" for releases of less than 0.5 kgs peryear. For all releases, the source ofdata and/orbasis for determination should be described in detail. Suggested information about the possible sources/basis includes: 1. Ifthe 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 ofDetection (LOD)/Level ofQuantification (LOQ). 2. Ifthe source/basis is a mass balance, then • Showthe mass balance calculation. • Showthat the mass balance closes. • Ifthe mass balance does not close, then report the fraction oftotal feedstock that is not accounted for and the assumptions you made to correct the balance. Describe the uncertainties. 3. Ifthe source/basis is otherthan measurement ormass balance, then • Describe the method used. For example, ifengineering calculations are used, give a general description and state your assumptions. Describe the uncertainties. 5COMPANY SANITIZED DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION
Part IV (cont.) A. ON-SITE AIRRELEASES Estimate the total fugitive ornon-point releases to air and the number ofdays peryearthe 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 occurthrough stacks, vents, pipes, or other confined air streams as stack orpoint source releases. Include storage tank emissions and releases from pollution control equipment. Ifdesired, you can provide estimates ofthe accuracies ofyourrelease estimates.

Basis for each release estimate:

Part IV (cont.) Estimated TotalEstimated% Annual ReleasesAccuracy (kgs) (Optional)

6 #Days/year Release OccursCOMPANY SANITIZED DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION



### B. WATER RELEASES FROM SITE Estimate the total releases ofthe chemical leaving the fence line ofyour facility from all discharge points to all streams orwater bodies. Include all discharges from process outfalls such as pipes, open trenches, releases from on-site wastewater treatment, and contribution from storm waterrunoff, ifapplicable. Do not include discharges to a POTW or other off-site wastewater treatment facilities. Ifdesired, you can provide an estimate ofthe accuracy ofyourrelease estimate. Estimated Total Annual Releases (kgs) Estimated% Accuracy (Optional) 

### #Days/year Release Occurs
Enterthe names ofthe streams or water bodies to which the facility directly discharges the chemical. Also, enterthe NPDES permit number for the facility. Ifmore than one number is assigned to the facility, list each number for the appropriate discharge quantity and receiving water identified. Receiving WaterName(s): Alz NPDESnumber(s): notavailable Basis for each release estimate:

7COMPANY SANITIZED DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION


### Part IV (cont.) Estimate the total releases ofthe chemical for each category ofland disposal, ifapplicable. Estimate only on-site releases. Do not estimate leaks from landfills separately. This should be accounted for in your estimate oftotal 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 ofearthen materials designed to hold an accumulation ofthe chemical. Underground injection is the technology ofplacing fluids underground, in porous formations of rocks, through wells or other similar conveyance systems. Otherreleases include any amount ofthe chemical that is released to land otherthan those listed. An example is the accidental release ofthe chemical from an underground pipeline or storage tank.

Landfill Land Treatment/Land Amendment Surface Impoundments Underground Injection Other (specify): Basis for each release estimate: Estimated Total Annual Releases (kgs)

notapplicable not applicable notapplicable notapplicable 

### (See discussion on source/basis in beginning ofSection IV.)

Part IV (cont.) 

### 8 Estimated% Accuracy (Optional)COMPANY SANITIZED DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION



### D. OFF-SITE TRANSFERS Estimates ofoff-site transfers should be similar in accuracy and precision to previous release estimates. Dl. Transferto Publicly Owned Treatment Works (POTW) Number ofdays/year the release occurs:- Estimate the total quantity ofthe 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. Enterthe POTW's NPDES permit number, ifknown. Annual Transfer (kgs): Estimated % 

### Accuracy ofTransferEstimate (optional) POTW Name: On-site waste water treatment plant operated by InfraServ Gendorf Street Address: ----- City: Burgkirchen State: Germany NPDES number: --------
Basis for each release estimate: County: ----------- Zip Code: 84508

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

Comments: (This section is available to clarify your responses. Attach additional pages ifdesired.)

9COMPANY SANITIZED DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION


### Part IV (cont.) D2. Transfers to other off-site locations In this section, estimate the quantity ofthe subject chemical, not the waste stream, transferred and the accuracy ofthe estimate for each category listed. Ifyour facility sends the subject chemical in waste to an off-site location where some ofthe chemical will be recycled and the remainder will be treated, estimate each amount separately (i.e., waste treatment and recycling activities).
Incineration Wastewater Treatment (Excluding POTW) Underground Injection Hazardous Waste (RCRA Subtitle C) Landfill OtherLandfill Recycle orRecovery (Does not include internally recycled) Internally Recycled Unknown or Other Estimated Annual Transfers (kgs) 

### see comments below not applicable not applicable not applicable not applicable notapplicable not applicable notapplicable

10 

### Estimated% accuracy (Optional)Exhibit A



# CBICOMPANY SANITIZED DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION



# AppendixD 

# Report on Product Content 

# 2012 FluorotelomerbasedA3F Chemicals

• PFOA •· PFCA (other than PFOA) • DirectPrecursors (CsF11-J and C7Fts-COOCzH4CsFI7) 

## • IndirectPrecursors I 

## HigherHomologuesCOMPANY SANITIZED DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 

## 2010/15 PFOA Stewardship Program 

# Report on Product Content I. CHEMICAL IDENTIFICATION Identify the product (e.g tluoropolymer dispersion) for which you are submitting information:

Product description (including concentrations ofpertluoroalkyl chemicals identified in Section IV below and year ofproduction):



### II. COMPANYIDENTIFICATION Identify the company and location ofthe facility submitting information: Company name: ClariantProdukte (Deutschland) GmbH Site location: Burgkirchen-Gendorf Identify a company technical contact who can respond to inquiries about the information submitted: Technical contact: Dr. Wolfgang Knaup Phone: +49 8679 7 4653 Address: email Wolfgang.knaup@clariant.com 

### III. PRODUCTION Calendaryear for which you are reporting: 

### Jan 1, 2012 

### to Dec 31, 2012 Provide the amount ofthe product for the reporting year at each specific site:COMPANY SANITIZED DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION


### IV. PRODUCT CONTENT A. CONCENTRATIONS OF RELEVANT PERFLUOROALKYL CHEMICALS Please provide the concentrations (ppb) ofvarious 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 ofchemicals that should be included: PFOA andits salts • Octanoic acid, pentadecafluoro- (CAS 335-67-1) • Octanoic acid, pentadecafluoro- ammonium salt (CAS 3825-26-1) PFOAprecursors • 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)

3COMPANY SANITIZED DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION
Part IV (cont.) B. ANALYTICAL METHODS Analyses should be conducted using the most accurate instrumentation and procedures available as ofthe time oftesting. 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.

4COMPANY SANITIZED DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION

5COMPANY SANITIZED DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION



# Appendix D 

# Report on Product Content 

# 2012 Fluorotelomerbased PolymerDispersions

• PFOA • PFCA (otherthan PFOA) • DirectPrecursors (CsFt7-J and C7Fts-COOC2H4CsF11) 

## • Indirect Precursors I 

## HigherHomologuesCOMPANY SANITIZED DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 

## 2010/15 PFOA Stewardship Program 

# Report on Product Content I. CHEMICAL IDENTIFICATION Identify the product (e.g fluoropolymer dispersion) for which you are submitting information: Product name: Product description (including concentrations ofperfluoroalkyl chemicals identified in Section IV below and year of duction):



### II. COMPANYIDENTIFICATION Identify the company and location ofthe facility submitting information: Company name: Clariant Produkte (Deutschland) GmbH Site location: Burgkirchen-Gendorf, Germany Identify a company technical contact who can respond to inquiries about the information submitted: Technical contact: Dr. Wolfgang Knaup Phone: +49 8679 7 4653 Address: email: wolfgang.knaup@clariant.com 

### III. PRODUCTION Calendar year for which you are reporting: Jan 1, 

### 2012 to Dec 31, 2012 Provide the amount ofthe product for the reporting year at each specific site:

2COMPANY SANITIZED DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION

IV. PRODUCT CONTENT A. CONCENTRATIONS OF RELEVANT PERFLUOROALKYL CHEMICALS Please provide the concentrations (ppb) ofvarious pertluoroalkyl chemicals in yourproduct. For chemicals for which you do not have actual data, please provide range estimates. The following is a nonexhaustive list ofchemicals that should be included: PFOA andits salts • Octanoic acid, pentadecatluoro- (CAS 335-67-1) • Octanoic acid, pentadecafluoro- ammonium salt (CAS 3825-26-1) PFOAprecursors • Octane, 1,1,1,2,2,3,3,4,4,5,5,6,6,7,7, 8,8-heptadecatluoro-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-heptadecatluoro- (CAS 678-39-7) • 1-Decene, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-heptadecatluoro- (CAS 21652-58-4) • 2-Propenoic acid, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-heptadecatluorodecyl 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-heptadecatluorodecyl ester (CAS 1996-88-9) • 2-Decenoic acid, 3,4,4,5,5,6,6,7,7,8,8,9,9, 10,10,10-hexadecatluoro- (CAS 70887-84-2) • Decanoic acid, 3,3,4,4,5,5,6,6,7,7,8,8,9,9, 10,10,10-heptadecatluoro- (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-pentacosatluoro-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-heneicosatluoro-10-iodo- (CAS 423-62- 1) • Nonanoic acid, heptadecatluoro- (CAS 375-95-1) • Decanoic acid, nonadecatluoro- (CAS 335-76-2) • 1-Decanol, 3,3,4,4,5,5,6,6,7,7,8,8,9,9, 10,10,1 0-heptadecatluoro- (CAS 678-39-7) • Decane, 1,1, 1,2,2,3,3,4,4,5,5,6,6,7,7,8,8-heptadecatluoro-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-heneicosatluoro-12-iodo- (CAS 2043-54-1) • 2-Propenoic acid, 3,3,4,4,5,5,6,6,7,7,8,8,9,9, 10,10,1 0-heptadecatluorodecyl 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- heneicosatluorododecyl ester (CAS 17741-60-5)

3COMPANY SANITIZED DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION

Part IV (cont.) B. ANALYTICAL METHODS Analyses should be conducted using the most accurate instrumentation and procedures available as ofthe time oftesting. 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.

4COMPANY SANITIZED DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION

5

--· **----~=~=~~~~--~--**