COMPANY SANITIZED PUBLIC COPY OCTOBER 30, 2009

Appendix D

Facility Report on Product Content

Fluorotelomers

Company Sanitized Public Copy
COMPANY SANITIZED PUBLIC COPY OCTOBER 30, 2009

2010/15 PFOA Stewardship Program

Facility Report on Product Content

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I. CHEMICAL IDENTIFICATION

Identify the product (e.g fluoropolymer dispersion) for which you 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 production):

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 can respond to inquiries about the information

submitted:

Technical contact: Stephen Korzeniowski

Phone: 302-695-8672

Address: DuPont Experimental Station

ESL 402-5231

Route 141 and Henry Clay

Wilmington, DE 19803
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III. PRODUCTION

Calendar year for which you are reporting: Jan 1, 2008 to Dec 31, 2008

Provide the amount of the product for 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-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
COMPANY 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. 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 2008.
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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 fluoropolymersiii Fluorotelomer based products

4a

Production volume (kgs/year)iii

Concentrationiv % Reduction

from baseline year

Operations Chemical category Fluoropolymer

dispersionsv

(ppm wetweight)

Other

fluoropolymers1,vi

(ppb dry weight)

Telomer based

productsvii

(Year End run

rate - kgs.)

Fluoropolymer

dispersions

Other

fluoropolymers1

Telomer

based

products

PFOA, PFOA salts 16 97%

4b

Global

Facilities

Direct Precursors

C8 Telomer A

8-2-8 Ester

<3

2

<1

97%

Please provide information on the methods, assumptions, uncertainties and detection limits for the data provided above.

4d

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 individual 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 the

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.
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ii Fluoropolymers manufactured with PFOA.

iii 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 1,000,000 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.
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