# 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 che mical for which you are submitting information:

Chemical name:

_ Perfluoroalkyl Chemicals

_____________________

CAS number:

______________________ __

II. COMPANY IDENTIFICATION

Identify the company and location of the facility submitting informati on:

Company name:

_ Asahi Glass Co., Ltd.

_________ ______________ _

Site location:

_ Chiba Plant, 10, Goikaigan, Ichihara

- shi, Chiba, 290

- 8566,

Japan

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

submitted:

Technical contact:

_ Seiji Shin

- ya

__________________ Phone:

_ 81

- 436

- 23

- 3871

__________________________ ___ Address:

_ 10, Goikaigan, Ichihara

- shi, Chiba 290

- 8566, Japan

___III. ON

- SITE ACTIVITIES

Calendar year for which you are reporting: Jan 1, 20 1 1 _ to Dec 31, 20 1 1

_ (Normalized data based on year end run rate.)

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

I mported (virgin)

_____ 0

_ ___ kgs /yr

Imported (externally recycled)

_____ 0 ____kgs/yr

M anufactured

_ CBI kgs /yr

CBI deleted.

Estimate the amount of subject chemical distributed off

- site:

____ 100

___ % 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:

_____ 0

_____ 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 expo sures to the subject chemical.

Atta ch additional pages if desired. The narrative and process flow schematic should cover major unit operations a nd 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 an d 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. Narative Description and Process Flow Schematic :

CBII V. SITE RELEAS E 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 monito ring 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 b e 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/bas i s include s :

1. If the source/basis is an analytica l 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 no t close, then report the fraction of total

feed stock that is not accounted for and the assumptions you made to

correct the balance. D escribe 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

uncertai nties.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. Th ese releases include equipment leaks from valves, pump seals, flanges, compressors, samplin g 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 % # D ays/year

Annual Releases Accuracy R elease O ccurs (kgs ) (Optional)

Fugitive (non

- point)

_ CBI

_ _____ _ 333

_

Stack (point)

_ CBI

_ _____ _ 333

_

Bas i s for each release estimate : (S ee discussion on so urce/basis in beginning of Section IV.)

Air release was estimated based on volume of off

- gas/vent gas and the concentration of subject chemicals at the handling temperature.

Comments: ( This section is available to clarify your responses . Atta ch add itional pages if desired.)Part I V ( con t.)

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

pr ocess 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 pro vide an estimate of the accuracy of your release estimate.

Estimated Total Estimated % # D ays/year

Annual Releases Accuracy R elease O ccurs (kgs ) (Optional)

Water releases:

_ CBI

_ _____ _ 333

_

Enter the names of the streams or water bodies to w hich 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.

Receivin g Water Name (s) :_ The Tokyo Bay

_

NPDES number (s) :_______________

Bas i s for each release estimate : (S ee discussion on source/basis in beginning of Section IV.)

CBI

.

Comments: ( This section is available to clarify your responses . Atta ch addition al pages if desired.)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 release s . 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 impoundme nts are natural topographic depressions, man

- made excavations, or diked are as formed primarily of earthen materials designed to hold an

accumulation of the chemical.

Underground injection is the technology of placing fluids underground, in porous

formati ons 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 stora ge tank.

Estimated Total Estimated %

Annual Releases Accuracy (kgs ) ( Optiona l)

Landfill

_ na

_ __ _____

Land Treatment/Land Amendment

_ na

__ _____

Surface Impoundments

__ na

_ _____

Underground Injection

_ na

__ _____

Other ( specify):

_ na

__ _____

Bas i s for each release estimate : (S ee discussion on source/basis in beginning of Section IV.)

No on

- site land releases.

Comments: ( This section is available to clarify your responses . Atta ch additional pages if desired.)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: _ na

____

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 know n.

Annual Transfer ( kgs ):

_____

Estimated % Accuracy of Transfer Estimate (optional) _____

POTW Name:____________________________

S treet Address: ___________________________________________ City: _____

___________ County: _____

_________ State: ____

_ Zip Code: _____

NPDES number: _______________________

Bas i s for each release estimate : (S ee discussion on source/basis in beginning of Section IV.)

No transfer to POTW

.

Comments: ( This section is available to clarify y our responses . Atta ch additional pages if desired.)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 ca tegory 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 recycl ing activities).

Estimated Annual Estimated % Transfers ( kgs ) accuracy (Optional)

Incineration

_ CBI

_____

Wastewater Treatment (Excluding POTW)

_ na

__ _____

Underground Injection

_ na

__ _____

Hazardous Waste (RCRA

Sub title C) L andfill

_ na

__ _____

Other L andfill

__ na

_ _____

Recycle or Recovery

_ na

__ _____ (Does not include internally recycled)

Internally Recycled

_ na

_ _____

Unknown or Other

_ na

___ _____

B as i s for each release estimate : (S ee discussion on source/basis in beginning of Section IV.)

Comments: ( This section is available to clarify your responses . Atta ch additional pages if desired.)

There is o n site incineration, which is CBI kg, besides the above mentioned off

- site

i ncineration. The amount for landfill was based on analysis of representative samples.

# Company sanitized

Does not contain Confidential Business Information

(CBI)

Appendix D



# Draft F acility 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 y ou are submitting

information :

Product name:

_ Tel omer Products

______________________

Product description (including concentrations of perfluoroalkyl chemicals identified in Section IV below and year of production): Products include both polymeric and non

- polymeric chemicals. Exports are global.

____________________ __________ ______

II. COMPANY IDENTIFICATION

Identify the company and location of the facility submitting information:

Company name:

_ Asahi Glass Co. , Ltd.

_______ _______

Site loca tion:

_ Chiba Plant, 10, Goikaigan, Ichihara

- shi, Chiba, 290

- 8566,

Japan

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

submitted:

Technical contact:

_ Seiji Shin

- ya

___ ___________________ Phone:

___ 81

- 436

- 3871

__________________ ____________ Address:

_ 10, Goikaigan, Ichihara

- shi, Chiba 290

- 8566, Japan

III. PRODUCTION

Calendar year for which you are reporting: Jan 1, 20 1 1 _ to Dec 31, 20 1 1

_ (Normalized data based on year end run rate.)

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

I mported

___ 0

_____ kgs /yr

M anufactured

_ see S ection IV

_ kgs /yrIV

. PRODUCT CONTENT

A. CONCENTRATIONS OF RELEVANT PERFLUOROALKYL CHEMICALS

Please provide the concen trations (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

 Octan oic 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

- hepta decafluoro

- (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

 Dode cane, 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

- heneicos afluoro

- 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 )Products transferred to our subsidiary , Seimi, as raw material were not counted in the

manufactured amount of Asahi below but were counted in the report of Seimi to avoid

double count.

1. TBPP ( CBI )

Manufactured: CBI Content of Perfluoroalkyl Chemicals

Precursors: CBI PFOA and homologues: CBI 2. TBPP ( CBI )

Manufactured: CBI Content of Perfluoroalkyl Chemicals

Precursors: CBI PFOA and homologues: CBI

3. CBI

Manufactured: CBI Content of Perfluoroalkyl Chemicals

Precursors: CBI

4. CBI

Manufactured: CBI Content of Perfluoroalkyl Chemicals

Precursors: CBI

5. CBI

Manufactured : CBI Content of Perfluoroalkyl Chemicals

Precursors: CBI

6. CBI

Manufactured : CBI Content of Perfluoroalkyl Chemicals

Precursors: C BIPart 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 analytica l standards used, sampling, sample treatment, analysis), assumptions made, uncertainties and detection limits (LOD, LOQ) for the data provided.

1. Determination of perfluorooctanoic acid

, perfluoro nonan oic acid

, and perfluoro dec anoic acid

1

- 1 Sample

(1) P roduct (2) Waste water (3) Waste solid (sludge)

1

- 2 Reagents Test substance, perfluorooctanoic acid (PFOA, 98.9%, lot. C17001401) and the surrogate standard, 9

- hydrohexadeca

- fluorononanoic acid (9H

- PFNA, 97.8%, lot. C58002501), were purchased from Daiki n Fine Chemical (Osaka, Japan). P erfluoro non ano ic acid (PF NA

, 99.9 %,

lot. JI020606 ) w as produc ed in Seimi Chemical Co., Ltd. ( Kanagawa, Japan ). P erfluoro dec ano ic

acid (PF DA , lot. HC01 ) w as purcha ed from Tokyo Chemical Industry Co., Ltd. ( Tokyo, Japan ).

Dis tilled water was produced in

- house and checked for contaminants by LC/MS before use. Distilled water was filtered through a pre

- column, Preclean

- ORG (GL Sciences Inc. (Tokyo, Japan)) placed between HPLC pump and solvent mixing unit. HPLC grade methanol, re agent grade ethanol and isopropanol (IPA), and reagent grade ammonium acetate were purchased from Kanto Chemical Co., Inc. In order to avoid contamination, disposable lab ware (tubes, pipettes, etc) was used. 2 mmol/L

aqueous a mmonium acetate solution was prepared for HPLC mobile phase.

1

- 3 Preparation of fortification and surrogate standard

Each fortification standard containing appropriate amount of PFOA , PFNA, and PFDA was prepared using a solvent (2 / 8 (wt) mixture of distilled water / ethanol). A su rrogate standard containing 100 ng/ml 9H

- PFNA was prepared using a solvent (1 / 1 (wt) mixture of distilled water / ethanol).

1

- 4 Pretreatment of samples (1) Product After the sample was shaken well for homogeneity, 1ml of the sample was put in each

of se veral vials. A ppropriate amount of e ach fortification standards of PFOA was added into the vials and shaken vigorously, and 5 ml of IPA was added and mixed well. Precipitate was separated by centrifugation at 8000 rpm for 40 minutes. 1 ml of each supernata nt and 9 ml of surrogate standard were put in a vial and mixed well. A portion of the solution was put into the

auto

- sampler vial, and injected into LC/MS conditioned as follows. The calculation of concentration in sample was conducted using standard addit ion method

.(2) Waste water

A ppropriate amount of the sample was put in each of several vials. A ppropriate amount
of e ach fortification standards of PFOA , PFNA, and PFDA w ere added into the vials and shaken vigorously . The mix solution was a ppropriate ly d iluted with the surrogate standard

. A portion of the solution was put into the auto

- sampler vial, and injected into LC/MS conditioned as follows.

The calculation of concentration in sample was conducted using standard addition method

. (3) Waste solid (slud ge) One g of the sample was put in each of several vials. A ppropriate amount of e ach

fortification standards of PFOA , PFNA, and PFDA w ere added into the vials . Five ml of ethanol

was added into each vials for the extraction by ultrasonic. Precipitate was s eparated by centrifugation or filtration

. E ach supernatant was a ppropriate ly diluted with the surrogate standard. A portion of the solution was put into the auto

- sampler vial, and injected into LC/MS

conditioned as follows. The calculation of concentration in sample was conducted using standard

addition method

.

1

- 5 LC/MS analytical conditions LC/MS analysis was conducted with the conditions listed below.

<Instruments> (1) LC/MS

HPLC Agilent Technologies, Model 1100 Mass spectrometer Agilent Technol ogies, Model 1100MSD (SL) (2) LC column Imtakt (Kyoto, Japan), cadenza CD

- C18 2 mm (diameter) X 100 mm (3) PC Hewlett Packard Kayak PC Workstation OS: MS

- Windows NT 4.0 (4) Software LC/MSD ChemStation, Rev. A. 08. 03 (5) LC/MS vial 2ml vial for auto

- sampler, Chromatography

- Convenience 400

- C80,

Tomsic (Tokyo, Japan)

<Analytical conditions> (1) Column temp. 35 ° C (2) Mobile phase Solution A : 2 mmol/L ammonium acetate

Solution B : Methanol (3) Gradient min 0 → 1 → 5 → 15 → 15.01

B % 43 → 43 → 1 00 → 100 → 43 (post run : B 43 % , 10 min) (4) Flow rate 0.3 mL/min (5) Injection volume 5 micro L

<MS operating parameters> (1) Ionization mode Electrospray (ESI) (negative ion mode) (2) Fragmentor voltage 100 V (3) Ion monitored m/z = 413 (C 7 F 15 COO - ), 463 (C 8 F 17 COO - ), 513 (C 9 F 19 COO - ), 445 (CF 2 H(CF 2 ) 7 COO - ) (4) Desolvation temperature 350 ° C (5) Nebulizer gas N 2(6) Desolvation N 2 12 L/min

2 . Determination of precursors

2

- 1 Sample

(1) Product (2) Waste water (3) Waste solid (sludge)

2

- 2 Reagents

Te st substance, reagent grade 8

- 2 alcohol ( lot. A18202601 ) and 10

- 2 alcohol ( lot.

A 20 20 8602 ) were purchased from Daikin Fine Chemical (Osaka, Japan). 8

- 2 olefin (99. 8 %) was produced in

- house.

Other substances are obtained as described in the section 1

- 2.

2

- 3 Preparation of fortification standards

Each appropriate concentration of 8

- 2 alcohol , 10

- 2 alcohol, and 8

- 2 olefin w as prepared using

ethanol

.

2

- 4 Pretreatment of samples (1) Product After the sample was shaken well for homogeneity, 1ml of the sample was put in each

of several vials. A ppropriate amount of e ach fortification standards of the precursors was added

into the vials and shaken vigorously, and 5 ml of IPA was added and mixed well. Precipitate was separated by centrifugation at 8000 rpm for 40 minutes. A portion of supernatant was put into the

auto

- sampler vial, and injected into GC

- MS conditioned as follows. The calculation of concentration in sample was conducted using standard addition method

. (2) Waste water

A ppropriate amount of the sample was put in each of several vials. A ppropriate amount
of e ach fortification standards of the precursors w ere added into the vials and shaken vigorously

. The mix solution was a ppropriate ly diluted with ethanol. A portion of supernatant was put into

the auto

- sampler vial, and injected into GC

- MS conditioned as follows. The calculation of concentration in sample was conducted using standard addition method

. (3) Waste solid (sludge) One g of the sample was put in each of several vials. A ppropriate amount of e ac h

fortification standards of the precursors w ere added into the vials . Five ml of ethanol was added

into each vials for the extraction by ultrasonic. Precipitate was separated by centrifugation or filtration

. E ach supernatant was a ppropriate ly diluted with the surrogate standard. A portion of supernatant was put into the auto

- sampler vial, and injected into GC

- MS conditioned as follows.

The calculation of concentration in sample was conducted using standard addition method

.

2

- 5 GC

- MS analytical conditions

GC

- MS analysis was conducted with the conditions listed below.

<Instruments> (1)GC

- MS: Agilent Technologies, Model 5890 / JEOL GC mate II<GC

- MS Analytical conditions>

(1) Injector temp. 220 ° C (2) Oven temp. 40 ° C (2 min)  10 ° C/min  170 ° C (0 min)  30 ° C/min 

250 ° C (10 min) (3) Detector temp. 250 ° C (4) GC column J&W DB

- 1301 0.25 mm diameter X 30 m length with 1 micro m film thickness (5) Column top pressure 30 psi
(6) Injection volume: 1 micro L (7) Split 1:50 (8) Carrier gas He (>99.99%) (9) Ion monitored m/z = 95 (8

- 2 alcohol and 10

- 2 alcohol), 77 (8

- 2 olefin and 10

- 2 orefin)