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:_Perfluoroalkyl Chemicals_____________________

CAS number:________________________

II. COMPANY IDENTIFICATION

Identify the company and location of the facility submitting information:

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 inquiries 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, 2011_ to Dec 31, 2011_

(Normalized data based on year end run rate.)

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

 Imported (virgin) _____0____kgs/yr

 Imported (externally recycled) _____0____kgs/yr

Manufactured _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 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. 

Narative Description and Process Flow Schematic:

 CBI 
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) _CBI_ _____ _333_

Stack (point) _CBI_ _____ _333_

Basis for each release estimate:

(See discussion on source/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. Attach additional pages if desired.)
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: _CBI_ _____ _333_

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):_The Tokyo Bay_

NPDES number(s):_______________

Basis for each release estimate:

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

CBI. 

Comments:

(This section is available to clarify your responses. Attach additional 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 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 _na___ _____

Land Treatment/Land Amendment _ na __ _____

Surface Impoundments __na _ _____

Underground Injection _ na __ _____

Other (specify): _ na __ _____

Basis for each release estimate:

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

No on-site land releases.

Comments:

(This section is available to clarify your responses. Attach 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 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.)

 No transfer to POTW.

Comments:

(This section is available to clarify your responses. Attach 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 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 _CBI _____

Wastewater Treatment

(Excluding POTW) _na__ _____

Underground Injection _na__ _____

Hazardous Waste (RCRA

Subtitle C) Landfill _ na__ _____

Other Landfill __ na_ _____

Recycle or Recovery _ na__ _____

(Does not include internally recycled)

 Internally Recycled _ na_ _____

Unknown or Other _ na___ _____

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.)

 There is on site incineration, which is CBI kg, besides the above mentioned off-site 

incineration. The amount for landfill was based on analysis of representative samples. 
Company sanitized 

Does not contain Confidential Business Information 

(CBI)

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:_Telomer 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 location: _ 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, 2011_ to Dec 31, 2011_

(Normalized data based on year end run rate.)

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

 Imported ___0_____kgs/yr

Manufactured _see Section IV_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)
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: CBI
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.

1. Determination of perfluorooctanoic acid, perfluorononanoic acid, and perfluorodecanoic acid

1-1 Sample

(1) Product

(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 Daikin Fine Chemical (Osaka, Japan). Perfluorononanoic acid (PFNA, 99.9%,

lot. JI020606) was produced in Seimi Chemical Co., Ltd. (Kanagawa, Japan). Perfluorodecanoic 

acid (PFDA, lot. HC01) was purchaed from Tokyo Chemical Industry Co., Ltd. (Tokyo, Japan). 

Distilled 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, reagent 

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 ammonium 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 surrogate 

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 several vials. Appropriate amount of each 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 supernatant 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 addition method.
(2) Waste water

Appropriate amount of the sample was put in each of several vials. Appropriate amount

of each fortification standards of PFOA, PFNA, and PFDA were added into the vials and shaken 

vigorously. The mix solution was appropriately 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.

(3) Waste solid (sludge)

One g of the sample was put in each of several vials. Appropriate amount of each 

fortification standards of PFOA, PFNA, and PFDA were 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. Each supernatant was appropriately 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 Technologies, 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 → 100 → 100 → 43 (post run : B 43 %, 10 min)

(4) Flow rate 0.3 mL/min

(5) Injection volume 5 microL

<MS operating parameters>

(1) Ionization mode Electrospray (ESI) (negative ion mode)

(2) Fragmentor voltage 100 V

(3) Ion monitored m/z = 413 (C7F15COO-), 463 (C8F17COO-), 513 (C9F19COO-), 

445 (CF2H(CF2)7COO-)

(4) Desolvation temperature 350 °C

(5) Nebulizer gas N2
(6) Desolvation N2 12 L/min

2. Determination of precursors

2-1 Sample

(1) Product

(2) Waste water

(3) Waste solid (sludge)

2-2 Reagents

Test substance, reagent grade 8-2 alcohol (lot. A18202601) and 10-2 alcohol (lot. 

A20208602) 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 was 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. Appropriate amount of each 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

Appropriate amount of the sample was put in each of several vials. Appropriate amount

of each fortification standards of the precursors were added into the vials and shaken vigorously. 

The mix solution was appropriately 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. Appropriate amount of each 

fortification standards of the precursors were 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. Each supernatant was appropriately 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)