COMPANY SANITIZED 

DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 3Jiq5bb 

RECEIVED 

OPPT CBIC 

NOV 08 2012 20\2 OCT 31 PH 12: 48 

OPPT -2006-0621 

Appendix C 

Facility Report on Emissions in < 

2011 

for 

Direct Precursors 

(CsF17-J and C7Fts-COOC2H4CsF17) 

and 

Indirect Precursors I Higher Homologues 

(RJ.-C2Hrl; R1.-C2HrOH; R1·-C2H.;-OCO-CR=CH2: RrCH=CH2) 

with RF = CB I C8+ 

11111111111111111111111111111111111111111111111111111111111111111111111111 

63130000003/S 

Company Sanitized 
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 names:Direct precursors and indirect precursors/ higher homologues 

(RJ.-1; RrC2Hrl; R1,-C2HrOH; RrC2HrOCO-CR=CH2, RrCH=CH2) 

with RF -chain: C8 I C8+ 

CAS number: not applicable 

II. COMPANY IDENTIFICATION 

Identify the company and location of the 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 

2 
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III. ON-SITE ACTIVITIES 

Calendar year for which you are reporting: Jan 1, 2011 to Dec 31, 2011 

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

Imported (virgin) 

Imported (externally recycled) 

Manufactured 

Estimate the amount of subject chemical distributed off-site: 

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: 

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 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. 

3 
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Narrative Description and Process Flow Schematic: 

4 
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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. lfthe 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. Ifthe 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. 

5 
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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 

Annual Releases 

(kgs) 

Basis for each release estimate: 

Estimated% 

Accuracy 

(Optional) 

6 

#Days/year 

Release Occurs 
COMPANY SANITIZED 

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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 

Annual Releases 

(kgs) 

Estimated % # Days/year 

Accuracy Release Occurs 

(Optional) 

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): Alz 

NPDES number(s): not available 

Basis for each release estimate: 

7 
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8 
COMPANY SANITIZED 

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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. 

Landfill 

Land Treatment/Land Amendment 

Surface Impoundments 

Underground Injection 

Other (specify): 

Basis for each release estimate: 

Estimated Total 

Annual Releases 

(kgs) 

not applicable 

not relevant 

not relevant 

not relevant 

not relevant 

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

Comments: 

Estimated% 

Accuracy 

(Optional) 

(This section is available to clarify your responses. Attach additional pages if desired.) 

9 
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Part IV (cont.) 

D. OFF-SITE TRANSFERS 

Not applicable 

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: • 

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: ---------- (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 of Section IV.) 

Comments: 

(This section is available to clarify your responses. Attach additional pages if desired.) 

10 
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Part IV (cont.) 

02. 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). 

Incineration 

Wastewater Treatment 

(Excluding POTW) 

Underground Injection 

Hazardous Waste (RCRA 

Subtitle C) Landfill 

Other Landfill 

Recycle or Recovery 

(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 of Section IV.) 

II 

Estimated% 

accuracy 

(Optional) 
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Process Flow Schematic 2011 Telomer Production 
COMPANY SANITIZED 

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Appendix C 

3\\956~ 

RECEIVED 

OPPT CB!C 

Z0/2 OCT 31 PM 12: 48 

Facility Report on Emissions in 2011 

for 

Perjluorooctanoic acid (PFOA) 

Company Sanitized 
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 of the 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 

2 
COMPANY SANITIZED 

DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 

III. ON-SITE ACTIVITIES 

Calendar year for which you are reporting: Jan 1, 2011 to Dec 31, 2011 

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

Estimate the amount of subject chemical distributed off-site: 

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: 

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 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. 

3 
COMPANY SANITIZED 

DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 

Narrative Description and Process Flow Schematic: 

4 
COMPANY SANITIZED 

DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 

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. Ifthe 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. 

5 
COMPANY SANITIZED 

DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 

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. 

Basis for each release estimate: 

Estimated TotalEstimated % 

Annual ReleasesAccuracy 

(kgs) (Optional) 

6 

#Days/year 

Release Occurs 
COMPANY SANITIZED 

DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 

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. 

Water releases: 

Estimated Total 

Annual Releases 

(kgs) 

Estimated% 

Accuracy 

(Optional) 

#Days/year 

Release Occurs 

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): Alz 

NPDES number(s): not available 

Basis for each release estimate: 

7 
COMPANY SANITIZED 

DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 

Part IV (cont.) 

Estimate the total releases of the chemical for each category ofland 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. 

Landfill 

Land Treatment/Land Amendment 

Surface Impoundments 

Underground Injection 

Other (specify): 

Basis for each release estimate: 

Estimated Total 

Annual Releases 

(kgs) 

not applicable 

not applicable 

not applicable 

not applicable 

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

8 

Estimated% 

Accuracy 

(Optional) 
COMPANY SANITIZED 

DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 

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: -

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 ofTransfer Estimate (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 of Section IV.) 

Comments: 

(This section is available to clarify your responses. Attach additional pages if desired.) 

9 
COMPANY SANITIZED 

DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 

Part IV (cont.) 

02. 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). 

Incineration 

Wastewater Treatment 

(Excluding POTW) 

Underground Injection 

Hazardous Waste (RCRA 

Subtitle C) Landfill 

Other Landfill 

Recycle or Recovery 

(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 

not applicable 

not applicable 

not applicable 

10 

Estimated% 

accuracy 

(Optional) 
COMPANY SANITIZED 

DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 

Process Flow Schematic 2011 Telomer Production 
COMPANY SANITIZED 

DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 

Appendix D 

Report on Product Content 

2011 

3'-\9Sb6 

RECEIVED 

OPPT CBIC 

2012 OCT 31 PH 12: 48 

Fluorotelomer based Polymer Dispersions 

• PFOA 

• PFCA (other than PFOA) 

• Direct Precursors 

(CsF17-J and C7FwCOOCzH4CsF17) 

• Indirect Precursors I Higher Homologues 

Company Sanitized 
COMPANY 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: Fluorotelomer based Polymer Dispersions 

Product description (including concentrations ofperfluoroalkyl chemicals 

identified in Section IV below and of · 

II. COMPANY IDENTIFICATION 

Identify the company and location of the 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, 2011 to Dec 31, 2011 

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

Imported 

Manufactured 

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IV. PRODUCT CONTENT 

A. CONCENTRATIONS OF RELEVANT PERFLUOROALKYL CHEMICALS 

Please provide the concentrations (ppb) of various pertluoroalkyl 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: 

P FOA and its salts 

• Octanoic acid, pentadecatluoro- (CAS 335-67-1) 

• Octanoic acid, pentadecatluoro- ammonium salt (CAS 3825-26-1) 

P FOA precursors 

• 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, I 0, 1 0-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, 10,1 0,1 0-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, 10,1 0,1 0-heptadecatluorodecyl 

ester (CAS 1996-88-9) 

• 2-Decenoic acid, 3,4,4,5,5,6,6,7,7,8,8,9,9, 10,1 0,1 0-hexadecatluoro- (CAS 70887-84-2) 

• Decanoic acid, 3,3,4,4,5,5,6,6, 7, 7,8,8,9,9, 10,1 0,1 0-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, 10,1 0,11,11, 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, 10,1 0-heneicosatluoro-1 0-iodo- (CAS 423-62-

1) 

• Nonanoic acid, heptadecatluoro- (CAS 375-95-1) 

• Decanoic acid, nonadecatluoro- (CAS 335-76-2) 

• 1-Decano1, 3,3,4,4,5,5,6,6, 7, 7,8,8,9,9, 10,1 0,1 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-1 0-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, 10,1 0-heneicosatluoro-12-iodo- (CAS 

2043-54-1) 

• 2-Propenoic acid, 3,3,4,4,5,5,6,6,7,7,8,8,9,9, 10,1 0,1 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) 

3 
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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 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. 

4 
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'.t-. ,,, '' 

5