COMPANY SANITIZED DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 

# 3Jiq5bb RECEIVED OPPT CBIC 

# NOV 08 

# 2012 20\2OCT 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

## HigherHomologues (RJ.-C2Hrl; R1.-C2HrOH; R1·-C2H.;-OCO-CR=CH2:RrCH=CH 2 ) with RF = CB I C8+
11111111111111111111111111111111111111111111111111111111111111111111111111 63130000003/S 

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

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 74653 wolfgang.knaup@clariant.com



### 2COMPANY SANITIZED DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION



### III. ON-SITE ACTIVITIES Calendaryear for which you are reporting: 

### Jan 1, 2011 

### to Dec 31, 2011 Provide the amount ofchemical identified above for the reporting year at specific site: Imported (virgin) Imported (externally recycled) Manufactured Estimate the amount ofsubject chemical distributed off-site:
Provide the amount used (including any that was manufactured, imported [virgin orexternally recycled], orinternally 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 eventthe 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 TRANSFER INFORMATION (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 per year for the reporting period. Enterthe values as whole numbersto 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 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/or basis for determination should be described in detail. Suggested information aboutthe 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 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 or mass 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 AIR RELEASES 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, orother 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 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 wastewatertreatment, and contribution from storm water runoff, ifapplicable. Do not include discharges to a POTW orotheroff-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 orwater 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 NPDES number(s): not available Basis for each release estimate:



### 7COMPANY SANITIZED DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION

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

### 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 yourestimate 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 similarconveyance systems. Other releases 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 relevant not relevant not relevant not relevant (See discussion on source/basis in beginning ofSection IV.) Comments: Estimated% Accuracy (Optional)

(This section is available to clarify yourresponses. Attach additional pages ifdesired.)
9COMPANY SANITIZED DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION
Part IV (cont.) 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) Numberofdays/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. Enter the POTW's NPDES permit number, ifknown. Annual Transfer (kgs): Estimated % Accuracy ofTransfer 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 ofSection IV.)

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

10COMPANY SANITIZED DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION

Part IV (cont.) 02. 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 WastewaterTreatment (Excluding POTW) Underground Injection Hazardous Waste (RCRA Subtitle 

### C) Landfill OtherLandfill Recycle or Recovery (Does not include internally recycled) Internally Recycled Unknown orOther Basis for each release estimate: Estimated Annual Transfers (kgs)

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

II Estimated% accuracy (Optional)COMPANY SANITIZED DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 

# Process Flow Schematic 2011 Telomer ProductionCOMPANY SANITIZED DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION



# Appendix C

# 3\\956~ RECEIVED 

## OPPT CB!C Z0/2OCT31 PM 12:

## 48



# FacilityReport on Emissions in 2011 for Perjluorooctanoic acid(PFOA)



# Company SanitizedCOMPANY 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: 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, 2011 to Dec 31, 2011
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 orexternally recycled], orinternally 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 eventthe 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 per year for the reporting period. Enterthe 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 ofdays per year the 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 of less than 0.5 kgs per year. For all releases, the source ofdata and/or basis 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 correctthe balance. Describe the uncertainties. 3. Ifthe source/basis is otherthan measurement or mass 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 AIR RELEASES Estimate the total fugitive or non-point releases to air and the number ofdays 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 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 ofyour release estimates.

Basis for each release estimate: Estimated TotalEstimated % Annual ReleasesAccuracy (kgs) (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.



### Water releases: Estimated Total Annual Releases (kgs) Estimated% Accuracy (Optional) #Days/year Release Occurs
Enter the names ofthe streams or water bodiesto 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): not available 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 orother 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 notapplicable notapplicable notapplicable (See discussion on source/basis in beginning ofSection IV.)

8 Estimated% Accuracy (Optional)COMPANY SANITIZED DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION
Part IV (cont.) 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) Numberofdays/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. Enter the POTW'sNPDES permit number, ifknown. Annual Transfer (kgs): Estimated% Accuracy ofTransfer Estimate (optional) POTW Name: On-site waste watertreatment 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.) 02. Transfers to otheroff-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 subjectchemical 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 WastewaterTreatment (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 notapplicable notapplicable notapplicable notapplicable notapplicable notapplicable notapplicable

10 Estimated% accuracy (Optional)COMPANY SANITIZED DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 

# Process Flow Schematic 2011 Telomer ProductionCOMPANY SANITIZED DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION



# AppendixD 

# Report on ProductContent 

# 2011 

# 3'-\9Sb6 RECEIVED OPPT CBIC 

## 2012OCT 31 PH 

## 12: 48



# Fluorotelomerbased PolymerDispersions

• PFOA • PFCA (otherthan PFOA) • DirectPrecursors (CsF17-J and C7FwCOOCzH4CsF17) 

## • IndirectPrecursors I 

## HigherHomologues


# Company SanitizedCOMPANY 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 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 Calendaryear for which you are reporting: 

### Jan 1, 

### 2011 to Dec 31, 2011 Provide the amount ofthe product for the reporting year at each specific site: Imported Manufactured 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 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, pentadecatluoro- (CAS 335-67-1) • Octanoic acid, pentadecatluoro- 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,I0, 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, 10,10,10-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-Decano1, 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, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-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

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