COMPANY SANITIZED PUBLIC COPY OCTOBER 31, 2012 

2010/15 PFOA Stewardship Program October 31, 2013 

DuPont Submission Page 1 of 1 

 

Index of Documents – Public Version 

 

 Document Number of 

 Date Document Pages__ 

 10.31.13 Transmittal letter for report 1 

 10.31.13 CBI 5 

 

 10.31.13 Appendix D - Facility Report on Product 

 Content - Aqueous Fluoropolymer Dispersion 6 

 10.31.13 Appendix D – Facility Report on Product 

 Content – Fluoroelastomers 6 

 10.31.13 Appendix D – Facility Report on Product 

 Content – Fluorotelomers 6 

 10.31.13 Appendix F – Company Annual Report 

Summary of Reductions in Emissions and 

Product Content 3 

 10.31.13 CBI (Attachments) 7 

 

 

COMPANY SANITIZED PUBLIC COPY OCTOBER 31, 2013

2010/15 PFOA STEWARDSHIP PROGRAM 

October 31, 2013 

DuPont Submission 

Document 002 

Claimed as Confidential Business Information
COMPANY SANITIZED PUBLIC COPY OCTOBER 31, 2013

2010/15 PFOA STEWARDSHIP PROGRAM 

October 31, 2013 

DuPont Submission 

Document 003 

Claimed as Confidential Business Information
COMPANY SANITIZED PUBLIC COPY OCTOBER 31, 2013

2010/15 PFOA STEWARDSHIP PROGRAM 

October 31, 2013 

DuPont Submission 

Document 004 

Claimed as Confidential Business Information
COMPANY SANITIZED PUBLIC COPY OCTOBER 31, 2013

2010/15 PFOA STEWARDSHIP PROGRAM 

October 31, 2013 

DuPont Submission 

Document 005 

Claimed as Confidential Business Information
COMPANY SANITIZED PUBLIC COPY OCTOBER 31, 2013

2010/15 PFOA STEWARDSHIP PROGRAM 

October 31, 2013 

DuPont Submission 

Document 006 

Claimed as Confidential Business Information 
COMPANY SANITIZED PUBLIC COPY OCTOBER 31, 2013

Appendix D 

Facility Report on Product Content 

Aqueous Fluoropolymer Dispersion 

Confidential Business Information (CBI) 

CBI is [bracketed] 
COMPANY SANITIZED PUBLIC COPY OCTOBER 31, 2013

2010/15 PFOA Stewardship Program 

Facility Report on Product Content 

Confidential Business Information

I. CHEMICAL IDENTIFICATION 

Identify the product (e.g fluoropolymer dispersion) for which you are submitting 

information: 

 

 Product name: Aqueous Fluoropolymer Dispersion 

 

Product description (including concentrations of perfluoroalkyl 

chemicals identified in Section IV below and year of production): 

 

Aqueous fluoropolymer dispersions of PTFE and melt copolymers 

[CBI] 

II. COMPANY IDENTIFICATION 

Identify the company and location of the facility submitting information: 

 

 Company name: E. I. DuPont de Nemours and Company 

 Site location: [CBI] 

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

information submitted: 

 Technical contact: Laura A Korte 

 Phone: 302-999-3651

Address: DuPont Chemicals & Fluoropolymers 

 CRP 702/2310-B 

 4417 Lancaster Pike 

 Wilmington DE, 19805 

III. PRODUCTION 

Calendar year for which you are reporting: Jan 1, 2012 to Dec 31, 2012 
COMPANY SANITIZED PUBLIC COPY OCTOBER 31, 2013

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

 

 Imported (not reported) kgs/yr 

 

 Manufactured [CBI] 

 [CBI] 

IV. PRODUCT CONTENT 

A. CONCENTRATIONS OF RELEVANT PERFLUOROALKYL 

CHEMICALS 

Please provide the concentrations (ppb) of various perfluoroalkyl chemicals in 

your product. For chemicals for which you do not have actual data, please 

provide range estimates. 

The following is a nonexhaustive list of chemicals that should be included: 

PFOA and its salts 

 Octanoic acid, pentadecafluoro- (CAS 335-67-1) 

 Octanoic acid, pentadecafluoro- ammonium salt (CAS 3825-26-1) 

PFOA precursors 

 Octane, 1,1,1,2,2,3,3,4,4,5,5,6,6,7,7, 8,8-heptadecafluoro-8-iodo- (CAS 507-63-1) 

 1-Decanol, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-heptadecafluoro- (CAS 678-39-7) 

 1-Decene, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-heptadecafluoro- (CAS 21652-58-

4) 

 2-Propenoic acid, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-heptadecafluorodecyl ester 

(CAS 27905-45-9) 

 2-Propenoic acid, 2-methyl-, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-

heptadecafluorodecyl ester (CAS 1996-88-9) 

 2-Decenoic acid, 3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-hexadecafluoro- (CAS 70887-

84-2) 

 Decanoic acid, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-heptadecafluoro- (CAS 27854-

31-5) 

Higher homologues 

 Dodecane, 1,1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,11,11,12,12-

pentacosafluoro-12-iodo- (CAS 307-60-8) 

 Decane, 1,1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10-heneicosafluoro-10-iodo- 

(CAS 423-62-1) 

 Nonanoic acid, heptadecafluoro- (CAS 375-95-1) 
COMPANY SANITIZED PUBLIC COPY OCTOBER 31, 2013

 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) 

Part IV (cont.) 

B. ANALYTICAL METHODS 

PFOA concentration is measured on all production by Gas Chromatograph/Electron 

Capture Detector (GC/ECD) at the US and European sites and by High Performance 

Liquid Chromatography (HPLC) method at our Japan site. The Limit of Detection 

(LOD) for the GC/ED method is 1 ppm. The LOD for the HPLC method is 3 ppm at this 

time. 
COMPANY SANITIZED PUBLIC COPY OCTOBER 31

SECTION 4: SUMMARY OF PRODUCT CONTENT Polymers – Company Sanitized Version CBI is brReporting Period (use calendar year - e.g. Jan 1, 2005 to Dec 31, 2005) January 1, 2012 – December 31,2012 

4a Product type Fluoropolymer dispersions Other fluoropolymersi T

Production volume (kgs/year)ii [CBI]

4b 

Operations Chemical category

Concentrationiii % R

from ba

Fluoropolymer 

dispersionsiv

(ppm wetweight) 

Fluoropolymer 

dispersions,v

(ppm dry weight) 

Telomer based 

productsvi

(ppb dry weight ) 

Fluoropolymer 

dispersions 

(wet)

fluoro

U.S. facilities

PFOA, PFOA salts and higher homologues 

6 11 99.3% 

Precursors 

4c Non-U.S. facilities

PFOA, PFOA salts and higher homologues 

5 8 99.6% 

Precursors 

4d

Please provide information on the methods, assumptions, uncertainties and detection limits for the data proPFOA concentration is measured on all production by Gas Chromatograph/Electron Capture Detector (GC/

European sites and by High Performance Liquid Chromatography (HPLC) method at our Japan site. The L(LOD) for the GC/ED method is 1 ppm. The LOD for the HPLC method is 3 ppm at this time. 

i Fluoropolymers manufactured with PFOA or PFNA. ii Use the following ranges: (1) Zero (2) > 0 – 10 kgs; (3) > 10 kgs – 100 kgs; (4) > 100 kgs – 1,000 kgs; (5) > 1,000 kgs – 10,000 kg

100,000 kgs; (7) > 100,000 kgs – 1,000,000 kgs; (8) Over 1,000,000 kgs. 

iii Concentration should reflect the concentration of chemical in the product as sold by the reporting company. If the reporting company 

concerning the concentration of chemical in the product as used by others – for example, as incorporated by dilution into a formulation 

information would also be helpful. 

iv This value should be expressed as a weighted average concentration and range. 
COMPANY SANITIZED PUBLIC COPY OCTOBER 31

v This value should be expressed as a maximum concentration. vi This value should be expressed as a simple (not weighted) average and range. 
COMPANY SANITIZED PUBLIC COPY OCTOBER 31, 2013 

Appendix D 

Facility Report on Product Content 

Fluoroelastomers 

Confidential Business Information (CBI) 

CBI is bracketed. 

 
COMPANY SANITIZED PUBLIC COPY OCTOBER 31, 2013 

2010/15 PFOA Stewardship Program 

Facility Report on Product Content 

Confidential Business Information

I. CHEMICAL IDENTIFICATION 

Identify the product (e.g., fluoropolymer dispersion) for which you are submitting 

information: 

 

 Product name: Fluoroelastomer 

 

 Product description (including concentrations of perfluoroalkyl chemicals 

 identified in Section IV below and year of production): 

Elastomer made from fluorinated monomers in aqueous dispersion with 

the ammonium salt of PFOA, i.e. Octanoic acid, pentadecafluoroammonium salt (CAS 3825-26-1) 

II. COMPANY IDENTIFICATION 

Identify the company and location of the facility submitting information: 

 

 Company name: DuPont Performance Elastomers LLC 

 

 Site location: [CBI] 

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

submitted: 

 Technical contact: Denny Wright 

 Phone: 302 695 2066 

 Address: Experimental Station ESL 293/214 

 200 Powder Mill Rd. Rt141 

 Wilmington, Delaware 19880-0293 
COMPANY SANITIZED PUBLIC COPY OCTOBER 31, 2013 

III. PRODUCTION 

Calendar year for which you are reporting: Jan 1, 2012 to Dec 31, 2012

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

 

 Imported (not reported) kgs/yr 

 

 Manufactured [CBI] 

 [CBI] 

IV. PRODUCT CONTENT 

A. CONCENTRATIONS OF RELEVANT PERFLUOROALKYL CHEMICALS 

Please provide the concentrations (ppb) of various perfluoroalkyl chemicals in your 

product. For chemicals for which you do not have actual data, please provide range 

estimates. 

The following is a nonexhaustive list of chemicals that should be included: 

PFOA and its salts 

 Octanoic acid, pentadecafluoro- (CAS 335-67-1) 

 Octanoic acid, pentadecafluoro- ammonium salt (CAS 3825-26-1) 

PFOA precursors 

 Octane, 1,1,1,2,2,3,3,4,4,5,5,6,6,7,7, 8,8-heptadecafluoro-8-iodo- (CAS 507-63-1) 

 1-Decanol, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-heptadecafluoro- (CAS 678-39-7) 

 1-Decene, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-heptadecafluoro- (CAS 21652-58-

4) 

 2-Propenoic acid, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-heptadecafluorodecyl ester 

(CAS 27905-45-9) 

 2-Propenoic acid, 2-methyl-, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-

heptadecafluorodecyl ester (CAS 1996-88-9) 

 2-Decenoic acid, 3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-hexadecafluoro- (CAS 70887-

84-2) 

 Decanoic acid, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-heptadecafluoro- (CAS 27854-

31-5) 

Higher homologues 

 Dodecane, 1,1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,11,11,12,12-

pentacosafluoro-12-iodo- (CAS 307-60-8) 

 Decane, 1,1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10-heneicosafluoro-10-iodo- 

(CAS 423-62-1) 

 Nonanoic acid, heptadecafluoro- (CAS 375-95-1) 
COMPANY SANITIZED PUBLIC COPY OCTOBER 31, 2013 

Part IV (cont.) 

 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) 

B. ANALYTICAL METHODS 

The method of analysis consisted of a process of extraction using high purity methanol as 

the solvent, followed by LC-MS-MS analysis of the extract as described in the following article: 

 Larsen, B. S.,Kaiser, M. A., Botelho, M., Wooler, G. R., Buxton, L. W. Comparison of 

Pressurized Solvent and Reflux Extraction methods for the determination of perfluorooctanoic 

acid in polytetrafluoroethylene polymers using LC-MS-MS. Analyst. 2005, 130, 59-62.
COMPANY SANITIZED PUBLIC COPY OCTOBER 31, 2013 

SECTION 4: SUMMARY OF PRODUCT CONTENT Fluoroelastomers CBI is bracketed Reporting Period (use calendar year - e.g. Jan 1, 2005 to Dec 31, 2005) January 1, 2012 – December 31, 2012 

4a 

Product type Fluoropolymer dispersions Other fluoropolymersi TProduction volume (kgs/year)ii [CBI] 

4b 

Operations Chemical category

Concentrationiii % R

from ba

Fluoropolymer 

dispersionsiv

(ppm wetweight) 

Other 

fluoropolymers1,v

(ppb dry weight) 

Telomer based 

productsvi

(ppb dry weight ) 

Fluoropolymer 

dispersions

fluoro

U.S. facilities

PFOA, PFOA salts and higher homologues 

Fluoroelastomers 3,000 ppb 3 ppm) 

 99% 

Precursors 

4c Non-U.S. facilities

PFOA, PFOA salts and higher homologues 

Fluoroelastomers 0 ppb

 100% 

Precursors 

4d

Please provide information on the methods, assumptions, uncertainties and detection limits for the data proFluoroelastomers content: analytical measurement GC/ECD (Gas Chromatography / Electron Capture Deteppm on limited but representative sample of past production, as elimination of use of PFOA occurred in 20

manufacturing of most fluoroelastomers. Current production analyzed with LC/MS/MS (Liquid Chromatog

Spectrometry Triple Quad) with LOD of 30 ppt after Pressurized Solvent Extraction Technique, as describearticle:  Larsen, B. S.,Kaiser, M. A., Botelho, M., Wooler, G. R., Buxton, L. W. Comparison of Pressurized Extraction methods for the determination of perfluorooctanoic acid in polytetrafluoroethylene polymers usi

Analyst. 2005, 130, 59-62. 
COMPANY SANITIZED PUBLIC COPY OCTOBER 31, 2013 

i Fluoropolymers manufactured with PFOA. ii Use the following ranges: (1) Zero (2) > 0 – 10 kgs; (3) > 10 kgs – 100 kgs; (4) > 100 kgs – 1,000 kgs; (5) > 1,000 kgs – 10,000 kg

100,000 kgs; (7) > 100,000 kgs – 1,000,000 kgs; (8) Over 1,000,000 kgs. 

iii Concentration should reflect the concentration of chemical in the product as sold by the reporting company. If the reporting company 

concerning the concentration of chemical in the product as used by others – for example, as incorporated by dilution into a formulation 

information would also be helpful. 

iv This value should be expressed as a weighted average concentration and range. v This value should be expressed as a maximum concentration. vi This value should be expressed as a simple (not weighted) average and range. 
COMPANY SANITIZED PUBLIC COPY OCTOBER 31, 2013

Appendix D 

Facility Report on Product Content 

Fluorotelomers 

Confidential Business Information (CBI) 

CBI is [bracketed]
COMPANY SANITIZED PUBLIC COPY OCTOBER 31, 2013

2010/15 PFOA Stewardship Program

Draft Facility Report on Product Content 

Confidential Business Information

I. CHEMICAL IDENTIFICATION 

Identify the product (e.g. fluoropolymer dispersion) for which you are submitting information: 

 

 Product name: Fluorotelomer-based polymeric and surfactant products 

 

 Product description (including concentrations of perfluoroalkyl chemicals 

 identified in Section IV below and year of production): 

 Production year: 2012

 [CBI] 

II. COMPANY IDENTIFICATION 

Identify the company and location of the facility submitting information: 

 

 Company name: E. I. du Pont de Nemours and Company 

 

 Site locations: [CBI] 

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

submitted: 

 Technical contact: Ronald Evans 

 Phone: 302-999-2315 

 Address: Dupont Integrated Operations 

 Chestnut Run Plaza CRP 702-2230-F 

 4417 Lancaster Pike 

 Wilmington, DE 19805 
COMPANY SANITIZED PUBLIC COPY OCTOBER 31, 2013

III. PRODUCTION 

Calendar year for which you are reporting: Jan 1, 2012 to Dec 31, 2012 

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

 

 Imported NA kgs/yr 

 

 Manufactured [CBI] 

 

IV. PRODUCT CONTENT 

A. CONCENTRATIONS OF RELEVANT PERFLUOROALKYL CHEMICALS 

Please provide the concentrations (ppb) of various perfluoroalkyl chemicals in your product. For 

chemicals for which you do not have actual data, please provide range estimates. 

The following is a nonexhaustive list of chemicals that should be included: 

PFOA and its salts 

 Octanoic acid, pentadecafluoro- (CAS 335-67-1) 

 Octanoic acid, pentadecafluoro- ammonium salt (CAS 3825-26-1) 

PFOA precursors 

 Octane, 1,1,1,2,2,3,3,4,4,5,5,6,6,7,7, 8,8-heptadecafluoro-8-iodo- (CAS 507-63-1) 

 1-Decanol, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-heptadecafluoro- (CAS 678-39-7) 

 1-Decene, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-heptadecafluoro- (CAS 21652-58-4) 

 2-Propenoic acid, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-heptadecafluorodecyl ester (CAS 

27905-45-9) 

 2-Propenoic acid, 2-methyl-, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-heptadecafluorodecyl 

ester (CAS 1996-88-9) 

 2-Decenoic acid, 3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-hexadecafluoro- (CAS 70887-84-2) 

 Decanoic acid, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-heptadecafluoro- (CAS 27854-31-5) 

Higher homologues 

 Dodecane, 1,1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,11,11,12,12-pentacosafluoro-12-iodo- 

(CAS 307-60-8) 

 Decane, 1,1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10-heneicosafluoro-10-iodo- (CAS 423-62-

1) 

 Nonanoic acid, heptadecafluoro- (CAS 375-95-1) 

 Decanoic acid, nonadecafluoro- (CAS 335-76-2) 

 1-Decanol, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-heptadecafluoro- (CAS 678-39-7) 
COMPANY SANITIZED PUBLIC COPY OCTOBER 31, 2013

 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) 

 [CBI] 

B. ANALYTICAL METHODS – Not CBI

The general methods used for the analyses reported here have been published in the following 

article: 

Larsen, B.S.; Stchur, P.; Szostek, B.; Bachmura, S.F.; Rowand, R.C.; Prickett, K.B.; 

Korzeniowski, S.H.; Buck, R.C. Method development for the determination of residual 

fluorotelomer raw materials and perfluorooctanoate in fluorotelomer-based products by gas 

chromatography and liquid chromatography mass spectrometry. Journal of Chromatography A. 

2006 (1110), 117-124. 

In general the LOQ was 2 ppm and LOD was 0.7 ppm. 

Unpublished improvements have been made to the PFOA method providing for an LOQ of 0.5 

ppm and an LOD of 0.15 ppm. This improved method was used in 2007 – 2011. 
Company Sanitized Public Copy October 31, 20

SECTION 4: SUMMARY OF PRODUCT CONTENT - Telomers Company Sanitized Public Copy Reporting Period (use calendar year - e.g. Jan 1, 2005 to Dec 31, 2005) As of December 31, 2012 

4a 

Product type Fluoropolymer dispersions Other fluoropolymersiii TProduction volume (kgs/year)iii [CBI] 

4b 

Operations Chemical category

Concentrationiv % R

from ba

Fluoropolymer 

dispersionsv

(ppm wetweight) 

Other 

fluoropolymers1,vi

(ppb dry weight) 

Telomer based 

productsvii

(Year End run 

rate - kgs.) 

Fluoropolymer 

dispersions

fluoro

Global Facilities

PFOA, PFOA salts 7 Direct Precursors  C8 Telomer A  8-2-8 Ester 

 <3 

1 1 

 

4d

Please provide information on the methods, assumptions, uncertainties and detection limits for the data pro

LOQs for analytical methods for impurities in DuPont FT products is 2 ppm. Methods used were as follows: LC/MS/MS - PF

Values were obtained by measuring individual products, obtaining the impurity levels in ppm, and then calculating the actual p multiplying the pounds made times the ppm of impurities. These are the values reported above. If a value was determined to  standard EPA convention of 1/2 LOQ as the measurement for the yearly pounds calculation. The general methods used for the  here have been published in the following article: 

Larsen, B.S.; Stchur, P.; Szostek, B.; Bachmura, S.F.; Rowand, R.C.; Prickett, K.B.; Korzeniowski, S.H.; Buck, R.C. Method de

determination of residual fluorotelomer raw materials and perfluorooctanoate in fluorotelomer-based products by gas chromatog

chromatography mass spectrometry. Journal of Chromatography A. 2006 (1110), 117-124. In general the LOQ was 2 ppm and Unpublished improvements have been made to the PFOA method providing for an LOQ of 0.5 ppm and an LOD of 0.15 ppm. Tused in 2007 - 2010 As noted above, the values obtained for this reporting were determined by measurements of actual finished products. Where pomost every major product were analyzed and then averaged. p005a App D for 2010 
Company Sanitized Public Copy October 31, 20

ii Fluoropolymers manufactured with PFOA. iii Use the following ranges: (1) Zero (2) > 0 – 10 kgs; (3) > 10 kgs – 100 kgs; (4) > 100 kgs – 1,000 kgs; (5) > 1,000 kgs – 10,000 k

100,000 kgs; (7) > 100,000 kgs – 1,000,000 kgs; (8) Over 1,000,000 kgs. 

iv Concentration should reflect the concentration of chemical in the product as sold by the reporting company. If the reporting company 

concerning the concentration of chemical in the product as used by others – for example, as incorporated by dilution into a formulation 

information would also be helpful. 

v This value should be expressed as a weighted average concentration and range. vi This value should be expressed as a maximum concentration. vii This value should be expressed as a simple (not weighted) average and range. 
Company Sanitized Public Copy October 31, 2013 

Appendix F 

Company Annual Report – Summary of 

Reductions in Emissions and Product Content 

Company Sanitized Public Copy
Company Sanitized Public Copy October 31, 2013 

SECTION 1: REPORT DATE October 31, 201SECTION 2: COMPANY IDENTIFICATION 

2a 

Company Name E. I. du Pont de Nemours and Company Street Address 1007 Market Street, Wilmington DE USA 19808 

SECTION 3: SUMMARY OF EMISSIONS Reporting Period (use calendar year - e.g. Jan 1, 2005 to Dec 31, 2005) January 1, 2012 – December 31, 2012 

3a 

Operations Chemical category

Releases to all environmental media from 

fluoropolymer and telomer manufacture 

kgs 

1 kgs of fluoropolymers

kgs of category

kgs of telome

kgs of catego

U.S. facilities

PFOA and PFOA salts 137 Higher homologues Precursors [ CBI ] 

3b Non-U.S. facilities

PFOA and PFOA salts 353 Higher homologues Precursors 

3c

Please provide information on the methods, assumptions, uncertainties and detection limits for the data pro

Methods, assumptions, etc. provided in business/site specific forms 
Company Sanitized Public Copy October 31, 2013 

Product Content information is not summarized – see the individual Appendix D reports SECTION 4: SUMMARY OF PRODUCT CONTENT Reporting Period (use calendar year - e.g. Jan 1, 2005 to Dec 31, 2005) January 1, 2012 – December 31, 2012 

4a 

Product type Fluoropolymer dispersions Other fluoropolymers1 TProduction volume (kgs/year)2

4b 

Operations Chemical category

Concentration3 % R

from b

Fluoropolymer 

dispersions4

(ppm wetweight) 

Other 

fluoropolymers1,5

(ppb dry weight) 

Telomer based 

products6

(ppb dry weight ) 

Fluoropolymer 

dispersions 

fluoro

U.S. facilities

PFOA, PFOA salts and higher homologues Precursors 

4c Non-U.S. facilities PFOA, PFOA salts and higher homologues Precursors 

4d 

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

1 Fluoropolymers manufactured with PFOA. 2 Use the following ranges: (1) Zero (2) > 0 – 10 kgs; (3) > 10 kgs – 100 kgs; (4) > 100 kgs – 1,000 kgs; (5) > 1,000 kgs – 10,000 kg

100,000 kgs; (7) > 100,000 kgs – 1,000,000 kgs; (8) Over 1,000,000 kgs. 

3 Concentration should reflect the concentration of chemical in the product as sold by the reporting company. If the reporting company 

concerning the concentration of chemical in the product as used by others – for example, as incorporated by dilution into a formulation 

information would also be helpful. 

4 This value should be expressed as a weighted average concentration and range. 5 This value should be expressed as a maximum concentration. 6 This value should be expressed as a simple (not weighted) average and range. 
CONFIDENTIAL BUSINESS INFORMATION OCTOBER 31, 2013 

2010/15 PFOA STEWARDSHIP PROGRAM 

October 31, 2013 

DuPont Submission 

Document 011 

Claimed as Confidential Business Information 
CONFIDENTIAL BUSINESS INFORMATION OCTOBER 31, 2013 

Index of Attachments 

1 Attachment 1 - Pascagoula PFOA results letter 1-2012 thru 12-2012, 

2. CBI

3. CBI 

4. CBI 
Attachment 1

Company Sanitized Public Copy October 31, 2013
Attachment 1

Company Sanitized Public Copy October 31, 2013
COMPANY SANITIZED PUBLIC COPY OCTOBER 31, 2013 

ATTACHMENT 2 

CLAIMED AS CONFIDENTIAL BUSINESS INFORMATION 
COMPANY SANITIZED PUBLIC COPY OCTOBER 31, 2013 

ATTACHMENT 3 

CLAIMED AS CONFIDENTIAL BUSINESS INFORMATION 
COMPANY SANITIZED PUBLIC COPY OCTOBER 31, 2013 

ATTACHMENT 4 

CLAIMED AS CONFIDENTIAL BUSINESS INFORMATION