p. 1 

Reply To: THOMAS H. SAMPLES 

E. I. du Pont de Nemours and Company 

Director, Risk Management 

1007 Market Street 

Wilmington, DE 19898 

Telephone: 302.999.5565 

Email: Thomas.H.SamplesPdupont.com 

PUBLIC COPY - NO CBI 

CBIC CONTROL # 362450_S 

October 31, 2014 

VIA OVERNIGHT DELIVERY 

OPPT Document Control Office (DCO) 

Attention: Docket ID Number EPA-HQ-OPPT-2006-0621 

1201 Constitution Avenue, NW 

EPA East Building, Room 6428 

Washington, DC 20004 

Dear Sir/Madam: 

2010/15 PFOA Stewardship Program Report 

DuPont is pleased to submit its annual report describing our progress in meeting the 2010/15 PFOA 

Stewardship Program goals. The report describes accomplishments in 2013 against the major 

milestones set when the program launched in January 2006. 

For 2013, DuPont has reduced its facility emissions and product content by over 99.5% from the base 

years established for this program. DuPont made additional progress toward the second program goal 

to work toward elimination of PFOA and related chemicals by 2015. Consistent with the DuPont 

commitment in 2007 to no longer make, buy or use PFOA by 2015, or earlier if possible, DuPont ceased 

its manufacture of PFOA in first quarter 2013. DuPont also eliminated use of PFOA in the manufacture 

of fluoropolymers as of the end ofJune 2013 and in perfluoroelastomers as of the end of December 

2013, two years ahead of the EPA goal. We made additional progress in our remaining product line, and 

by the end of 2013 had converted nearly 90% of the fluorotelomer products to short-chain chemistry 

that cannot break down to PFOA in the environment. We are on track to complete this conversion to 

alternatives for the remaining fluorotelomer products by the end of 2014. 

Since our transition to alternatives will be completed at the end of 2014, DuPont will submit its final 

report for the PFOA Stewardship program in 2015. We expect to submit this documentation for this 

voluntary program at the end of the second quarter 2015. DuPont continues to support appropriate 

science-based regulation and looks forward to completion of the Chemical Action Plan by the US EPA to 

address the manufacture and use of long-chain perfluoroalkyl substances (PFAS) by manufacturers, 

importers and processors that have not participated in the 2010/15 PFOA Stewardship Program. 

Thomas H. Samples 
OPPT-2006-0621 

2010/15 PFOA Stewardship Program 

DuPont Submission 

CBIC Control Number 

363442 

RECEIVED 

OPPT CBIC 

2015 Ai 20 A1111: 04 

p. 2 

October 31, 2014 

Page 1 of I 

Index of Documents — Public Version 

Document Number of 

Date Document Pages 

10.31.14 Transmittal letter for report 1 

10.31.14 CBI 5 

10.31.14 Appendix D - Facility Report on Product 

Content - Aqueous Fluoropolymer Dispersion 5 

10.31.14 Appendix D — Facility Report on Product 

Content — Fluoroelastomers 6 

10.31.14 Appendix D — Facility Report on Product 

Content — Fluorotelomers 6 

10.31.14 Appendix F — Company Annual Report 

Summary of Reductions in Emissions and 

Product Content 3 

10.31.14 CBI (Attachments) 6 

COMPANY SANITIZED PUBLIC COPY OCTOBER 31, 2014 
COMPANY SANITIZED PUBLIC COPY OCTOBER 31, 2014

2010/15 PFOA STEWARDSHIP PROGRAM 

October 31, 2014 

DuPont Submission 

Document 002 

Claimed as Confidential Business Information
COMPANY SANITIZED PUBLIC COPY OCTOBER 31, 2014

2010/15 PFOA STEWARDSHIP PROGRAM 

October 31, 2014 

DuPont Submission 

Document 003 

Claimed as Confidential Business Information
COMPANY SANITIZED PUBLIC COPY OCTOBER 31, 2014

2010/15 PFOA STEWARDSHIP PROGRAM 

October 31, 2014 

DuPont Submission 

Document 004 

Claimed as Confidential Business Information
COMPANY SANITIZED PUBLIC COPY OCTOBER 31, 2014

2010/15 PFOA STEWARDSHIP PROGRAM 

October 31, 2014 

DuPont Submission 

Document 005 

Claimed as Confidential Business Information
COMPANY SANITIZED PUBLIC COPY OCTOBER 31, 2014

2010/15 PFOA STEWARDSHIP PROGRAM 

October 31, 2014 

DuPont Submission 

Document 006 

Claimed as Confidential Business Information 
Company Sanitized Public Copy OCTOBER 31, 2014

Appendix D 

Facility Report on Product Content 

Aqueous Fluoropolymer Dispersion 

Company Sanitized Public Version 
Company Sanitized Public Version OCTOBER 31, 2014

2010/15 PFOA Stewardship Program 

Facility Report on Product Content 

Company Sanitized Public Version

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. du Pont 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 

 974 Centre Road 

 Wilmington DE, 19805 

III. PRODUCTION 

Calendar year for which you are reporting: Jan 1, 2013 to Dec 31, 2013 
Company Sanitized Public Version OCTOBER 31, 2014

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 Version OCTOBER 31, 2014

 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 Version OCTOB

SECTION 4: SUMMARY OF PRODUCT CONTENT Polymers – Company Sanitized Public Version Reporting Period (use calendar year - e.g. Jan 1, 2005 to Dec 31, 2005) January 1, 2013 – December 31,2013 

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 

2 3 99.9% 

Precursors 

4c Non-U.S. facilities

PFOA, PFOA salts and higher homologues 

1 1 99.9% 

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 Version OCTOB

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 Version October 31, 2014 

Appendix D 

Facility Report on Product Content 

Fluoroelastomers 

Company Sanitized Public Version 

 
Company Sanitized Public Version October 31, 2014 

2010/15 PFOA Stewardship Program 

Facility Report on Product Content 

Company Sanitized Public Version

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 Polymers 

 

 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 and Fluoroproducts 

 CRP702/2310-B 

 974 Centre Rd 

 Wilmington, Delaware 19805 
Company Sanitized Public Version October 31, 2014 

III. PRODUCTION 

Calendar year for which you are reporting: Jan 1, 2013 to Dec 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 Version October 31, 2014 

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 Version October 31, 2014 

SECTION 4: SUMMARY OF PRODUCT CONTENT Fluoroelastomers Company Sanitized Public VerReporting Period (use calendar year - e.g. Jan 1, 2005 to Dec 31, 2005) January 1, 2013 – December 31, 2013 

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 2,000 ppb 2 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 Version October 31, 2014 

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 Version OCTOBER 31, 2014

Appendix D 

Facility Report on Product Content 

Fluorotelomers 

Public Version
Company Sanitized Public Version OCTOBER 31, 2014

2010/15 PFOA Stewardship Program

Facility Report on Product Content 

Company Sanitized Public Version

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: 2013

 [CBI] 

II. COMPANY IDENTIFICATION 

Identify the company and location of the facility submitting information: 

 

 Company name: DuPont 

 

 Site locations: [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 and Fluoroproducts 

 Chestnut Run Plaza CRP 702-2310-B 

 974 Centre Road 

 Wilmington, DE 19805 
Company Sanitized Public Version OCTOBER 31, 2014

III. PRODUCTION 

Calendar year for which you are reporting: Jan 1, 2013 to Dec 31, 2013 

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) 

 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) 
Company Sanitized Public Version OCTOBER 31, 2014

 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 Version OCTOBER 31, 2014

SECTION 4: SUMMARY OF PRODUCT CONTENT - Fluorotelomers Company Sanitized Public VersioReporting Period (use calendar year - e.g. Jan 1, 2005 to Dec 31, 2005) January 1, 2013 to December 31, 2013 

4a 

Product type Fluoropolymer dispersions Other fluoropolymersiii TProduction volume (kgs/year)iii Over 

4b 

Operations Chemical category

Concentrationiv % R

from base

Fluoropolymer 

dispersionsv

(ppm wetweight) 

Other 

fluoropolymers1,vi

(ppb dry weight) 

Telomer based 

productsvii

(kgs) 

Fluoropolymer 

dispersions

fluoro

U.S. facilities

PFOA, PFOA salts 2 kgs Direct Precursors  C8 Telomer A  8-2-8 Ester Indirect Precursors  8-2 Alcohol  8-2 Iodide  8-2 Olefin 

 [CBI] 

4c Non-U.S. facilities 

PFOA, PFOA salts 7 kgs Direct Precursors  C8 Telomer A  8-2-8 Ester Indirect Precursors  8-2 Alcohol  8-2 Iodide  8-2 Olefin 

 [CBI] 

4d

Please provide information on the methods, assumptions, uncertainties and detection limits for the data proC005a App D for 2012. Full year best estimates based on anticipated product mix and site production split PFOA Reduction overall is nearly 99%; IDPs reduction overall is 97% 
Company Sanitized Public Version OCTOBER 31, 2014

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 - 2011. 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. 

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 

Appendix F 

Company Annual Report – Summary of 

Reductions in Emissions and Product Content 

Company Sanitized Public Version 
Company Sanitized Public Copy 

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, 2013 – December 31, 2013 

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 90 Higher homologues Precursors [CBI] 

3b Non-U.S. facilities

PFOA and PFOA salts 45 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 

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, 2011 – December 31, 2011 

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. 
Company Sanitized Public Copy October 31, 2014 

2010/15 PFOA STEWARDSHIP PROGRAM 

October 31, 2014 

DuPont Submission 

Document 011 

Claimed as Confidential Business Information 
Company Sanitized Public Copy October 31, 2014 

Index of Attachments 

1 Attachment 1 - Pascagoula PFOA results letter 1-2013 thru 12-2013 

2. CBI

3. CBI 

4. CBI