# Company sanitized

Does not contain Confidential Business Information

(CBI)

Appendix C



# Draft Facility Report on Emissions

## 2010/15 PFOA Stewardship Program



# Draft Facility Report on Emissions

I. CHEMICAL IDENTIFICATION

Identify the chemical for which you are submitting information:

Chemical name: Ammonium perfluorononanoate

CAS number:

___ 4149

- 60

- 4

___

II. COMPANY IDENTIFICATION

Identify the company and location of the facility submitting information:

Company name:

___ ASAHI GLASS CO.,LTD

______ _

Site location:

_____ Chiba Plant

__________

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

submitted:

Technical contact:

__ Tomoaki Y o shinaka

________ Phone:

__ 81

- 436

- 23

- 3146

______ ____________ Address:

_ 10, Goikaigan, Ichihara

- shi, Chiba 290

- 8566, Japan

_______III. ON

- SITE ACTIVITIES

Calendar year for which you are reporting: Jan 1, 20 1 1 to Dec 31, 20 1 1

(Normalized data based on year end run rate)

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

I mported (virgin)

___ CBI

___ kgs /yr

Imported (externally recycled)

__ ZERO __kgs/yr

M anufactured

__ ZERO

__ kgs /yr

Estimate the amount of subject chemical distributed off

- site:

_____ 0

____ % of manufacture/import

Provide the amount used (includi ng any that was manufactured, imported [virgin or

externally recycled] , or internally recycled) of the subject chemical for the reporting year

at specific site:

____ CBI

___ kgs /yr

Narrative Descrip tion and Process Flow Schematic :

Provide overall material balance of the chemical being reported

, showing releases

and products ( kgs /year). Use the following page to provide a narrative description and

process flow schematic of on

- site activities, and i nclude information that gives an

understanding of the nature and extent of potential expo sures to the subject chemical.

Atta ch 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. I n the event the subject chemical is used in many

different processes, provide information on each major process instead of each individual

process.

Narrative Description and Process Flow Schematic :

CBII V. SITE RELEASE AND TRANSFER IN FORMATION

(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

significan t 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 “N A ” 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 s ources/bas i s include s :

1. If the source/basis is an analytical measurement, then

 Describe the method (including analytical standards used, sampling,

sample treatment, analysis).

 Describe the uncertainties and assumptions made.

 Give the Level of Detection (LOD) /Level of Quantification (LOQ)

.

2. If the source/basis is a mass balance, then

 Show the mass balance calculation.

 Show that the mass balance closes.

 If the mass balance does no t close, then report the fraction of t otal

feed stock 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 ca lculations are

used, give a general description and state your assumptions. Describe the

uncertainties.Part IV (cont.)

A. ON

- SITE AIR RELEASES

Estimate the total fugitive or non

- point releases to air and the number of days per

year the releases occur. Th ese 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 pollut ion control equipment.

If desired, you can provide estimates of the accuracies of your release estimates.

Estimated Total Estimated % # D ays/year

Annual Releases Accuracy R elease O ccurs

(kgs ) (Optional)

Fugitive (non

- point)

_ CBI ± 50%

__ CBI

_

Stack (point)

_ NA

__ _____ _____

Bas i s for each release estimate :

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

APFN content of polymer subjected to drying was analyzed. All APFN in polymer were

assumed to be emitted to air.

Comments:

( This section is available to clarify your responses . Atta ch additional pages if desired.)Part I V ( con t.)

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 treatm ent,

and contribution from storm water runoff, if applicable. Do not include discharges to a

POTW or other off

- site wastewater treatment facilities. If desired, you can provide an

estimate of the accuracy of your release estimate.

Estimated Total Estimated % # D ays/year

Annual Releases Accuracy R elease O ccurs

(kgs ) (Optional)

Water releases: CBI ± 50 %

_ CBI

_

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) :__ Tokyo Bay

__ _

NPDES number (s) :__ Not a pplicable

__ _______ _

Bas i s for each release estimate :

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

An alysis of samples of wastewater

Comments:

( This section is available to clarify your responses . Atta ch additional pages if desired.)Part IV (cont.)

C. ON

- SITE LAND RELEASES

Estimate the total releases of the chemical for each category of land disposal, if

applicable. Estimate only on

- site release s . Do not estimate leaks from landfills separately.

This should be accounted for in your estimate of total landfill release.

Releas es 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 di ked are as 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.

Ot her releases include any amount of the chemical that is released to land other

than those listed. An example is the accidental release of the chemical from an

underground pipeline or storage tank.

Estimated Total Estimated %

Annual Releases Accuracy

(kgs ) ( Optiona l)

Landfill ZERO

_____

Land Treatment/Land Amendment ZERO

_____

Surface Impoundments ZERO

_____

Underground Injection ZERO

_____

Other (specify): ZERO

_____

Bas i s for each release estimate :

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

Comments:

( This section is available to clarify your responses . Atta ch additional pages if desired.)No such activity.

Part IV (cont.)

D. OFF

- SITE TRANSFERS

Estimates of off

- site transfers should be similar in accuracy and precision to

previous release estimates.

Dl. Transfer to Publicly Owned Treatment Works (POTW)

Number of days/year the release occurs: _ NA

_

Estim ate 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.

Annu al Transfer ( kgs ):

_____

Estimated % Accuracy of Transfer Estimate (optional) _____

POTW Name:____________________________

S treet Address: ___________________________________________

City: _____

___________ County: _____

_________ State: _____ Zip Code: _____

NPDES number: _______________________

Bas i s for each release estimate :

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

Comments:

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

No transfer to POTW in year 2004.Part IV (cont.)

D2. Transfers to other off

- site locations

In this section

, estimate the quantity of the subject chemical , not the waste stream,

transferred and the accuracy of the estimate for each categ ory 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 recycl ing activities).

Est imated Annual Estimated %

Transfers ( kgs ) accuracy

(Optional)

Incineration CBI ± 50 %

Wastewater Treatment

(Excluding POTW) ZERO

_____

Underground Injection ZERO

_____

Hazardous Waste (RCRA

Subtitle C) L andfi ll ZERO

_____

Other L andfill CBI ± 50 %

Recycle or Recovery ZERO

_____ (Does not include internally recycled)

Internally Recycled ZERO

_____

Unknown or Other ZERO

_____

Bas i s for each release estimate :

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

Analysis of CBI

Mass balance of CBI

.

Comments:

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

# Appendix D



# Draft Facility Report on Product Content

## 2010/15 PFOA Stewardship Program



# Draft Facility Report on Product Content

I. CHEMICAL IDENTIFICATION

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

information :

Product name:

__ Carboxylate polymer

__ ________________

Product description (including concentrations of perfluoroalkyl chemicals

identified in Section IV below and year of production):

CBI

.

II. COMPANY IDENTIFICATION

Identify the company and location of the facility submitting information:

Company name:

__ ASAHI GLASS Co.,LTD

_________ _

Site location:

________ Chiba Plant

__________________

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

submitted:

Technical contact:

_ T omoaki Yoshinaka

__________________

Phone:

_ 81

- 436

- 23

- 3146

________________ ____________ Address:

_ 10, Goikaigan, Ichihara

- shi, Chiba 290

- 8566, Japan

_

III. PRODUCTION

Calendar year for which you are reporting: Jan 1, 20 1 1 to Dec 31, 20 1 1

_ (Normalized data based on year end run rate)

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

< Confidential Business Information >

I mported

___ ZERO

____ kgs /yr

M anufactured

___ CBI

___ kgs /yrIV

. 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 279 05

- 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

- 6 2

- 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

- (CA S 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

Analyses should be conducted using the most accurate instrumentation and procedures

availab le as of the time of testing. Please provide detailed information on the methods

used (including analytical standards used, sampling, sample treatment, analysis),

assumptions made, uncertainties and detection limits (LOD, LOQ) for the data provided.

1. D etermination of perfluorononanoate

1

- 1 Sample

(1) Product

(2) Waste water

(3) Waste methanol

(4) Waste C6H

1

- 2 Reagents

Test substance, ammonium perfluorononanoate (APFN, 99.9%, S

- 111P, lot. JI020619)

was produced in Seimi Chemical (Kanag awa, Japan). The surrogate standard, 9

- hydrohexadecafluorononanoic acid (9H

- PFNA, 97.8%, lot. C58002501), were purchased from

Daikin Fine Chemical (Osaka, Japan). Distilled water was produced in

- house and checked for

contaminants by LC/MS before use. Disti lled water was filtered through a pre

- column, Preclean

ORG (GL Sciences Inc. (Tokyo, Japan)) placed between HPLC pump and solvent mixing unit.

HPLC grade methanol, reagent grade ethanol, and reagent grade ammonium acetate were

purchased from Kanto Chemical Co., Inc.

In order to avoid contamination, disposable lab ware (tubes, pipettes, etc) was used. 2 mmol/L

ammonium acetate aqueous solution was prepared for HPLC mobile phase.

1

- 3 Preparation of fortification and surrogate standard

A fortification standa rd containing appropriate amount of PFOA was prepared using a

solvent (2 / 8 (wt) mixture of distilled water / ethanol). A surrogate standard containing 100

ng/ml 9H

- PFNA was prepared using a solvent (1 / 1 (wt) mixture of distilled water / ethanol).

1

- 4 Pretreatment of samples

(1) Product

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

fortification standards of APFN was added into the vials. Five ml of ethanol was added into each

vials for the extraction by ultrasonic. P recipitate was separated by centrifugation or filtration. 0.1

ml of each supernatant and 2 ml of surrogate standard were put in a vial and mixed well. A

portion of the solution was put into the auto

- sampler vial, and injected into LC/MS conditioned

as foll ows. The calculation of concentration in sample was conducted using standard addition

method.

(2) Waste water

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

of each fortification standards of APFN was added into the vials and shaken vigorously. The mixsolution was appropriately diluted with the surrogate standard. A portion of the solution was put

into the auto

- sampler vial, and injected into LC/MS conditioned as follows. The calculation of

concentration in sample wa s conducted using standard addition method.

(3) Waste methanol

Same as (2) Waste water.

(4) Waste C6H

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

fortification standards of APFN were added into the vials. Ten ml of eth anol/water (1/1 (wt)) was

added into each vials for the extraction by shaking. The solution in ethanol/water layer was

appropriately diluted with the surrogate standard. A portion of the solution was put into the auto

sampler vial, and injected into LC/MS conditioned as follows. The calculation of concentration

in sample was conducted using standard addition method.

1

- 5 LC/MS analytical conditions

LC/MS analysis was conducted with the conditions listed below.

<Instruments>

(1) LC/MS

HPLC Agilent Techn ologies, Model 1100

Mass spectrometer Agilent Technologies, Model 1100MSD (SL)

(2) LC column Imtakt (Kyoto, Japan), cadenza CD

- C18 2 mm (diameter) X 100 mm

(3) PC Hewlett Packard Kayak PC Workstation OS: MS

- Windows NT 4.0

(4) Software LC/MSD ChemSt ation, Rev. A. 08. 03

(5) LC/MS vial 2ml vial for auto

- sampler, Chromatography

- Convenience 400

- C80,

Tomsic

(Tokyo, Japan)

<Analytical conditions>

(1) Column temp. 35 °C

(2) Mobile phase Solution A : 2 mmol/L ammonium acetate aqueous solution

Solu tion B : Methanol

(3) Isocratic B : 65 %

(4) Flow rate 0.3 mL/min

(5) Injection volume 5 microL

<MS operating parameters>

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

(2) Fragmentor voltage 100 V

(3) Ion monitored m/z = 463 (C 8 F 17 COO

- ), 4 45 (CF 2 H(CF 2 ) 7 COO

- )

(4) Desolvation temperature 350 °C

(5) Nebulizer gas N 2 (6) Desolvation N 2 12 L/min