Appendix C 

Draft Facility Report on Emissions 

October 2010 Submission 

APFN 

NON CBI 

Company Sanitized 
2010/15 PFOA Stewardship Program 

Draft Facility Report on Emissions 

I. CHEMICAL IDENTIFICATION 

Identify the chemical for which you are submitting information: 

Chemical name: APFN 

CAS number: 77623-77-9 

II. COMPANY IDENTIFICATION 

Identify the company and location of the facility submitting information: 

Company name : SOLVAY SOLEXIS, INC. 

Site location : THOROFARE, NJ 

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

submitted : 

Technical contact : VIRGINIA HUBERT 

Phone: (713)525-6051 

Address : _ 10 LEONARD LANE 

THOROFARE, NJ 
III. ON-SITE ACTIVITIES 

Calendar year for which you are reporting: Jan 1, 2009 to Dec 31, 2009 

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

Imported (virgin) 

Imported (externally recycled) 

Manufactured 

Estimate the amount of subject chemical distributed off-site : 

% of manufacture/import 

kgs/yr 

kgs/yr 

- kgs/yr 

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

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

at specific site : 

Narrative Description and Process Flow Schematic : 

Provide overall material balance 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 include information that gives an 

understanding of the nature and extent of potential exposures to the subject chemical . 

Attach additional pages if desired. The narrative and process flow schematic should cover 

major unit operations and chemical conversions for manufacturing and on-site uses, if 

applicable. The narrative should provide insight into why and how releases are caused by 

the process. The schematic should show the points of release of the subject chemical in 

the workplace and to the environment. In the event the subject chemical is used in many 

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

process . 
Narrative Description and Process Flow Schematic : 
p. 6 
IV. SITE RELEASE AND TRANSFER INFORMATION 

(For manufacturing and on-site processing/use if applicable) 

In this section, estimate the total media-specific releases after on-site treatment of 

the chemical from your facility . You may estimate the releases by using monitoring data 

or any other method you believe appropriate. Estimates should be reported in kgs per 

year for the reporting period . Enter the values as whole numbers to no more than two 

significant figures. For example, if your annual releases are estimated to be 12,360 kgs, 

an estimate of 12,000 kgs should be reported . 

Estimate the number of days per year the release occurs . Enter a whole number 

with a maximum of 2 significant figures. 

Insert "NA" for release activities not associated with the chemical or "0" for 

releases of less than 0.5 kgs per year. 

For all releases, the source of data and/or basis for determination should be 

described in detail . Suggested information about the possible sources/basis includes : 

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

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

sample treatment, analysis) . 

" Describe the uncertainties and assumptions made. 

" Give the Level of Detection (LOD)/Level of Quantification (LOQ) . 

2 . 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 not close, then report the fraction of total 

feedstock that is not accounted for and the assumptions you made to 

correct the balance. Describe the uncertainties . 

3 . If the source/basis is other than measurement or mass balance, then 

" Describe the method used. For example, if engineering calculations are 

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

uncertainties. 
Part IV (cont .) 

A. ON-SITE AIR RELEASES 

Estimate the total fugitive or non-point releases to air and the number of days per 

year the releases occur. These releases include equipment leaks from valves, pump seals, 

flanges, compressors, sampling connections, and open-ended lines; evaporative losses 

from surface impoundments and spills ; releases from building ventilation systems; and, 

any other fugitive or non-point air emission. 

In addition, estimate the total releases that occur through stacks, vents, pipes, or 

other confined air streams as stack or point source releases. Include storage tank 

emissions and releases from pollution control equipment . 

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

Fugitive (non-point) 

Stack (point) 

Estimated Total Estimated % # Days/year 

Annual Releases Accuracy Release Occurs 

(kgs) (Optional) 

Basis for each release estimate : 

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

365 

MASS BALANCE - CALCULATED BY DIFFERENCE content in the wash water and 

in the solids were measured 

0 

Comments : 

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

B. WATER RELEASES FROM SITE N/A 

Estimate the total releases of the chemical leaving the fence line of your facility 

from all discharge points to all streams or water bodies . Include all discharges from 

process outfalls such as pipes, open trenches, releases from on-site wastewater treatment, 

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

POTW or other off-site wastewater treatment facilities . If desired, you can provide an 

estimate of the accuracy of your release estimate . 

Estimated Total Estimated % # Days/year 

Annual Releases Accuracy Release Occurs 

(kgs) (Optional) 

Water releases : 365 

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): 

NPDES number(s) : 

Basis for each release estimate : 

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

Comments: 

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

C. ON-SITE LAND RELEASES N/A 

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

applicable. Estimate only on-site releases. Do not estimate leaks from landfills separately. 

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

Releases to land treatment/land amendment include all waste containing the 

chemical that is applied or incorporated into soil on-site. Do not include waste that is 

landfilled . 

Surface impoundments are natural topographic depressions, man-made 

excavations, or diked areas formed primarily of earthen materials designed to hold an 

accumulation of the chemical. 

Underground injection is the technology of placing fluids underground, in porous 

formations of rocks, through wells or other similar conveyance systems . 

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

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

underground pipeline or storage tank. 

Estimated Total Estimated % 

Annual Releases Accuracy 

(kgs) (Optional) 

Landfill 

Land Treatment/Land Amendment 

Surface Impoundments 

Underground Injection 

Other (specify) : 

C ~J 

r 

Basis for each release estimate : 

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

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

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 : 365 

Estimate the total quantity of the subject chemical , not the waste stream, 

transferred to the POTW. Complete section below for each POTW to which your facility 

discharges wastewater containing the chemical . Enter the POTW's NPDES permit 

number, if known. 

Annual Transfer (kgs): 

Estimated % Accuracy of Transfer Estimate (optional) 

POTW Name: GLOUCESTER COUNTY UTILITY AUTHORITY 

Street Address : 2 PARADISE ROAD 

City: WEST DEPTFORD County: GLOUCESTER 

State: NJ Zip Code: 08066 

NPDES number: NJ0024686 

Basis for each release estimate : 

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

The surfactant content in the wash water was measured per the attached method 

PF 89/110 WAS E - Perfluorooctanoate and Higher Homologues in Wastewater 

and Surface Water - Concentration on Porapack Q and Esterification 

Comments : This is the method that was used in 2009 to obtain the data for the mass 

balance . 
;; AusimonT ., : 

APPROVED-COPY N° 

AUSIMONT S.P.A. 

Centro Ricerche e Sviluppo 

Bollate 

Analytical Method 

PF 89/110 WAS E 

Perfluorooctanoate and higher homologues 

in wastewater and surface water 

Concentration on Porapack Q 

and esterification 

This document is composed by: 

N° pages: 6 N° tables : 

N° figures : N° attachments: 

Edition: 3 Date : June 2001 

Laboratory: GC Author: Oriani 

I Verification: Morandi Approval : Pace 

1 Scope and application 

1.1 This method is for the extraction of perfluorooctanoate (APFO) and related 

homologues from wastewater and surface water. 

1 .2 Applicable compounds are : perfluorooctanoate (APFO) [C7FjSCOO-], 

perfluorononanoate [C8Fi7C00], perfluorodecanoate [C9F,9C00-], 

perfluoroundecanoate [C,oFz]C00-], perfluorododecanoate [Cl,F23C00-] and 

higher homologues. 

1.3 Matrices: waste water and aqueous matrixes with APFO concentration lower 

than 5ppm . 

2 Summary 

2.1 Transfer about 70ml of acidic water in a 100ml dreschel bottle . Connect to gas 

dispersion side tube a cartridge packed with about 700mg of Porapack Q 60-80 

PF 89/110 WAS E Page 1 of 6 
;; 

ausimonT,. 

mesh . Connect the second line of dreschel bottle to a Nitrogen supply and 

pressurise at about 20-50 kPa allowing a liquid flow rate through the cartridge of 

about 1 ml/min. Collect effluent water in a cylinder and stop flow after collection 

of about 50m1 . Connect the cartridge directly to Nitrogen supply for 5 minutes to 

remove the most part of water. Elutes with 6ml of ethanol in a lOml vial. Add 

0.4m1 NaOH 0 .1% in ethanol and allow drying at room temperature under 

Nitrogen flow. Add 2ml of methanol containing 1 % Sulphuric acid. Close 

carefully the vial with a PTFE capped septum, then allow PFOA esterification at 

70°C over night. At room temperature add 0.5ml of CFC 113 . Wash out acidic 

methanol with 6ml water. Remove water layer then wash again with 3m1 water. 

Allow phases separation at room temperature for 15 minutes. Inject 1 pl of lower 

liquid layer. Analyse using method PF 89/110 GC E . 

3 Definitions 

3 .1 APFO: perfluorooctanoate . 

4 Safety precautions 

4.1 When handling samples or solvents and hot vials wear appropriate protective 

gloves, eyewear, clothing and any other protective devices mandatory in your 

working area. 

5 Interferences 

5.1 To minimise interferences when analysing samples PTFE vials and tubing should 

not be used for sample storage or handling. 

6 Equipment 

6.1 Balance (+/- 1 mg) 

7 Supplies and materials 

7.1 Gloves 

7.2 Timer 

7.3 Syringes glass 1 cc, 5 cc 

7.4 Micro-syringes glass 10 V1, 250 pl 

7.5 Pasteur pipette 8x6mm diameter 

7.6 Centrifuge tubes glass lOml 

7.7 Vials 10m1 

7.8 Glass bottles nominal 100m1 

7.9 Volumetric flasks 100ml, 500ml volume 

7.10 Athermic gloves 

7.11 Dreschel bottle 100ml and 500m] 

PF 89/110 WAS E Page 2 of 6 
V pusimonT .~ . 

7.12 Glass graduated cylinder 100ml and 500ml 

8 Reagents and standards 

8.1 Concentrated sulphuric acid R.P.E . Carlo Erba or equivalent 

8.2 Methanol R.S. Carlo Erba or equivalent 

8.3 Ethanol anhydrous R.S. Carlo Erba or equivalent 

8.4 Acetone R.S . Carlo Erba or equivalent 

8.5 CHZC12 R.S . Carlo Erba or equivalent 

8.6 CFC 113 Fluka for IR or equivalent 

8 .7 Ammonia 30% R.P.E. Carlo Erba or equivalent 

8 .8 NaOH R.P.E. Carlo Erba or equivalent 

8 .9 Nitrogen GC grade 

8 .10 Porapack Q 60-80 mesh 

8 .11 Reagent preparation 

1% sulphuric acid in methanol : in a bottle of nominal 100ml (true volume 

116ml) weigh 49 .5g of methanol then add slowly 0.5 g concentrated sulphuric 

acid. 

1% NaOH in ethanol : in a 500ml volumetric flask weigh 0.5g of NaOH then add 

500ml ethanol . 

8.12 Standard preparation 

SoI.A: weigh 100mg of solid ammonium salt of perfluoro-acid, dissolve in 

100ml methanol in volumetric flask. 

S200ppm : transfer 100[1 of SoI .A in a lOm] vial, add 1 .9ml of methanol 1% 

sulphuric acid and follow the esterification procedure . 

S100ppm: transfer 50p1 of SoI.A in a 10ml vial, add 2ml of methanol 1% 

sulphuric acid and follow the esterification procedure . 

S50ppm : transfer 25p1 of Sol.A in a 10m1 vial, add 2ml of methanol 1% 

sulphuric acid and follow the esterification procedure . 

S20ppm : transfer 10~t1 of SoI.A in a l Oml vial, add 2ml of methanol 1 % 

sulphuric acid and follow the esterification procedure . 

S10ppm: transfer 5~t1 of SoI.A in a lOml vial, add 2ml of methanol 1% sulphuric 

acid and follow the esterification procedure . 

8.13 Cartridge preparation 

Weigh about 700mg Porapack Q. Introduce a small plug of glass wool in a 

Pasteur pipette down to diameter restriction . Transfer to the pipette the Porapack 

Q then insert a second small plug of glass wool to keep polymer bed in place . 

Wash with 15ml Acetone, 15ml Ethanol and 15ml CHZCI2 . Keep cartridge under 

Ethanol until use. 

PF 89/110 WAS E Page 3 of 6 
V Ausimonr, 

Before use let ethanol flowing out then wash with lOml distilled water. Connect 

moist cartridge to the sampling line. 

8.14 Sample preparation 

Transfer 70ml of water sample, measured in a graduated cylinder, into dreschel 

bottle . Add, slowly 0 .3ml sulphuric acid. 

8.15 Water spike preparation 

Sp500- In a volumetric flask measure 100ml drinking water. Add 50~t1 So1 .A, 

shake for few minutes then follow 8 .14 Sample preparation . 

Sp250- In a volumetric flask measure 100ml drinking water. Add 25u1 Sol .A, 

shake for few minutes then follow 8 .14 Sample preparation . 

Sp100- In a volumetric flask measure 100ml drinking water. Add 10u1 SoI .A, 

shake for few minutes then follow 8 .14 Sample preparation . 

Sp50- In a volumetric flask measure 100ml drinking water. Add 5pl Sol.A, shake 

for few minutes then follow 8.14 Sample preparation . 

9 Quality control 

9.1 Method and matrix blank 

Use drinking water and apply sample preparation, as in 8.14, recovery and 

esterification procedure. 

9.2 Matrix spike 

Prepare spiked samples as in 8.15 and apply recovery and esterification 

procedure. 

9 .3 Continuing calibration check 

9 .3 .1 With each batch of samples prepare S20ppm calibration solution . 

9.3.2 Analyse S20ppm sample first to assure the accuracy of initial calibration 

curve. 

9.3 .3 Analyse S20ppm sample per group of 10 samples. 

9.3.4 Analyse S20ppm sample last to assure the accuracy of data. 

10 Calibration and standardisation 

10 .1 APFO response line 

10 .1 .1 Prepare calibration standards 

PF 89/110 WAS E Page 4 of 6 
V AusimonT> . 6 

10.1 .2 Inject 1 ViI each at least in duplicate 

10 .1 .3 Calculate concentration of APFO in solution assuming that Sol .A contains l ~tg 

APFO/pl solution . Correct concentration only if weighed APFO differs from 

nominal 100mg more that + / - 10% (namely less than 90mg or more than 

110mg). 

10.2 Calibration line 

10.2.1 Prepare spiked samples as in 8 .15 

10.2 .2 Apply each the recovery procedure 

10.2 .3 Inject 1 pl each at least in triplicate 

10.2 .4 Calculate concentration of APFO in water from APFO concentration in spiked 

samples assuming that So1 .A contains 1 pg APFO/pl solution . Correct 

concentration only if weighed APFO differs from nominal 100mg more that + 

/ - 10% (namely less than 90mg or more than 1 I Omg). 

11 Procedures 

11 .1 Prepare samples as in 8 .14 or 8.15 for spiked samples and label flasks with 

sample ID. 

11 .2 Connect to gas dispersion side tube the cartridge prepared as in 8 .13 . 

11 .3 Connect the second line of dreschel bottle to a Nitrogen supply and pressurise at 

about 20-50 kPa allowing a liquid flow rate through the cartridge of about 1 

ml/min. 

11.4 Collect effluent water in a cylinder and stop flow after collection of about 50ml . 

11.5 Connect the cartridge directly to Nitrogen supply for 5 minutes to remove the 

most part of water. 

11.6 Elutes with 6m1 of ethanol in a l Oml vial. Add 0.4ml NaOH 1 % in ethanol and 

allow drying at room temperature under Nitrogen flow. 

11.7 Add 2ml of methanol containing 1 % Sulphuric acid . Close carefully the vial with 

a PTFE capped septum, then allow PFOA esterification at 70°C over night. 

11.8 At room temperature add 0 .5ml of CFC 113 . Wash out acidic methanol with 6m1 

water. Remove water layer then wash again with 3ml water. 

11.9 Allow phases separation at room temperature for 15 minutes. 

11.10 At room temperature, inject 1 pl of lower liquid layer. Analyse using method 

PF 89/110 GC E. 

12 Data analysis and calculations 

Calculate actual concentration of APFO, or other applicable compounds, from 

calibration line (10.2) using an external standard method . 

13 Method performances 

PF 89/110 WAS E Page 5 of 6 
V ausimonT .I . 

Method detection limit is 50ppb APFO in water. Method quantitation limit is 

100ppb in water. 

Precision and accuracy are calculated from data of calibration line ; precision is 

percent standard deviation at each point, accuracy is percent ratio of average 

calculated amount to nominal concentration at each point. 

Recovery at each point is percent ratio of average area of calibration line to 

average area of APFO response line calculated at same nominal concentration . 

14 Pollution prevention and waste management 

Samples in CFC are disposed in dedicated container. 

Samples in water / methanol are disposed in dedicated container 

Solvents are disposed in dedicated container 

Disposable glass vials are disposed in broken glass containers located in 

laboratory. 

15 Records 

None 

PF 89/110 WAS E Page 6 of 6 
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 category listed . If your facility sends 

the subject chemical in waste to an off-site location where some of the chemical will be 

recycled and the remainder will be treated, estimate each amount separately (i .e ., waste 

treatment and recycling activities) . 

Estimated Annual Estimated % 

Transfers (kgs) accuracy 

(Optional) 

Incineration 

Wastewater Treatment 

(Excluding POTW) 

Underground Injection 

Hazardous Waste (RCRA 

Subtitle C) Landfill 

Other Landfill 

Recycle or Recovery 

(Does not include internally recycled) 

Internally Recycled 

Unknown or Other 

Basis for each release estimate : `" 

The surfactant content in the polymer was measured per the attached method PF 

89/110 GC E - Perfluorooctanoate and Higher Homologues in Algoflon Matrices 

- Analysis using GC-FID 

Comments: 
_. ;= 

APPROVED -COPY N° 

AUSIMONT S.P.A. 

Centro Ricerche e Sviluppo 

Bollate 

Analytical Method 

PF 89/110 GC E 

Perfluorooctanoate and higher homologues 

in Algoflon matrices 

Analysis using GC-FID , 

This document is composed by: 

N° pages : 4 N° tables : 

N° figures : N° attachments: 

Edition : 4 Date: Oct 2001 

Laboratory : GC Author: Oriani 

I Verification : Morandi Approval: Pace 

1 Scope and application 

1 .1 This method is for the analysis of extracts of perfluorooctanoate (APFO) and 

related homologues . 

1 .2 Applicable compounds are : perfluorooctanoate (APFO) [C7F15C00-], 

perfluorononanoate [C8F»COO], perfluorodecanoate [C9F19C00-], 

perfluoroundecanoate [CJoF2,C00-], perfluorododecanoate [C>>F23C00-] and 

higher homologues. 

1.3 Matrices: Algoflon based formulations and environmental samples compatible 

with esterification and GC-FID determination . 

2 Summary 

2.1 Analysis of APFO and homologues extracted matrices is performed by injection 

in a packed column, glass, 2m long, 6mm o.d., 3mm i .d ., packed with metylPF 89/110 GC E Page 1 of 4 
siloxane rubber SE 30 20% on Chromosorb W AW DMCS 80-100 mesh, 

isothermal run at 80°C, flame ionisation (FID) detector . 

3 Definitions 

3.1 APFO: perfluorooctanoate . 

3.2 Gaschromatograph (GC) with flame ionisation detector (FID): model 8000 top 

from Fisons equipped with standard packed column injector. 

3.3 Data system: Electronic integrator mod. Chromjett from Fisons or PC based 

acquisition system mod. Chromcard from Fisons . 

4 Safety precautions 

4 .1 Use caution with temperatures of GC injector and detector. When running 

temperatures are of about 250°C . 

4.2 When handling samples or solvents wear appropriate protective gloves, eyewear, 

clothing and any other protective devices mandatory in your working area. 

5 Interferences 

5.1 To minimise interferences when analysing samples PTFE vials and tubing should 

not be used for sample storage or handling. 

6 Equipment 

6.1 GC FID mod. 8000 from Fisons 

6.2 Electronic recording integrator mod. Chromjett from Fisons or PC running 

Chromcard software from Fisons 

7 Supplies and materials 

7.1 GC grade Nitrogen used as carrier gas 

7.2 GC grade Hydrogen used for FID 

7.3 GC grade Air used for FID 

7.4 Micro-syringes glass 10 pl 

7.5 Centrifuge tubes glass l Oml 

7.6 Vials lOml 

8 Reagents and standards 

8 .1 CFC 113 Fluka for IR or equivalent 

PF 89/110 GC E Page 2 of 4 
u5! 6T1 onT _ . 

8 .2 Standard 

Typically one method and matrix blank and one continuing calibration standard 

S20ppm are prepared with each group of samples . 

9 Quality control 

9.1 Method and matrix blank 

Analyse a method and matrix blank prior to each group of samples . 

9.2 Matrix spike 

Analyse a matrix spike prior to standard calibration curve. 

9.3 Continuing calibration check 

9.3 .1 Analyse S20ppm sample first to assure the accuracy of initial calibration 

curve. 

9.3 .2 Analyse S20ppm every tenth samples . 

9.3 .3 If a significant change (i .e . >25%) in peak area occurs, relative to the initial 

calibration curve, subsequent analysis will be invalid . 

10 Calibration and standardisation 

10 .1 Prepare and analyse a standard calibration curve after each maintenance 

intervention 

10 .2 The r2 value for linear regression of data should be 0 .98 or greater 

10 .3 If curve does not meet requirements change analytical column or re-prepare 

calibration standards . 

11 Procedures 

11 .1 Use a packed column, , glass, 2m long, 6mm o .d ., 3mm i .d ., packed with metylsiloxane rubber SE 30 20% on Chromosorb W AW DMCS 80-100 mesh 

11 .2 Carrier : Nitrogen, flow rate : 40ml/min measured at room temperature connecting 

flow meter to detector outlet . 

11.3 Injector : standard packed at 250°C 

11 .4 Detector: FID at 250°C, Hydrogen flow rate: 30m1/min, Air flow rate 500m1/min 

11 .5 Oven temperature: isothermal at 80°C 

11 .6 Injection volume: liquid measured 1 W 

11 .7 APFO retention time: 3 minutes 

PF 89/110 GC E Page 3 of 4 
RU5lCfl1Df1T 

12 Data analysis and calculations 

Calculate actual concentration of APFO, or other applicable compounds, from 

calibration line using an external standard method. 

13 Method performances 

Method detection limit and method quantitation limit are referred to each matrix 

and reported in specific methods. 

14 Pollution prevention and waste management 

Samples in CFC are disposed in dedicated container. 

Samples in water / methanol are disposed in dedicated container 

Solid polymer residuals are disposed in dedicated container 

Disposable glass vials are disposed in broken glass containers located in 

laboratory. 

15 Records 

None 

PF 89/110 GC E Page 4 of 4 
Appendix D 

Draft Facility Report on Product Content 

APFN 

NONCBI 

Company Sanitized 
2010/15 PFOA Stewardship Program 

Draft Facility Report on Product Content 

I. CHEMICAL IDENTIFICATION 

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

Product name: 

FLUOROPOLYMER 

Product description (including concentrations of perfluoroalkyl chemicals 

identified in Section IV below and year of production) : 

~ ~APFN_CAS number: 77623-779 

II. COMPANY IDENTIFICATION 

Identify the company and location of the facility submitting information: 

Company name : SOLVAY SOLEXIS, INC 

Site location : THOROFARE, NJ 

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

submitted: 

Technical contact: VIRGINIA HUBERT 

Phone: (713 )52 5-6051 

Address: 10 Leonard Lane, Thorofare, NJ 

III. PRODUCTION 

Calendar year for which you are reporting: Jan l, 2009 to Dec 31, 2009 

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

Imported 

Manufactured 

L-- 

kgs/yr 

kgs/yr 
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. 

CAS # 77623-77-9 

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 

" 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) 

" 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 

The surfactant content in the polymer was measured per the attached method PF 89/110 

POW E - Perfluorooctanoate and Higher Homologues in Polymer Bulk or Sintered -

Extraction and Esterification . 

Comments: 
RUSimon-r .-_r -~ 

APPROVED -COPY N° 

AUSIMONT S.P.A. 

Centro Ricerche e Sviluppo 

Bollate 

Analytical Method 

PF 89/110 POW E 

Perfluorooctanoate and higher homologues 

in polymer bulk or sintered 

Extraction and esterification 

This document is composed by: 

N° pages : 5 N° tables : 

N° figures : N° attachments: 

Edition : 3 Date: June 2001 

Laboratory: GC Author: Oriani 

I Verification : Morandi Approval: Pace 

1 Scope and application 

1.1 This method is for the extraction of perfluorooctanoate (APFO) and related 

homologues from Algoflon (PTFE) polymer bulk or sintered . 

1 .2 Applicable compounds are : perfluorooctanoate (APFO) [C7F,SCOO-], 

perfluorononanoate [CgF»COO], perfluorodecanoate [C9F19C00-], 

perfluoroundecanoate [C,oFZ]C00-], perfluorododecanoate [C,1F23C00-] and 

higher homologues. 

1 .3 Matrices: Algoflon polymer, bulk or sintered, dry (humidity lower than 5% by 

weight). 

2 Summary 

2 .1 About 500mg (I g if sintered) of Algoflon is weighed in a 10 ml vial . Add 2ml of 

methanol containing 1% Sulphuric acid. Close carefully the vial with a PTFE 

PF 89/110 POW E Page 1 of 5 
usimon-r_P _- 

capped septum, then allow APFO esterification at 70°C over night. At room 

temperature add l ml of CFC 113, centrifuge then transfer 2 ml of clear solution 

in a lOml vial . Wash out acidic methanol with 4ml water. Close vial and allow 

phases separation at 40°C for 15 minutes. Inject 1~d of lower liquid layer. 

Analyse using method PF 89/110 GC E. 

3 Definitions 

3.1 APFO: perfluorooctanoate . 

4 Safety precautions 

4.1 When handling samples or solvents and hot vials wear appropriate protective 

gloves, eyewear, clothing and any other protective devices mandatory in your 

working area. 

5 Interferences 

5.1 To minimise interferences when analysing samples PTFE vials and tubing should 

not be used for sample storage or handling. 

6 Equipment 

6.1 Centrifuge ALC CENTRIFUGETTE 4236 

6.2 Shaker IKA-VIBRAX-VXR 

6.3 Balance (+/- lmg) 

7 Supplies and materials 

7.1 Gloves 

7.2 Timer 

7.3 Syringes glass 1 cc, 5 cc 

7.4 Micro-syringes glass 10 ~tl, 250 41, 

7.5 Centrifuge tubes glass lOml 

7.6 Vials lOml 

7.7 Glass bottles nominal 100m1 

7.8 Glass volumetric flasks 100ml volume 

7.9 Athermic gloves 

8 Reagents and standards 

8 .1 Concentrated sulphuric acid R.P.E . Carlo Erba or equivalent 

8 .2 Methanol R.S . Carlo Erba or equivalent 

8 .3 CFC 113 Fluka for IR or equivalent 

8.4 Ammonia 30% R.P.E . Carlo Erba or equivalent 

PF 89/110 POW E Page 2 of 5 
RU5I tT'1 onT ., 

8 .5 Reagent preparation 

1 % sulphuric acid in methanol : in a bottle of nominal l 00m1 (true volume 

116m1) weigh 49.5g of methanol then add slowly 0.5 g concentrated sulphuric 

acid. 

8 .6 Standard preparation 

So1.A: weigh 100mg of solid ammonium salt of perfluoro-acid, dissolve in 

100ml methanol in volumetric flask. 

S200ppm : transfer 100~1 of So1 .A in a 10m1 vial, add 1 .6ml of methanol 1% 

sulphuric acid and follow the esterification procedure. 

S 100ppm : transfer 50~1 of So1.A in a l Oml vial, add 1 .8m1 of methanol 1 % 

sulphuric acid and follow the esterification procedure. 

S50ppm: transfer 25p1 of So1 .A in a lOml vial, add 1 .9m1 of methanol 1% 

sulphuric acid and follow the esterification procedure. 

S20ppm: transfer 10p1 of So1.A in a l Oml vial, add 2m1 of methanol 1 % 

sulphuric acid and follow the esterification procedure. 

S10ppm: transfer 5~1 of So1.A in a l0ml vial, add 2ml of methanol 1% sulphuric 

acid and follow the esterification procedure. 

9 Quality control 

9.1 Method and matrix blank 

In a lOml vial weigh 500mg of Hyflon' MFA powder, follow esterification 

procedure. 

Note: Hyflon polymers are free from APFO and Surflon surfactants 

With each batch of samples prepare and analyse a blank as first sample . 

9.2 Matrix spike 

In a lOml vial weigh 500mg of Hyflon' MFA powder, add 5 pl of So1 .A then 

follow esterification procedure. 

Note : Hyflon polymers are free from APFO and Surflon surfactants . 

With each complete calibration prepare a matrix spike and a blank. 

As last samples after calibration inject in triplicate blank and matrix spike. 

9.3 Continuing calibration check 

9.3 .1 With each batch of samples prepare S20ppm calibration solution . 

PF 89/110 POW E Page 3 of 5 
U51monTa~- 

9.3.2 Analyse S20ppm sample first to assure the accuracy of initial calibration 

curve . 

9.3.3 Analyse S20ppm sample per group of 10 samples, followed by a blank (9.1) . 

9 .3 .4 Analyse S20ppm sample last to assure the accuracy of data. 

10 Calibration and standardisation 

10 .1 Prepare calibration standards 

10 .2 Inject 1 pl each at least in triplicate 

10 .3 Calculate concentration of APFO in dispersion from APFO concentration in 

solution assuming that So1 .A contains about 1 pg APFO/pl solution and Algoflon 

weight is 500mg. Correct concentration only if weighed APFO differs from 

nominal 100mg more that + / - 10% (namely less than 90mg or more than 

110mg) . 

11 Procedures 

11 .1 Weigh about 500mg (I g if sintered) Algoflon in a l Oml vial 

11.2 Record weight and label vial with sample ID 

11 .3 Prepare S20ppm solution and label accordingly 

11 .4 At room temperature, add 2ml of methanol containing 1 % Sulphuric acid. 

11 .5 Close carefully the vial with a PTFE capped septum. 

11.6 Allow APFO esterification at 70°C over night. 

11 .7 At room temperature add 1 ml of CFC 113, centrifuge then transfer 2 ml of clear 

solution in a lOml vial . 

11.8 Wash out acidic methanol with 4ml water. Close vial and allow phases 

separation at 40°C for 15 minutes. 

11 .9 Using a syringe take out the aqueous layer. Wash a second time with 4ml water. 

Close vial and allow phases separation at 40°C for 15 minutes . 

11 .10 At room temperature, inject lpl of lower liquid layer. Analyse using method 

PF 89/110 GC E. 

12 Data analysis and calculations 

Calculate actual concentration of APFO, or other applicable compounds, from 

calibration line using an external standard method. Correct data calculated from 

calibration line only if the amount of polymer used differ from 500mg by a quote 

higher than +/- 5% using the formula: 

Conpp,n = Calpp,T, * (Trueamt/500) 

Where: 

Conppm = Concentration in ppm of surfactant corrected for polymer weight 

Calppm = Concentration in ppm of surfactant from calibration line 

Trueamt = Weight in mg of polymer used 

PF 89/110 POW E Page 4 of 5 
monT 

13 Method performances 

Method detection limit is 4ppm APFO in Algoflon . Method quantitation limit is 

l Oppm. 

For sintered Algoflon method detection limit is 2ppm APFO. Method 

quantitation limit is 6ppm . 

Precision and accuracy are calculated from data of calibration line; precision is 

percent standard deviation at each point, accuracy is percent ratio of average 

calculated amount to nominal concentration at each point. 

Recovery is percent ratio of average area of matrix spike to average area of 

S l Oppm calibration point. 

14 Pollution prevention and waste management 

Samples in CFC are disposed in dedicated container. 

Samples in water / methanol are disposed in dedicated container 

Solid polymer residuals are disposed in dedicated container 

Disposable glass vials are disposed in broken glass containers located in 

laboratory. 

15 Records 

None 

PF 89/110 POW E Page 5 of 5