# CBIC Control Number 

# 362479
RECEIVED OPPT CBIC

201 1 1 NOV -3 Mi H : 39 p. 1



# CLARIANT" I

4000 Monroe Road Charlotte NC 28205 704.331.7059 Erin.Russell@clariant.com

THIS LETTER DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION

October 31, 2014

ATTN: EPA-HQ-OPPT-2006-0621 Document Control Office 7407M

Mr. Toni Krasnic Office of Pollution Prevention and Toxics (OPPT) US EPA - East 1200 Pennsylvania Avenue NW Washington DC 20460-0001 

# 006 00


# \AO\I A 241k ADOGOI Gt.1%1Sik

Re: US EPA 2010/15 PFOA Stewardship Program

Dear Mr. Krasnic:

Please find enclosed the US EPA 2010/2015 PFOA Stewardship Program reports for 2013. This report includes the numeric results of the cumulative progress in residual reduction and site emissions reduction through 2013 for both the Clariant production and the Archroma business.

As a fluorotelomer manufacturer, neither Clariant nor Archroma makes or uses PFOA in production processes, nor did either company add PFOA to its respective products. Trace levels of PFOA are present in fluorotelomer products as an impurity.

When evaluating the enclosed report, it is critical to note that due to the absolute number for both product content and emissions being so very low, the percent values are not solely indicative of the progress made in this program. Calculating or measuring an emission below one kilogram of an annual production volume is difficult and not fully accurate. The progress made in fulfillment of the program, however has been significant and we believe are on target for meeting the program commitments.

Last year Clariant informed the EPA of the sale of its paper and textile business lines which are the businesses with products relevant to the stewardship program . These businesses are now part of Archroma Management LLC. The transaction closed at the end of September 2013. We are jointly filing the attached stewardship reports cumulatively covering both the Clariant period of production and the Archroma production.

The reports were prepared by Archroma and reviewed by Clariant. Should you have any question on the technical aspects of these documents, please contact Wolfgang Knaup whose contact information is contained in the reports.

Best regards,

Erin Russell

Enclosures

### DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 

# p. 2



# Appendix F



# Company Annual Report

2013

Summary of Reductions

in Emissions and Product Content

PFOA

Direct Precursors

# P. 3ECTION2:COMPANYIDENTIFICATIONCompanyNameArchromaGermanyGmbHStreetAddress84508 Burgkirchen(Germany)

cd CASECTION3:SUMMARYOFEMISSIONS%ReductionoftotalkgsreleasedfrombaselineyearNotapplicableIalciroildde08<g8<rmationonthemethods,assumptions,uncertaintiesanddetectionlimitsforthedataprovided above.PFOAisanalyzed,afterderivatisation,byGC orGC-MS;MethodLOD0.1ppm.DirectPrecursorsareanalyzedbyGC and/orGC-MS;MethodLODdependsonspecificfluorotelomerstructure50-100ppmReleasestoall environmental mediafromfluoropolymerandtelomermanufacturekgsof telomersNotapplicableNotapplicable

I Ikgsoffluoropolymers1NotapplicableNotapplicableNotapplicablealvonddulomReportingPeriods2)1NotapplicableNotapplicable0•1c1>Chemical categoryPFOA andPFOA saltsDirectPrecursorsPFOA and PFOA saltsDirectPrecursorsOperationsU.S.facilitiesNon-U.S.facilities



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## p. 4DOESNOT CONTAINCONFIDENTIALBUSINESSINFORMATIONSECTION4:SUMMARY OFPRODLCTCONTENTReportingPeriodJan1,2013 toDec31,2013Telomerbased products(8)%ReductionfrombaselineyearTelomerbasedproductsNotapplicableNotapplicable06176limitsforthedataprovided above.PFOAisanalysed,afterderivatisation,byGC orGC-MS;Method LOD0.1ppm.DirectPrecursorsareanalysedbyGC and/orGC-MS;MethodLODdependsonspecificfluorotelomerstructure50 -100 ppmOtherfluoropolymers'Notapplicablealquonddr I I I I I IFluoropolymerdispersionsNotapplicableamoildctoToN I I I I I 1Otherfluoropolymers1Concentration3Telomerbasedproducts6(inkgs)NotapplicableNota.•licableI>L>[einformationonthemethods,assumptions,uncertaintiesand detectionIOtherfluoropolymers1.5(ppb dryweight)Nota.•licableNotapplicable

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I I I I I IProducttypeProductionvolume(kgs/year)2ChemicalcategoryPFOA,PFOA saltsDirectPrecursorsPFOA,PFOA saltsDirectPrecursors

c./)

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

# P. 5



# Appendix C



# Facility Report on Emissions in 2013

for

Perfluorooctanoic acid (PFOA)

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



# 2010/15 PFOA Stewardship Program 

# Facility Report on Emissions

I. CHEMICAL IDENTIFICATION

Identify the chemical for which you are submitting information:

Chemical name: Perfluorooctanoic acid (PFOA)

CAS number: 335-67-1

II. COMPANY IDENTIFICATION

Identify the company and location of the facility submitting information:

Company name: 

# Archroma Germany GmbH

Site location: Germany, Burgkirchen/Gendorf

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

# submitted: Technical contact: Dr. Wolfgang Knaup

Phone: +49 8679 7 4653 Address: email wolfgang.knaup@archroma.com p. 6

2

# P. 7

COMPANY SANITIZED - DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION



# II I. 

# ON

- 

# SITE ACTIVITIES

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

Provide the amount of chemical identified above for the reporting 

# year at specific site:

Estimate the amount of subject chemical distributed off-site:

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.

3

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

# p. 8



# Narrative Description and Process Flow Schematic:



# 4

# P. 9

COMPANY SANITIZED - DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION



# 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.

5

# p. 10

COMPANY SANITIZED - DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION



# Part IV (cont.)

A. ON-SITE AIR RELEASES

Estimate the total fugitive or non-point releases to air and the number 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.

Estimated TotalEstimated % # Days/year Annual ReleasesAccuracy Release Occurs (kgs) (Optional)



# Basis for each release estimate:

6

# p. 11

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# Part IV (cont.)

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 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)



# 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): Alz NPDES number(s): not available

Basis for each release estimate:

7

# p. 12

COMPANY SANITIZED - DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION



# Part IV (cont.)



# 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 

# not applicable

Surface Impoundments not applicable

Underground Injection not applicable Other (specify): not applicable

Basis for each release estimate: (See discussion on source/basis in beginning of Section IV.)

8

# p. 13

COMPANY SANITIZED - DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION



# 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: 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: On-site waste water treatment plant operated by InfraServ Gendorf Street Address: City: Burgkirchen County: State: Germany Zip Code: 84508

NPDES number:

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.)

9

# p. 14

COMPANY SANITIZED - DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION



# 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 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).

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 Estimated Annual Transfers (kgs)



# see comments below

not applicable

not applicable

not applicable

not applicable

not applicable

not applicable

not applicable Estimated %

accuracy (Optional)



# 10

# ATTACHMENT A

CONFIDENTIAL

BUSINESS

INFORMATION p. 15

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

## p. 1 6



# Appendix C



# Facility Report on Emissions in

2013

for

Direct Precursors
(C 8 F 17 -J and C7F15-000C2H4C8F17)



# and

Indirect Precursors / Higher Homologues (R,C 2 H 4 -I, R j -c 2 H r ox, R,-c 2 H

4 -oco-cR=cH 2 R F

-CH=CH 2 )

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



# 2010/15 PFOA Stewardship Program 

# Facility Report on Emissions

I. CHEMICAL IDENTIFICATION



# Identify the chemical for which you are submitting information:

Chemical names:Direct precursors and indirect precursors/ higher homologues

(R b

- 

# I; RF

- 

# C2H4

- 

# 4 RF

- 

# C2H4

- 

# 0H; R h

- 

# C2H 4

- 

# 000

- 

# CR=CH2, R h

- 

# CH=CH 2 )


# CAS number: not applicable

II. COMPANY IDENTIFICATION



# Identify the company and location of the facility submitting information:

Company name: Archroma Germany GmbH

Site location: Germany, Burgkirchen/Gendorf



# Identify a company technical contact who can respond to inquiries about the information submitted: Technical contact: Dr. 

# Wolfgang Knaup

Phone: +49 8679 7 4653 Address: email wolfgang.knaup@archroma.com p. 

# 17



# 2

# p. 18

COMPANY SANITIZED - DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION



# III. ON-SITE ACTIVITIES

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

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

Estimate the amount of subject chemical distributed off-site:

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

3

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



# of each individual process.

Narrative Description and Process Flow Schematic: p. 19



# 4

# p. 20

COMPANY SANITIZED - DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION



# 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 chem ical 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.

5

# p. 21

COMPANY SANITIZED - DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION



# Part IV (cont.)

A. ON-SITE AIR RELEASES

Estimate the total fugitive or non-point releases to air and the number 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.

Estimated Total Estimated % # Days/year Annual Releases Accuracy Release Occurs (kgs) (Optional)



# Basis for each release estimate:

6

# p. 22

COMPANY SANITIZED - DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION



# Part IV (cont.)

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 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)



# 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): Alz



# NPDES number(s): not available

Basis for each release estimate:

7

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

# p. 23



# 8

# p. 24

COMPANY SANITIZED - DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION



# 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 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 not applicable

Land Treatment/Land Amendment not relevant

Surface Impoundments not relevant

Underground Injection not relevant

Other (specify): not relevant

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.)

9

# p. 25

COMPANY SANITIZED - DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION



# Part IV (cont.)

D. OFF-SITE TRANSFERS

Not applicable

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: 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) +/- 20
POTW Name: (on-site wastewater treatment plant InfraServ Gendorf) Street Address: City: County: State: Zip Code:

NPDES number:

Basis for each release estimate: (See discussion on source/basis in beginning of Section IV.)

10

# p. 26

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# 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 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 Transfers (kgs)

Incineration

Wastewater Treatment (Excluding POTW) not relevant
Underground Injection not relevant

Hazardous Waste (RCRA Subtitle C) Landfill not relevant

Other Landfill not relevant
Recycle or Recovery not relevant (Does not include internally recycled)

Internally Recycled not relevant

Unknown or Other not relevant

Basis for each release estimate: (See discussion on source/basis in beginning of Section IV.) Estimated % accuracy (Optional)



# 11

# ATTACHMENT A

CONFIDENTIAL

BUSINESS

INFORMATION p. 27

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

# p. 28



# Appendix 

# D

Report on Product Content

2013

Fluorotelomer based A3F Chemicals

• PFOA

• PFCA (other than PFOA)

• Direct Precursors
(C 8 F 17 

### -J and C7F15-000C2H4C8F17)



# • Indirect Precursors / Higher Homologues

# p. 29

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# 2010/15 PFOA Stewardship Program 

# Report on Product Content

I. CHEMICAL IDENTIFICATION

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

Product name s :

Product description (including concentrations of perfluoroalkyl chemicals identified in Section IV below and ear of roduction :

H. COMPANY IDENTIFICATION

Identify the company and location of the facility submitting information:

Company name: Archroma Germany GmbH

Site location: Burgkirchen-Gendorf

Identify a company technical contact who can respond to inquiries about the information submitted: Technical contact: Dr. Wolfgang Knaup

Phone: +49 8679 7 4653 Address: email wolfgang.knaup@archroma.com

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:

# p. 30

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# I V. 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)

• I -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)

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# Part IV (cont.)

B. ANALYTICAL METHODS

Analyses should be conducted using the most accurate instrumentation and procedures available 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.

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# Appendix D



# Report on Product Content

2013

Fluorotelomer based Polymer Dispersions

• PFOA

• PFCA (other than PFOA)

• Direct Precursors

(C8F17-J and C7F15-000C2H4C8F17)



# • Indirect Precursors / Higher Homologues

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# 2010/15 PFOA Stewardship Program 

# Report on Product Content

CHEMICAL IDENTIFICATION

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

Product name: Fluorotelomer based Polymer Dispersions

Product description (including concentrations of perfluoroalkyl chemicals identified in Section IV below and ear of rod uction :

COMPANY IDENTIFICATION

Identify the company and location of the facility submitting information:

Company name: Archroma Germany GmbH

Site location: Burgkirchen-Gendorf, Germany

Identify a company technical contact who can respond to inquiries about the information submitted: Technical contact: Dr. Wolfgang Knaup

Phone: +49 8679 7 4653 Address: email: wolfgang.knaup@archroma.com

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

Manufactured

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# 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)

• 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)

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# Part IV (cont.)

B. ANALYTICAL METHODS
Analyses should be conducted using the most accurate instrumentation and procedures available 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.

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