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 

00600 

\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. 3 

ECTION 2: COMPANY IDENTIFICATION 

CompanyName ArchromaGermany GmbH 

Street Address 

84508 Burgkirchen(Germany) 

cd 

CA 

SECTION 3: SUMMARY OF EMISSIONS 

% Reductionof 

total kgsreleased 

from baselineyear 

Notapplicab le 

I alciroildde 

08< 

g8< 

rmationonthemethods,assumptions,uncertaintiesand detection limits forthe dataprovided above. 

PFOA isanalyzed,after derivatisation, by GC or GC-MS; Method LOD 0. 1ppm. 

DirectPrecursorsareanalyzed by GC and/or GC-MS; Method LOD dependsonspecific fluorotelomerstructure 5 0 - 1 00ppm 

Releasestoall environmental media from fluoropolymerand 

telomermanufacture 

kgsof telomers 

Notapplicable Notapplicable 

I I 

kgsof fluoropolymers1 

Notapplicable Notapplicable Notapplicable 

alvonddu lom 

ReportingPeriod 

s2)1 

Notapplicable 

Notapplicable 

0•1 

c 1> 

Chemical category 

PFOA and PFOA salts DirectPrecursors PFOA and PFOA salts 

Direct Precursors 

Operations 

U.S. fac ilities 

Non-U.S. 

facilities 

as 

cn 

cl£ 

0 

Cr) 

October201 4 

DOESNOT CONTAIN CON FIDENTIAL BUSINESS IN FORMATION 

SECTION 1:REPORT DATE 
C) 

CD 

0 

—. 

A 

0 

0 

0 7.1 

4-I 

CI 

= 

''.■ :1 

ci,-, .5 174 

zA" cc! 

,.= 1 bh 

... >, = = 0 co cc; ..,-.4- c> a, ccs c> O E "5 

--, ° E o , 

1 tao 

49, 

c6 

to 

... 

t 

c, co 0 — 

co,, —. o 0 

A 

.--. .- 

r.r

-")N • .0 

,...-. 

h . ' a ' F f0›. ..s4 

0) 0::) 0 

c'.., 

,__, 

0 t1.0 taL 0 

I •-• 0 t c.) v) 0 0 

CIA C4 • ''' 

... a) 0 

o a) . 

0 - P. —o" t) ai 

0 110 0 

to c4-. o 6,0 

co • 0 „, -o t.. 

c> ,„„u) o •-, z 

 

-to 

1 = g 

00 .6

• 

1),c$.0>' 

i

• 

l

• 

ba 

CZ) 4.... ;-■ ;-. 

A ,--, 

i LI 

E 1 

..

7_ 

,02 

to

• 

 a) bi) al 0 •aj- 

- 

• 

00,_7 a) o 3 

2 0 

t4) 0 a) I ,. . 0 -0 •-•.- 

..., c' c' '64 

a ,....- c> 0 — 3 E • c7 

s g E . at at 

O '-' o ',..) -4 al 

ucci ctu" 

't 

,4 7:, . . ci, .flz j 

^ct -9" &) $1 1)-) $A z . ," ... 0 z 0, cn cn cn 

C.. t 0 - .. 03°cl.)08 ': )) 1° "I- ' > <2 1 . 8: 1 

= 0 -0 c0 

§ 11 2 : 2 : _ .., , ` 1- ' . 4. ! .4! • b'°- A c.) M cvu'

.r.L 0: s-, 

. . . . , • . - , . - C ; . > V1 V) V) 

›, 

C . .D C74 2 

I. '64 ii) .1"C9 --.! c': f' I) ! 

s. 

c.,. ., c) u 0 t H F. O ,) , 0

, c a) . 0 .0 0 

• vi c; 0 6) 0 = ...E 

- r, - en U • --. --1- , ,c, 

p. 4 

DOES NOT CONTAIN CON FIDENTIAL BUSINESSINFORMATION 

SECTION4:SUMMARY OFPRODLCTCONTENT 

ReportingPeriod Jan1,20 13 toDec3 1,2013 

Telomerbased products 

(8) 

% Reduction 

frombaselineyear 

Telomer 

based 

products 

Not 

applicable 

Not 

applicable 

06 

176 

l imits forthe dataprovided above. 

PFOA isanalysed,after derivatisation, by GC orGC-MS;Method LOD0. 1ppm. DirectPrecursorsareanalysed byGC and/or GC-MS; Method LOD dependsonspecific fluorotelomerstructure50 -100 ppm 

Other 

fluoropolymers' 

Not 

applicable 

alquonddr 

I 

I 

I 

I 

I 

I 

Fluoropolymer 

dispersions 

Not 

applicable 

amoildcto 

ToN 

I I I 

I I 1 

Otherfluoropolymers 1 

Concentration3 

Telomer based 

products6 

(in kgs) 

Not 

applicable 

Not 

a.•licable 

I> 

L> 

[e informationonthemethods,assumptions,uncertaintiesand detectionI 

Other 

fluoropolymers 1 .5 

(ppb dryweight) 

Not 

a.•licable 

Not 

applicable 

I 1 I 

I 1 I 

Fluoropolymerdispersions 

Fluoropolymer 

dispersions4 

(ppmwetweight) 

ojqoijdd 

Not 

alicable 

I I I 

I I I 

Producttype Productionvolume(kgs/year)2 

Chemical 

category 

PFOA, PFOA salts DirectPrecursors 

PFOA,PFOA salts 

DirectPrecursors 

c./) 

,--. 

0 

. — 

CC) 

Cl.. 

0 U. S. 

' facilities 

Non-U.S. 

fac ilities 

Pleaseprovid 

0-f7 
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 

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 
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 

(C8F17-J and C7F15-000C2H4C8F17) 

and 

Indirect Precursors / Higher Homologues 

(R,C2H4-I, Rj-c2Hrox, R,-c2H4-oco-cR=cH2RF-CH=CH2) 
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 

(Rb-I; RF-C2H4-4 RF-C2H4-0H; Rh-C2H4-000-CR=CH2, Rh-CH=CH2) 

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 

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). 

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 

(C8 F17-J and C7F15-000C2H4C8F17) 

• Indirect Precursors / Higher Homologues 
p. 29 

COMPANY SANITIZED - DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 

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 

COMPANY SANITIZED - DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 

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) 

3 
p. 31 

COMPANY SANITIZED - DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 

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. 

4 
p. 32 

COMPANY SANITIZED - DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 

5 
COMPANY SANITIZED - DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 

p. 33 

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 
p. 34 

COMPANY SANITIZED - DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 

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 

2 
p. 35 

COMPANY SANITIZED - DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 

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) 

3 
p. 36 

COMPANY SANITIZED - DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 

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. 

4 
p. 37 

COMPANY SANITIZED - DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 

5