# Company sanitized

Does not contain Confidential Business

Information (CBI)

Appendix C



# Draft Facility Report on Emissions

## 2010/15 PFOA Stewardship Program



# Draft Facility Report on Emissions

I. CHEMICAL IDENTIFICATION

Identify the chemical for which you are submitting information:

Chemical name: ammonium perfluorooctanoate

CAS number: 3825

- 26

- 1

II. COMPANY IDENTIFICATION

Identify the company and location of the facility submitting information:

Company name: AGC Chemicals Europe, Ltd

Site location: Hillhouse, UK

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

submitted:

Technical contact: Mr G P Andrews

Phone: +44 (0) 1253 861 989

Address: York House, H illhouse International,

Thornton Cleveleys,

Lancs

., FY5 4QD, UKIII. ON

- SITE ACTIVITIES

Calendar year for which you are reporting: Jan 1, 20 10 _ to Dec 31, 20 10

__ (Normalized data based on year end run rate)

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

CBI

Imported (externally recycled) zero

Manufactured zero

Estimate the amount of subject chemical distributed off

- site:

0 % of manufacture/import

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:

CBI

Narrative Description and Process Flow Schematic :

Provide overall material balance of the chemical being reported, showing releases

and products (kg/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 su bject chemical is used in many

different processes, provide information on each major

CBI process instead of each individual

process.IV.

(For manufacturing and on

- site processing/use if applicable) SITE RELEASE AND TRANSFER INFORMATION

In this secti on, 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 kg should be reported.

Estimate the number of days per year the rel ease 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 det ermination 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 mas s 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

**•** Desc ribe 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 fr om 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

emi ssions 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

(kg) (Optional)

Fugitive (non

- p oint) CBI CBI 340

Stack (point) CBI CBI 340

Basis for each release estimate:

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

**•** APFO usage known (purchases plus recycle plus decrease in inventory)

**•** APFO content of product sold ana lysed (Facility report on Product content), quantity

sold known.

**•** APFO content of sample of bulk aqueous effluent analysed. Bulk flows of aqueous

effluent measured using magnetic flow meters.

**•** APFO content of minor aqueous effluent analysed, quantities esti mated.

**•** Capture efficiency from aqueous stream measured using UV

- vis analysis confirmed

by third party laboratory

.

**•** Release to air calculated from known APFO content of wet PTFE prior to drying and

capture efficiency of recovery system (measured by specialis t contractor)

.

**•** APFO content of sample of waste to landfill analysed, weight of waste known

**•** Overall mass balance used to confirm accuracy of above calculations.

Analysis of samples (Gas Chromatography using methods SAM/GC/254 and

SAM/CHEM/PAF/7 previousl y submitted. UV

- vis spectroscopy using method FTM166

previously submitted).Comments:

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

Part IV (cont.)

B. WATER RELEASES FROM SITE

Estimate the total relea ses 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 fr om 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.

Water releases: Estimated Total Estimated % # Da ys/year

Annual Releases Accuracy Release Occurs

(kg) (Optional)

CBI CBI 340

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

th an one number is assigned to the facility, list each number for the appropriate discharge

quantity and receiving water identified.

Receiving Water Name(s): River Wyre (tidal estuary)

NPDES number(s): Not applicable

Basis for each release estimate:

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

See part AComments:

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

Part IV (cont.)

C. ON

- SITE LAND RELEASES

Estimate the total releases of t he 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 amendm ent 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 ea rthen 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

(kg) ( Optiona l)

Landfill Zero

_____

Land Treatment/Land Amendment Zero

_____

Surface Impoundments Zero

_____

Underground Injection Zero

_____

Other (specify): Zero

_____

Comments:

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

Solid waste sent to specialist landfill site (see section D2)

D. OFF

- SITE TRANSFERS

Estimates of off

- site transfers should be similar in accuracy and precision to

previous release estimates.

Dl. Transfer to Publi cly Owned Treatment Works (POTW)

Number of days/year the release occurs: _ 0

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 was tewater containing the chemical. Enter the POTW’s NPDES permit

number, if known.

Annual Transfer (kg):

_ 0

Estimated % Accuracy of Transfer Estimate (optional) _____

POTW Name:___

Street Address: __ _____

City: _ _ County: ______________

State: _ Zip Code: _____

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.)

Pa rt IV (cont.)

D2. Transfers to other off

- site locationsIn 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 chemic al 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 (kg) accur acy

(Optional)

Incineration CBI

_____

Wastewater Treatment

(Excluding POTW) zero

_____

Underground Injection zero

_____

UK hazardous Waste Landfill CBI

_____ site

Other Landfill zero

_____

R ecycle or Recovery zero

_____ (Does not include internally recycled)

Internally Recycled CBI

_____

Unknown or Other zero

_____

Basis for each release estimate:

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

See part A

Comments:

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

An amount of APFO was incinerated had been collected in previous years. The majority did not

come from 2010 production activities.

# Appendix D



# Draft Facility Report on Product Content

## 2010/15 PFOA Stewardship Program



# Draft Facility Report on Product Content

I. CHEMICAL IDENTIFICATION

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

Product n ame PTFE dried coagulated dispersion

Product description (including concentrations of perfluoroalkyl chemicals identified in Section IV below

and year of production):

Coagulated dispersion typically contained 80 ppb AP FO.

II. COMPANY IDENTIFICATION

Identify the company and location of the facility submitting information:

Company name: AGC Chemicals Europe, Ltd

Site location: Hillhouse, UK

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

submitted:

Technical contact: Mr G P Andrews

Phone: +44 (0) 12 53 861 989

Address: York House, Hillhouse International,

Thornton Cleveleys,

Lancs FY5 4QD, UKIII. PRODUCTION

Calendar year for which you are repo rting: Jan 1, 20 10 to Dec 31, 20 10

(Normalized data based on year end run rate)

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

Imported CBI

Manufactured CBI

IV. PRODUCT CONTENT

A. CONCENTRATIONS OF RELEVANT P ERFLUOROALKYL 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

- D ecanol, 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

- heptade cafluoro

- (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 aci d, 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

- , 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,11,11,1 2,12,12

- heneicosafluorododecyl ester (CAS 17741

- 60

- 5)Part IV (cont.)

B. ANALYTICAL METHODS

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

(i) Derivatisation to the methyl ester and quantification by gas chromatog raphy. Methods SAM/GC/254

and SAM/CHEM/PAF/7 previously submitted.

(ii) In house UV

- vis spectroscopy. Method FTM166 previously submitted.