# 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 ch emical 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 Ch emicals 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, Hil lhouse International,

Thornton Cleveleys,

Lancs

., FY5 4QD, UKIII. ON

- SITE ACTIVITIES

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

(Normalized data based on year end run rate.)

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

Total CBI

Imported (Recycled, Source Country Japan) CBI

Manufactured zero

Estimate the amount of subject chemical distributed off

- site:

0 % of manufacture/import

Provide the a mount 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 us es, 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.

CBIIV. SITE RELEASE AND TRANSFER INFORMATION

(For manufacturing and on

- site processing/use if applicable)

In this section, estimate th e 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 p eriod. 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 release occurs. En ter 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 shou ld 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).

 Des cribe 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 n umber 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 ve ntilation 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 rel eases 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

- point) CBI C BI 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 analysed (Facili ty 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 estimated.

 Captur e 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 specialist 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 previously submitted. UV

- vis spectroscopy using method FTM166

previously submitted).Part IV (cont.)

Comments:

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

B. WATER RELEASES FROM SITE

Estimate the total releases of the chemic al 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 ru noff, 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 % # Days/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 than 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:

(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.)Part IV (cont.)

C. ON

- SITE LAND RELEASES

Estimate the total releases of the chemical for eac h 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 was te 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 des igned 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 tha t 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 additional 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 Publicly Owned Tre atment 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 wastewater conta ining 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: _ Z ip 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.)Part IV (co nt.)

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 was te 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) accuracy

(Optional)

Incineration CBI

_____

Wastewater Treatment

(Excluding POTW) zero

_____

Underground Injection zero

_____

UK hazardous Waste Landfill CBI

_____ site

Other Landfill zero

_____

Recycle o r 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.)

# Appendix D



# Draft Facility Report on Product Content

## 2010/15 PFOA Stewardship Program



# Draft Facility Report on Prod uct Content

I. CHEMICAL IDENTIFICATION

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

Product n ame PTFE dried coagulated dispersion

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

and year of production): All products manufactured in year 2011

Coagulated dispersion typically contained 80 ppb APFO

II. COMPANY IDENTIFICATION

Identify the company and location of the facility submitting in formation:

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 8 61 989

Address: York House, Hillhouse International,

Thornton Cleveleys,

Lancs FY5 4QD, UKIII. PRODUCTION

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

(Normalized data based on year end run rate.)

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

Imported CBI

Manufactured CBI

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)Part IV (cont.)

B. ANALYTICAL METHODS

Analy ses 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), assump tions made, uncertainties

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

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

and SAM/CHEM/PAF/7 previously submitted.

(ii) In house UV

- vis spectrosco py. Method FTM166 previously submitted.