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SANITIZED Appendix C



# Dyneon Gendorf Facility Report on Emissions

for 2008

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SANITIZED 2010/15 PFOA Stewardship Program 

# Dyneon Gendorf 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 s ubmitting information:

Company name:___Dyneon

__________________

Site location:_____Gendorf, Germany

______________

Identify a company technical contact who can respon d to inquiries about the

information submitted: Technical contact:_George H. Millet_______________

____ Phone:_____651-733-5637

__________________________ Address:__6744 33 rd St N., Oakdale, MN, 55082

_________

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SANITIZED III. ON-SITE ACTIVITIES

Calendar year for which you are reporting: Jan 1, 2008 to Dec 31, 2008

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

site:

Imported (virgin) SANIT IZED kgs/yr

Imported (externally recyc led) SANITIZED kgs/yr

Manufactured (virgin) SANITIZED kgs/yr

Estimate the amount of subject chemical distributed off-site:

SANITIZED kgs/yr % of manufacture/import

Provide the amount used (including any that was man ufactured, imported [virgin or externally recycled], or internally recycled) of the subject chemical for the reporting year at specific site:

SANITIZED kgs/yr

Narrative Description and Process Flow Schematic :

Provide overall material balance of the chemical be ing reported, showing releases and products (kgs/year). Use the following page to provide a narrative description and process flow schematic of on-site a ctivities, and include information that gives an understanding of the natu re and extent of potential exposures to the subject chemical. Attach additiona l pages if desired. The narrative and process flow schematic should cover m ajor unit operations and chemical conversions for manufacturing and on-site uses, if applicable. The narrative should provide insight into why and how r eleases are caused by the process. The schematic should show the points of re lease of the subject chemical in the workplace and to the environment. In the eve nt the subject chemical is used in many different processes, provide information on each major process instead of

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SANITIZED each individual process.

Narrative Description and Process Flow Schematic fo r Gendorf :

2008 was a transition year for Dyneon. We began th e year using APFO, the ammonium salt of PFOA (CAS # 3825-26-1), as an emulsifier in the polymerization of SANITIZED. By the end of the year we eliminated the use of APF O in the manufacture of fluoropolymers at Dyneon’s Gendorf, Germany facilit y. This completed Dyneon’s

efforts to reduce and then eliminate APFO emissions and product content on a global basis. In doing so, we have achieved the goal of e liminating Dyneon’s use of APFO, seven years ahead of the time set by the EPA’s 2010 /15 Voluntary PFOA Stewardship Program.

We were able to meet the Voluntary PFOA Stewardship Program goal by developing a new emulsifier for the fluoropolymers that formerly were made using APFO. Compared to APFO, our new emulsifier has an improved mammali an toxicological profile, a similar environmental toxicological profile and a faster el imination rate in laboratory animals.

The new emulsifier also can be recovered effectivel y by the containment technology that Dyneon used to recover APFO from waste streams and products. This technology has

enabled us to recover and reuse the new emulsifier as efficiently as we were able to recover and reuse APFO. Dyneon is also using this technology to reduce the new emulsifier content of our liquid fluoropolymer disp ersion products.

The product families mentioned above are sold as li quid dispersion products and/or dry resin products. The processes for making these fam ilies of fluoropolymers are similar, regardless of which type of fluoropolymer is manufa ctured, and regardless of whether APFO or our new emulsifier is used in the polymeriz ation step, so the following description covers all processes, with any variatio ns noted.

The aqueous emulsion polymerization process is cond ucted in a stirred, pressurized, temperature controlled reactor. Water, emulsifier, and other polymerization ingredients (initiators, etc.) are introduced into the reactor and heated to the polymerization temperature. Monomers are fed into the headspace of the reactor as gases; the polymerization reaction takes place in the aqueous phase as the monomers diffuse into it.

Monomers continue to be fed into the reactor until the polymerization is complete, as judged by the amount of monomer consumed. During n ormal operations, there are no releases or emissions of emulsifier at this stage d ue to the enclosed nature of the process.

The resultant emulsion (or dispersion) is transferr ed through a filter, and the filtered solids (“pre-coagulum”) is landfilled in an on-site waste facility. This pre-coagulum is

estimated to contain <0.1% of the total of the emul sifier charged to the reactor.

If the fluoropolymer emulsion produced above is des tined to be sold as a liquid fluoropolymer dispersion product, it is concentrate d, stabilized, treated to remove emulsifier, and packaged at this point. The proces s to reduce the emulsifier content of

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SANITIZED liquid dispersion fluoropolymers consistes of SANIT IZED. This process reduces the emulsifier content from about 1500 - 2000 ppm to 5 to 50 ppm depending on the fluoropolymer. The emulsifier captured by the proc ess is regenerated and purified for

reuse. There are small releases to waste water from this process.

If the fluoropolymer emulsion produced above is des tined to be sold as a dry fluoropolymer product, then the filtered emulsion i s transferred to equipment in which it is separated into solid polymer particles (“agglome rate”) and an aqueous phase, by chemical or mechanical means. The wet agglomerate is then washed with water to remove the remaining polymerization ingredients, in cluding emulsifier.

The majority of the emulsifier used in the polymeri zation step is contained in these aqueous phases. We estimate that more than 90% of the total amount of emulsifier in this waste water is recovered, recycled and reused.

Emulsifier is recovered from waste water streams us ing an anion exchange resin bed. The waste water is filtered to remove particulate m atter then run though the bed. Emulsifier content entering the bed is an average a bout 100 ppm, and the water exiting contains about 1 ppm emulsifier. This concentratio n is measured routinely as a process control to identify when the resin bed is exhausted and needs to be changed. The analysis is done by GC-MS and the LOQ is 1 ppm. The treated waste water then flows to the site waste water treatment facility. Not all waste wate r streams are treated by ion exchange to remove emulsifier; some are so low in concentration or volume that they pass directly to the waste water treatment system.

The clean, wet agglomerate is then dried. There ar e small amounts of emulsifier emission to air from drier exhausts. These are poi nt source emissions. The largest drying oven exhaust gas stream is passed through a scrubbe r that removes emulsifier for recycling. The scrubber medium is aqueous potassiu m carbonate; this converts the emulsifier in the exhaust gas to the corresponding potassium salt.

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Because there is little residual emulsifier present in these dry fluoropolymers, one would expect there to be no releases or emissions from th is stage of the process.

By the end of 2007, most of our fluoropolymer manuf acturing waste water and exhaust gas streams were connected to emulsifier removal an d recovery systems. Removal, recovery and reuse, had grown from about 10% of the AFPO used in Gendorf in 2000 to

about 83% in 2008.

Emulsifier is recovered and recycled from the ion e xchange resin by SANITIZED. Emissions from this process are small, and waste fr om the process is incinerated on site.

The amount of APFO reported as “destroyed” was 2,50 0 kg in 2008. This was less than last year due to our reduced usage of APFO compared to last year.

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SANITIZED The process flow diagram below is a broad overview of the APFO mass flow in 2008.

Overview of Gendorf Fluoropolymer Manufacturing Pro cess - 2008

APFO Mass Balance Table – Gendorf 2008

Category Amount of APFO (kg) Percent of Total

Used SANITIZED

Air Release 300

Water Release 700

Solid Release 20 Destroyed 2,500 Recycled SANITIZED

In Products SANITIZED Dyneon Fluoropolymer Manufacturing
Process Emulsifier
Removal / Recovery

Emulsifier
Removal / Recovery Dyneon
Emulsifier Recycling-Plant Emulsifier
Removal / Recovery Process Off

- Gas

Process Waste
Water Product (Dispersion)

Waste Water
Treatment Gendorf

Releases to water
& landfill Releases to Air

Releases to landfill Process Solid

Waste To Incinerator

To Inci nerator

Recycled Emulsifier Reuse Polymerization Ingredients: Emulsifier, Water, Monomers,
Initiator and

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SANITIZED IV. SITE RELEASE AND TRANSFER INFORMATION (For manufacturing and on-site processing/use if ap plicable)

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 belie ve appropriate. Estimates should be reported in kgs per year for the reportin g period. Enter the values as whole numbers to no more than two significant figur es. 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 oc curs. Enter a whole number with a maximum of 2 significant figures.

Insert “NA” for release activities not associated w ith 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 abou t the possible sources/basis

includes:

1. If the source/basis is an analytical measureme nt, 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 Quantifi cation (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 assumpt ions you made

to correct the balance. Describe the uncertainties

.

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

• Describe the method used. For example, if engineer ing calculations are used, give a general description a nd state your assumptions. Describe the uncertainties.

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SANITIZED Part IV (cont.)

A. ON-SITE AIR RELEASES

Estimate the total fugitive or non-point releases t o air and the number of days per year the releases occur. These releases i nclude 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 fugiti ve 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 po int source releases. Include storage tank emissions and releases from pollution control equipment.

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

Estimated Total Estimated % # Days/year Annual Releases Accuracy Release

Occurs (kgs) (Optional)

Fugitive (non-point) __0

__ _____ _____

Stack (point) _300 __ __95 _ __360

_

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

2008 data based on air emission concentration sampl ing and engineering estimates of

exhaust air volumes. Stack air emission concentrat ions measured by impinger bottle sampling, followed by extraction and quantitation u sing liquid chromatography with mass spectrometry detection, or GC-MS depending on expected concentration in the sampling medium.

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SANITIZED Comments: (This section is available to clarify your response s. Attach additional pages if

desired.)

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 o r water bodies. Include all discharges from process outfalls such as pipes, ope n trenches, releases from onsite wastewater treatment, and contribution from st orm water runoff, if applicable. Do not include discharges to a POTW or other off-si te wastewater treatment facilities. If desired, you can provide an estimate of the accuracy of your release

estimate.

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

Water releases: _ 700 _ __95 ___ _360

_

Enter the names of the streams or water bodies to which the facility directly discharges the chemical. Also, enter the N PDES permit number for the facility. If more than one number is assigned to th e facility, list each number for the appropriate discharge quantity and receiving wa ter identified.

Receiving Water Name(s):__Alz River

___

NPDES number(s):_N/A

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

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SANITIZED Waste water releases were calculated by measuring w aste water outfall concentration routinely, and multiplying by total v olume of waste water flow.

Comments: (This section is available to clarify your response s. 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 rele ases. 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 a ll waste containing the chemical that is applied or incorporated into s oil on-site. Do not include waste

that is landfilled.

Surface impoundments are natural topographic depres sions, man-made excavations, or diked areas formed primarily of ear then 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 t hat is released to land other than those listed. An example is the accident al release of the chemical from an underground pipeline or storage tank.

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SANITIZED Estimated Total Estimated % Annual Releases Accuracy (kgs) ( Optiona l)

Landfill 20__

_____

Land Treatment/Land Amendment __0__

_____

Surface Impoundments __0__

_____

Underground Injection __0__

_____

Unknown or Other (DESTROYED) _2,500 _____describe

Internally Recycled _SANITIZED _____describe

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

Coagulum and scrap was disposed of on site in an in ert waste landfill. Leachate from the chemical waste landfill is managed by pump ing and treatment before transfer to the site waste water treatment plant.

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Destroyed amount is an engineering estimate based o n air flow to an on site fluorochemical incinerator through the central vacu um system, and the known amount of WWT sludge incinerated.

Comments: (This section is available to clarify your response s. Attach additional pages if

desired.) Part IV (cont.)

D. OFF-SITE TRANSFERS

Estimates of off-site transfers should be similar i n accuracy and precision to previous release estimates.

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SANITIZED Dl. Transfer to Publicly Owned Treatment Works (POT W)

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 containing the chemi cal. Enter the POTW’s NPDES permit number, if known.

Annual Transfer (kgs): __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 Sec tion IV.)

Understanding of waste disposal practices at the Ge ndorf manufacturing site.

Comments: (This section is available to clarify your response s. Attach additional pages if

desired.)

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SANITIZED Part IV (cont.)

D2. Transfers to other off-site locations

In this section, estimate the quantity of the subje ct chemical , not the waste stream, transferred and the accuracy of the estimat e for each category listed. If your facility sends the subject chemical in waste t o an off-site location where some of the chemical will be recycled and the remai nder will be treated, estimate each amount separately (i.e., waste treatment and r ecycling activities).

Estimated Annual

Estimated % Transfers (kgs)

accuracy

(Optional)

Incineration __0__

_____

Wastewater Treatment (Excluding POTW) __0__

_____

Underground Injection __0__

_____

Hazardous Waste (RCRA Subtitle C) Landfill __0

__ _____

Other Landfill _ 0

__ _____

Recycle or Recovery __0__

_____ (Does not include internally recycled)

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

Comments: (This section is available to clarify your response s. Attach additional pages if

desired.)