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 perfluorononanoate

CAS number:___4149-60-4___

II. COMPANY IDENTIFICATION

Identify the company and location of the facility submitting information:

Company name:___ASAHI GLASS CO.,LTD_______

Site location:_____Chiba Plant__________

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

submitted:

Technical contact:__Toshinori Eto_

Phone:_

_______

_81-436-23-3146_

Address:_

_________________

10, Goikaigan, Ichihara-shi, Chiba 290-8566, Japan_______
III. ON-SITE ACTIVITIES

Calendar year for which you are reporting: Jan 1, 2010 to Dec 31, 2010

(Normalized data based on year end run rate)

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

 Imported (virgin) ___CBI___kgs/yr

 Imported (externally recycled) __ZERO __kgs/yr

Manufactured __ZERO __kgs/yr

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___kgs/yr

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. 

Narrative Description and Process Flow Schematic

 CBI

:
IV.

(For manufacturing and on-site processing/use if applicable)

SITE RELEASE AND TRANSFER INFORMATION 

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.
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)

Fugitive (non-point) _CBI ±50% __CBI_

Stack (point) _NA__ _____ _____

Basis for each release estimate:

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

APFN content of polymer subjected to drying was analyzed. All APFN in polymer were 

assumed to be emitted to air. 

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 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)

Water releases: CBI ±50% _CBI_

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):__Tokyo Bay__ _

NPDES number(s):__Not applicable__ ________

Basis for each release estimate:

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

Analysis of samples of wastewater

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 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 ZERO _____

Land Treatment/Land Amendment ZERO _____

Surface Impoundments ZERO _____

Underground Injection ZERO _____

Other (specify): ZERO _____

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.)
No such activity. 

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: _NA_

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:____________________________

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.)

 No transfer to POTW in year 2004.
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 Estimated %

Transfers (kgs) accuracy

(Optional)

Incineration CBI ±50%

Wastewater Treatment

(Excluding POTW) ZERO _____

Underground Injection ZERO _____

Hazardous Waste (RCRA

Subtitle C) Landfill ZERO _____

Other Landfill CBI ±50%

Recycle or Recovery ZERO

(Does not include internally recycled)

_____

 Internally Recycled ZERO _____

Unknown or Other ZERO _____

Basis for each release estimate:

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

 Analysis of CBI

 Mass balance of CBI.

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 Product Content

I. CHEMICAL IDENTIFICATION

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

information:

Product name:__Carboxylate polymer__________________

Product description (including concentrations of perfluoroalkyl chemicals 

identified in Section IV below and year of production): 

CBI. 

II. COMPANY IDENTIFICATION

Identify the company and location of the facility submitting information:

Company name:__ASAHI GLASS Co.,LTD__________

Site location:________Chiba Plant__________________

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

submitted:

Technical contact:_Toshinori Eto

Phone:_

__________________

81-436-23-3146 

Address:_

____________________________

10, Goikaigan, Ichihara-shi, Chiba 290-8566, Japan _

III. PRODUCTION

Calendar year for which you are reporting: Jan 1, 2010 to Dec 31, 2010_

(Normalized data based on year end run rate)

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

 < Confidential Business Information>

 Imported ___ZERO ____kgs/yr

Manufactured ___CBI ___kgs/yr
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

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.

1-1 Sample

1. Determination of perfluorononanoate

(1) Product

(2) Waste water

(3) Waste methanol

(4) Waste C6H

1-2 Reagents

Test substance, ammonium perfluorononanoate (APFN, 99.9%, S-111P, lot. JI020619) 

was produced in Seimi Chemical (Kanagawa, Japan). The surrogate standard, 9-

hydrohexadecafluorononanoic acid (9H-PFNA, 97.8%, lot. C58002501), were purchased from 

Daikin Fine Chemical (Osaka, Japan). Distilled water was produced in-house and checked for 

contaminants by LC/MS before use. Distilled water was filtered through a pre-column, PrecleanORG (GL Sciences Inc. (Tokyo, Japan)) placed between HPLC pump and solvent mixing unit. 

HPLC grade methanol, reagent grade ethanol, and reagent grade ammonium acetate were 

purchased from Kanto Chemical Co., Inc.

In order to avoid contamination, disposable lab ware (tubes, pipettes, etc) was used. 2 mmol/L 

ammonium acetate aqueous solution was prepared for HPLC mobile phase.

1-3 Preparation of fortification and surrogate standard

A fortification standard containing appropriate amount of PFOA was prepared using a 

solvent (2 / 8 (wt) mixture of distilled water / ethanol). A surrogate standard containing 100 

ng/ml 9H-PFNA was prepared using a solvent (1 / 1 (wt) mixture of distilled water / ethanol).

1-4 Pretreatment of samples

(1) Product

One ml of the sample was put in each of several vials. Appropriate amount of each 

fortification standards of APFN was added into the vials. Five ml of ethanol was added into each 

vials for the extraction by ultrasonic. Precipitate was separated by centrifugation or filtration. 0.1 

ml of each supernatant and 2 ml of surrogate standard were put in a vial and mixed well. A 

portion of the solution was put into the auto-sampler vial, and injected into LC/MS conditioned 

as follows. The calculation of concentration in sample was conducted using standard addition 

method.

(2) Waste water

Appropriate amount of the sample was put in each of several vials. Appropriate amount 

of each fortification standards of APFN was added into the vials and shaken vigorously. The mix 
solution was appropriately diluted with the surrogate standard. A portion of the solution was put 

into the auto-sampler vial, and injected into LC/MS conditioned as follows. The calculation of 

concentration in sample was conducted using standard addition method.

(3) Waste methanol

Same as (2) Waste water.

(4) Waste C6H

One g of the sample was put in each of several vials. Appropriate amount of each 

fortification standards of APFN were added into the vials. Ten ml of ethanol/water (1/1 (wt)) was 

added into each vials for the extraction by shaking. The solution in ethanol/water layer was 

appropriately diluted with the surrogate standard. A portion of the solution was put into the autosampler vial, and injected into LC/MS conditioned as follows. The calculation of concentration 

in sample was conducted using standard addition method.

1-5 LC/MS analytical conditions

LC/MS analysis was conducted with the conditions listed below.

<Instruments>

(1) LC/MS

 HPLC Agilent Technologies, Model 1100

 Mass spectrometer Agilent Technologies, Model 1100MSD (SL)

(2) LC column Imtakt (Kyoto, Japan), cadenza CD-C18 2 mm (diameter) X 100 mm

(3) PC Hewlett Packard Kayak PC Workstation OS: MS-Windows NT 4.0

(4) Software LC/MSD ChemStation, Rev. A. 08. 03

(5) LC/MS vial 2ml vial for auto-sampler, Chromatography-Convenience 400-C80, 

Tomsic

(Tokyo, Japan)

<Analytical conditions>

(1) Column temp. 35 °C

(2) Mobile phase Solution A : 2 mmol/L ammonium acetate aqueous solution

Solution B : Methanol

(3) Isocratic B : 65 %

(4) Flow rate 0.3 mL/min

(5) Injection volume 5 microL

<MS operating parameters>

(1) Ionization mode Electrospray (ESI) (negative ion mode)

(2) Fragmentor voltage 100 V

(3) Ion monitored m/z = 463 (C8F17COO-

), 445 (CF2H(CF2)7COO-)

(4) Desolvation temperature 350 °C

(5) Nebulizer gas N2

(6) Desolvation N2 12 L/min