Clariant 

Clarlant Corporation 

4000 Monroe Road 

Charlotte, NC 28205 

Erin Russell 

Assistant General Counsel 

erin .russell@darlant.com 

704.331 .7059 

COVER LETTER DOES NOT CONTAIN 

CONFIDENTIAL BUSINESS INFORMATION 

October 29, 2009 

ATTN: EPA-HQ-OPPT-2006-0621 

Document Control Office 6428 

Office of Pollution Prevention and Toxics (OPPT) 

1241 Constitution Avenue NW 

Washington DC 20004 

Re: 2008 Submission 

US EPA 2010/l5 PFOA Stewardship Program 

Dear Document Control Officer: 

Please find attached the Clariant submission for the US EPA 2010/15 PFOA 

Stewardship Program. Documents are segregated into confidential and non-confidential 

envelopes. Should you have any questions on this package please feel free to contact me. 

Very truly yours, 

C. ' 

Enclosure 

Erin Russell 

Assistant General Counsel 

CONTAINS NO CB ~ ~2 ~ ~ 
DOES NOT CONTAIN 

CONFIDENTIAL BUSINESS INFORMATION 

Appendix F 

Company Annual Report 

2008 

Summary of Reductions 

in 

Emissions and Product Content 

PFOA 

+ 

Direct Precursors 

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COMPANY REDACTED 

DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 

Appendix C 

Facility Report on Emissions in 2008 

for 

Perfl'uorooctanoic acid (PFOA) 

Company Sanitized 
COMPANY REDACTED 

DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 

2010/15 PFOA Stewardship Program 

Facility Report on Emissions 

1. 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 : Clariant Produkte (Deutschland) 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@clariant.com 
COMPANY REDACTED 

DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 

Ill. 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) 

Imported (externally recycled) -

Manufactured -

[Unintended byproduct - 

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 (kgsiyear) . 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 ma'or process instead 

of each individual process . 
COMPANY REDACTED 

DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 

Narrative Description and Process Flow Schematic: 
COMPANY REDACTED 

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. 
COMPANY REDACTED 

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 : 
COMPANY REDACTED 

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 : 
COMPANY REDACTED 

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 

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.) 
COMPANY REDACTED 

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: 84504 

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.) 
COMPANY REDACTED 

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 Estimated % 

Transfers (kgs) accuracy 

(Optional) 

Incineration see comments below 

Wastewater Treatment 

(Excluding POTW) not applicable 

Underground Injection not applicable 

Hazardous Waste (RCRA 

Subtitle C) Landfill not applicable 

Other Landfill not applicable 

Recycle or Recovery not applicable 

(Does not include internally recycled) 

Internally Recycled not applicable 

Unknown or Other not applicable 

Basis for each release estimate : 
ATTACHMENT A 

CONFIDENTIAL 

BUSINESS 

INFORMATION 
COMPANY REDACTED 

DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 

Appendix C 

Facility Report on Emissions in 

2008 

for 

Direct Precursors 

(CeF,rJ and C7F,s-COOC=H,CeF,T) 

and 

Indirect Precursors / Higher Homologues 
COMPANY REDACTED 

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 

(RF-I; RF-CZH,-I; RF-CZH4-OH ; RF-CZH,-OCO-CR=CH2; RF-CH=CHZ) 

with RF = C8 / C8+ 

CAS number: not applicable 

II. COMPANY IDENTIFICATION 

Identify the company and location of the facility submitting information: 

Company name: Clariant Produkte (Deutschland) 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@clariant.com 
COMPANY REDACTED 

DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 

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) ------ 

Imported (externally recycled) ------

Manufactured 

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 maior process instead 

of each individual process. 
COMPANY REDACTED 

DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 

Narrative Description and Process Flow Schematic: 
COMPANY REDACTED 

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. 
COMPANY REDACTED 

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) 

Fugitive (non-point) -----

Stack (point) _ 

Basis for each release estimate: 
COMPANY REDACTED 

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) 

Water releases : 

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: 
COMPANY REDACTED 

DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 
COMPANY REDACTED 

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.) 
COMPANY REDACTED 

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) 

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.) 

Comments: 

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

10 
COMPANY REDACTED 

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 Estimated % 

Transfers (kgs) accuracy 

(Opdonal) 

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 

Basis for each release estimate: 

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

11 
ATTACHMENT A 

CONFIDENTIAL 

BUSINESS 

INFORMATION 
COMPANY REDACTED 

DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 

Appendix D 

Report on Product Content 

2008 

Fluorotelomer based Polymer Dispersions 

" PFOA 

" PFCA (other than PFOA) 

" Direct Precursors 

(CgF,rJ and C7F,s-COOC=H,CBFI7) 

" Indirect Precursors / Higher Homologues 

,J 1 

Company Sanitized 
COMPANY REDACTED 

DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 

2010/15 PFOA Stewardship Program 

Report on Product Content 

I. 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 year of production): 

II. COMPANY IDENTIFICATION 

Identify the company and location of the facility submitting information: 

Company name: Clariant Produkte (Deutschland) 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@clariant.com 

III. PRODUCTION 

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

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

Imported 

Manufactured 
COMPANY REDACTED 

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, l,l,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-l0-iodo-(CAS423-62-

1) 

" Nonanoic acid, heptadecafluoro- (CAS 375-95-1) 

" Decanoic acid, nonadecafluoro- (CAS 335-76-2) 

" l-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-l2-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) 
COMPANY REDACTED 

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. 
COMPANY REDACTED 

DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 
COMPANY REDACTED 

DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 

Appendix D 

Report on Product Content 

2008 

Fluorotelomer based A3F Chemicals 

" PFOA 

" PFCA (other than PFOA) 

" Direct Precursors 

(C'F,rJ and C7F,S-COOC2H,CgF,7) 

" Indirect Precursors / Higher Homologues 
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2010/15 PFOA Stewardship Program 

Report on Product Content 

I. CHEMICAL IDENTIFICATION 

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

Product name(s): Fluorotelomer based A3F chemicals 

and 

Perfluoroalkylethyliodide (customer A3F manufacturing) 

Product description (including concentrations of perfluoroalkyl chemicals 

identified in Section IV below and year of production): 

II . COMPANY IDENTIFICATION 

Identify the company and location of the facility submitting information: 

Company name: Clariant Produkte (Deutschland) 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@clariant.com 

III. PRODUCTION 

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

Provide the amount of the product for the reporting year at each specific site : 
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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-l0-iodo-(CAS423-62-

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-l2-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) 
COMPANY REDACTED 

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 . 
COMPANY REDACTED 

DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION