# Company Sanitized

Dose not Contains 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 c hemical 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

.

_ Chemicals Company

__

Site location:

___ Chiba, Japan

_______________

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

submitted:

Technical contact:

__ Hiroaki Shida

Phone:

____ _______________ 81

- 436

- 23

- 1251

Address:

__ _____________________ 10, Goikaigan, Ichihara

- shi, Chiba 290

- 8566, Japan

__III. ON

- SITE ACTIVITIES

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

_

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

Imported (virgin) CBI

__ kgs/yr

Imported (externally recycled) __________kgs/yr

Manufactured __________kgs/yr

Estimate the amount of subject ch emical 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 si te:

___ 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 followi ng 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. Th e 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 sh ould 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.

Narrativ e Description and Process Flow Schematic :

CBIIV. (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 f rom 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 sou rces/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 Detectio n (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 accou nted 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 genera l 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 equipme nt 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 estim ates of the accuracies of your release estimates.

Estimated Total Estimated % # Days/year

Annual Releases Accuracy Release Occurs (kgs) (Optional)

Fugitive (non

- point)

_____ _____ _____

Stack (point) CBI

_____ _ 85

_

Ba sis for each release estimate: (See discussion on source/basis in beginning of Section IV.)

CBI

Comments: (This section is available to clarify your responses. Attach additional pages if desired.)Part IV (cont.)

B. WATER RELEASES FROM SITE

Es timate 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 treatmen t, 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 Estimate d % # Days/year

Annual Releases Accuracy Release Occurs (kgs) (Optional)

Water releases:

_ CBI

_____ _ 85

_

Enter the names of the streams or water bodies to which the facility directly discharges the chemical. Also, enter the NPDES permit numb er 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.)

CBI

Comments: (This section is available to clarify your responses. Attach additional pages if desired.)Part IV (cont.)

C. ON

- SITE LAND RELEASES

Estimate the t otal 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 tre atment/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 form ed 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 i nclude 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) ( Optio na l)

Landfill

_ na

__ _____

Land Treatment/Land Amendment

_ na

__ _____

Surface Impoundments

_ na

__ _____

Underground Injection

_ na

__ _____

Other (specify):

_ na

__ _____

Basis for each release estimate: (See discussion on sourc e/basis in beginning of Section IV.)

Comments: (This section is available to clarify your responses. Attach additional pages if desired.)Part IV (cont.)

D. OFF

- SITE TRANSFERS

Estimates of off

- site transfers should be similar in accuracy and precisio n 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 sect ion 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 disc ussion on source/basis in beginning of Section IV.)

Comments: (This section is available to clarify your responses. Attach additional pages if desired.)Part IV (cont.)

D2. Transfers to other off

- site locations

In this section, estimate the quant ity 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 remai nder will be treated, estimate each amount separately (i.e., waste treatment and recycling activities).

Estimated Annual Estimated % Transfers (kgs) accuracy (Optional)

Incineration

_ na

__ _____

Wastewater Treatment (Excluding POTW)

_ na

__ _____

Underground Injection

_ na

__ _____

Hazardous Waste (RCRA Subtitle C) Landfill

_ na

__ _____

Other Landfill

_ na

__ _____

Recycle or Recovery

_ na (Does not include internally recycled ) __ _____

Internally Recycled

_ na

__ _____

Unknown or Other

_ na

__ _____

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

Comments: (This section is available to clarify your responses. At tach 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 fluoropolym er dispersion) for which you are submitting

information:

Product name: PTFE granular grade; suspension polymerisation

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. Chemicals company

___

Site location:

________ Chiba, Japan

____________

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

submitted:

Technical contact: Hiroaki Shida

Phone:

____ _______________ 81

- 436

- 23

- 3326

Address:

____ ______________________ 10, Goikaigan, Ichihara

- shi, Ch iba 290

- 8566, Japan

__

III. PRODUCTION

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

__

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

Imported

____ 0 ____kgs/yr

Manufactured G Grade*

___ CBI * Only product used APFN __kgs/yr ;IV. PRODUCT CONTENT

A. CONCENTRATIONS OF RELEVANT PERFLUOROALKYL CHEMICALS

Please provide the concentrations (ppb) of various perfluoroalkyl chemicals in your product. For che micals 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

- am monium 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

- he ptadecafluoro

- (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 aci d, 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

- pentacosafluor o

- 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 usi ng 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 a nd detection limits (LOD, LOQ) for the data provided.

1. Determination of perfluorooctanoate

1

- 1 Sample (1)Product ( Powder type) (2)Waste water

1

- 2 Reagents Test substance, ammonium perfluorooctanoate (APFO, over 98%, RM

- 364, lot. 210009) were purchased from Miteni (Italy). 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 u se. Distilled water was filtered through a

pre

- column, Preclean

- ORG (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 fortificati on standard containing appropriate amount of APFO 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 /

ethano l).

1

- 4 Pretreatment of samples (1) Product (CD type) Ten g of the sample was placed into the sohxlet. The sohxlet

- extraction using 100 ml of ethanol was conducted for 5 hours. Appropriate amount of each fortification standards of

APFO was added into the extracted solution which was put in each of several vials. Each mixed 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 calculat ion 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 APFO was added into the vials and shaken vigorously. The mix solution was appropriately diluted with the surrogate standard. Aportion 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.

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

- Conven ience

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 = 413 (C7F15COO

- ), 445 (CF2H(CF2)7COO

- ) (4) Desolvation tem perature 350 °C (5) Nebulizer gas N2 (6) Desolvation N2 12 L/min