COMPANY SANITIZED- DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 

OPPT-2006·0621 

CBIC Control Number 

366919-S 

AppendixC 

Facility Report on Emissions in 2014 

for 

Perfluorooctanoic acid (PFOA) 
COMPANY SANITIZED- 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 name: Perfluorooctanoic acid(PFOA) 

CAS number: 335-67-1 

II. COMPANY IDENTIFICATION 

Identify the company and location of the facility submitting information: 

Company name: Archroma Germany GmbH 

Site location: Germany, Burgkirchen/Gendorf 

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

submitted: 

Technical contact: 

Phone: 

Address: email 

Dr. Wolfgang Knaup 

+49 8679 7 4653 

wolfgang.knaup@archroma.com 

2 
COMPANY SANITIZED- DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 

III. ON-SITE ACTIVITIES 

Calendar year for which you are reporting: Jan 1, 2014 to Dec 31, 2014 

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

-

-

-

Estimate the amount of subject chemical distributed off-site: 

Provide the amount used (including any that was manufactured, impmted [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 nanative 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: 

3 
COMPANY SANITIZED- DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 

4 
COMPANY SANITIZED- 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 repotted. 

Estimate the number of days per year the release occurs. Enter a whole number with a 

maximum of 2 significant figures. 

Insett "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 uncettainties. 

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. 

Patt IV (cont.) 

A. ON-SITE AIR RELEASES 

5 
COMPANY SANITIZED- DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 

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. 

Basis for each release estimate: 

Patt IV (cont.) 

B. WATER RELEASES FROM SITE 

Estimated Tota!Estimated% 

Annual ReleasesAccuracy 

(kgs) (Optional) 

- -

- -

#Days/year 

Release Occurs 

• • 

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 

6 
COMPANY SANITIZED- DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORM A TTON 

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 

Annual Releases 

(legs) 

-

Estimated% 

Accumcy 

(Optional) 

#Days/year 

Release Occurs 

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 

NP DES number(s): not available 

Basis for each release estimate: 

Part IV (cont.) 

Estimate the total releases of the chemical for each category ofland 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. 

7 
COMPANY SANITIZED- DOES NOT CONTAIN CON~'IDENTIAL BUSINESS INFORMATION 

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. 

Landfill 

Land Treatment/Land Amendment 

Surface Impoundments 

Underground Injection 

Other (specify): 

Basis for each release estimate: 

Estimated Total 

Annual Releases 

(kgs) 

not 

-

applicable 

not applicable 

not applicable 

not applicable 

Estimated% 

Accuracy 

(Optional) 

-

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

Part IV (cont.) 

D. OFF-SITE TRANSFERS 

Estimates of off-site transfers should be similar in accuracy and precision to previous release 

estimates. 

D I. Transfer to Publicly Owned Treatment Works (POTW) 

8 
COMPANY SANITIZED- DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 

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: B urgkirchen 

State: Germany 

NPDES number: 

Basis for each release estimate: 

County: -----------

Zip Code: 84508 

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

I 

Comments: 

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

Part IV (cont.) 

D2. T!'ansfers 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). 

9 
COMPANY SANITIZED- DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 

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 

Estimated Annual 

Transfers (kgs) 

see comments below 

not applicable 

not applicable 

not applicable 

not applicable 

not applicable 

not applicable 

not applicable 

10 

Estimated% 

accuracy 

(Optional) 
ATTACHMENT A 

CON Fl DENTIAL 

BUSINESS 

INFORMATION 
Process Work Flow 2014 Telomer Production 

Telomerization Plant 
COMPANY SANITIZED- DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 

Appendix C 

Facility Report on Emissions in 

2014 

for 

Direct Precursors 

(CsF11-J and C,Fis-COOCzH,CsFI7) 

and 

Indirect Precursors I Higher Homologues 

(Rp-C,H,-1; Rp-C,H,-OH; RJ.-C,H,-OCO-CR=CH,, RF-CH=Cli,) 
COMPANY SANITIZED- 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-1; Rp-C2Hrl; Rp-C2HrOH; Rp-C2HrOCO-CR~CH2:RJ.'CH~CH2) 

CAS number: not applicable 

II. COMPANY IDENTIFICATION 

Identify the company and location of the facility submitting information: 

Company name: Archroma Germany GmbH 

Site location: Germany, Burgkirchen/Gendorf 

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

submitted: 

Technical contact: 

Phone: 

Address: email 

Dr. Wolfgang Knaup 

+49 8679 7 4653 

wolfgang.lmaup@archroma.com 

2 
COMPANY SANITIZED- DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 

III. ON-SITE ACTIVITIES 

Calendar year for which you are reporting: Jan 1, 2014 to Dec 31, 2014 

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

• • 

Estimate the amount of subject chemical distributed off-site: 

Provide the amount used (including any that was manufactured, impmted [virgin or extemally 

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 (legs/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. 

3 
COMPANY SANITIZED- DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 

Narrative Description and Process Flow Schematic: 

4 
COMPANY SANITIZED- DOES NOT CONTAIN CONFIDENTIAL BUSINESS IN~"ORMATION 

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 repmted 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 

of2 significant figures. 

Insett "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: 

Pmt IV (cont.) 

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 uncettainties. 

5 
COMPANY SANITIZED- DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 

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 

Annual Releases 

(kgs) 

Basis for each release estimate: 

Part IV (cont.) 

Estimated% 

Accuracy 

(Optional) 

6 

#Days/year 

Release Occurs 

• • 
COMPANY SANITIZED- DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 

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 

Annual Releases 

(kgs) 

Estimated % # Days/year 

Accuracy Release Occurs 

(Optional) 

I 

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: 

7 
COMPANY SANITIZED- DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 

Part IV (cont.) 

8 
COMPANY SANITIZED- DOES NOT CONTAIN CON~'IDENTIAL BUSINESS INFORMATION 

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. 

Landfill 

Land Treatment/Land Amendment 

Surface Impoundments 

Underground Injection· 

Other (specify): 

Basis for each release estimate: 

Estimated Total 

Annual Releases 

(kgs) 

not applicable 

not relevant 

not relevant 

not relevant 

not relevant 

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

Comments: 

Estimated% 

Accuracy 

(Optional) 

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

Part IV (cont.) 

9 
COMPANY SANITIZED- DOES NOT CONTAIN CON~'IDENTTAL BUSINESS INFORMATION 

D. OFF-SITE TRANSFERS 

Not applicable 

Estimates of off-site transfers should be similar in accuracy and precision to previous release 

estimates. 

D 1. 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)+/- 20 

POTW Name: ---------- (on-site wastewater treatment plant InfraServ Gendorf) 

Street Address: -------

City: -------------

State: ------------

NPDES number: 

Basis for each release estimate: 

County: -----------

Zip Code: ----------

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

Comments: 

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

Patt IV (cont.) 

10 
COMPANY SANITIZED- DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 

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 whyre some of the chemical will be recycled and the remainder will 

be treated, estimate each amount separately (i.e., waste treatment and recycling activities). 

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: 

Estimated Annual 

Transfers (kgs) 

not relevant 

not relevant 

not relevant 

not relevant 

not relevant 

not relevant 

not relevant 

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

Basis for each release estimate: 

11 

Estimated% 

accuracy 

(Optional) 
ATTACHMENT A 

CON Fl DENTIAL 

BUSINESS 

INFORMATION 
Process Work Flow 2014 Telomer Production 

Telomerization Plant 

FluoroTelomer Plant (FTB) 
COMPANY SANITIZED- DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 

AppendixD 

Report on Product Content 

2014 

Fluorotelomer based A3F Chemicals 

• PFOA 

• PFCA (other than PFOA) 

• Direct Precursors 

(CsFn-J and C,F"-COOC,H,CsFn) 

• Indirect Precursors I Higher Homologues 
COMPANY SANfl'IZED- 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 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: Archroma Germany 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@archroma.com 

III. PRODUCTION 

Calendar year for which you are reporting: Jan 1, 2014 to Dec 31, 2014 

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

.. I -
COMPANY SANITIZED- 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, pentadecat1uoro- ammonium salt (CAS 3825-26-1) 

P FOA 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, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,1 0-heptadecafluoro- (CAS 678-39-7) 

• 1-Decene, 3,3,4,4,5,5,6,6, 7,7,8,8,9,9, I 0,1 0,1 0-heptadecafluoro- (CAS 21652-58-4) 

• 2-Propenoic acid, 3,3,4,4,5,5,6,6,7, 7,8,8,9,9,1 0,1 0,1 0-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, I 0,1 0,1 0-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, 10,10,1 0-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, 10,1 0-heneicosafluoro-1 0-iodo- (CAS 423-62-

1) 

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

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

• 1-Decano1, 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-1 0-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, 10,1 0-heneicosafluoro-12-iodo- (CAS 

2043-54-1) 

• 2-Propenoic acid, 3,3,4,4,5,5,6,6,7,7 ,8,8,9,9, 10,1 0,1 0-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) 

3 
COMPANY SANITIZED- 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. 

I 

I 

4 
COMPANY SANITIZED- DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 

-

.. 

5 
COMPANY SANITIZED- DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 

AppendixD 

Report on Product Content 

2014 

Fluorotelomer based Polymer Dispersions 

• PFOA 

• PFCA (other than PFOA) 

• Direct Precursors 

(CsF11-J and C7FIS-COOC,H,CsF!7) 

• Indirect Precursors I Higher Homologues 
COMPANY SANITIZED- 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 

II. COMPANY IDENTIFICATION 

IdentifY the company and location of the facility submitting information: 

Company name: Archroma Germany 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@archroma.com 

III. PRODUCTION 

Calendar year for which you are reporting: Jan 1, 2014 to Dec 31, 2014 

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

Imported 

Manufactured 

I -

,. 

2 
COMPANY SANITIZED- DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFOR!VIATION 

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, 7,8,8,9,9,1 0,10,1 0-heptadecafluoro- (CAS 678-39-7) 

• 1-Decene, 3,3,4,4,5,5,6,6, 7,7,8,8,9,9, I 0, I 0, I 0-heptadecafluoro- (CAS 21652-58-4) 

• 2-Propenoic acid, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,1 0,1 0,10-heptadecafluorodecyl ester (CAS 

27905-45-9) 

• 2-Propenoic acid, 2-methy1-, 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, 3,4,4,5,5,6,6,7,7,8,8,9,9,1 0,1 0,1 0-hexadecafluoro- (CAS 70887-84-2) 

• Decanoic acid, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,1 0,10-heptadecafluoro- (CAS 27854-31-5) 

Higher homologues 

• Dodecane, 1,1 ,I ,2,2,3,3,4,4,5,5,6,6, 7, 7,8,8,9,9, 10,1 0,11,11,12, 12-pentacosafluoro-12-iodo-

(CAS 307-60-8) 

• Decane, 1,1,1,2,2,3,3,4,4,5,5,6,6, 7, 7,8,8,9,9,1 0,1 0-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, 7,8,8,9,9,10,1 0-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) 

3 
COMPANY SANITIZED- 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. 

I 

I 

I 

I 

4 
COMPANY SANITIZED- DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORM A TTON 

5 
DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 

AppendixF 

Company Annual Report 

2014 

Summary of Reductions 

in 

Emissions and Product Content 

PFOA 

+ 

Direct Precursors 
DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 

2010/15 PFOA Global Stewardship Program 

Company Report: Summary of Reductions in Emissions and Product Content 

I SECTION 1: REPORT DATE i . il October 2015 

SECTION 2: COMPANY IDENTIFICATION ·• .. · ... ,·· ..... · .... .. , ...... · .. ··::,: '········::',,::·.;'•·· ..... ·.··· , ... , .. ', ' ... ·•i ''/•.:' 

Company Name Archroma Germany GmbH 

'2a' Street Address 

84508 Burgkirchen (Germany) 

I ·: 

SECTION 3: SUMMARY OF EMISSIONS. 

Reporting Period I Jan 1, 2014 to Dec 31, 2014 

Releases to all environrye~ta] media fr?m flu6~6~6)YJtier and.· .. · .. :.·:.·• . ·.,•.· .·· · . . ·: ... , .··:: ·.·· . )'· telorri~r manufact!lt~· · ., · · .i/' ', · ·· ·:.·.''})>Reduction of',' 

.. , .. . . ·.. ki< of category ' . k~ ~[category total kgs r~leased Kgs . ,, . . . ·" , , . 1 . . from baselme year j<:gs of fluoropo1ymers kgs of telomers 

PFOA and PFOA salts• ' Not applicable Not applicable Not applicable Not applicable 

Direct Precursors.··· Not applicable Not applicable Not applicable Not applicable 

I 3a l• Operati. ·ons •.. 

I .·. .· .. ·.·, ... U.S. j'a~ilities 

3

b I No?~l!;S. PFQ.i\a:g4PFOAsalts <0.5 Not applicable - >95 

facJhtJes I;lirectprecursors <I Not applicable - 90 

3c I Please provide inforriultion on the methods, assumptions, uncertainties. and detection limits .f()r,theC!~ta provided above. ·, 
DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 

PFOA is analyzed, after derivatisation, by GC or GC-MS; Method LOD 0.1 ppm. 

Direct Precursors are analyzed by GC and/or GC-MS; Method LOD depends on specific fluorotelomer structure 50- 100 ppm 

Production vothme (kgsfye~)~ , '""",. · · .. ':.,;:;.,,11,'1

,·. 

, facilities 

i':i:·:·:·.,:'·:.:;'. 

... ,.,, 

Chemic~!! , .:.:r:: ':\,:'·.:: category,,.·.,, ' ' : ,)~i.''.: 

Oirect Precursors ':' :·~: ,·,, 

1 Fluoropolymers manufactured with PFOA. 

FluoroP'd})rmer dispersio~~·.::·'\::.:· ·'·'' ' ·,,:.,,' 

Other fluoropolymers1 

Concentrafi~h3 .. ,:·::,'.:, 

Fluoropolrri~/ Other " i.J~l~m"r based 

dispersioll:S1::.·:~,·:·/ .. fluoropolymetS. ;e.~:·: .. ::. '.: .. : .. · ·,::P'rO~~~ts~ 

(ppm weti, ·•> • (ppb dry weight) : ·.· ...•. ·,' (irlj<gs) wei'ghtY:·::·,·.:.:·,. · · .. ·' · '.'·, , ....... :, · , ... , ... 

Not Not 

a licable 

Not Not 

applicable applicable applicable 

.. I%,'R.educti<lri 

:frbril lJiiselin~ ye<JT 

Fluoropolymer 

d~·spersions · 

Not 

a licable 

Not 

applicable 

Other 

fluO:ro.: ·p.olymers~.:· ', ,.. ', ' 

Not 

a licable 

Not 

applicable 

a 

Telomer. 

based 

products 

Not 

licable 

Not 

aPPlicable 

2 Use the following ranges: (I) Zero (2) > 0- 10 kgs; (3) > 10 kgs- 100 kgs; (4) > 100 kgs- 1,000 kgs; (5) > 1,000 kgs- 10,000 kgs; (6) > 10,000 kgs100,000 kgs; (7) > 100,000 kgs -1,000,000 kgs; (8) Over 1,000,000 kgs. 3 Concentration should reflect the concentration of chemical in the product as sold by the reporting company. If the reporting company has information 

concerning the concentration of chemical in the product as used by others -for example, as incorporated by dilution into a formulation- that additional 

information would also be helpful. 4 This value should be expressed as a weighted average concentration and range. 5 This value should be expressed as a maximum concentration. 6 This value should be expressed as a simple (not weighted) average and range. 
DOES NOT CONTAIN CONFIDENTIAL BUSINESS INFORMATION 

l4c Non-U.S.. I I'BOA, PFOA salts. --- I --- <1 --- I --- >90 

facilities 1. Diiect Precursors ···.·• ·· --- I --- 8 --- I --- >90 

Please provide infob:nation on the 'methods, assumptions, uncertainties and deteCtion li:inits for the data provided above. 

I;,. 

Ad PFOA is analysed, after derivatisation, by GC or GC-MS; Method LOD 0.1 ppm. 

Direct Precursors are analysed by GC and/or GC-MS; Method LOD depends on specific fluorotelomer structure 50 - 100 ppm 

I