Document ZBa3OJQYa0do0QQwkrk7mr3nJ

Guidance Document - AGC Chemicals Europe Ltd 1. Quantification of PFAS releases to water 1.1 Screening We require you to conduct screening to identify presence of PFAS compounds listed in Annex I in W1 effluent discharge. Please provide a breakdown of your chosen procedure for review before proceeding. Minimum 2 samples required. 1.2 Monitoring Following the completion of screening phase and provision of screening results, any PFAS compounds listed in Annex I which identify as present in W1 effluent discharge will need further monitoring. We suggest the use of the EPA method for wastewater - PFAS Analytical Methods Development and Sampling Research | US EPA - or a similar methodology. Please provide a breakdown of your chosen procedure for us to review before proceeding. We require you to monitor releases of PFAS compounds listed in Annex III from W1 effluent discharge point. You may wish to use existing procedures and techniques as required in site permit monitoring conditions. We require you to conduct Total Organofluorine (TOF) analysis to determine releases of all fluoroorganic compounds from W1 effluent discharge. Please provide a breakdown of your chosen procedure for us to review before proceeding. All monitoring to take place at W1 effluent discharge point. Please provide the flow rate from W1 effluent discharge point for each round of monitoring. All monitoring is to take place over a 12 month period, minimum 24 samples from each effluent discharge point with a minimum of 2 samples taken per month. This will allow us to assess the seasonal variation of releases from W1 effluent discharge point. Please provide background chemical quality data at the discharge point for each substance to be monitored. This will allow a more accurate assessment of the effect of these substances in the discharge on the receiving water. A minimum of 24 samples over a 12 month period should be provided along with a grid reference of the sample point. 2 samples per month. Please provide a breakdown of your chosen procedure for us to review before proceeding. 1.3 Mass releases We require you to provide annual mass releases for PFAS compounds listed in Annex II from W1 effluent discharge point. This can be completed by mass balance, or any other suitable method you wish to propose. 1.4 Surface water risk screening Following the completion of the monitoring phase, you will need to complete a surface water risk screening assessment. Online guidance is available here (screening test: estuaries and coastal waters) - Surface water pollution risk assessment for your environmental permit - GOV.UK (www.gov.uk). The Marine Modelling Team will provide further guidance if needed. 2. Quantification of PFAS releases to air 2.1 Screening We require you to conduct screening to identify presence of Perfluorobutanoic acid (PFBA) and Perfluorohexanoic acid (PFHxA) from aerial emission points. Please provide a breakdown of your chosen procedure for review before proceeding. Minimum 2 samples required. 2.2 Monitoring We require you to monitor releases of PFAS compounds listed in Annex III from PTFE emissions points. Please provide a breakdown of your chosen procedure for review before proceeding. We require you to monitor for 3,3,4,4,5,5,6,6,6-Nonafluorohexene - perfluorobutylethylene (PFBE) and Trideca-1,1,1,2,2,3,3,4,4,5,5,6,6-fluorohexane - 1H-perfluorohexane (1H-PFHx) [AC-2000] (C6H) releases from ETFE emission points. Please provide a breakdown of your chosen procedure for review before proceeding. If screening phase identifies presence of PFBA or PFHxA, they may require further monitoring. We would suggest the use of OTM - 45 or a similar methodology. Please provide a breakdown of your chosen procedure for review before proceeding. If a 24-hour analysis method is proposed, 4 samples will be required. If another method is proposed, we will need to reassess the number of samples required. 2.3 Mass releases We require you to provide annual mass releases for 1,1,1,2,2,3,3-Heptafluoro-3[(trifluorovinyl)oxy]propane (PPVE) and Hexafluoropropylene (HFP) to air. This can be completed by mass balance, or any other suitable method you wish to propose. 2.4 Air Emissions Risk Assessment Following the completion of the monitoring phase, you will need to complete an air emissions risk assessment. Online guidance is available here - Air emissions risk assessment for your environmental permit - GOV.UK (www.gov.uk). 3. Other PFAS releases Are the company aware of any PFAS, as defined by OECD but excluding fluoropolymers, other than the substances listed in Annexes I, II and III being released from the site to all media? If so, please provide details of annual mass releases for each substance. "All media" refers to air, water, waste and product. 4. Information regarding PFAS contamination, risks and impacts on site and in surrounding areas We require you to provide copies of third-party prepared site survey reports produced between January 1st 2000 and DATE OF ISSUE which contain information regarding PFAS contamination, risks and impacts on site and in surrounding areas. 5. Proposals to reduce PFOA releases to water We require you to provide proposals to reduce PFOA releases to water. 6. Proposals to reduce Perfluoro(2-ethoxy-2-fluoroethoxy)acetic acid ammonium salt [EEA-NH4 (SAA-1000) releases to water We require you to provide proposals to reduce Perfluoro(2-ethoxy-2-fluoroethoxy)acetic acid ammonium salt [EEA-NH4] (SAA-1000) releases to water. 7. Historic information related to releases of PFOA from the site We require you to provide total mass releases of PFOA to air, land, water and in products from first production on site to DATE OF ISSUE. 8. Modelling of emissions from product dryer We wish to model air dispersion of PFOA released from the product dryer. We are assuming emissions were from a single stack, if this is not correct, please let us know. Please provide the following information: Stack height Stack diameter Stack temperature Stack velocity PFOA release rate If exact information is not available, please provide a best estimate. ANNEXES ANNEX I Analyte Perfluoro-1-butanesulfonic acid (PFBS) Perfluoro-1-pentanesulfonic acid (PFPeS) Perfluoro-1-hexanesulfonic acid (PFHxS) Perfluoro-1-heptanesulfonic acid (PFHpS) Perfluoro-1-octanesulfonic acid (PFOS) Perfluoro-1-nonanesulfonic acid (PFNS) Perfluoro-1-decanesulfonic acid (PFDS) 1H, 1H, 2H, 2H-perfluorohexane sulfonic acid (4:2 FTS) 1H, 1H, 2H, 2H-perfluorooctane sulfonic acid (6:2 FTS) 1H, 1H, 2H, 2H-perfluorodecane sulfonic acid (8:2 FTS) Perfluorobutanoic acid (PFBA) Perfluoropentanoic acid (PFPeA) Perfluorohexanoic acid (PFHxA) Perfluoroheptanoic acid (PFHpA) Perfluorononanoic acid (PFNA) Perfluorodecanoic acid (PFDA) Perfluoroundecanoic acid (PFUnDA) Perfluorododecanoic acid (PFDoDA) Perfluorotridecanoic acid (PFTrDA) Perfluorotetradecanoic acid (PFTeDA) CAS RN 375-73-5 2706-91-4 355-46-4 375-92-8 1763-23-1 68259-12-1 335-77-3 757124-72-4 27619-97-2 39108-34-4 375-22-4 2706-90-3 307-24-4 375-85-9 375-95-1 335-76-2 2058-94-8 307-55-1 72629-94-8 376-06-7 N-ethylperfluoro-1-octanesulfonamidoacetic acid (N-EtFOSAA) N-methylperfluoro-1-octanesulfonamidoacetic acid (N-MeFOSAA) Perfluoro-1-octanesulfonamide (PFOSA) 2991-50-6 2355-31-9 754-91-6 ANNEX II Analyte 1,1,1,2,2,3,3-Heptafluoro-3[(trifluorovinyl)oxy]propane (PPVE) 3,3,4,4,5,5,6,6,6-Nonafluorohexene - also known as perfluorobutylethylene (PFBE) Trideca-1,1,1,2,2,3,3,4,4,5,5,6,6-fluorohexane also known as 1H-perfluorohexane (1H-PFHx) Hexafluoropropylene (HFP) CAS RN 1623-05-8 19430-93-4 355-37-3 116-15-4 ANNEX III Analyte CAS RN Perfluoro(2-ethoxy-2-fluoroethoxy)acetic acid ammonium salt [EEA-NH4] (SAA-1000) Perfluorooctanoic acid (PFOA) 908020-52-0 335-67-1