Document kg7XzNj8xkROomp0XvE2zdyb

AGC Chemicals Europe Ltd. Regulation 61 Notice Submission Regulation 61 Notice - Part 6: Historic information related to releases of PFOA from the site. Issued 20th December 2023 Environment Agency Request We require you to provide total mass releases of PFOA to air, land, water and in products from first production (ICI period) on site to 03/10/2023. PFOA Mass Balance Ammonium perfluorooctanoate (APFO) is a perfluorinated anionic surfactant. It has a chemical formula of C8F15O2NH4. APFO is referred to as PFOA (perfluooroctanoic acid; C8F15O2H); this is a similar compound with the difference being that the ammonium counter ion in APFO is replaced by a hydrogen ion. However, in solution, they both dissociate to the same C8F15O2- anion with APFO being significantly more soluble than PFOA. APFO was used as a charge stabilising surfactant during the polymerisation of tetrafluoroethylene (TFE) in an aqueous medium to make polytetrafluoroethylene (PTFE) dispersions. APFO was last used in Q1 2012 and was replaced with SAA-1000 (30% solution of EEA-NH4). Since first production at the Hillhouse site the total mass releases of PFOA to air, land, water and in product is approximately 178 tonnes. The approximate break down of these emissions is set out below: Emission to air 49.1 tonnes Emission to land (i.e. landfill) 6.2 tonnes Emission to water 54.3 tonnes Within product (sent to customers) 63.3 tonnes Captured and destroyed through incineration 5.1 tonnes Table 1 provides a summary of PFOA mass release during period of PFOA use at the Hillhouse site. Residual PFOA mass emissions from Q2 2012 onwards are already accounted for in the in the 178 tonnes total mass release from legacy PFTE production. Since Q2 2012 PFOA emission from the Hillhouse site are typically: Emission to air <255g per year due to PFOA presence as an impurity in PTFE lubricant grades Emission to land approximately 1.2 kg per year to landfill (filter cake from effluent treatment process) Approximately 4 kg per year PFOA emission to water (residual effluent contamination from historic use of PFOA and environmental background levels) Within product <125g PFOA per year is inadvertently generated in the PTFE lubricant manufacturing process Approximately 750g per year PFOA captured in the atmospheric scrubber and then destroyed though high temperature incineration at an external site. Table 2 provides a summary of PFOA mass release after period of PFOA use at Hillhouse (since Q2 2021 to October 2023). 1 AGC Chemicals Europe Ltd. Regulation 61 Notice Submission Table 1: Summary of PFOA mass release during period of PFOA use at Hillhouse Year Notes Air (t) 1952-1953 Imperial Chemical Industries Ltd. (ICI) commenced TFE & PTFE manufacture at the Hillhouse site in 1952. These were granular products with no APFO - use. 1954-1959 ICI development of dispersion polymerisation recipes from 1954 to1958. 20tpa TFE pilot plant operational in 1955 with a 200tpa TFE plant 0.7 operational from 1956. 1960-1969 - 5.0 1970-1979 - 6.6 1980-1989 In 1981 ICI established a joint venture with Asahi Glass Co., Ltd. (AGC) - 8.9 "Asahi ICI Fluoropolymers Co., Ltd." 1990-1999 In 1999 AGC became the sole owner of the joint venture including the PTFE 13.2 businesses - "Asahi Glass Fluoropolymers Co., Ltd.". 2000-2009 Commencement of PFOA capture and destruction by incineration from 2005. In 2007 the UK Hillhouse site and Amsterdam offices merged & became 14.7 "AGC Chemicals Europe, Ltd." (AGCCE) From 2007 emission to atmosphere reduced by atmospheric scrubber and effluent emission reduced by ion-exchange resin (IER) plant. 2010-2012 From 2011 further IER effluent treatment plant operational. 0.1 PFOA not used after Q1 2012. TOTAL (t) 49.1 Land (t) Water (t) Product (t) - - - 0.1 0.7 0.9 0.5 5.1 6.0 0.6 6.8 7.9 0.9 9.0 10.6 1.4 14.2 17.7 2.6 17.2 18.8 0.2 1.3 1.4 6.2 54.3 63.3 Captured and incinerated (t) - - 2.1 2.9 5.1 Total used (t) - 2.4 16.5 22.0 29.3 46.4 55.4 5.9 178.0 2 AGC Chemicals Europe Ltd. Regulation 61 Notice Submission Table 2: Summary of PFOA mass release after period of PFOA use at Hillhouse Year Notes Q2 2012 October 2023 Residual PFOA emission from Q2 2012 onwards is already accounted for in the mass release total from legacy PFTE production emission and is not included in the Table 1 total. Residual PFOA emissions in effluent are from previous use of PFOA and environmental background levels. Air (t) 0.0 Land (t) Water (t) 0.0 0.2 Product (t) 0.0 Captured and incinerated (t) 0.0 Total used (t) - 3