Document 2qz9E56z8M8m7Ba9XRGz3rjyg

ENTSOE identifies gaps and proposes a differentiated approach to PFAS restriction in electrical equipment Committee Review| 4 September 2023 DRAFT VERSION ENTSOE Mission Statement Who we are ENTSOE, the European Network of Transmission System Operators for Electricity, is the association for the cooperation of the European transmission system operators (TSOs). The 39 member TSOs, representing 35 countries, are responsible for the secure and coordinated operation of Europe's electricity system, the largest interconnected electrical grid in the world. In addition to its core, historical role in technical cooperation, ENTSOE is also the common voice of TSOs. ENTSOE brings together the unique expertise of TSOs for the benefit of European citizens by keeping the lights on, enabling the energy transition, and promoting the completion and optimal functioning of the internal electricity market, including via the fulfilment of the mandates given to ENTSOE based on EU legislation. Our mission ENTSOE and its members, as the European TSO community, fulfil a common mission: Ensuring the security of the interconnected power system in all time frames at panEuropean level and the optimal functioning and development of the European interconnected electricity markets, while enabling the integration of electricity generated from renewable energy sources and of emerging technologies. Our vision ENTSOE plays a central role in enabling Europe to become the first climateneutral continent by 2050 by creating a system that is secure, sustainable and affordable, and that integrates the expected amount of renewable energy, thereby offering an essential contribution to the European Green Deal. This endeavour requires sector integration and close cooperation among all actors. Europe is moving towards a sustainable, digitalised, integrated and electrified energy system with a combination of centralised and distributed resources. ENTSOE acts to ensure that this energy system keeps consumers at its centre and is operated and developed with climate objectives and social welfare in mind. ENTSOE is committed to use its unique expertise and systemwide view - supported by a responsibility to maintain the system's security - to deliver a comprehensive roadmap of how a climateneutral Europe looks. Our values ENTSOE acts in solidarity as a community of TSOs united by a shared responsibility. As the professional association of independent and neutral regulated entities acting under a clear legal mandate, ENTSOE serves the interests of society by optimising social welfare in its dimensions of safety, economy, environment, and performance. ENTSOE is committed to working with the highest technical rigour as well as developing sustainable and innovative responses to prepare for the future and overcoming the challenges of keeping the power system secure in a climateneutral Europe. In all its activities, ENTSOE acts with transparency and in a trustworthy dialogue with legislative and regulatory decision makers and stakeholders. Our contributions ENTSOE supports the cooperation among its members at European and regional levels. Over the past decades, TSOs have undertaken initiatives to increase their cooperation in network planning, operation and market integration, thereby successfully contributing to meeting EU climate and energy targets. To carry out its legally mandated tasks, ENTSOE's key responsibilities include the following: > Development and implementation of standards, network codes, platforms and tools to ensure secure system and market operation as well as integration of renewable energy; > Assessment of the adequacy of the system in different timeframes; > Coordination of the planning and development of infrastructures at the European level (TenYear Network Development Plans, TYNDPs); > Coordination of research, development and innovation activities of TSOs; > Development of platforms to enable the transparent sharing of data with market participants. ENTSOE supports its members in the implementation and monitoring of the agreed common rules. ENTSOE is the common voice of European TSOs and provides expert contributions and a constructive view to energy debates to support policymakers in making informed decisions. Position Draft for review by PCG and RDIC WG 1 I 28 August 2023 entsoQ The European Network of Transmission System Operators for Electricity (ENTSO-E) represents 39 European Transmission System Operators (TSOs) from 35 countries. ENTSO-E is committed to collaborating with European authorities in gradually replacing the usage of per- and polyfluoroalkyl substances (PFAS). ENTSO-E welcomes the European Chemicals Agency's (ECHA) consultation, published on 22 March 2023, which seeks input on the draft restriction of PFAS proposed by Denmark, Germany, the Netherlands, Sweden and Norway. TSOs build and operate the critical power grid infrastructure to supply electricity to European industry and citizens. TSOs make sure to keep the environmental impact of the grid to a minimum and even enhance nature restoration and biodiversity in their corridors. PFAS may pose an environmental and health risk to the neighbouring and more distant populations, including to the workforce in grid operation and should be avoided whenever possible. Working towards PFAS-free grid equipment wherever possible is thus a goal shared by European TSOs and European Authorities. The sophisticated high and extra high voltage equipment used in power grids is built to last 40+ years. It is designed to operate and withstand extraordinary and harsh conditions, such as high pressure, extreme voltage levels and temperatures, and to guarantee the functioning and resilience of the grid at any time. The use of PFAS in solid, liquid, and gaseous components of grid equipment is determined by manufacturers to ensure the highest requirements for its performance and reliability. Due to a lack of data, TSOs do not yet have a comprehensive overview of the use of PFAS in the components of their electrical equipment, nor the PFAS used to manufacture this equipment. Furthermore, there is also insufficient information on possible alternatives to replace them. European TSOs are committed to protecting the public and workforce wherever risks stemming from PFAS are identified. Therefore, ENTSO-E would like to highlight typical use cases for PFAS where information exists and stress the need for use case-specific derogations in the restriction proposal in case no alternatives are available. 1. PFAS in solid components and spare parts of electrical equipment la. Solid components PFASs are used in electrical grid equipment, machinery components and parts, such as insulated nozzles1, sealings, plain bearings, etc. The insulated nozzle is a key component for interrupting fault current (the arc of a short circuit current) inside a circuit breaker. More use cases are further specified in the annex. Once manufactured, solid components with PFAS are usually installed within the machinery. The decommissioning and recycling are carried out respecting all applicable legislation and in close collaboration with manufacturers. ENTSO-E is not aware of any alternative solutions to the PFAS use cases listed. Therefore, an undifferentiated restriction of PFAS for these components of grid equipment would signify a ban on new equipment and spare parts for critical infrastructure within 18 months after its entry into I Insulated nozzles in high-voltage circuit breakers are components designed to provide electrical insulation and prevent the occurrence of unwanted electrical discharges or arcs between different parts of the circuit breaker. the insulated nozzles help control the path of electrical arcs that are generated during the interruption process. ENTSO-E I Rue de Spa, 8 1 1000 Brussels I M@entsoe.eu I www.entsoe.eu I @entso_e Page 3 of 8 Position Draft for review by PCG and RDIC WG 1 I 28 August 2023 entsop force. This would effectively bring all current European grid development projects to a halt and then would endanger the ongoing energy transition, as no manufacturer is currently able to supply PFAS-free equipment. As research and development of alternatives is only starting, ENTSOE urges ECHA to acknowledge this gap in the current proposal and to add a derogation of 13,5 years for solid components in electrical transmission equipment. More specifically, derogation 6. in the restriction proposal for fluoropolymers and perfluoropolyethers should be extended for use in high-voltage electricity transmission equipment by adding the paragraph "6 g high-voltage electricity transmission equipment". lb. Spare parts containing PFAS should be exempted Many PFAS are used in existing electric equipment already installed with a minimum lifetime of 40 years. It is, therefore, necessary that the supply of spare parts is secured throughout this lifetime. The operation, maintenance, repair and extension of existing equipment containing PFAS must be ensured until the end of its lifetime, as PFAS-free spare parts may not work in the originally designed equipment. Otherwise, they would need to be decommissioned prematurely, entailing additional environmental and climate-related burdens, without consideration of circular economy or reparability principles. ENTSO-E reiterates and stresses the importance of being able to use equipment during its lifetime. Therefore, ENTSO-E recommends an unlimited derogation for using spare parts containing PFAS in existing electrical equipment. 2. PFAS in liquids and lubricants Several liquids and lubricants used for the servicing and maintenance of electrical equipment use PFAS (see annex). The properties of mineral oils and lubricants are modified with PFAS additives to fulfil the highest quality demands, e.g., on temperature behaviour and ageing stability They are used, for instance, in circuit breakers, which need to work impeccably when used. ENTSO-E is not aware of any alternative solutions to the use cases listed. An undifferentiated restriction of lubricants and liquids containing PFAS would impede TSOs from carrying out their legal obligation to maintain and service their equipment to ensure proper functionality and efficient operation of the grid, bearing considerable risks regarding grid stability, security of supply and workers' safety. Therefore, ENTSO-E strongly supports the proposal to allow a 13.5year derogation for lubricants used under harsh conditions. On top of that, ENTSO-E recommends a 13.5-year derogation for PFAS in liquids, in particular technical mineral oil with PFAS additives, until alternatives have been developed and proven to satisfy comparable quality standards regarding long-term reliability and performance requirements. 3. PFAS in gases In recent years, TSOs have been using PFAS-containing gases as insulation medium in electrical switchgear to replace SF6, the most potent greenhouse gas, and decarbonise their electric equipment. For the new installations above 145 kV, as well as for specific uses on all voltage levels, TSOs currently have limited possibilities to replace SF6. One key component to do so has been PFAS- ENTSO-E I Rue de Spa, 8 1 1000 Brussels I M@entsoe.eu I www.entsoe.eu I @entso e Page 4 of 8 Position Draft for review by PCG and RDIC WG 1 I 28 August 2023 entsop. containing insulation gases, such as fluoronitrile (C4F7N). The application of the gases in electrical equipment, listed in the annex per use-case, is used in closed cycles and has state-of-the-art leakage detection devices to ensure smooth operation, protect the environment and minimise workforce exposure. As of today, it is not certain whether PFAS-Gas-free solutions above 145kV and for specific uses on all voltage levels will be commercially available in 6,5 years time, also in sufficient quantity for all ranges of TSOs application. This is due to long development, qualification, and standardisation processes. If PFAS in switchgear insulation gases were banned after the derogation period of 6,5 years, it would mean that it would not be possible to decarbonise new electric equipment anymore and that the already ordered and installed equipment supposed to operate with PFAS gases may not be put into operation, maintained, nor extended after the ban date and that existing equipment would have to be put out of order and become a stranded asset. Thus, ENTSO-E urges ECHA and policymakers to take into account the ongoing negotiations on the draft F-Gases Regulation, which foresees to authorise the use of PFAS-gases in high-voltage switchgear until solutions with GWP<10 are available or when their global carbon footprint is as advantageous as the one of solutions with GWP<10. PFAS gases for insulation in new electrical equipment must, therefore, remain authorised without time limitation until solutions with GWP<10 are available, or as long their global carbon footprint remains as advantageous as one of the solutions with GPW<10, in line with article 13 (5) of the draft F-Gases Regulation 2012/0305(COD). The draft F-Gases Regulation already foresees a restriction on PFAS solutions as soon as PFAS-free solutions are available. It must also be ensured that switchgear operating with PFAS gases that have been lawfully put into operation according to the F-Gases Regulation can be refilled for maintenance purposes or extended with the corresponding gas as long as it cannot be maintained or extended with PFASfree gases. Therefore, ENTSO-E recommends an unlimited derogation for PFAS gases used for refilling, maintenance, or extension purposes of switchgear. Replacing existing switchgear operating with PFAS gases before their end-of-life would lead to stranded assets, which would contradict the principles of reparability and circularity. 4. Inherent dilemmas and trade-offs between environmental concerns of PFAS and climate objectives High-voltage equipment using PFAS gases is typically installed in critical network nodes. Their shutdowns would cause the rejection of renewably generated power. This would equal a tremendous amount of wasted resources. The proposal to restrict PFAS should not prevent either the decarbonisation of the electricity grid infrastructure or the grid development, which is essential to properly deliver the energy transition (by allowing the integration of renewable energies and the electrification of uses). The PFAS currently used for the electricity grid infrastructure contributes to its functionality and high efficiency. Complete restrictions of their placing on the market and use should always be considered in light of the availability of alternatives. Decarbonisation and the ENTSO-E I Rue de Spa, 8 1000 Brussels I M@entsoe.eu I www.entsoe.eu I @entso e Page 5 of 8 Position Draft for review by PCG and RDIC WG 1 I 28 August 2023 entso4a protection of human health and the environment are key. ECHA's proposal to restrict PFASs should, therefore, strike a good balance between both objectives. Finally, finding a suitable alternative to PFAS will require a roadmap. To this aim, ENTSO-E would like to stress that its members are fully committed to working together with ECHA, the European Commission and national authorities to contribute to a constructive and robust PFAS restriction regime that stimulates innovation towards PFAS-free equipment. ENTSO-E I Rue de Spa, 8 1 1000 Brussels I M@entsoe.eu I www.entsoe.eu I @entso_e Page 6 of 8 Position Draft for review by PCG and RDIC WG 1 I 28 August 2023 entsoqb Annex: Non-comprehensive overview of the PFAS in components of TSO equipment Disclaimer: As users, TSOs currently do not have a comprehensive overview of the use of PFASs in components of their electrical equipment. TSOs also lack the data to determine the amount of PFAS contained in their equipment, as well as the PFAS used to manufacture this equipment. The following overview shows typical use cases for PFAS for which information is available for the TSOs. Material classification Solid Asset / equipment Gas insulated switchgear (GIS) Transformer / shunt reactor Circuit breaker Instrument transformer HV-Cable Converter Capacitor Bank Offshore Systems Usage Electrical Insulation Wires of coils Contact systems Electronics Printed Circuit Boards Cable insulation Electronic components PFAS PTFE PVDF Interconnectors Gaskets Reactive-power compensation systems Thermally stable and insulating pipes Measurement sensors Mechanical components Grid protection Drives Network control Actuators Communication Power electronics (HVDC Converters, STATCOM) Insulated nozzles Liquide Transformer/ shunt Reactor Electrical insulation Instrument transformer Lubricants Additives PFPE) Converter Capacitor bank Offshore systems Corrosion painting protection Thermally stable paintings Interconnectors Reactive-power compensation systems Gaseous Gas insulated switchgear Electrical insulation (GIS) Fluorinated (C4-FN) Circuit breaker Instrument Transformer Offshore systems (e.g. gas ENTSO-E I Rue de Spa, 8 1 1000 Brussels I M@entsoe.eu I www.entsoe.eu I @entso_e Page 7 of 8 Position Draft for review by PCG and RDIC WG 1 I 28 August 2023 Interconnectors Reactive-power compensation systems entscx4 ENTSO-E I Rue de Spa, 8 1 1000 Brussels I M@entsoe.eu I www.entsoe.eu I @entso_e Page 8 of 8