Document 8yMrQRwy9NEV0KaNNDqnYJJm

Fluoropolymers in Chemical and Industrial Processes Chemours as a user perspective August 15th, 2023 Page 1 of 21 Content Summary 3 Introduction: Uses and Functionality of Fluoropolymers in Chemical and 3 Industrial processes Chemours as a downstream user; practical examples of uses of 5 fluoropolymers in the chemical industry Other chemical and industrial processes 8 Alternatives 12 Socio-economic Impact 20 Conclusions 21 Page 2 of 21 Summary The chemical industry is of major importance for economic development and wealth, providing modern products and materials and enabling solutions in virtually all sectors. A wealth generating sector of the economy, and a valuable part of Europe's economic infrastructure, it aims to provide solutions for the achievement of a competitive, low carbon and circular economy in Europe and beyond. There are several risks associated with the chemical processing industry. Because chemicals are inherently hazardous and a number of them are flammable, explosive, toxic and/or corrosive, it's important for processing plants to use materials which can handle the aggressive manufacturing environment. This chapter demonstrates how the use of fluoropolymers is critical in chemical and industrial processes. Their unique properties make them highly resistant to chemical corrosion, and they provide resistance and stability to a number of products, technologies, and applications relevant for the sector. This is critical for the safety & reliability of operations, including but not limited to mitigating fire hazards, explosion hazards, brittle failures, mechanical failures, and release of toxic, noxious, and other hazardous materials. In addition, it is critical for the prevention of contamination of products that are manufactured in the chemicals processing industries, particularly in the food and beverage industry and industries that require ultra-high purity chemicals, such as the pharmaceutical- and semiconductor- industries. This ultimately generates significant socio-economic benefits. In contrast, the proposed risk management objective, i.e., a phase-out of fluoropolymers for uses in the Chemical Processing Industries, 18 months after Entry into Force, would result in disproportionate impacts on society unless the proposed restriction is modified. Against this background, we advocate for a timeunlimited derogation for fluoropolymers used in chemical and industrial processes. Please note that all sources cited are attached to, or referenced in this submission. Introduction: Uses and Functionality of Fluoropolymers in Chemical and Industrial processes The chemical industry comprises of companies that develop, manufacture and/or process industrial, specialty and other chemicals. Central to societies around the globe, this industry converts raw materials, such as oil, natural gas, air, water, metals, and minerals, into industrial and consumer products. To do so, utilizing and applying fluoropolymers, which include fluoroelastomers, is essential. In chemical and industrial processes, fluoropolymers are used in various products and applications, most often in1: Coatings, linings, piping, vessels, and vents Hoses, sealants, gaskets, and tubing for corrosive fluid handling Lining for heat exchangers or incinerators 1 S. Ebnesajjad, P. Khaladhar: Fluoropolymer Applications in the Chemical Processing Industries , Second Edition (2018) Page 3 of 21  Transmissions (membranes / water service) Conveyor belts Wire and cable coatings for sensors, high-frequency data cable, and high mechanical strength cables Filters systems (filter housing, cartridge, woven filters, etc.) Separator in electrolysis processes for chemical production Their use enables a high level of efficiency and safety in various chemical and industrial manufacturing processes, prevents off-gas emissions, and helps to purify chemicals or filter harsh substances from emissions. Moreover, fluoropolymers are crucial for the prevention of leaks or egress of gases and fluids in general. Mitigating corrosion of metal equipment in the Chemicals Processing Industries is critical, particularly in applications involving aggressive chemical fluids. Used as coatings or liners in metal equipment, or as replacement of these metal components, fluoropolymers provide significant benefits for chemical and industrial processes, as they provide a high level of corrosion resistance to industrial corrosive chemicals, including, but not limited to, gasoline, acetone, ammonia, hydrochloric acid, hydrofluoric acid, sulfuric acid, petroleum oils, amyl alcohol, sodium hydroxide, chlorine, dioxane, and sodium hypochlorite. For instance, TefzelTM, a specific fluoropolymer resin, is a proven performer in the chemical and petrochemical processing industries by being resistant to over 450 chemicals whose corrosive characteristics would - without the use of this fluoropolymer resin - generate added costs, maintenance efforts, and would significantly shorten machinery's life cycle (see Annex A). Moreover, since fluoropolymers' continuous use temperature expands over a 250C range (from -100 C to +150 C), they provide a uniquely high level of corrosion protection for equipment and components throughout the process. As a result, machine parts protected with fluoropolymers last longer, as they are protected from the corrosive effects of various chemicals. In addition, the use of fluoropolymers are often critical for the prevention of contamination of products that are manufactured in the chemicals processing industries. Similarly, use of fluoropolymers in lined piping and equipment improves the purity of foods, beverages, and/or pharmaceuticals by eliminating metal ions that would otherwise slough off from metal piping and equipment. At the same time, it reduces the amount of time and chemicals required for process cleaning.2 In addition, the various moving parts of machines tend to generate a large amount of friction when they come in contact with one another. If unchecked, this contact will cause major damage over time. Here, fluoropolymers can significantly reduce friction generated by the sliding motion of machine parts due to their low surface friction, and therefore substantially lengthen the working lifespan of machines. This characteristic helps prevent a major cause of wear and tear commonly sustained by industrial machines. For example, Chemours's products FluoroguardTM3 and KrytoxTM4 provide these properties, which have 2 Consider Using Fluoropolymers in Biological Applications , AIChE (2004) 3 FluorogardTM Polymer additive Technical Information 4 KrytoxTM Performance Lubricants Product information Page 4 of 21 been shown to effect friction and wear.5 Extracted from Plastics Europe Fluoropolymer Group's 2017 "Socio-economic Analysis of the European Fluoropolymer Industry", Tables 2.2 and 2.5 outline key characteristics and benefits of fluoropolymers in chemical and industrial processes, and a number of concrete uses are outlined in detail (Annex B). Chemours as a downstream user; practical examples of uses of fluoropolymers in the chemical industry Chemours depends on the use and performance of fluoropolymers and polymeric perfluoropolyethers (PFPEs) in critical and high hazard processes at many of its manufacturing sites globally. The use of fluoropolymers and polymeric perfluoropolyethers (PFPEs) falls into three primary categories, namely (1) corrosive chemical containment and product purity, (2) process sealing, and (3) lubrication, which are discussed in more detail below. Corrosive Chemical Containment and Product Purity All Chemours manufacturing sites make use of fluoropolymers in lined pipes, pumps, and equipment to safely contain corrosive materials. Hydrofluoric acid (HF) and hydrochloric acid (HCl) are present at some level in many of our process streams (whether as intermediates or waste), and both are extremely corrosive to most metallic construction materials. Fluoropolymers that are used to line pipes, pumps and equipment can extend equipment life because of their inertness to chemical attack and permeation. For example, a carbon steel pipe in acid service may have a life span of one or two months, while a pipelined with fluoropolymer will have a life span of more than 20 years. Example 1: a FEP Lined Tower Chemours uses in one of its installations a spray tower, designed to neutralize process constituents from various process ventilation systems. The tower operates above ambient conditions (45-50 oC). Due to corrosion concerns with the use of metals, the bottom section of this tower is lined with FEP and has successfully been used since 1986 with no chemical degradation or incidents of release due to liner failure. Therefore, there is an obvious economic incentive to extend the service life of manufacturing equipment by using fluoropolymers to safely hold corrosive materials. More than that, however, not using fluoropolymers would make it impossible to safely operate a metallic system with such a short service life, and the risk of loss of containment due to pipe failure with potential exposure of workers would increase. 5 E. Okrent, The Effect of Lubricant Viscosity and Composition on Engine Friction and Bearing Wear (2008) Page 5 of 21 Furthermore, some R&D developmental work and commercially operating sites involve the use of super acids containing fluorides, aqueous HF, and/or aqueous HCl. For this reason, must containment vessels (e.g., high pressure autoclaves, reactors and associated equipment) have to be fluoropolymer lined or made entirely from PFA or PTFE, given their high corrosion resistance against such chemicals which provides the necessary safety. Without the use of fluoropolymers, it would be impossible to safely pursue R&D work with such corrosive and hazardous super acids or HF/HCl. This R&D work, however, is critical to the Chemours Company's future innovation and development of processes and materials, which in turn are an essential building block in the hydrogen economy, vehicle electrification, chips manufacturing, and communications infrastructure, which all directly contribute to the European Green Deal, Fit-For-55, REpowerEU, the Chips Act and other ambitious future-oriented EU policy programs. Example 2: a PVDF lined tower This lined tower is an emission reduction unit. The liner is a dual laminate PVDF lined fiber reinforced polymer. The unit processes HF, HCl and iodine and operates at ~ 50 oC. The PVDF liner has been in service since 2004 with proper inspection and maintenance. Alternate replacements for this material as a liner would be platinum-rhodium- or platinumiridium liners on a metal substrate. Example 3: an ETFE lined tank This tank is lined with dual laminate ETFE lined fiber reinforced polymer. This tank serves as storage for acid vents (HCl and HF) from process and relief valves in the event of an emergency, to safely remove acid gas. It operates under ambient temperature conditions and has been in service for 30 years with proper inspection and maintenance. Installed in 1992, it continuously operated for 16 years with no recorded issues before it needed reconditioning in 2008. ETFE lining weld leaks/stains were repaired, passed all subsequent inspections after repair, and was put back on service. In 2020, the vessel was reconditioned again similar to 2008 and successfully operated ever since with no recorded issues. Process Sealing All Chemours manufacturing sites require gasketing to seal pipe and vessel flanges. Fluoropolymers including Fluoroelastomers are commonly used as gasket materials due to their inertness and ability to conform to flange surfaces, thereby creating a reliable seal. This is especially important when controlling fugitive emission is critical to the functionality of the gasket and the safety of workers6 7 8 9 10 11. 6 D. W. Reeves , J.W. Ross, M. Wasielewski: Assessing fugitive emissions performance in valves and packing Valve world (2005 7 Parker Prdifa. PTFE Seal Design Guide 8 Fluid Sealing Association/European Sealing Association: COMPRESSION PACKING Technical Manual 4th Edition 9 United States Environmental Protection Agency: Control Techniques for Fugitive VOC Emissions from Chemical Process Facilities (Handbook, 1994) 10 A Riedl: Emission measurements of industrial valves according to TA Luft and EN ISO 15848-1, Valve World (2007) 11 United States Environmental Protection Agency: Leak Detection and Repair-A Best Practices Guide (2007) Page 6 of 21 Lubrication Many Chemours plant sites use polymeric perfluoropolyethers (PFPE) lubricants in classical bearing applications and, even more important, in pump mechanical seals. In these seals, petroleum-based lubricants would react with process fluids resulting in equipment failure and a loss of process containment. These are typically pumps involved in highly reactive material processing where equipment failure must be avoided for safety reasons, and no alternative lubricants provide the same performance or lubricant lifetime. These types of uses are applicable to many different chemical processes in the chemical industry. For representative Codes and Industry Best Practice Documents, we refer to: Eurochlor GEST 06/318 - Valve Requirements and Design for Use on Liquid Chlorine where PTFE is mandatory for gaskets and packing. Please see: https://www.eurochlor.org/technical-safety/technical-documentation/documentsearch/ Fluoropolymers are more commonly included in Industry Recommended Practice documents such as the Chlorine Institutes Pamphlet 6 on Pipe Design (please see: https://bookstore.chlorineinstitute.org/mm5/merchant.mvc?Session_ID=bd14e92 cca395e12244776f1aa30e171&), Pamphlet 5 on Gasket Selection, and Pamphlet 98 on Hydrochloric Acid. In most cases, the material chosen is based on corrosion tables and economic considerations if an appropriate material can be found. For example, Hastelloy alloy B-2 has fair resistance to aqueous HCL, however it is 510 times the cost, and much less available, than functionally equivalent FP lined equipment. Other examples of industry practice are: o "Materials of Construction Guideline for Hydrofluoric Acid (HF) Solution" document published by the Hydrogen Fluoride Industry Practices Institute (HFIPI, http://www.hfipi.com/SitePages/Recommended%20Practices.aspx), a subsidiary of the American Chemistry Council. For applications involving aqueous HF, which is not only corrosive but a highly toxic material (HTM), fluoropolymers such as PTFE, PFA, FEP, ECTFE, etc. are specifically recommended for use as loose or bonded liners in vessels, piping systems, pumps, valves (including packing), and hoses. Perfluoroelastomers, e.g., Kalrez (FFKM per ASTM D1418), and fluoroelastomers, e.g, VitonTM (FKM per ASTM D1418) are recommended for use as O-ring seals in instrumentation and valves. o NACE International (https://nace.org/home) Publication 5A171-2007-SG, "Materials for Storing and Handling Commercial Grades of Aqueous Hydrofluoric Acid and Anhydrous Hydrogen Fluoride"12 o Eurofluor publication Recommendation on materials of construction for Anhydrous Hydrogen Fluoride and Hydrofluoric Acid solutions (Materials, 12 Materials for Storing and Handling Commercial Grades of Aqueous Hydrofluoric Acid and Anhydrous Hydrogen Fluoride, NACE 5A171, 2007 Edition Page 7 of 21 compatibility, case studies) 13. Other chemical and industrial processes Hydrogen Fluoride Production Hydrogen fluoride (HF), better known as hydrofluoric acid when dissolved in water, is a critical raw material for a wide range of commercial and industrial products, such as electronics, the metallurgical industry, petroleum, pharmaceuticals, crop protection, fluorochemicals, detergents, crystal glass, ceramics, and a range of consumer products. Given their wide-range importance, in 2015, European HF production reached 232,000 tons with a value of around EUR 270 million. Around 300 people are directly employed at nine HF production sites in four European countries. It is estimated that the total number of jobs related to the fluorine industry, including downstream products, amounts to more than 50,000.14 HF is produced by reacting fluorspar, a naturally occurring mineral substance, with sulphuric acid, and it is considered a highly corrosive acid. As such, HF must be handled with extreme caution. Therefore, safety is a priority for both producers and users of HF. Due to their chemical resistance, fluoropolymers including fluoroelastomers are one of the few recommended construction materials for aqueous hydrofluoric acid solutions .15 16 The safe production and handling of HF is not possible without utilizing fluoropolymers including fluoroelastomers. As such, a ban of the use of fluoropolymers for HF production would have a huge impact on the respective downstream industries and its products, which are an essential part of modern societies. A second, anti-corrosion related benefit of fluoropolymer lined equipment is product purity. Corrosion, by its very nature, transfers metal from equipment to process fluids, and the metal contamination remains with that fluid until it is removed (if that is possible). Reducing metal contamination and creating ultra-high purity products are especially important in the pharmaceutical and semi-conductor industries, where trace metal contaminants are not tolerable, even at the ppb and sometime ppt levels. As such, fluoropolymer lined equipment is absolutely essential in these sectors to guarantee the product purity required. Corrosion products can also affect yield, catalyst selectivity and deactivation. Oxygen Production and Handling Oxygen is produced from air by low-temperature rectification (approx. -180 C), by a 13 Eurofluor: Recommendation on materials of construction for Anhydrous Hydrogen Fluoride and Hydrofluoric Acid solutions (Materials, compatibility, case studies) (not dated) 14 Eurofluor brochure: A snapshot of the fluorine industry available in several languages 15 Eurofluor, Recommendation on materials of construction for Anhydrous Hydrogen Fluoride and Hydrofluoric Acid solutions 16 Materials for Storing and Handling Commercial Grades of Aqueous Hydrofluoric Acid and Anhydrous Hydrogen Fluoride, NACE 5A171, 2007 Edition Page 8 of 21 specific process of adsorption (the adhesion of molecules or gases) or via a specific membrane process. In addition to being used as breathing gas in medicine, aerospace and space, oxygen is mainly required for combustion processes and as an oxidizing agent. In combustion processes, the use of oxygen instead of air leads to higher temperatures. Oxygen is mainly used in numerous key chemical processes, such as: Olefin oxidation (ethylene oxide production) Partial oxidation of coal and heavy oil for production of hydrogen (see input on Alternative Energy earlier in this document) and synthesis gas Production of: o sulfuric acid o nitric acid o acetylene o acetaldehyde o acetic acid o vinyl acetate o chlorine Oxyacetylene technology in welding, cutting, flame blasting, with thermal cutting Food industry Melting in the glass industry Treatment of drinking and waste water Ozone generation Fluoropolymers including fluoroelastomers are used as critical parts, lubricants and filling liquids for vacuum pumps in oxygen management systems to enable the safe use and operation of such systems. As the Code of Practice M 034-1 "List of nonmetallic materials compatible with oxygen"17 by the German Federal Institute for Materials Research and Testing (Bundesanstalt fr Materialforschung und -prfung, short: BAM) and the Code of Practice M 034e ,,Oxygen" (DGUV Information 213-074) of the German Social Accident Insurance Institution for the raw materials and chemical industry (Berufsgenossenschaft Rohstoffe und chemische Industrie, short: BG RCI) demonstrate in a detailed overview: without fluoropolymers including fluoroelastomers, and perfluoropolyethers (PFPE), safe production, handling and use of oxygen - a key substance for healthcare and industry - will likely not be possible. 18 Chlor-Alkali Production Chlor-alkali production is an essential building block for the manufacture of numerous products that we rely on every day. Across Europe, millions of jobs are dependent on the availability of competitively priced chlor-alkali supplies. This process produces caustic soda and chlorine, which are critical base chemicals for industry. Moreover, in many parts of the world, chlorine is critical in the helping to provide clean drinking water.19 The other product of this process is caustic soda, which is used in the pulp and paper industry, in 17 BG RCI, Merkblatt M 034-1, Liste der nichtmetallischen Materialien fr den Einsatz in Sauerstoff zu Merkblatt M 034 "Sauerstoff" (DGUV Information 213-073) (2020 edition) 18 DGUV Information 213-073 Sauerstoff (Merkblatt M 034 der Reihe "Gefahrstoffe") DGUV Information 213-073 Sauerstoff (Merkblatt M 034 der Reihe "Gefahrstoffe") 19 SDG target 6.1 Page 9 of 21 the production of alumina, soap and detergents, and in water treatment. In the context of chlor-alkali production, fluoropolymer ion exchange membranes are a technology that has replaced the use of mercury and asbestos and accounts for about 86% of the volume produced. This shift from mercury or asbestos diaphragm cell towards fluoropolymer-based membrane technology has mostly been due to environmental and safety concerns. Mercury is a toxic and bio-accumulative pollutant. Asbestos can be suspended in the air, causing lung damage, amongst others. In contrast, fluoropolymer ion exchange membranes are neither bio-accumulative, toxic nor lung damaging. Fluoropolymers are the only alternative to restrictions on mercury and asbestos. In addition, when accounting for an adequate operating environment, membrane chloralkali technology based on specialized fluoropolymer ionomers offer unparalleled energy efficiency and superior voltage performance, which in turn result in significant cost reductions and a reduced environmental footprint (see Annex D) Controlled Flue Gas Cooling, Heat Exchangers, Heat Recovery Systems Flue gas cooling in several large and small industrial settings (e.g. power plants, wasteto-energy and biomass plants, steel production, petrochemical industry, chemical industry, and overall air emission control) is needed to fulfill strict air regulations, lower emissions and to recover more energy. Most heat exchangers (technology used for flue gas cooling) currently in operation in EU countries are lined with fluoropolymers to prevent fouling and corrosion, and to prolong equipment lifetime and overall efficiency. The benefits of fluoropolymers in flue gas cooling technology for heat recovery and heat displacement have been widely reported20 21 22 23 24 A case study in Plastics Europe Fluoropolymer Product Group's "Socio-economic Analysis of the European Fluoropolymer Industry" (2017, Annex B) demonstrates how a Combined Heat and Power (CHP) plant in Poland was able to generate significant savings utilizing fluoropolymer lined heat exchangers, partly due to reduced CO2 emissions: "For CHP installations alone, heat exchanger technology enabled by fluoropolymers could contribute to energy savings worth around 8bn and CO2 emission reductions worth around 0.5bn at market prices or 3bn considering the societal cost of CO2." The study also shows that when fluoropolymers are used, heat exchangers are "significantly less expensive and more durable" in the event of incidents involving corrosive flue gases. 20 https://ieaghg.org/docs/General_Docs/PCCC3_PDF/4_PCCC3_4A_Dittmann.pdf 21 P. Roberts C. J. Luther ElsI; Ol. BosyiII; G. Kornelius: The economics of flue gas cooling technology for coal-fired power stations with flue gas desulfurization, Clean Air Journal (2018) 22 Y. Xiong H.Tan, Y. Wang, W. Xu, H.MikulciN. Dui: Pilot-scale study on water and latent heat recovery from flue gas using fluorine plastic heat exchangers, Journal of Cleaner Production (2017) 23 S. Espatolero, C. Corts, L. M. Romeo: Optimization of boiler cold-end and integration with the steam cycle in supercritical units, Applied Energy (2010) 24 J. Buchta; A. Oziemski: Flue Gas Heat Recovery in High Efficient Coal-fired Power Plant, 2019 20th International Scientific Conference on Electric Power Engineering (EPE) Page 10 of 21 Similarly, B.F. Shelley (2014) 25 highlights the benefits of utilizing PTFE in heat exchangers and provides details on the size of such industrial-size units: "The first PTFE heat exchanger was installed in 1985 in a coal-fired power plant in Schwandorf, Germany, and that unit reduced SO2 emissions by 90 percent. In 1991, after 200,000 hours of successful experience with that unit, further units were installed at the same plant. Other units were installed a few years later in several other power plants in Germany and the Czech Republic. An advantage of PTFE tube is that they are better able to resist the corrosive effects of sulfur oxides, which form sulfuric acid when condensed. In the past, high nickel alloy tubes have been used in such units but had limited lifespans of up to only two years, due to the high temperatures and acid concentrations encountered in flue gas systems. In Europe, PTFE tubes have been shown to resist corrosion and have a lifetime at least five times that of high alloy tubes. PTFE tubes have nonstick surface properties, and as a result, they don't allow fly ash and dust from flue gas to build up. Units are usually equipped with water spray nozzles that are intended to wash the fly ash off the tubes. With metal tubes this has proven to be very difficult and the tubes typically become fouled, reducing heat transfer and accelerating corrosion because the tubes run hotter. With PTFE, water sprays are very effective at preventing fly ash buildup and at maintaining acceptable heat transfer rates. Better heat transfer helps maintain the increase in efficiency of the power plant and the reduction in sulfur dioxide emissions. Typical heat exchanger modules used in power plants have a surface area of approximately 1,750 m2 and are approximately 2m by 13.5m overall length with 1,800 U-shaped tubes installed bundle. A typical power plant of 600-800 MW may have 5 to 10 modules installed." In such installations, fluoroelastomers are utilized as elastomeric flue duct expansion joints as they provide a number of advantages compared with metal joints, including light weight, ease of installation, superior abrasion resistance, and much higher design flexibility in terms of accommodating ductwork movement and offset. Any synthetic elastomer can be used in the manufacturing of expansion joints, but they differ drastically in their performance characteristics. In this application, resistance to heat and various classes of chemicals and fluids is important. For example, resistance to sulfuric acid at elevated temperature is critical. The following graphic provides an overview of how different elastomers perform in such an environment, ultimately highlighting that fluoroelastomers (FKM) show the best performance while most elastomers do not display acid resistance at elevated temperatures (see Annex E): 25 B.F. Shelley (2014), Non-stick heat transfer: PTFE approved for plant exhaust. Mechanical Engineering - CIME, 136 (2014), 18-19 Page 11 of 21 Alternatives There is no blanket replacement for fluoropolymers including fluoroelastomers in the chemical processing industry. Material selection is founded on the following principles26: 26C.P. Dillon: Corrosion control in the chemical process industries., Materials Technology Institute of the Chemical Process Industries, MIT Publication Nr. 45, ISBN 1-877914-58-4 (1994) Page 12 of 21 1) Safety & reliability, including but not limited to fire hazards, explosion hazards, brittle failures, mechanical failures, and release of toxic, noxious, and other hazardous materials. 2) Cost, included but not limited to the initial cost of fabrication and installation, the corrosion resistance, the amenability to corrosion control, and service life of the part. 3) Environmental Aspect, concerning air and effluent industrial water streams. 4) Energy Considerations, such as fuel, cooling water, steam losses, etc. at plant locations, raw material transportation. 5) Material Conservation, due to the finite nature of resources, elements in critical supply should be used sparingly unless they contribute to the real service life of the part. Halide environments are some of the most corrosive environments to metals. Due to the inert properties of fluoropolymers and high temperature resistance (~260C, grade dependent), fluoropolymers allow for safe and continuous use of lined equipment in halide service when properly installed, inspected, and maintained. Halide environments include chlorides, fluorides, iodides and bromides. In the anhydrous form, most materials of construction are acceptable for use. For example, anhydrous HF and anhydrous HCl can be stored in carbon steel vessels with minimal concern for corrosion so long as strict moisture control is in place. However, in the aqueous form is where the extreme corrosion resistance is needed. Depending on the specific halide in aqueous form, the corrosive effects are different for different base materials. Following are examples of the performance of metals in various environments: In Chloride environments, specifically hydrochloric acid (HCl) environments27 Carbon steel and low alloy steels are susceptible to accelerated corrosion when exposed to any concentration of HCl below 6.0 pH. Common damage mechanisms for carbon steel include uniform thinning, localized corrosion or under deposit attack. General corrosion rates of carbon steel in 36% HCl at ambient temperatures are ~11,000 mpy (11 inches/year or 280 mm/year)28 Austenitic stainless steels are susceptible to pitting corrosion, crevice corrosion, and chloride stress corrosion cracking. General corrosion rates of austenitic stainless steels in any concentration of HCl at any temperature are >40mpy (>0.04 inches/ year; >1 mm/year)28 Cu-Ni alloys and some other high nickel alloys have good resistance to dilute HCl, but the presence of oxidizing agents will increase corrosion rates in some metals. 27 ASM Handbook, Volume 13C: Corrosion: Environments and Industries, S.D. Cramer, B.S. Covino, Jr., editors (2006) 28 C.P. Dillon, I Warren: Materials selector for hazardous chemicals : vol 3: hydrochloric acid, hydrogen chloride and chlorine, Materials Technology Institute, St. Louis, MO (1999) Page 13 of 21  Some reactive metals, such as Ti, have good resistance to dilute HCl in oxidizing conditions, but do not perform well in anhydrous HCl. Zr is not suitable in oxidizing halide environments and may experience pitting attack and chloride stress corrosion cracking is some environments29. In Fluoride environments, specifically hydrofluoric acid (HF) environments Carbon steel is susceptible to accelerated corrosion rates in aqueous HF depending on the concentration. At room temperature, general corrosion rates can vary from 2-120 mpy (0.002-0.120 inches/year) at concentrations between 5869.9% aq. HF, corrosion rates typically increase as temperature increases30 Corrosion Product Figure 1: Carbon Steel flange with corrosion by aq. HF Austenitic stainless steels can be susceptible to pitting, crevice corrosion and intergranular stress cracking in fluoride environments Cu-Ni alloys and Ni-Cu alloys are suitable for use in HF service at any concentration, up to the atmospheric boiling point of HF (see Figure 2 chart regions "D") in de-aerated and low velocity conditions, Ni-Cr-Mo alloys are acceptable for use at low temperatures and low concentration limitations (see Figure 2 chart region "B") Reactive metals, such as Ti and Zr, are not suitable for use in fluoride environments even at ppm levels of fluorides due to potential hydride/ hydrogen embrittlement. Hydrogen embrittlement can result in catastrophic failure, and it cannot be easily inspected for/ monitored31. The photos below are examples of the degree of carbon steel corrosion that can occur in the presence of aqueous HF. 29 G.D. Smith: Corrosion of Precious Metals and Alloys (ASM Handbook, 2005) 30 Nickel Institute: Alloy selection for service in hydrogen fluoride, hydrofluoric acid and fluorine, Second edition (2019) 31 G.D. Smith: Corrosion of Precious Metals and Alloys (ASM Handbook, 2005) Page 14 of 21 Figure 2: Metals and alloys for HF service: regions where observed corrosion rates are 0.51 mm/y (20 mpy) or less (Iso-Corrosion Chart for Material Selection in HF from Nickel Institute: Alloy selection for service in hydrogen fluoride, hydrofluoric acid and fluorine, Second edition (2019); see reference 30) Page 15 of 21 The iso-corrosion chart depicts general corrosion rates of various metals equal to or less than 20mpy (0.02 inches/ year or 0.5mm/year) in HF service. Alloying elements, like Nb and Ti, are readily attacked by HF and thus increase the corrosion rate of metals that they are alloyed in, such as Inconel 625 (UNS N06625). NACE International Publication 5A17132 Table 1 provides guidance on commonly used materials of construction for storage and handling for commercial grades of aqueous HF and anhydrous HF. In this document, equipment such as stationary tanks, tank trucks, 32 Materials for Storing and Handling Commercial Grades of Aqueous Hydrofluoric Acid and Anhydrous Hydrogen Fluoride., NACE International Publication 5A171. Provided with permission from the Association of Materials Protection and Performance (AMPP), this is a reproduction of Table 1 and Figure 5 from 5A171, "Materials for storing and Handling Commercial Grades of Aqueous Hydrofluoric Acid and Anhydrous Hydrogen Fluoride" (December 2007). Please see entire document for full context. Page 16 of 21 rail tank cars, piping, pumps, valves, gaskets, and hosing all list fluoroplastic lined steel or fluoroplastic as one of the commonly used materials of construction for 70% AqHF and 49% AqHF. Gaskets and hoses only list fluoroplastic/ fluoroplastic lined materials for both anhydrous and aqueous HF conditions. In 49% AqHF, fluoroplastic lined steel is the only material of construction that is listed. NACE International Publication 5A171 also includes a diagram, Figure 5 that depicts the combination of service temperatures and HF acid concentration for which specific plastics Page 17 of 21 and elastomers may be used in HF service. PTFE and FEP both show good performance in HF at all concentrations at temperatures up to 150C and 130C, respectively. ETFE shows good performance above the atmospheric boiling point of HF at all concentrations. Non-fluorinated polymers like PP, HDPE, and PVC can be found in aq HF service at temperatures below the atmospheric boiling point of HF and temperatures below 95C, 60C, and 20C respectively. 2In Iodide environments, specifically hydroiodic acid (HI) environments: Carbon steel and alloy steels readily corrode in iodine service Austenitic stainless steels are susceptible to pitting, crevice corrosion, and intergranular stress cracking in iodide environments. Nickel alloys are generally resistant to iodide containing environments with limitations. o In an internal Chemours study, the corrosion rates of several Ni-Cr-Mo alloys in reclaimed iodine with >500 ppm of moisture at 180C were determined to be greater than 50 mpy (1.25 mm/y). o In a NACE publication on process industry corrosion33 which referenced corrosion of iodine in a Chapter authored by E.L.Liening on "Materials of Construction for the Halogens", austenitic stainless steel corrosion rates increased from 0.15-0.33mpy to 102-160mpy as the relative humidity increased from 0% to 70% at 25C over 31 days. Alloy 825 corrosion rates increased from 0.01mpy to 42mpy under the same conditions and pure nickel corrosion rates increased from 0.4mpy to 85mpy. Alloy C-276 showed the most manageable increase at 0.01mpy to 1.5mpy at 25C over 31 days. Typically, corrosion rates increase as temperature increases. At 120C, the corrosion rate of C-276 increased to 18.3 mpy in the liquid portion of the autoclave after 49 days. Reactive metals such as Ti and Ti alloys are susceptible to pitting corrosion in iodine solutions, Zr and Zr alloys are generally resistant to iodine, but are still susceptible to hydrogen embrittlement34 In Bromide environments, specifically hydrobromic acid (HBr) environments: Austenitic stainless steels are susceptible to pitting, crevice corrosion, and intergranular stress cracking in bromide environments Nickel alloys are generally resistant to bromine containing environments with limitations. 33 Process Industries Corrosion-The Theory and Practice, National Association of Corrosion Engineers/ The Association for Materials Protection and Performance (1986) 34 Chapman et al, Hydrogen in Ti and Zr alloys: industrial perspective, failure modes and mechanistic understanding (2017) Page 18 of 21  Reactive metals such as Ti and Ti alloys are susceptible to pitting corrosion in bromine solutions as well as susceptibility to hydrogen embrittlement35 In general, noble (precious) metals, like silver and platinum can be used in halide service, Some noble metal alloy combinations can be used in various services as well.36 37 See example 2 for service life information of a fluoropolymer lined tower that was used in place of platinum-rhodium- or platinum-iridium liners. Reactive metals, like Ti, Zr, Ta, and Nb, are approved as structural materials, but they are typically applied as thin linings due to cost considerations. Galvanic corrosion is a primary concern when working with reactive metals due to the potential for hydrogen formation which can subsequently lead to hydrogen embrittlement of the material38. In Oxygen environments Oxygen is a highly reactive nonmetallic element that reacts with many other elements to form oxides through oxidation reactions. Oxygen comprises 20.9% of Earth's atmosphere and exists primarily in the form of O2 molecules. The highly reactive nature of oxygen requires that special care must be taken when using it in oxygen enriched environments in order to ensure the safety of personnel and equipment. Materials that do not burn in normal atmosphere can burn violently, sometimes to the point of explosion, in oxygen. It is known39 40 that with the exception of the noble metals and the metal oxides of the highest oxidation state, all substances are combustible in oxygen, especially in compressed oxygen. Several types of plastics become flammable at O2 concentrations at or slightly above ambient concentrations (21-30 %).39 Therefore, the use of oxygen, or oxygen-enriched medium, requires special safety precautions. The Berufsgenossenschaft Rohstoffe und chemische Industrie (BG RCI, Germany) maintains a list of non metal products that are compatible in Oxygen enriched environments.41 It is noted that depending on the conditions of use (pressurized/non pressurized, temperature etc), fluoropolymers, including elastomers, and PFPE are often the only products of choice. 35 C.P. Dillon: Corrosion control in the chemical process industries., Materials Technology Institute of the Chemical Process Industries, MIT Publication Nr. 45, ISBN 1-877914-58-4 (1994) 36 C.P. Dillon: Corrosion control in the chemical process industries., Materials Technology Institute of the Chemical Process Industries, MIT Publication Nr. 45, ISBN 1-877914-58-4 (1994) 37 S. Cramer et al, Corrosion: materials Volume 13B (2005), ASM Handbook 38 C.P. Dillon: Corrosion control in the chemical process industries., Materials Technology Institute of the Chemical Process Industries, MIT Publication Nr. 45, ISBN 1-877914-58-4 (1994) 39 NASA, An Elementary Overview of the Selection of Materials for Service in OxygenEnriched Environments, ASTM G04 Symposium 2012 40 DGUV Information 213-073 Sauerstoff (Merkblatt M 034 der Reihe "Gefahrstoffe") DGUV Information 213-073 Sauerstoff (Merkblatt M 034 der Reihe "Gefahrstoffe") 41 BG RCI, Merkblatt M 034-1, Liste der nichtmetallischen Materialien fr den Einsatz in Sauerstoff zu Merkblatt M 034 "Sauerstoff" (DGUV Information 213-073) (2020 edition) Page 19 of 21 Socio-Economic Impact Given fluoropolymers' significant added value for chemical and industrial processing, an estimated 11,000 tons of fluoropolymers were sold into this sector in 2020 in the European Economic Area (EEA), making it the second largest sector for use of fluoropolymers just behind transportation (15,000 tons).42 This enormous volume of sales further underlines the importance of the use of fluoropolymers for chemical and industrial processes and shows that they cannot be replaced in the vast majority of applications in this sector. As demonstrated before, the use of fluoropolymers in chemical and industrial processes significantly increases the lifetime of components while reducing maintenance costs, waste, and use of materials required to renew corroded components. As such, the use of fluoropolymers in chemical and industrial processes is a key component to ensure processes in this sector remain internationally competitive and to maintain or reduce total life cycle costs (see Annex B and Annex C). In particular, corrosion is a significant cost factor in chemical and industrial processes. In a 2016 study43, commissioned by National Association of Corrosion Engineers, the global cost of corrosion is estimated at 2.5 trillion US$, equivalent to 3.4 % of the that the global Gross Domestic Product (GDP) (Baseline: 2013) These costs typically do not include individual safety and environmental consequences. Applying these numbers to the EU27 chemical and power sector in 2013, this would imply total costs of corrosion of about 15bn for just these two sectors. In a similar vein, fluoropolymers help to significantly reduce maintenance costs, which typically account for about 5% of fixed capital costs in the chemical industry. Yearly capital spending in the EU chemical industry has been around 20bn per year over the last 20 years, and it has been steadily increasing over the past years reaching 27bn in 2021.44 Hence, current maintenance costs are estimated in the region of 1bn. In the absence of specific data, assuming conservatively that about 10% of the European chemical industry use fluoropolymer applications that helped to achieve savings as the chemicals manufacturer mentioned above, this suggests total savings to the sector as a whole could be in the order of up to 100m annually (Annex B). Given the unique performance of fluoropolymers in heat exchangers, a ban of this technology will likely lead to significantly increasing costs for end users due to corrosion and wear as well as increasing CO2 emissions as any alternative technology is less efficient and needs to be replaced more frequently. 42 "Update of market data for the socioeconomic analysis (SEA) of the European fluoropolymer industry" (2021 data) published in May 2022 by Plastics Europe - Fluoropolymer Product Group https://fluoropolymers.plasticseurope.org/application/files/1216/5485/3500/Fluoropolymers_Market_Data_ Update_-_Final_report_-_May_2022.pdf 43 International Measures of Prevention, Application and Economics of Corrosion Technology (Study), National Association of Corrosion Engineers (2016) 44https://cefic.org/a-pillar-of-the-european-economy/facts-and-figures-of-the-european-chemicalindustry/capital-ri-spending/ Page 20 of 21 Conclusion As demonstrated in this paper, the use of fluoropolymers in chemical and industrial processes significantly enhance performance, safety, efficiency, and longevity of process and manufacturing equipment, technologies, and applications. As the examples of uses demonstrate, reliable, high performance, high quality fluoropolymers including fluoroelastomers, and PFPE lubricants used in chemical and industrial processes possess significant properties; including a low coefficient of friction ensuring ease of operation in moving parts and increasing production output, anti-stick properties reducing residue buildup and increasing product quality, and the ability to prevent corrosion, extending the lifetime of crucial equipment responsible for the production of key substances for society. This leads to significant reductions of operating costs, enhances safety of chemical and industrial processes and promotes the competitiveness of the European chemicals and industrial sectors. The use of fluoropolymers in chemical and industrial processes also directly as well as indirectly support the EU in achieving the goals of the EU Green Deal and other ambitious policy programs, as they help to increase (energy) efficiency and reduce CO2 emissions. Moreover, there are no viable alternatives that could replace fluoropolymers in this sector without significantly affecting safety, performance or efficiency standards, or even product quality. The proposed risk management objective, i.e. a phase-out of fluoropolymers for uses in the Chemical Processing Industries, 18 months after Entry into Force, would result in disproportionate impacts on society unless the proposed restriction is modified. Against this background, we advocate for a time-unlimited derogation for fluoropolymers used in chemical and industrial processes. Page 21 of 21