Document LJ5Rpp6kevNx8MLaMb7MLOjL3

eurofeu broken down to a five year period -- a disposable volume of - 60,000 t of foam concentrate which sums up to 183 Mio , costs for cleaning, handling, hardware replacement, etc. NOT included. The below calculation uses the figures that also the DS has been using, but a more realistic indication for the volumes of foam actually consumed: item disposal cost per tonne price per tonne F3 stocked volume consumption rate per 5a volume consumed in 5a disposable residue disposal cost procurement cost handling/cleaning/hardware replacement Total replacement cost Total replacement cost per annum cost explanatory comment 830 /t see page 63 of the document, 1st paragraph: 0,83 incineration cost per kg AFFF form concenntrate 2,200 /t see page 62 of the document, last paragraph: 2.200 for replacement of AFFF by F3 per tonne 62,500t see page 62 of the document, pre-last paragraph 3.3% basis: 10% of the stock volume is used on fire over lifetime; the typical shelf life is 15 years on average 2,063t 60,438t 50,163,125 132,962,500 numbers are not available, hence left out 183,125,625 36,625,125 Table 1: Estimated cost for completion of transition from AFFF to F3 5 years after the regulation entering into force. We like to point out that the assumed price level for F3-foam agents of 2,200/ton might be correct for F3-foam agents for standard applications such as municipal firefighting. The industrial grade foam agents that would be required for the chemical/petrochemical industry and similar risks are 5,000/ton. System cleaning cost (excluding disposal cost for foam concentrates but including disposal of flushing water) are about 1/Itr of system content (e.g. a 10,0001tr tank requires 10,000 to clean to the proposed threshold level). We also like to make the readers aware that the cost for handling, cleaning and retrofitting can ramp up to 15-20 Mio for a single one of Europe's biggest chemical sites. On average a site operating 2040 storage tanks require 2-5 Mio. for retrofitting. Tankterminal.com lists 1,166 tank terminal facilities in Europe operating in total 30,982 tanks. This is per site on average 27 tanks having a total storage capacity of 215,000 m3. It also needs to be considered that any change to the system of a site also triggers additional testing and calibration costs to ensure full functionality. 2.1.5 Interchangeability of AFFF and F3 The dossier implies that fluorine containing foams can be replaced by fluorine free foams in a comparatively simple process because efficiency of F3 is similar to AFFF. A recent Study published January 20206 concludes after extensive comparative testing of Fluorine containing and Fluorine free foam concentrates "The AR-AFFF performed well against all test fuels included in this assessment (IPA, Heptane, and Gasoline (MILSPEC and E10). The F3s did well against heptane but struggled against some of the scenarios conducted with IPA and gasoline (both MILSPEC and E10), especially when the foam was discharged with a lower foam quality/aspiration. The F3s required between 2-4 times both the rates and the densities of the AR-AFFF to produce similar results against the IPA fires conducted in with the Type II test configuration. During the Type Ill tests, the F3s required between 3-4 times the extinguishment density' of the AR-AFFF for the tests conducted with 6Study by Fire Protection Research Foundation "Evaluation of the fire protection effective rine free firefighting foams", January 2020; 1 Batterymarch Park, Quincy, MA 02169-7417, USA Email: @nfpa.org I Web: nfpa.org/foundation The authors describe the "extinguishment density" as the total amount of foam needed to extinguish a fire of a given size. EUROFEU-PFHxA-Comments-final-20200512.docx May 2020 eurofeu 4 The DS puts PFHxA in such a context with other recognized dangerous PBT substances that the reader must assume that PFHxA has the same hazard characteristics. However, the DS contradicts himself by stating elsewhere that the substances are not comparable. The DSs calculations of releases, human exposure or replacement costs related to a phase-out of the substances are inconclusive, incoherent and incomprehensible, even if applying the figures used by the DS himself. Calculation results have such a huge spread that they become meaningless (20,000%!). Transition costs from AFFF to F3 are intentionally calculated far too low. Existing information on use and comparison of AFFF to F3 in terms of performance were disregarded. Still the DS claims that no information is available. The Dossier does in no way prove a hazard coming from the substances, neither at present or in the future, or the necessity of a restriction. On the contrary: It is in itself a plea for not restricting PFHxA and related substances. The quality of the dossier raises serious concerns about it becoming the basis of a legal act with an impact of the magnitude this restriction may develop. Additionally it would set a precedent for arbitrary restrictions on chemicals. For questions and comments related to this document or the subjects covered herein please contact our secretariat: EUROFEU Secretariat General Koellikerstrage 13 D-97070 Wurzburg Phone: +49 931 35292-0 Fax: +49 931 35292-29 Internet: www.eurofeu.org Or send us an e-mail to: M@eurofeu.org EU ROFEU-PFHxA-Comments-final-20200512.docx 5 May 2020 page 16 of 16