Document LJeZLo0XKzdd51DxkyxZ2O2Mz

Concawe (C EienFoaandocing Study on PFAS applications, potential release, alternatives, and impact of the restriction proposal in refineries and its EG [CT EP EY Data Sources We have combined multiple sources of data to obtain a holistic view of the use of PFAS in _-- industrial equipment in refineries and fuel distributioOnbctives ~ Jl eee [E] awesiomaie ci onmrdtuofcProtwse mein industri stqmernt poet EAS oon balsuppertse,n --fnhh imeni}ews + cInacemnseerunsdmerssFAaS neidnciuri rnentgindoustrfi BSEi fiapso op Rpsomes Latmine thPerreentdsoof PASauoses tahnedgraelsndaunsdteyiment aa i. (oncom Scope of the Study Our analysis covered a scope from crude offloaditnog refining activities and fuel distribution of refined products ---------------- bo ain i[et = :i Se TR | m 1 [1I I > | we:11 sSoonne NasBs so =ol ( Main PFAS Types Companies have identified 10 main types of PFAS in plants, representing ~50 PFAS molecules Identified PEASsubstances sods e INf @ usin = Ea Geos a P[i aeer. oo fNoMeriamettr)es oTM~s i > ee RT -- nana nm CT CT (Gone Overview of PFAS by Equipment Proces s Units Equipment Yes Don't know pProessseibnlcee No resp#onodfants Equipment Yes Don't know pProessseinbclee No Valves and accessories 56% 44% 100% 0% 18 Gasket and sealing 55% 35% 90% 10% 20 Pumps 50% 45% 95% 5% 20 Compressors 45% 55% 100% 0% 20 Agitators 42% 53% 95% 5% 19 Devices for process control 42% 47% 89% 11% 19 Refrigeration system 42% 58% 100% 0% 19 Devices for process analysis 37% 53% 89% 11% 19 Fans 37% 53% 89% 11% 19 Heat exchangers 37% 58% 95% 5% 19 Instruments 37% 58% 95% 5% 19 Motors and couplings 37% 58% 95% 5% 19 Turbines 37% 53% 89% 11% 19 Wastewater treatment 37% 47% 84% 16% 19 Piping 35% 50% 85% 15% 20 Fired heaters 33% 56% 89% 11% 18 Conveyors 32% 53% 84% 16% 19 Cooling tower 32% 47% 79% 21% 19 Storage tanks 32% 63% 95% 5% 19 Transportation Pipeline 32% 53% 84% 16% 19 Vessels 32% 58% 89% 11% Distillation Tower 26% 58% 84% 16% Reactors 26% 63% 89% 11% Process Units Vacuum pumps Membranes Absorption tower 26% 53% 79% 21% 22% 67% 89% 11% 21% 58% 79% 21% Steam ejector 21% 68% 89% 11% Gas purification unit 11% 74% 84% 16% Evaporators 0% 74% 74% 26% Safety Plant Safety Equipment 65% 30% 95% 5% And PPE Protection 47% 42% 89% 11% Power & Cable & Wiring Equipment 37% 53% 89% 11% Utilities Power Supply Equipment 26% 68% 95% 5% Refrigerant 37% 53% 89% 11% Grease 21% 58% 79% 21% Other process unit equipment 17% 50% 67% 33% Other Products Lubricant Other equipment 16% 68% 84% 16% 16% 74% 89% 11% Processing/auxiliary aids 11% 68% 79% 21% Catalyst 0% 63% 63% 37% 4 equipment have over 50% of companies confirming PFAS presence* when for most equipment approx. 50% of companies don't know if PFAS are used *Company having responded "Yes" Concawe # of respondants 19 19 19 19 18 19 19 19 19 20 19 19 19 19 19 18 19 19 19 19 PFAS Properties Overall, PFAS are chosen for their unique combination of resistance to multiple factors required in refineries Distribution of companies by number of sought properties in PFAS Distribution of PFAS properties selected by companies Most companies seek a combination of at least 4 properties related to PFAS Approx. 80% of companies choose PFAS for their chemical, thermal and mechanical strength properties* More than 4 properties 4 properties 70% 20% 4 3 properties 0% 0 2 properties 0% 0 1 property 5% 1 No property 5% 1 14 Chemical resistance Temperature resistance 90% 85% Mechanical strength 75% Non-flammability 70% Electrical resistance (dielectric constant) 65% Water/moisture resistance 50% Low coefficient of friction 50% Low surface tension 35% Repellency properties 35% UV-resistance 30% Other 20% Low vapor pressure (vacuum applications) 15% Share of respondents Share of respondents *The percentage was obtained by computing the ratio of the number of companies expressing interest in property X to the numbe r of companies having responded to the survey Concawe Refinery & Fuel Distribution Requirements Fluoropolymers inparticular show multiple resistance properties which make them the most used tyofpPFAeS. [ Legrefinery Requirements E i m BB) Fuel Disvibuton Requirements OSE > CU EET IIT weet mst en OI min ertint ems + FnSett ------ RT > esoctaopnrescsuree: Hahtent sent: Low fiction coffin: Gtdeadlier shesroive tara (@neave Exposure Risk During Operation Risk of exposure to PFAS released during operation is low due to the containment of PFAS within equipment and the use of mitigation measures such as PPE and HSE management plans PFAS State Exposure to workers in refinery Exposure to the general public Exposure to the environment Solid Liquid PFAS are confined within the equipment, there is a low exposure risk for workers No risk of PFAS exposure to the public if No exposure to fluoropolymers in end-products (e.g., fuel) are contaminated wastewater as they are insoluble in water with PFAS, as they are securely contained and transported using dedicated equipment (e.g., storage tanks, transportation facilities) Personal Protective Equipment (PPE), such No exposure as coveralls, gloves and masks, is employed to safeguard the well-being of workers Risk of exposure to lubricant/grease mainly in contact with refining equipment if released accidently Gaseous Industrial Hygiene best practices + specific measures guided by regional regulations substantially reduce the risk of exposure No exposure Concawe Sources: World Health Organization, Interviews of refining companies and suppliers, Desktop research, Accenture analysis Industrial Hygiene best practices + specific measures guided by regional regulations substantially reduce the risk of exposure PFAS Disposal Phase Refineries have in place measures for end-of-life management of solid, gases and liquids, fostered by local legislation PFAS State Disposal method in refineries Solid Liquid 1. Ordinary Industrial Waste (OIW) i. Metallic: Metal-specific waste bucket ii. Common: Ordinary waste bucket 2. Hazardous Industrial Waste (HIW) i. Equipment-Specific/PFAS-Specific 1. Stored in special drums Gaseous 1. Gas capture with specific treatment End of Life Incineration Recycling Specific treatment Local legislation in place Comments Release of pollutants and ash residues into the atmosphere if X incinerated For lubricants/grease: Incineration Recycling: regeneration to obtain a new lubricant Mandatory maintenance Periodic recycling Organized recovery Regulation for the recycling of lubricants Release of pollutants and ash residues into the atmosphere if incinerated EU F-gas regulation in place Gas treatment is subcontracted to specific companies Concawe Sources: World Health Organization, Interviews of refining companies and suppliers, Desktop research, Accenture analysis Current PFAS Management Plans More than half the companies in our study are adapting their environmental/emission management plans, mostly related to wastewater, to include PFAS" Environment/Emission Management Plan In development No 55% 45% Sources: 1see footnote More than half the companies are working towards launching dedicated PFAS emission control: Majority of plans are around wastewater management Plans are typically driven by local or national regulations Limited PFAS categories are concerned, such as refrigerant and firefighting foams Example of Driving Regulations European regulation on persistent organic pollutants (POPs): Defines measure of around 20 PFAS types in waste When detected above limits, companies are required to dispose waste according to specific conditions Ministerial Order2 to measure PFAS in wastewater in France: Companies have 3 months to submit list of PFAS likely to be or to have been released Mandates 3 consecutive monthly analysis on all aqueous discharge points likely to present significant PFAS presence (e.g., industrial effluents, etc.) Defines measure of concentration of 20 types of PFAS, fluoride levels (by Aqueous Organofluoride) and other substances Recommendations3 for nationwide assessment of contamination and disposal of PFAS-contaminated water and soil Defines measure of concentration of 13 types of PFAS Measure and technique of fluoride levels for aqueous & solid samples and quantification of unknown PFAS Concawe Sources: 1Accenture analysis of questionnaire and Interviews of refining companies, 2Ministerial decree of 20 June 2023 of French Ministry of Ecological Transition, 3German BMUV Federal Ministry's Guidelines for PFAS assessment, Desktop research Focus on Wastewater Plans Refineries are Ee developing wastewater ere management plans spn en SE, & Mature PFAS Treatment Methods Across the mature treatments for PFAS today, incineration is the most usually adopted eT fea) re - oxi limitationsbut iswidely used (85%of capture installations).Afteruse, GACmediacan bereactivated and Vightemperaturetechnology (700C) ---------- tn Sr S RE E _ preme-- Gove PFAS Removal - Wastewater Treatment Water Treatment is a core focus of patents related to PFAS removal1 Innovation in water treatment included removing PFAS by... Potential Newcomer Growing Core ... heating concentrated stream in the presence of calcium oxide to produce calcium fluoride ... sorbing to colloidal gas aphrons ... using metal organic framework (MOF) material with improved adsorption efficiency and adsorption regeneration rate of more than 90% ... adsorbing of PFOS by modified hydrated iron oxide ... using silicon-based mesoporous material ass the adsorbing material ... mixing water with hydroxy radical quencher and irradiating mixture with UV light Outdated Segment Crumbling Core ... electrochemical filtration system that comprises filter body and carbon nanofiber membrane 1Patents related to PFAS removal include "PFAS" near / adjacent to keyword such as remove, recycling, replace, free of, destruct, destroy, substituting, alternative Concawe Sources: Accenture Research based on DerwentInnovationTM(Clarivate,2023) Key Challenges for PFAS Management Plans However, the further adoption of PFAS management plans in refineries faces the following challenges Current state Unclear requirements due to legislative variety Dependence on external capabilities Other Drawbacks Companies' plans are compliant to national and regional regulation Half the companies in our scope are working towards adapting their wastewater management plans Companies cannot invest in a technology and establish a process without confirmation that it will correspond to requirements of license to operate Variety in legislation - including existing local rules and wider regulatory requirements - with potential varying requirements, create a heavier burden for companies to comply Refineries rely on specialized laboratories to conduct detailed PFAS analysis but there are only a few able to measure concentration of PFAS in water/soil Companies also rely on waste contractors to collect and select the most applicable technique to manage PFAS waste Limited options for disposal in end-of-life management including few incineration laboratories available High GHG emissions from high temperature elimination techniques Limited footprint in refineries for installation of additional processes Expenses would increase as PFAS dismantling in equipment at end of life is complex and costly Difficulty to fulfill the diversity of customer requests regarding PFAS presence in products Concawe Sources: Accenture analysis of survey and interviews of Refining players Potential Alternatives to PFAS Some materials have been identified as potential technical alternatives to PFAS based on usecases requirements Focus on identified PFAS alternatives by categories In refineries, most PFAS exist in solid state Solid State Materials in Refinery Equipment Liquid State Gaseous State Polymers Plastics PVC PEEK PPS PSU Elastomers NBR EPDM Metals Other Materials Stainless Steel Glass Nickel Alloys Ceramics Hastelloy Graphite Exotic material (Tantalum, Zirconium, Titanium) Lubricants /Grease Foams Powder Hydrocarbons Graphite Detergents Molybdenum Siloxanes Proteins Refrigerant Ammonia CO2 Hydrocarbons (e.g., Propane/Isobutane/Butane) Concawe Sources: Accenture analysis of survey and interviews of Refining players, Desktop research 58 Potential Substitutes by Equipment The industry has identified some potential substitutes for the following PFAS equipment for certain use cases (1/2) ErecomentTotsiion TrReasEE oes IN TTP ~ LJ = JWaJ weemaailvegrille kes11 sr toress ngse} rs s isse u] ieersh e 0 (ForReiforcdls] Lower spertemperatre rt nd erche resitance Hasta WBharE Heavywightca indo changes in trcturaldog of supports3nd Glstiiog uMtechanaica opty (@neawe Potential Substitutes by Equipment The industry has identified some potential substitutes for the following PFAS equipment for certain use cases (2/2) (ist asshioit has afsnndroansaie i EE sr[o r--ts Ji components] LT olRrFrTerE:teFaP iirn r ES E e-- R . E T-- .. ---- oxy ore `Enameled steel vabves, IT Higher friction coefficientandlowersealing capacities,lowavailt Ea eRSn i hu prs nly EN a Wg IT i mmm mms (@ncave Drawbacks of PFAS Alternatives Aside the material performance, alternative materials have other drawbacks that would make substitution challenging Safety of the future installations As they are not widespread use material, need to demonstrate performance in the long term of existing alternatives. Some known reduced performances: sealing, emission International well established design standards for PFAS-based equipment in the industry will have to be updated, such as: ISO API ASTM Alternatives development Long process of developing substitutes potentially lasting many years, requiring: R&D Testing Approval from certifying bodies and clients Long guarantee of new products required by clients (typically around 10 years) Properties of alternative materials To satisfy the desired properties for equipment the alternative materials to PFAS will also be persistent materials, which will could bring similar challenges to PFAS long life Production asset and supply chain adaptation Production asset debottlenecking: New sites to be built from scratch for some materials and equipment (e.g., high nickel alloy or ceramic piping used in niche applications) Important brownfield modifications on existing installations (e.g., gaskets) Challenges in procuring potential alternative material (e.g., tantalum) PFAS presence in alternative materials/equipment PFAS potentially used to improve performance of alternatives: Some alternatives coated with thin layer of PFAS PFAS surfactants used in the production of non-PFAS polymers identified as theoretical substitutes to PFAS polymers Concawe Sources: Interviews of Refining companies and suppliers, Accenture analysis Impacts by Dimension Refineries indicate higher impacts of the PFAS ban to be on maintenance, followed by production, health and safety Wainenance - Production Heth ste Waste Management Emision/MEanvnraognmmeenntt Thvoertmiin Ii Bs ow Bl verion (@oncawe Impacts on the Value Chain A ban on PFAS today would impact all the energy value chain, risking supply and accessto fuels in CEruurdoepoeffoading Refinery Fuel Disrbution ) Rrikofesrptinctupphotarde m CE p m RRkrohimemutonoffodiang G Seonrey iesingto r Tam al Torrell LI] F kofsoppy rs ptionoors s gmen iy pot ross Unnichrpars | S tegn i (@neawe The results of the industry survey, interviews, advanced analytics and patent analysis lead to the following conclusions for the use of PFAS in Refineries and Fuel Distribution DcesopintedchuaalcdleettnagieelseddicnlvleencttoirnygofintfhoermuasteioonfoFnAtSheinuRseefoifniPnEgAaSnfdroFmulsuDpipsltireisbuatnidoneEqquuiippmmenetntdocumentation, we have 76S mostly fuoropolymers have been detectedin largeshareof refineries' equipment, specially in everpresentcomponents such soins, valves, pumps, tc. TrehlearteeditogmraonwaignigngefefmoritssiniotnhseoifndFuAstSryintowadsevteelwoaptedredicated environmental management plans or PAS, especially iodrenatifsiiegdn,ifpioctanetnthiaalresuobsftiintduutsetsrilaalcekqcuoimpbmiennetdaplrtopeerrntaiteisvnteos ePFAeSfodrodprnooeceesxdsietstaonddates.afeFtoy rmeaqsutiroefmtehnetsuses "iTshterisbuuprpiloyncinhdaunstroyr, wpiotthenttiiael altneorncataipveascdiofteoyrstnhoetvhoalvuemseusffriecqiueinrtemdattouruiptdyattoedtahyefocoamlplthetrvelfiuneincghainnd uel + Gere A P6AS ban refinery and Fuel Distribution equipment would hve severe impacts cross theenergyvalue chain, puting at isk fuel supply in Europe