Document N39NyxDX4dKQ4Rgmmeg67xOR

European Commission DG Environment / European Chemicals Agency (ECHA) The use of PFAS and fluorine-free alternatives in fire-fighting foams Final report Specific contracts No 07.0203/2018/791749/ENV.B.2 and ECHA/2018/561 Wood Environment and Infrastructure Solutions - June 2020 0 Wood Environment & Infrastructure Solutions UK Limited wood. Report for Valentina Bertato Policy Officer European Commission -- Directorate General Environment Directorate B -- Circular Economy and Green Growth Unit B.2 -- Sustainable Chemicals BU 9 B-1049 Brussels Denis Mottet Scientific officer Risk Management Unit II European Chemicals Agency PO Box 400 / Annankatu 18 00121 HELSINKI, Finland Main contributors Liz Nicol, Julius KreiBig, Caspar Corden, Ian Keyte, Rob Whiting, Alex Matulina, David Tyrer, Marc Sollner, Leonie Constantine (Wood); Miriam Schopel, Milos Milunov, Alexandra Polcher (Ramboll); Marlies Warming, Carsten Lassen (COWI) Issued by ulius KreiBig Approved by Caspar Corden Wood Floor 23 25 Canada Square Canary Wharf London E14 5LB United Kingdom Tel 1610 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 r:\projects\41288 ppchem pfass and fluorine -free alternatives\c client related\reports\revised final report i3\41288-41433_pfas fire-fighting foams - revised final report (i3)_20200604.docx Copyright and non-disclosure notice The contents and layout of this report are subject to copyright owned by Wood save to the extent that copyright has been legally assigned by us to another party or is used by Wood under licence. 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Document revisions No. Details 1 Interim report 2 Draft final report (working draft for info) 3 Draft final report 4 Final report 5 Final report (issue 2) 6 Final report (issue 3) Date 19/07/2019 09/12/2019 10/12/2019 17/04/2020 22/05/2020 05/06/2020 June 2020 Doc Ref. 41288 WOD )O( XX RP OP 0009_A_P03 3 Wood Environment & Infrastructure Solutions UK Limited Executive summary Purpose of this report This is the combined final report for two studies on "The use of PFASs and fluorine-free alternatives in firefighting foams" (commissioned by the European Commission) and an "Assessment of alternatives to PFAScontaining fire-fighting foams and the socio-economic impacts of substitution" (commissioned by ECHA), prepared by Wood working in partnership with Ramboll and COWI. The overall aim of the report is to collect information to support the assessment of potential regulatory management options to address the human health and environmental risks associated with the use of PFAS in fire-fighting foams in the EU, as well as providing that information in the format of a REACH Annex XV dossier. Key results Substance identification Three substance classes were considered: PFAS substances, including various carboxylic/sulfonic short- and long chain PFAS and a variety of fluorotelomers were found to be (or to have been) used in fire-fighting foams. These substances differ in chain length and substitution and only a relatively small amount of these substances could be identified by CAS/EC number. Furthermore, other PFAS substances were found, that do not belong to any of the named PFAS-categories; Fluorinated but non-PFAS alternatives. No examples of the use of such substance was identified, and this was confirmed by external experts and stakeholders. These were therefore not considered further; and The identified fluorine-free PFAS-replacements can be grouped into four classes: hydrocarbons, detergents, siloxanes and proteins. For the latter two classes, the information gathered and the number of identified substances is relatively small1. In the case of the siloxanes, the usage of these substances in firefighting foams is still under development. In contrast to this, a variety of hydrocarbons (around 24) and detergents (33) were identified, that are used as a replacement for PFAS-substances. In summary, a large number of highly diverse PFAS substances were found in the context of use in firefighting foams. This could be an indication of extensive replacement chemistry that was initiated due to industry and regulatory concerns about the potential health and environmental impacts of long-chain PFAS and lately also short-chain PFAS. Based on these results, a proposal for a definition is provided in the form of a substance identity description that could be used when consulting further on the impacts of a potential restriction. 1 However a possible issue with the protein-based alternatives is that many of these will not be identified by a standard identifier (e.g. CAS number) and so they may have been underrepresented in the data reviewed on the alternatives. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 4 Wood Environment & Infrastructure Solutions UK Limited Market analysis Based on information provided by Eurofeu and individual fire-fighting foam manufacturers, it has been estimated that at least 14,000 tonnes, but probably as much as around 20,000 tonnes of PFAS-based firefighting foams are sold in the EU annually. The main application is the chemical and petrochemical industry, which employs 59% of these foams. This is followed by municipal fire brigades, marine applications, airports and the military. The foams are used in fire incidents, tests and training exercises, and may also be released via spills. There are likely several tens or potentially hundreds of thousands of facilities using (or at least holding) fire-fighting foams, not counting those only having fire-extinguishers. Prices for PFAS-based firefighting foams are highly variable and range from 2 to 30 per litre for concentrates, with the average estimated at around 3 per litre (though this is subject to significant uncertainty). For fluorine-free firefighting foams, it has been estimated that at least some 7,000 tonnes, but probably as much as around 9,000 tonnes of are sold in the EU annually. A breakdown by chemical group of alternatives (based on the grouping established in the substance identification) is not available, but consultation responses suggest that the main alternatives used are based on hydrocarbon surfactants and detergents. The split by sector of use varies considerably from that of PFAS-based foams, with a much larger share used by municipal fire brigades but a much smaller share in the chemical/petrochemical sectors. Prices for fluorinefree foams range from 0.7 to 10 per litre, with the average estimated around 3 per litre (and again this is subject to significant uncertainty). Emissions and hazards Using a source-flow model and various assumptions, emission estimates have been developed to provide an illustrative assessment to help better understand the material flow and key emission compartments of firefighting foams. The source-flow model has been used to produce emission estimates for 10 unique nonfluorinated substances (hydrocarbons and detergents); as well as two PFAS-based substances. The results indicate that fresh surface water and soil are the key receiving environmental compartments. For nonfluorinated substances, live incidents are the major point of release, while for PFAS live incidents are still significant but the waste phase is the larger life-cycle stage for emissions, primarily from losses associated with releases at WWTPs. A review of hazards for these substances based on PNECs and data on biodegradation and bioaccumulation was also undertaken. This suggests that the two PFAS substances should be considered as being of greater hazard and greater potential environmental risk compared to the non-fluorinated substances. This is due to the PFAS being both non-biodegradable and having relatively low PNECs for water and soil. Some of the alternative substances exhibit low PNECs, however, this needs to be considered in the context of their ready biodegradation. It should be noted however that data availability on the hazards and properties of the alternatives is not always comparable to that of the PFAS substances. Remediation costs and technologies A distinction is made in this report between more costly `remediation' relating to long-term accumulation of contamination, and the less-costly and more short-term `clean-up' of geographically-contained contamination from recent activities. For PFAS-containing foams, remediation is warranted and likely required by regulatory agencies when sensitive receptors (including groundwater) are threatened or already impacted. Typically, a risk-based remediation approach would be implemented by describing the risk to relevant receptors based on analytical data collected from environmental media such as soil, surface water and/or groundwater. Clean-up is driven to a large degree by the flammable liquid itself, the soot, water and "dirt" in general terms that contribute to the fire-fighting water runoff and its potential to affect the environment. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 5 Wood Environment & Infrastructure Solutions UK Limited The most relevant technologies for the remediation of PFAS resulting from fire-fighting foam use are identified and potential costs estimated, although these are highly site-specific and can vary considerably. Commonly used soil remediation technologies include excavation and landfilling or incineration, and soil capping. For coarser-grained soil, soil washing can be an option which is in use at sites featuring the right geological setting. However, soil washing water will require subsequent treatment, and the finer soil fraction needs to be treated in a different fashion (landfilling, incineration). Water treatment (including groundwater, surface water, and storm-/ waste water) typically include adsorption of PFAS compounds from the aqueous matrix onto an adsorbent such as granular activated carbon (GAC), or resins (non-regenerable or regenerable). The typical costs per site can range from around half a million Euros (only soil remediation required, lower estimate) to just over 100 million (sum of soil excavation and incineration, groundwater pump and treat and drinking water reverse osmosis, higher estimates). Analysis of Alternatives Seven fluorine-free fire-fighting foams are selected from a list of more than 30 products marketed as alternatives to PFAS-based fire-fighting foams. These are considered to be representative of the products on the market for the most critical uses of fire-fighting foams for liquid hydrocarbon fires and of products that are in actual use. An overall assessment of the technical feasibility, economic feasibility, and availability of these seven alternatives is undertaken. In addition, two case stories about transitions to fluorine-free alternatives in the aviation and petrochemicals sectors are presented. It is concluded that alternatives are generally available and technically feasible and have been successfully implemented by many users in most of the main user sectors identified. Use areas where PFAS-free alternatives have not been fully tested, are in the downstream petrochemical sector (refineries and steam crackers) and large storage tank facilities. In particular, combatting fires involving large storage tanks requires foams capable of flowing on large burning liquid surfaces and sealing against hot metal surfaces to prevent reignition. More testing is required to prove performance of alternatives under some conditions. To date, no real-world examples of a successful transition in installations with large tanks have been identified. Socio-economic analysis Two main restriction scenarios are considered in the analysis: Scenario 1: Restriction (ban) on the placing on the market of PFAS-based FFF. The use of legacy foams, i.e. foams already in stock at producers' or users' sites, would still be permitted. So, under this scenario, new sales would be prevented but existing stocks could be used and run down incrementally; and Scenario 2: Restriction (ban) on the placing on the market and the use of PFAS-based FFF. In addition to a restriction on sale, legacy foams, i.e. foams already in stock at producers' or users' sites, would need to be disposed of safely. So, under this scenario, not only would new sales be prevented, but existing stocks would also need to be disposed of and replaced with new volumes of fluorine-free foams. Both scenarios require purchasing of alternative foams which is estimated to incur additional costs (compared to the baseline) of around 27m per year in the EU. This would be partly off-set by savings, e.g. from lower disposal cost of fluorine-free foams when they reach their expiry date. However, Scenario 2 would also require existing stocks of PFAS-based foams to be written off, and new stocks would have to be purchased, subject to replacement costs (minus the value of existing stocks already depreciated) estimated at June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 6 Wood Environment & Infrastructure Solutions UK Limited around 1.0 billion (range -60 million2 to 8.3 billion). In Scenario 2, additional costs would also be incurred for the disposal of the existing stocks of PFAS-based foams. Total EU costs (one-off) are estimated at up to 320 million (range up to 60m to 4.8bn). There are other potential economic costs for transitioning that are difficult to quantify, of which cleaning/replacement of equipment before switching the foam are likely the most important. These costs could be significant (e.g. costs of cleaning could potentially be in the order of 1 billion, depending on the residual concentration limit and number of installations affected). There are potentially significant benefits in terms of reduced clean-up / remediation costs for PFAScontaminated sites. As a very high-level estimate for illustration, the potential order of magnitude of avoided remediation could be hundreds of millions of Euros to billions of Euros. Treatment costs for run-off could be around 0.7 per litre (range ca 0-11) or up to tens of millions of Euro per incident less expensive when fluorine-free foams are used, but data on the total amount of fire-water run-off treated was lacking to quantify an EU total. In cases where fire-water run-off is not contained and further clean-up is required, clean-up costs may also be lower for fluorine-free foams due to their lower persistence. No specific data was available to quantify this saving, but for illustration the potential order of magnitude of savings could be several million Euros. Regulatory management option analysis (pre-RMOA) The RMOA discusses the need for further regulatory management of the concerns associated with the use of PFAS in fire-fighting foams. Significant hazards have been shown at least for some PFAS, including some short-chain PFAS. However, the hazards of PFAS themselves were not a primary focus of this study, given ongoing work by the PFAS working group3. Many PFAS are highly mobile, highly persistent, have the potential to accumulate within the environment and living organisms, and to cause cross-border pollution. There is a lack of existing regulation, and of implementation or proven effectiveness of other risk management measures to address the release of PFAS from the use of PFAS-based fire-fighting foams. National regulation does not appear to be forthcoming and discrepancies across Member States could affect the functioning of the internal market. It is therefore concluded that a restriction on the placing on the market (and potentially the use) of PFAS-containing fire-fighting foams at EU-level appears to be an appropriate option. In order to maximise effectiveness while minimising potential adverse socio-economic impacts of such a restriction, it appears appropriate to vary the specific conditions (particularly transition periods) by application and user sectors, because of their significant divergence in terms of the likelihood of emissions and implications of switching to alternative foams. It is concluded that training and testing should be the highest priority for a quick transition to fluorine-free foams. Chemicals / petrochemicals is the largest user sector. Users have suggested a longer transition period of up to 10 years is required and derogations with a longer transition period may be needed for specific applications (notably large tank fires) where further testing is required to determine the technical feasibility of alternatives and potential fire-safety risks from using alternatives may be higher (and are still under investigation). This is the largest user sector, so in order to ensure effectiveness of a restriction in reducing PFAS-emissions, it seems appropriate that any longer transition period should be limited to the most sensitive applications within this sector, particularly large incidents and large atmospheric storage tanks. For small incidents4 as well as all other sectors, shorter transition periods between 3-6 years have been suggested and are expected to minimise socio-economic implications of a restriction. 2 I.e. a potential saving of 60 million, if fluorine-free alternatives are less expensive than the PFAS-based foams they replace (possible in some cases but unlikely on average) and no additional volumes are required. 3 A working group under ECHA's stewardship to assess the hazards associated with PFAS substances, including persistence, mobility, bioaccumulation and toxicity. 4 Note that the distinction between small and large incidents is based on stakeholder feedback and would need to be more precisely defined, for instance in any consultation as part of a potential future restriction proposal. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 7 Wood Environment & Infrastructure Solutions UK Limited Regarding thresholds for the remaining concentration of PFAS in equipment that previously used PFASbased fire-fighting foams, a balance would need to be struck between the amount of PFAS emissions remaining if a given threshold is adopted, versus the costs of cleaning imposed in order to achieve that threshold. Stakeholder input suggests that 100 ppb can be achieved with a relatively simple cleaning process (cost likely low but not quantified); such a limit would remove the vast majority of emissions. Lower thresholds are achievable with more complex and costly processes. For instance, achieving 1 ppb could cost around 12,300 per appliance according to one estimate, which could imply EU total costs in the order of 1 billion. However, setting a lower concentration threshold would lead to a relatively small additional reduction in PFAS emissions, compared to the overall reduction achieved by the restriction. Lastly, it is advisable to further investigate a potential obligation to apply best practice emission reduction measures during and after the use of PFAS-based fire-fighting foam, as a condition of any restriction. These could cover, for instance, containment, treatment, and proper disposal of foams and fire water run-off. These measures could provide relatively effective reduction of PFAS-emissions at relatively low cost particularly during the transition periods when PFAS-based foams continue to be used in certain applications and if the use of existing foams is not restricted (scenario 1). June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 8 Wood Environment & Infrastructure Solutions UK Limited Contents 1. Introduction 13 1.1 This report 13 1.2 Scope of work 13 1.3 Structure of this report 17 2. Joint consultation 18 2.1 Introduction 18 2.2 Approach 18 2.3 Consultation questionnaire results 20 2.4 Consultation workshop 21 2.5 Additional consultation and resources 22 3. Task 1. Substance identification 23 3.1 Introduction 23 3.2 Approach 23 3.3 Final results 24 Task 1.1: Substance identification non-PFAS fluorinated alternatives 24 Task 1.2: Substance identification - FFF (fluorine-free foams) 25 Task 1.3: Substance identification - PFAS 34 4. Task 2. Market analysis 54 4.1 Introduction 54 4.2 Approach 54 4.3 Results: PFAS in fire-fighting foams 55 Tonnages and values 55 Functions provided in the foams and types of fires the foams are used for 65 4.4 Fluorine-free fire-fighting foams 65 Tonnages and values 65 Functions provided in the foams and types of fires the foams are used for 68 4.5 Summary of results 68 5. Task 3. Assessment of the emissions and hazard of fluorine-free foams 70 5.1 Introduction 70 5.2 Approach 70 5.3 Results and analysis 81 June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 9 Wood Environment & Infrastructure Solutions UK Limited 6. Task 4 - Remediation costs and technologies 90 6.1 Introduction 90 6.2 Approach 90 6.3 Results 90 Step 1: What is what: Definition of "remediation" versus "clean-up" 91 Step 2: Contamination scenarios: PFAS-containing foams and fluorine-free foams 93 Step 3: Point of treatment - source area, site hydraulic control, plume, and "end-of-pipe" 94 Step 4: Drivers for active measures - why is clean-up / remediation required? 96 Step 5: Treatment technologies and treatment scenarios - soil and water 97 Step 6: Cost of remediation / treatment: soil and water 101 7. Task 1: Analysis of alternatives to PFAS-containing fire-fighting foams 106 7.1 Introduction 106 7.2 Approach 106 7.3 Initial screening and consultation results 107 Step 1 - Literature review on fluorine-free products 108 Step 2 - Consultation of stakeholders 109 7.4 Preparation of example list of alternative fluorine-free products 110 Step 3 - Preparation of shortlist of alternatives 110 7.5 Properties of shortlisted products 113 Step 4 - Additional information gathering and assessment of shortlisted alternatives 113 7.6 Representative case studies where fluorine-free alternatives are already in use in the EU 123 Step 5 - Assessment of illustrative cases 123 7.7 Overall analysis of alternatives 128 Step 6 - Final summary 128 8. Task 2: The socio-economic impacts of substitution of PFAS- containing fire-fighting foams 137 8.1 Aims and scope of the SEA The aim of the SEA Definition of the "baseline" scenario Identification and definition of the assessed regulatory management options 8.2 Analysis of the impacts Overview a. Cleaning of equipment: costs and remaining contamination b. Other options and their impacts c. Fire safety: impacts of technical performance of alternatives d. Use patterns of alternative fire-fighting foams to achieve comparable/acceptable performance e. Impacts associated with the economic feasibility of alternatives f. Environmental/health impacts of alternatives g. Remediation and clean-up h. Availability of alternatives i. Other impacts j. Emissions from disposal of legacy foams k. Technical feasibility / availability of disposal options (legacy foams) l. Costs of disposal (of legacy foams) 137 137 137 138 139 139 141 143 143 146 147 152 153 . 156 159 159 161 163 June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 10 Wood Environment & Infrastructure Solutions UK Limited 8.3 Conclusions 164 Scenario 1: Restriction on the placing on the market of PFAS-containing fire-fighting foams 169 Scenario 2: Restriction on the placing on the market and the use of PFAS-based fire-fighting foams 171 Cost-effectiveness 172 Assumptions and uncertainties 175 9. Task 5. Regulatory management option analysis (pre-RMOA) 177 9.1 Introduction 177 9.2 Hazard information 177 9.3 Information on tonnage, uses and exposure 178 9.4 Overview of current measures 182 9.5 Need for (further) regulatory management 186 9.6 Identification and assessment of regulatory management options 187 Transition periods 193 Concentration thresholds 194 Other risk management targeted at reducing release 195 9.7 Conclusions on the most appropriate (combination of) regulatory management options 195 Table 3.1 Table 3.2 Table 3.3 Table 3.4 Table 3.5 Table 3.6 Table 3.7 Table 3.8 Table 3.9 Table 3.10 Table 3.11 Table 3.12 Table 4.1 Table 4.2 Table 4.3 Table 5.1 Table 5.2 Table 5.3 Table 5.4 Table 5.5 Table 5.6 Table 5.7 Table 5.8 Identified hydrocarbons (identified by CAS) incl. CAS/EC identifier, the substance name, chemical group and the supplier and/or product name 26 Identified detergents (identified by CAS) incl. CAS/EC identifier, the substance name, chemical group and the supplier and/or product name 29 Siloxanes (identified by CAS) incl. CAS/EC identifier, the substance name, chemical group and the supplier and/or product name 33 PFSAs (identified by CAS) with C6 incl. CAS/EC identifier, the designation, the acronym and the supplier and/or product name 36 PFCAs (identified by CAS) with C8 incl. CAS/EC identifier, the designation, the acronym and the supplier and/or product name 37 PFSAs (identified by CAS) with <C6 incl. CAS/EC identifier, the designation, the acronym and the supplier and/or product name 38 PFCAs (identified by CAS) with <C8 incl. CAS/EC identifier, the designation, the acronym and the supplier and/or product name 39 Identified derivates of perfluoroalkyl sulfonic PFAS (also PASF-based substances) 41 Fluorotelomer (identified by CAS) substances incl. CAS/EC identifier, the designation, the acronym and the supplier and/or product name 44 Other per- or polyfluorinated substances (identified by CAS) incl. CAS/EC identifier, the designation, the acronym and the supplier and/or product name 49 Overview of the PFAS classification, generalised chemical structures, and minimal number of C-atoms of substances that were identified as being used in AFFF 51 Comparison of the substance identification as in the PFOA restriction and a proposal made for the PFAS- substances in AFFF. 51 Overview of quantitative data from literature on the market of PFAS in fire-fighting foams 56 Tonnage of fluorosurfactants purchased for the production of fire-fighting foams by manufacturers participating in the 2018 Eurofeu survey 59 Summary of key preliminary market analysis results 68 Industry splits and usage rates based on data from Eurofeu and Brooke et al (2004)* 73 Summary of factors applied to data 74 Final selection of substances (substances highlighted in blue selected) - see also footnotes at end of table.77 PFAS based substances for selection 81 Overview of ratios for emissions by different environmental compartment for all life-cycle stages combined. 82 Overview or ratios for emissions by different life-cycle stages 82 log Koc values for a set of solvents, POPs and PFAS based substances as indicative guide to partitioning against Koc values. 84 log Koc values for non-fluorinated substances included within Task 3. 84 June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 11 Wood Environment & Infrastructure Solutions UK Limited Table 5.9 Table 6.1 Table 6.2 Table 6.3 Table 6.4 Table 7.1 Table 7.2 Table 7.3 Table 7.4 Table 7.5 Table 7.6 Table 7.7 Table 7.8 Table 7.9 Table 8.1 Table 8.2 Table 8.3 Table 8.4 Table 8.5 Table 8.6 Table 8.7 Table 8.8 Table 8.9 Table 8.10 Table 8.11 Table 8.12 Table 8.13 Table 8.14 Table 8.15 Table 8.16 Table 8.17 Table 8.18 Table 9.1 Table 9.2 Table 9.3 Overview on substances used in fluorine-free fire-fighting foams and one substance used in a fluorinated foam. Shown are the product, CAS/EC, PNECs, and the used reference. The respective lowest PNECs are highlighted in bold. 86 Nordic Council report case studies of PFAS contamination from AFFF use 96 Cost estimation of soil remediation 103 Cost estimation of groundwater remediation 104 Cost estimation of drinking water remediation 105 Example list of products for further analysis 112 Respondol ATF 3-6% 113 Re-Healing Foam RF3x6 ATC 115 Re-Healing Foam RF1 1% 116 Moussol FF 3x6 (F-15) 118 FOAMOUSSE 3% F-15 119 Ecopol Premium 120 Orchidex BlueFoam 3x3 121 Evaluation of potential alternatives by application area 134 Estimated costs for the replacement of fire extinguishers in the whole of the EU 143 Effectiveness of alternatives - summary 144 Use patterns of alternatives - summary 146 Annual foam costs - input assumptions 148 Scenarios, gross and net foam costs -annual cycle replacement costs for total EU market (m denotes millions) 148 Quantitative data - economic costs 149 Quantitative data - economic costs 149 Overview of key hazards of alternatives based on information from SDS 153 Typical cost per site of remediation of PFAS contamination resulting from the use of fire-fighting foams 154 Availability of alternatives - summary 157 "Top down" assessment - annual demand and supply of PFAS and Fluorine free FFF 158 Processing time based on existing incinerator capacity processing 25l per hour. 162 Processing time based on existing incinerator capacity processing one tonne per hour. 162 Estimated costs of disposal 163 Summary of socio-economic considerations for the main expected impacts of potential regulatory management options 165 Estimate of total annual PFAS emissions from fire-fighting foams 172 Estimate of total quantifiable cost of a potential restriction on PFAS in fire-fighting foams 173 Estimate of cost-effectiveness of the reduction of PFAS emissions from fire-fighting foams 175 Overview of ratios for emissions by different environmental compartment for all life-cycle stages combined. 181 Overview or ratios for emissions by different life-cycle stages 181 Comparison of substitution potential, socio-economic impacts and PFAS risk reduction potential of different user sectors and applications 191 Figure 3.1 Figure 3.2 Figure 3.3 Figure 3.4 Figure 3.5 Figure 4.1 Figure 4.2 Figure 6.1 Figure 6.2 Figure 7.1 Figure 8.1 Figure 8.2 Figure 9.1 Figure 9.2 Chemical structure of sodium octyl sulphate 28 Sugar-based siloxane as described by Hetzer et al. 34 Hierarchical clustering of the identified short-, long-chain and substituted PFAs substances 43 Hierarchical clustering of identified fluorotelomers 48 Chemical structure of Dodecafluoro-2-methylpentan-3-one, a fluorinated ketone 49 Split of PFAS-based fire-fighting foams by sector 61 Yearly use of fluorine-free firefighting foams by sector. 66 Overview of "Remediation" vs. "Clean-up" 93 Overview of PFAS fate and transport from use of fire-fighting foams 95 Training at Copenhagen airport with crash tender. Picture courtesy of Kim T. Olsen, Copenhagen Airports A/S. (https://beros.dk/skum/Kim_Thorbjoern_Olsen_CPH.pdf). 125 Map summarising potential effects of a restriction on the placing on the market of PFAS-based fire-fighting foams 139 Map summarising potential effects of a restriction on the use of PFAS-based fire-fighting foams 140 Split of PFAS-based fire-fighting foams by sector 180 Yearly use of fluorine-free firefighting foams by sector. 180 June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 12 Wood Environment & Infrastructure Solutions UK Limited Appendix 1 Appendix 2 Appendix 3 Appendix 4 Appendix 5 Appendix 6 Appendix 7 Consultation questionnaire Workshop report Overview of PFAS physical properties and why they contribute to hazards Detailed foam transition timescales (from industry) List of international standards for fire-fighting foam performance List of alternative fire-fighting foam products available on the EU market, as identified in consultationresponses "Pre-Annex XV Dossier" June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 13 Wood Environment & Infrastructure Solutions UK Limited 1. Introduction 1.1 This report Wood has been contracted by the European Commission, DG Environment (`DG ENV') and by the European Chemicals Agency (`ECHA') to provide services on: "The use of PFASs and fluorine-free alternatives in fire-fighting foams" (the `DG ENV study')5; and "Assessment of alternatives to PFAS-containing fire-fighting foams and the socio-economic impacts of substitution" (the `ECHA study')6. Wood is working in partnership with Ramboll on the DG ENV study and with COWI on the ECHA study, both acting as subcontractors to Wood. This is the combined final report for both studies, which contains details of the results for all tasks under the two studies. For convenience, the full scope of work for both studies is set out below, based on the scope of work confirmed at project inception. 1.2 Scope of work Objectives DG ENV study As set out in the Terms of Reference the overall objective of this project is to assess the use of polyfluoroalkyl and perfluoroalkyl substances (PFAS) and fluorine-free alternatives in fire-fighting foams, looking specifically at: i. their volumes of use; ii. their functionality; iii. their emissions to the environment; and iv. the costs for remediation of soil and water due to environmental release. The specific objectives within this are to: Assess the potential hazard (and risk, to the extent possible) of fluorine-free alternatives, with regard to human health, the environment and humans exposed via the environment; Assess the cost and technologies for remediation of soil and water for both "long chain" and "short chain" PFAS and for the fluorine-free alternatives; and Consider the above points for both foams already on the market and installed in fire-fighting systems (both fixed and mobile), as well as foams not yet in use. 5 Reference 07.0203/2018/791749/ENV.B.2 under the Framework Contract ENV.A.3/FRA/2015/0010. 6 Reference ECHA/2018/561 under Framework Contract ECHA/2015/50. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 14 Wood Environment & Infrastructure Solutions UK Limited ECHA study The terms of reference for the ECHA study state that the project should assess the technical feasibility, economic feasibility and availability of alternatives to PFAS-containing fire-fighting foams and the socioeconomic impacts of substitution, broken down into the following tasks: Task 1: Technical feasibility; Economic feasibility; and Availability of alternatives to PFAS-containing fire-fighting foams. Task 2: Socio-economic impacts of substitution of PFAS-containing fire-fighting foams. Task 3: Support in organising a workshop to collect the input of the various stakeholders (including producers and users of fire-fighting foams). Tasks DG ENV study Task 1 - Substance identification - input for the scope of a possible measure Identify the PFAS (long and short chain), their salts and precursors present or potentially present in firefighting foams, including those intentionally used and those that might be present as impurities. Identify the constituents of the fluorine-free fire-fighting foams and any non-PFAS fluorinated alternatives, if they exist. This task should be performed in close cooperation with the ECHA study, especially when consulting stakeholders. Task 2 - Market analysis Estimate the tonnages of fluorine-based and fluorine-free fire-fighting foams manufactured and placed on the market in the EU. The analysis is to include the different functions (e.g. film-forming, surfactants, solvents) provided by different components of fire-fighting foams and the type of fires for which their use is recommended. The comparison between the function provided by PFAS-based and fluorine-free foams will be part of the ECHA Analysis of Alternatives. A large consultation with manufacturers and professional users of fire-fighting foams is to be organised. Task 3 - Assessment of the emissions and hazard of fluorine-free foams Estimate the emissions of PFAS and of the constituents of the alternative fluorine-free fire-fighting foams to the environment, broken down by environmental compartment (aquatic environment (marine and inland waters), terrestrial environment) and the possible uptake by humans via the consumption of food and water. While the hazard of PFAS will be part of the work of the PFAS Working Group, the study should also assess the hazard (and risk, to the extent possible) to human health, to the environment and to humans via the environment of the fluorine-free foams and any non-PFAS fluorinated alternatives, if they exist. Such assessment shall follow the relevant guidance provided by ECHA7. 7 See available guidance documents at: https://echa.europa.eu/guidance-documents/guidance-on-reach June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 15 Wood Environment & Infrastructure Solutions UK Limited Task 4 - Assessment of the remediation costs Assess the cost and technologies for remediation of soil and drinking water for both "long chain" and "short chain" PFAS and for the alternatives. It should consider both foams not yet in use and those already installed in the fire-fighting systems (both fixed and mobile). Task 5 - Summary of the information in the form of a risk management option analysis (pre-RMOA) Summarise all the information following the structure of a RMOA ("pre-RMOA) to allow the Commission to identify the most appropriate instrument for possible regulatory risk management activities to address the concerns resulting from the use of PFAS in fire-fighting foams. The draft pre-RMOA is to be included in the interim report. The final pre-RMOA is to include the findings of the ECHA study on the Analysis of Alternatives and Socio-Economic impacts and the outcome of the work of the PFAS Working Group on the hazard of PFAS. Task 6 - "Pre-Annex XV dossier" Present the full information collected (including the part developed by the ECHA study and the hazard of PFAS developed by the PFAS Working Group) in the form of an Annex XV dossier, so that the Commission can use it as a basis for any future regulatory action, if this is considered necessary. The DG ENV study also includes contributing to the organisation of the workshop (preparing the agenda, contacting the experts, preparing the supporting documentation and reporting). More details on the workshop are provided in Task 3 of the ECHA study. ECHA study Task 1 - Analysis of alternatives to PFAS-containing fire-fighting foams Analyse the alternatives in terms of: 1. Technical feasibility. Including, but not necessarily limited to aspects such as: Comparison between the function provided by PFAS-containing foams and their alternatives; Performance (efficacy) to fight various types of fires, including liquid fuel fires ("Class B" fires); Required machinery/equipment/storage tanks; and Uses where alternatives do not meet (fully or partially) the required performance and why. 2. Economic feasibility. Including, but not necessarily limited to aspects such as: Annualised cost for an assessment period that takes into account the investment cycle in the industry; Cost difference of bringing forward investment(s); Required amounts/loadings of alternative foams; Price per kg; Shelf life; Machinery/equipment/storage tanks changes; Any need for specific training to use the alternative foams; Possible savings to fire-fighting users; June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 16 Wood Environment & Infrastructure Solutions UK Limited Training (e.g. benefits of being able to practice with the alternative foams with minimal cleaning requirement); Possible instant clean up after fire made unnecessary or less expensive; For PFAS-containing foams already placed on the market; Incineration costs (including transfer and availability of technically suitable incinerators); and Clean-up of tanks (considering practical concentration limit, i.e. remaining PFAS concentrations achievable with reasonable cost). 3. Availability of alternatives Whether and when alternatives are available in the required quantities. If not, expected time to reach the necessary quantities. Task 2 - Assessment of the socio-economic impacts of substituting PFAS-containing fire-fighting foams Assess, considering the scenario(s) of an EU-wide restriction or total ban of the use of PFAS-containing foam, and the socio-economic impacts of such restriction/ban scenarios: Including, but not necessarily limited to aspects such as: The likely reaction of producers and users of fire-fighting foams (both PFAS-containing and alternatives) in and outside the EU; The likely related impacts to this restriction (e.g. as reduced emissions of fluorinated substances or other hazardous chemicals, fire safety aspects, and economic impacts to the foam producers and their users); and The likely impact of different transitional periods. Task 3 - Supporting the organisation of a stakeholders' workshop Support ECHA and the Commission in the organisation of a workshop in the EU gathering the most relevant stakeholders to collect their input. In collaboration with ECHA and the Commission: Define the best suitable time for organising the workshop, in light of the timing of ECHA's and Commission's studies requirements; Draft the workshop agenda and description; Identify the key elements for discussion/information requirements to be addressed in the workshop; Identify and contact the relevant stakeholders to invite, including the speakers; Prepare short background materials to be sent to the participants in advance of the workshop; Prepare presentations on the context of ECHA's study and the required input from stakeholders; Assist ECHA and, the Commission in running the discussions during the workshop to achieve the desired outcome; Provide assistance in drawing the conclusions from the workshop; and Short report on stakeholder workshop (including a high-level summary and first conclusions). June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 17 Wood Environment & Infrastructure Solutions UK Limited Task 4 of the ECHA study was optional and will no longer be necessary as the overlap in project team members allows for the ready exchange of information between both projects. 1.3 Structure of this report This report is structured as follows: Part 1, consisting of Section 2 only, provides an overview of the consultation undertaken jointly between the ECHA study and the DG ENV study; Part 2 presents the following tasks of the DG ENV study: The approach and detailed results of the substance identification (Task 1) are presented in Section 3; An overview of approach and results of the market analysis (Task 2) are presented in Section 4; The assessment of the emissions and hazard of PFAS substances and their alternatives (Task 3) is presented in Section 5; and Section 6 provides an assessment of the remediation costs associated with PFAS-based fire-fighting foams and potential alternatives (Task 4). Part 3 then focuses on the tasks of the ECHA study: The approach and results of the Analysis of Alternatives (Task 1) is presented in Section 7; and Section 8 presents the outcomes of the SEA (Task 2). Part 4, consisting of Section 9 only, summarises all the above results in the format of a preRMOA (DG ENV study Task 5); and The information collected is also presented in the form of an Annex XV dossier (DG ENV study Task 6), in Appendix 7. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 18 Wood Environment & Infrastructure Solutions UK Limited PART 1 - Joint consultation 2. Joint consultation 2.1 Introduction In the inception of both Commission and ECHA projects, it was recognised that effective engagement with key stakeholders from across the fire-fighting foam sector, particularly the manufacturers and users of the foams, would be critically important in the data collection process of both projects. It was also noted that the relevant stakeholders, who would be likely to be able to contribute key information, would be able to feed into both projects. Therefore, to conduct both projects with optimal efficiency, and to ensure the consistency of the data feeding into both projects, it was agreed to carry out a joint stakeholder consultation across the two projects in parallel. It was agreed that it was essential that the consultation cover all the relevant sectors and backgrounds across the fire-fighting foam supply chain, as well as regulators, researchers and special interest groups. The consultation therefore aimed to target the following stakeholders: Foam manufacturers / suppliers; Users of foams in major sectors (including airports, oil and gas, chemical plants, ports, railways); Key trade associations; International organisations; National-level authorities and agencies; Academics and R+D (especially those involved in developing alternative foam products); and Key NGOs and interest groups. It was agreed during the inception meeting that Wood, Ramboll and COWI would map stakeholders identified so far, indicating the best means of consulting each one of them: e.g. advisory group, questionnaire, one-to-one consultation, workshop, etc. An initial list of stakeholders was provided in the Inception report, and a finalised list was agreed with the Commission and ECHA prior to commencing the consultation activities. 2.2 Approach The agreed approach to collecting key information from the main categories of expert stakeholders (detailed above) was to carry out a consultation through a combination of i) scoping interviews, ii) a targeted stakeholder questionnaire, and iii) a stakeholder workshop. Our approach to carrying out these consultation activities is outlined in the following sections. Scoping interviews To inform the main data collection steps of the project (the stakeholder questionnaire and workshop) a series of initial scoping interviews was organised with a selected small number of key stakeholders. The purpose of the interviews was to: June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 19 Wood Environment & Infrastructure Solutions UK Limited I. Introduce and discuss the aims and scope of the project with key experts; II. Identify where the key data gaps were in relation to the objectives of the project(s); and III. Identify other key stakeholders in this sector to target in the next stages of the consultation. The stakeholders involved with the scoping interviews were: Eurofeu; Fire Fighting Foams Coalition; Copenhagen Airport; Heathrow Airport; LASTFIRE project; and IPEN. An interview template was developed, and shared with the interviewees ahead of the call, to guide the conversation more effectively and efficiently. Teleconference interviews of 30-60 minutes were held with each stakeholder. During the call, brief notes of the key discussion points were made. Since the purpose of these scoping interviews, was as an introductory discussion, rather than an evidence gathering exercise as such, a limited amount of specific information about the use of fire-fighting foam products was gained. A number of key outcomes from these scoping interviews are highlighted below: All stakeholders interviewed expressed an interest in the project and agreed to participate in the consultation; In some cases, for example, for key industry associations, it was agreed they would coordinate joint industry responses, and stakeholders provided the details of additional stakeholders to contact, and/or agreed to forward the consultation on directly; Both industry, users and others (e.g. NGOs) commented on the increased move towards and the rapidly increasing market share of fluorine-free foams, and their increasingly better overall performance now than previously; It was re-emphasised that alternative foams are designed for very specific applications, requiring compliance with specific performance criteria, so the analysis of their technical and economic feasibility will be challenging as it requires assessment of each product individually; There is likely to be variation in the situations with regards to alternative foams in different sectors of use (e.g. between aviation and oil and gas sectors) and in different locations/countries (e.g. certain countries have switched to alternatives, others have not); and The potential for contamination of foams was raised, leading to the inclusion of specific questions in the survey about the level of PFAS as impurities in foam products (both PFASbased and fluorine-free). The scoping interviews were then used to better inform our approach to the following consultation steps, allowing the survey and workshop to be designed more systematically to address the key knowledge gaps and target the most relevant stakeholders. This also helped to identify additional stakeholders to include in the next consultation steps. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 20 Wood Environment & Infrastructure Solutions UK Limited Consultation questionnaire The main consultation activity conducted involved the development of a written questionnaire, based on an assessment of the required data needed to generate and/or complement the information already gathered under the separate Tasks under the two projects. It was agreed that the most appropriate format of the questionnaire would be a Word document that could be sent to targeted stakeholders directly via email, allowing the respondents to fill in relevant details and return the completed questionnaires. The questionnaire covered the following aspects: Introductory information; Background information on the respondent; Chemical identity, functionality of PFAS in fire-fighting foams; Alternatives to PFAS in fire-fighting foams; Foam use and environmental emissions; Potential restrictions on PFAS in fire-fighting foams; and Additional information. The full consultation questionnaire is provided in Appendix 1 of this report. 2.3 Consultation questionnaire results A total of 33 written responses to the questionnaire were received8. Of the different types of stakeholder targeted, the most responses were from users/industry (11), with smaller numbers of responses from individual manufacturers (2), authorities/agencies (6), industry associations (2), NGOs (3) and `other' stakeholders (7) e.g. academic/testing/training professionals/technical consultant. It is noted that the responses from the users of foams cover all the main sectors of use the consultation aimed to cover (airports, oil refineries/storage, chemicals, petrochemicals, and rail). Responses to the consultation from a number of stakeholders also included the provision of previously published data or reports in addition to, or instead of, the questionnaire. This included published reports and analyses from national authorities9, research and testing information10, and special interest groups11 Since the questions in the stakeholder questionnaire were designed to gather information that will best feed into the delivery of tasks under each of the two projects, the responses received have generated useful information in this context. In particular, we highlight the following aspects, where the consultation yielded useful information: Identifying some of the key foam products containing PFAS on the EU market, and non-PFAS alternatives actually used in key sectors; Identifying specific PFAS, precursors and impurities present in some foam products; 8 Correct as of July 18 2019. 9 KEMI (2015) Chemical Analysis of Selected Fire-fighting Foams on the Swedish Market 2014 10 Published testing data, as provided by LASTFIRE: www.lastfire.co.uk/ 11 IPEN (2019) The Global PFAS Problem: Fluorine-Free Alternatives as Solutions, https://ipen.org/documents/global-pfas-problemfluorine-free-alternatives-solutions June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 21 Wood Environment & Infrastructure Solutions UK Limited The functionality of PFAS-containing foams useful to the major users of foams and reasons why products containing PFAS have not been fully replaced; Volumes of production and use, and unit price for a small number of individual products; Information on available alternatives, including specific products on the market in the EU, the type and sector of use, their availability, volumes of sale and use, their perceived technical feasibility and economic feasibility (see Section 3, Task 1 analysis of alternatives); Some details of fire-fighting foam use e.g. volumes, frequency; Some details of methods, regulations, and guidelines in place to prevent release to the environment; Some information on the methods/approach to disposal of individual foam products; Preliminary stakeholder opinions and feedback on different potential restriction options were provided; and Additional data, reports and other resources were provided by a number of stakeholders with their consultation response. For some sections, a number of information gaps, where the level of detail provided by respondents was less substantial, were identified. These data gaps helped to inform the approach to the organisation and format of the following stage of the consultation process, the stakeholder workshop, where these data gaps were explored further (see Section 2.4). 2.4 Consultation workshop The final stage of the consultation involved the organisation of an expert stakeholder workshop. This was hosted by ECHA in Helsinki on 24 September 2019. The purpose of the workshop was to present, validate and seek feedback on the preliminary project findings; gather views on possible risk management options; and explore the feasibility of replacing PFAS-based foams with fluorine-free alternatives. Stakeholder views were sought during the workshop through a series of breakout groups on key topics which focused on specific questions designed to inform possible future regulatory activities. The workshop was attended by a total of 36 participants, including manufacturers, users from different sectors (airports, chemical plants, oil and gas), researchers, NGOs, national authorities, and remediation experts. The format of the workshop included: Introductions from DG Environment, ECHA and the study team; Presentation of initial results; Plenary discussion on study findings to date; Presentations from invited speakers; and Breakout session on remaining data gaps. The invited speakers, who presented at the workshop were from the following organisations: Eurofeu (industry perspective); June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 22 Wood Environment & Infrastructure Solutions UK Limited Finavia Corporation (user perspective - airports); Total HSE (user perspective - oil and gas); and LASTFIRE project (testing and efficacy perspective). There were four breakout sessions for the workshop, each covering a specific set of questions, partly informed by the identified data gaps remaining from the consultation questionnaire and the other tasks relating to the two projects. The breakout sessions covered the following aspects: Different Risk Management Options; Essential uses and availability of alternatives; Remediation costs and technologies; and Current/ future market trends in PFAS-based and fluorine-free foams. The workshop report with more details about the set-up and results of the workshop is included in Appendix 2. 2.5 Additional consultation and resources The stakeholder consultation and workshop also resulted in a number of stakeholders providing additional information to supplement their consultation responses. This additional information was used, where relevant, in each of the specific tasks. Following the consultation questionnaire and workshop, a number of specific areas were identified as needing additional data or clarification, for example on volumes of firefighting foams produced, marketed and used in the EU. Where these additional data needs were identified, the project team undertook direct consultation with specific stakeholders identified as being the best source of the required information. Contact was made with these stakeholders via email or telephone to discuss the remaining data needs and obtain the required data. This additional consultation has provided additional detail and clarifications relating to critical uses, volume of production and use in the EU, and experiences from previous transitions. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 23 Wood Environment & Infrastructure Solutions UK Limited PART 2 - DG ENV STUDY 3. Task 1. Substance identification 3.1 Introduction The objective of this task is to identify the PFAS (including long and short chain, their salts and precursors, intentionally used or as impurities) present in fire-fighting foams, the constituents of the fluorine-free firefighting foams and any non-PFAS fluorinated alternatives (if they exist). In the following, the approach is briefly described (Section 3.2). Then, interim results are discussed in Section 3.3, in separate sub-sections first for alternatives to PFAS in fire-fighting foam that are fluorinated (but not based on PFAS), then for completely fluorine-free alternatives, and lastly for PFAS used in fire-fighting foams. 3.2 Approach The substance identification was based on desktop research covering: Literature research based on: Scientific peer reviewed literature (pubmed, google scholar); Reports or other publications by national and regional environmental agencies; and Reports or other publications by NGOs. Information gathered in the framework of regulations: REACH (for example RMOAs, Annex XV restriction reports, RAC & SEAC documents of PFAS substances); Stockholm convention (for example risk management evaluation, AoA reports, technical paper on the identification and assessment of alternatives); and Basel Convention (technical guidelines). Safety Data Sheets ((M)SDS) and any other information of known producers/associations; Environmental and human (bio-)monitoring data and case studies; and Expert knowledge (international experts). In general, all the above-named documents were screened by using the following search terms: fire, foam, fluor and/or alternative. More specifically, in case the documents covered the analysis of alternatives (e.g. documents by REACH, Stockholm and NGOs) the documents were screened using the search terms fire and foam. This strategy was also undertaken in the screening of more general reports, for example those reports that cover PFAS in general. These kinds of reports were mostly published by environmental agencies. In cases where analytical measurements were reported (case studies, (bio-) monitoring and scientific publications) it was made sure, that an unambiguous assignment to the usage of fire-fighting foam could be made. Only in cases where this was possible, the respective data was extracted. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 24 Wood Environment & Infrastructure Solutions UK Limited A different strategy was elaborated for (M)SDS, in this case only the term "fluor" was used. More detail about the specific search terms applied and the specific documents screened is provided alongside the results in the following sub-sections. A matrix was created to collect all potentially relevant information from the literature review, but the identified information is summarised in the following. 3.3 Final results Task 1.1: Substance identification non-PFAS fluorinated alternatives Due to concerns about their toxicity and regulatory pressure, long chain PFAS (such as C8, see definition later in this section) have been widely replaced by (perceived safer) alternative substances starting from the early 2000s. These alternatives include short-chain substances like C6 fluorotelomer based fluorosurfactants12, but also non-fluorinated substances. The knowledge of the chemical identity of these substances is currently very limited. As reflected in the Terms of Reference of this project, it is clear that a variety of PFAS and fluorine free-substances are used in fire-fighting foams, but it is not certain if there are any non-PFAS but fluorinated substances that have been or are still being used in fire-fighting foams. The distinction between PFAS and non-PFAS fluorinated substances is the following: PFAS are a fully (per) or partly (poly) fluorinated carbon chain that "contain one or more C atoms on which all the hydrogen atoms are substituted (present in the non-fluorinated analogues from which they are notionally derived) by F atoms, in such a manner that they contain the perfluoroalkyl moiety (CnF2n+1-)." (OECD 2018). Non-PFAS fluorinated substances do not exhibit this particular feature of having "one or more C atoms on which all the H- are substituted by F-atoms". An example for this substance group are silicon dioxide molecules which are perfluorinated. These substances might be used in textiles as an alternative to PFAS13. Based on the length of the fluorinated carbon chain, short and long chain PFASs can be distinguished. Long chains refer to: Perfluorocarboxylic acids (PFCAs) with carbon chain lengths C8 and higher, including perfluorooctanoic acid (PFOA); Perfluoroalkane sulfonic acids (PFSAs) with carbon chain lengths C6 and higher, including perfluorohexane sulfonic acid (PFHxS) and perfluorooctane sulfonate (PFOS); and Precursors of these substances that may be produced or present in products. Accordingly, short chain PFAS include: PFSAs with carbon chain lengths of C5 and lower, including perfluorobutane sulfonic acid (PFBS); PFCAs with carbon chain lengths of C7 and lower, including perfluorohexanoic acid (PFHxA); and Precursors of these substances may be produced or present in products. Examples are shortchain perfluoroalkyl sulfonyl fluoride-based raw materials and short-chain fluorotelomer-based raw materials. 12 Fluorosurfactants are synthetic organofluorine compounds with multiple fluorine atoms. They can be fluorocarbon-based or polyfluorinated (Lehmler, 2005). 13 https://greensciencepolicy.org/wp-content/uploads/2015/04/Presentation-Stefan-Posner-PFAS-April-2015.pdf June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 25 Wood Environment & Infrastructure Solutions UK Limited To identify any potential non-PFAS fluorinated substances used in fire-fighting foams, a literature research in pubmed and google scholar was undertaken, using the following search terms: (("substance" OR "chemical" OR "compound")) AND ("fire fighting foam" OR fire-fighting "fire fighting") As of April 2019, the pubmed search returned 53 hits. However, the relevant hits covered only poly- and perfluorinated compounds. The same result has been found using google scholar. SDS/supplier information, monitoring data, EPAs, NGOs, case studies and legislation were also screened for information on non-PFAS fluorinated substances (simultaneously with the screenings for information on the substance identity of PFAS- and fluorine free-chemicals, discussed below). No non-PFAS fluorinated substances could be identified. In conclusion, the analysis suggests that fluorinated non-PFAS alternatives in the area of fire-fighting foams do not exist. This was confirmed in personal communication by Zhanyun Wang (ETH Zrich), an international expert on PFAS chemicals. It was also discussed and not disputed at the project workshop. Task 1.2: Substance identification - FFF (fluorine-free foams) Because of regulatory pressure and consumer preferences for fluorine-free replacements, a lot of producers of PFAS-containing foams have introduced fluorine-free alternatives. Most of the foams are advertised as intended for use on class B hydrocarbon fuel fires such as oil, diesel and aviation fuels as well as class A fires such as wood, paper, textiles etc. As explained above, various information sources have been reviewed in order to identify any relevant alternative to PFAS in fire-fighting foams. Many of these sources did not provide chemical names or/and CAS/EC numbers. In a lot of sources (e.g. from NGOs, ECHA and Stockholm Convention documents), only very general hints on replacement substances or substance groups have been identified. This includes the naming of the following substance groups: 1. Hydrocarbons; 2. Detergents; 3. Siloxanes; and 4. Protein foams. However, more specific information on substances in FFF was identified in SDS and/or supplier information, some reports published by national authorities, and some peer-reviewed publications. Most relevant information was identified in SDS. As an additional source patents were considered using the google patent search. The results were in most cases the same as for the SDS. A report by the Swedish chemicals agency (KEMI) compiles available knowledge about fire-fighting foams that were available on the Swedish market in 2014, with respect to chemical content, use, handling and disposal14. Scientific peer-reviewed publications by Hetzer et al. highlighted various sugar-based siloxanes (Hetzer, R. et al. ; Hetzer, R. et al. 2014; Hetzer, R. H. und Kmmerlen 2016; Hetzer, R. H. et al. 2015). However, to our knowledge no CAS-numbers are available for these chemical compounds. In the following, the identified substances are presented in more detail. In general, AFFF concentrates are themselves mostly water, with other components such as surfactants, solvents and stabilisers. The lowering of surface tension to allow formation of foam and hence a blanket over the source of fuel, may be accomplished by use of both fluorocarbon and hydrocarbon surfactants. In this context, some of the substances identified in this task are not believed to be direct PFAS- replacements in terms of being a surface 14 https://www.kemi.se/global/pm/2015/pm-6-15.pdf June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 26 Wood Environment & Infrastructure Solutions UK Limited active agent15. In the following, only those substances which were identified by their chemical structure as replacements (R) for PFAS are discussed. It is also possible that some of the identified substances may need to be combined with other substances (for example a hydrocarbon in combination with a detergent) in order to fulfil their capacity as a PFAS-replacement. However, it should be noted that their suitability as alternatives to PFAS-based fire-fighting foams is discussed in more detail in the analysis of alternatives (Section 7). For a better overview, the substances were grouped in the following substance groups: hydrocarbons, siloxanes, protein foams and detergents based on expert judgement. Hydrocarbons In terms of hydrocarbons, a variety of different substances/substance groups were found. This includes for example various fatty acids, xanthan gums, sugars, alcohols, PEGs and alkanes. These substances are found in a variety of different products from different manufacturers. In the following table more information on this is given. This includes the CAS/EC identifier, the substance name, the chemical group, the supplier and respective product name. The chemical group was assigned based on the authors' knowledge and presented and not disputed at the stakeholder workshop". Table 3.1 Identified hydrocarbons (identified by CAS) incl. CAS/EC identifier, the substance name, chemical group and the supplier and/or product name CAS 500-344-6 939-523-2 112-53-8 EC Substance name Chemical group 15762794-6 Alcohols, C10-16, ethoxylated, sulfates, triethanolammonium salts Alcohols Alcohols, C8-10, ethoxylated, sulfates, sodium salts Alcohols 203-982-0 1-Dodecanol Alcohols 112-72-1 204-000-3 Tetradecanol Alcohols 160901-279 500-464-9 Alcohols, C9-11, ethoxylated, sulphates, ammonium salts Alcohols 67762-19-0 500-172-1 Alcohols, C10-16, ethoxylated, sulfates, ammonium salts Alcohols 67762-41-8 272-490-6 tetradecan-1-ol Alcohols Supplier and Product Name N/A (identified via ECHA's dissemination website) N/A (identified via ECHA's dissemination website) Respondol ATF 3-6%: Angus Fire (Angus International: Angus Fire, National Foam and Eau et Feu.) LS xMax: Dafo Fomtec AB STHAMEX 2% F6 Multi-purpose detergent foam: Dr Sthamer STHAMEX-SV/HT 1% F-5 #9142: Dr Sthamer Respondol ATF 3-6%: Angus Fire (Angus International: Angus Fire, National Foam and Eau et Feu.) LS xMax: Dafo Fomtec AB STHAMEX 2% F6 Multi-purpose detergent foam: Dr Sthamer STHAMEX-SV/HT 1% F-5 #9142: Dr Sthamer OneSeven of Germany GmbH. OneSeven Foam Concentrate Class A Kempartner AB: Meteor Allround Ma-13 Angus Fire: Expandol (aka Expandol 1-3), Expandol LT (aka Expanol 1-3LT) 15 Those substances are for example antimicrobial agents that are needed for the biological stability of the foam. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 27 Wood Environment & Infrastructure Solutions UK Limited CAS EC Substance name Chemical group Supplier and Product Name 68131-39-5 500-195-7 Alcohols, C12-15, ethoxylated Alcohols Verde Environmental Inc (Micro Blaze): Micro-Blaze Out 266-929-0 67701-057 Fatty acids, C8-18 and C18unsatd. Fatty Acid/oil N/A (identified via ECHA's dissemination website) 11138-66-2 234-394-2 Xanthan gum 9000-30-0 232-536-8 Cyamopsis gum; Cyanopsis tetragonoloba 9005-25-8 232-679-6 Starch 120962-030 601-748-6 Canola Oil 25322-68-3 500-038-2 Poly(oxy-1,2-ethanediyl),hydro--hydroxy- Ethane1,2-diol, ethoxylated Gum Gum Auxquimia: Phos-Chek 36 Fluorine Free (aka UNIPOL-FF 3/6); Phos-Chek Training Foam 140 Dr Sthamer: Moussol-FF 3/6 FireRein: Eco-Gel Kempartner AB: Unifoam Bio Yellow Verde Environmental Inc (Micro Blaze) : Micro-Blaze Out FireRein: Eco-Gel Hydrocarbon Solberg: US20080196908 Oil Eco-Gel; FireRein Polyethylene glycol Dafo Fomtec AB: Fomtec AFFF 1% F, Fomtec AFFF 3% S, Fomtec AFFF 3% 27252-80-8 608-068-9 ALLYLOXY(POLYETHYLENE OXIDE), METHYL ETHER (9-12 EO) Polyethylene glycol 1% AFFF Denko 3% AFFF Denko 6% AFFF Denko Alcohol AFFF 3% - 6% Single or Double Strength Denko 32612-48-9 608-760-0 Poly(oxy-1,2-ethanediyl), sulfo--(dodecyloxy)-, ammonium salt (1:1) P Polyethylene glycol Orchidee Fire: Orchidex BlueFoam 3x3 73665-22-2 616-006-7 Poly(oxy- 1,2-ethanediyl), .alpha.-sulfo-.omega.hydroxy-C6-10-alkyl ethers, sodium salts Polyethylene glycol Dr Sthamer: STHAMEX 2% F6 Multi-purpose detergent foam, STHAMEX 3% F6 Multi-purpose detergent foam, STHAMEX K 1% F-15 #9143,STHAMEX-SV/HT 1% F-5 #9142, TRAINING FOAM-N 1% F-0 #9141 96130-61-9 619-194-9 Poly(oxy-1,2-ethanediyl), sulfo--hydroxy-, C9-11alkyl ethers, sodium salts Polyethylene glycol Dafo Brand AB: ARC Milj Dafo Fomtec AB: Fomtec AFFF 1% A, Fomtec AFFF 1% F, Fomtec AFFF 1% Plus, Fomtec AFFF 1% Ultra LT, Fomtec AFFF 3%, Fomtec AFFF 3%ICAO, Fomtec AFFF 3% S, , Fomtec A-skum 308-766-0 98283-671 undecyl glucoside Sugar N/A (identified via ECHA's dissemination website) 439-070-6 439-070-6 (2R,3R,4S,5S)-2,3,4,5tetrahydroxyhexanal (2R,3S,4R,5R)-2,3,4,5,6pentahydroxyhexanal (2S,3S,4S,5R)-2,3,4,5tetrahydroxy-6-oxohexanoic acid acetic acid calcium Sugar N/A (identified via ECHA's dissemination website) June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 28 Wood Environment & Infrastructure Solutions UK Limited CAS EC Substance name Chemical group dihydride hydrate magnesium dihydride potassium hydride sodium hydride 110615-479 600-975-8 Alkylpolyglycoside C10-16 Sugar 54549-25-6 259-218-1 (3R,4S,5S,6R)-2-(decyloxy)-6(hydroxymethyl)oxane-3,4,5triol Sugar 68515-73-1 500-220-1 Alkyl polyglucoside Sugar N/a 917-341-4 AAlkyl polyglucoside Sugar Supplier and Product Name Orchidee Fire: Orchidex BlueFoam 3x3 Unifoam Bio Yellow Dafo Brand AB: ARC Milj Dafo Fomtec AB: Enviro 3x3 Plus, Enviro 3x3 Ultra, Enviro 3x6 Plus, Environ 6x6 Plus, LS aMax, MB -20, Trainer E-lite, Fomtec AFFF 1% A, Fomtec AFFF 1% F, Fomtec AFFF 1% Plus, Fomtec AFFF 1% Ultra LT, Fomtec AFFF 3% ICAO, Fomtec AFFF 3% S, Fomtec AFFF 3% OneSeven of Germany GmbH: OneSeven Foam Concentrate Class B-AFFF vs FOCUM: Silvara APC 3x6 Solberg: US20080196908 Detergents Chemically, detergents belong to the group of hydrocarbons, however in the context of this project this substance group is considered separately. This group is characterised by their amphiphilic nature, being partly hydrophilic (polar) and partly hydrophobic (non-polar). The polar headgroup is needed to ensure their action on surfaces/interfaces (formation of micelles, lowering of the surface tension of water). The substances identified in this group, cover various alkanes that differ in the carbonic chain length (e.g. decyl, lauryl) and the head group (e.g. betaine, sulphates, amido betaines, triethanolamines). A betaine is a quaternary ammonium compound having three methyl groups. This pattern is to some extent similar to those of the poly- and perfluorinated substances, in which an F-atom replaces the H-atom. In Figure 3.1 sodium octyl sulphate is shown, this substance has been identified in at least ten individual products from several suppliers as an alternative to PFAS substances. The polar head group is highlighted in red and the non-polar alkaline chain is highlighted in blue. It should be noted, that also PFAS-containing AFFF may also contain some of these detergents (for example STHAMEX -AFFF 3%). Figure 3.1 Chemical structure of sodium octyl sulphate June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 29 Wood Environment & Infrastructure Solutions UK Limited Table 3.2 Identified detergents (identified by CAS) incl. CAS/EC identifier, the substance name, chemical group and the supplier and/or product name CAS 308062-28-4 68155-09-9 70592-80-2 269-087-2 1469983-49-0 147170-44-3 61789-40-0 EC Substance name Chemical group 608-528-9 / 931-292-6 Amines, C12-14 (even numbered) alkyldimethyl, N-oxides Alkylamine 268-938-5 274-687-2 68187-32-6 939-455-3 604-575-4 / 931-333-8 931-296-8 Amides, coco, N-(3(dimethylamino)propyl), N-oxides Alkylamine Amines, C10-16alkyldimethyl, N-oxides Alkylamine l-Glutamic acid, N-coco acyl derivs., monosodium salts Alkylamine 1-Propanaminium, N(3-aminopropyl)-2hydroxy-N,N-dimethyl3-sulfo-, N-(C8-18(even numbered) acyl) derivs., hydroxides, inner salts Alkylbetaine 1-Propanaminium, 3amino-N(carboxymethyl)-N,Ndimethyl-, N-(C818(even numbered) and C18 unsaturated acyl) derivs., hydroxides, inner salts Alkylbetaine 1-Propanaminium, 3amino-N(carboxymethyl)-N,Ndimethyl-, N-(C1218(even numbered) acyl) derivs., hydroxides, inner salts Alkylbetaine Supplier and Product Name Dafo Fomtec AB: Enviro 3% ICAO, Enviro USP Dr Sthamer: vaPUREx LV 1% F-10 #7141 Angus Fire: Syndura (6% fluorine free foam) Angus Fire: Syndura (6% fluorine free foam) Dafo Fomtec AB: Enviro 3x3 Plus, Enviro 3x3 Ultra, Enviro 3x6 Plus, Environ 6x6 Plus, LS aMax, Silvara APC 1 Dr Sthamer: MOUSSOL-FF 3/6 F15 #7941 OneSeven of Germany GmbH: OneSeven Foam Concentrate Class A Solberg: Solberg Patent US20080196908 64265-45-8 68139-30-0 13150-00-0 264-761-2 268-761-3 236-091-0 N-(2-hydroxyethyl)-N[2-[(1oxooctyl)amino]ethyl]-alanine Alkylbetaine Cocamidopropyl hydroxysultaine Alkylbetaine Sodium 2-[2-[2(dodecyloxy)ethoxy]eth oxy]ethyl sulphate Alkylsulfate vs FOCUM: Silvara APC 1, Silvara APC 3x3, Silvara APC 3x6, Silvara ZFK (0.5%) Solberg: US20080196908 Kempartner AB : Unifoam Bio Yellow June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 30 Wood Environment & Infrastructure Solutions UK Limited CAS 139-96-8 142-31-4 EC 205-388-7 205-535-5 Substance name Chemical group 2-[bis(2hydroxyethyl)amino]eth anol; dodecyl hydrogen sulfate Alkylsulfate Sodium octyl sulphate Alkylsulfate Supplier and Product Name Dr Sthamer: Sthamex SVM Dr Sthamer: MoussolFF 3/6 Kempartner AB: Unifoam S Kempartner AB: Unifoam OneSeven of Germany GmbH: OneSeven Foam Concentrate Class B-AFFF vs FOCUM: Silvara 1 (1%) vs FOCUM: Silvara APC 1 vs FOCUM: Silvara APC 3x3 vs FOCUM: Silvara ZFK (0.5%) Angus Fire (Angus International: Angus Fire, National Foam and Eau et Feu.) : Syndura (6% fluorine free foam) Chemguard: 3% AFFF Foam Concentrate (C303) Chemguard: 3% Low Temp AFFF (C3LT) Dafo Brand AB: AFFF 36 % Fire Services Plus: FireAde Fire Services Plus: FireAde AR AFFF OneSeven of Germany GmbH: OneSeven Foam Concentrate Class B-AFFF OneSeven of Germany GmbH: OneSeven Foam Concentrate Class B-AFFF-AR Solberg : Solberg Patent US20080196908 Dr Sthamer: TRAINING FOAM-N 1% F-0 #9141 vs FOCUM: Silvara ZFK (0.5%) June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 31 Wood Environment & Infrastructure Solutions UK Limited CAS 142-87-0 EC 205-568-5 143-00-0 151-21-3 2235-54-3 25882-44-4 205-577-4 205-788-1 218-793-9 247-310-4 273-257-1 287-809-4 3088-31-1 68955-19-1 85586-07-8 221-416-0 June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 Substance name Chemical group Sodium decyl sulfate Alkylsulfate Dodecyl hydrogen sulfate;2-(2hydroxyethylamino)etha nol Alkylsulfate Sodium dodecyl sulphate Alkylsulfate Ammonium alkyl ether sulphate Alkylsulfate disodium;4-[2(dodecanoylamino)etho xy]-4-oxo-3sulfonatobutanoate Alkylsulfate Sulfuric acid, monoC12-18-alkyl esters, sodium salts Sulfuric acid, monoC12-14-alkyl esters, sodium salts Alkylsulfate Alkylsulfate Sodium 2-(2dodecyloxyethoxy)ethyl sulphate Alkylsulfate Supplier and Product Name Chemguard: 3% AFFF Foam Concentrate (C303) Chemguard: 3% Low Temp AFFF (C3LT) Chemguard: 6% AFFF Foam Concentrate (C603) Chemguard: 6% Low Temp AFFF (C6LT) Dafo Brand AB: AFFF 36 % Dafo Fomtec AB: LS xMax Dafo Fomtec AB: MB 20 Solberg : Solberg Patent US20080196908 Dr Sthamer: TRAINING FOAM-N 1% F-0 #9141 vs FOCUM: Silvara 1 (1%) Solberg : Solberg Patent US20080196908 Solberg: US20080196908 Fire Services Plus: FireAde; FireAde AR AFFF Kempartner AB: Unifoam, Unifoam S Angus Fire (Angus International: Angus Fire, National Foam and Eau et Feu.) : Expandol (aka Expandol 1-3), Expandol LT (aka Expanol 1-3LT) N/A (identified via ECHA's dissemination website) N/A (identified via ECHA's dissemination website) Buckeye Fire Equipment Company: Buckeye High Expansion Foam (BFC-HX) (aka Hi-Ex 2.2) 32 Wood Environment & Infrastructure Solutions UK Limited CAS 577-11-7 68081-96-9 68439-57-6 EC 209-406-4 268-364-5 Substance name Chemical group 1,4-bis(2-ethylhexoxy)1,4-dioxobutane Alkylsulfate Sulfuric acid, monoC10-16-alkyl esters, ammonium salts Alkylsulfate 931-534-0, 270-407-8 Sulfonic acids, C14-16alkane hydroxy and C14-16-alkene, sodium salts Alkylsulfate 68877-55-4 272-563-2 68877-55-4 272-563-2 68891-38-3 500-234-8 Sodium 3-[2-(2-heptyl4,5-dihydro-1Himidazol-1-yl)ethoxy] propionate Alkylsulfate Sodium 3-[2-(2-heptyl4,5-dihydro-1Himidazol-1-yl)ethoxy] propionate Alkylsulfate Sodium laureth sulfate Alkylsulfate 85338-42-7 85665-45-8 286-718-7, 939-332-4 939-262-4 Sulfuric acid, mono-C810 (even numbered)alkyl esters, sodium salts Alkylsulfate Sulfuric acid, mono-C814 (even numbered)alkyl esters, compds. with triethanolamine Alkylsulfate June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 Supplier and Product Name Dr Sthamer: STHAMEX K 1% F-15 #9143 Orchidee Fire: Orchidex BlueFoam 3x3 Verde Environmental Inc (Micro Blaze): Micro-Blaze Out Dafo Fomtec AB: Enviro 3x3 Plus, Enviro 3x6 Plus, Environ 6x6 Plus Dr Sthamer: STHAMEX 3% F6 Multi-purpose detergent foam, STHAMEX K 1% F-15 #9143 vaPUREx LV 1% F-10 #7141 OneSeven of Germany GmbH: OneSeven Foam Concentrate Class B-AFFF, OneSeven Foam Concentrate Class B-AFFF-AR OneSeven of Germany GmbH: OneSeven Foam Concentrate Class B-AFFF, OneSeven Foam Concentrate Class B-AFFF-AR Angus Fire: Expandol (aka Expandol 1-3), Expandol LT (aka Expanol 1-3LT), Respondol ATF 3-6% Dafo Fomtec AB: Enviro 3% ICAO, Enviro USP, LS xMax, Trainer E-lite Angus Fire: Respondol ATF 3-6% Dafo Fomtec AB: Enviro 3x3 Ultra, LS aMax Dr Sthamer: MOUSSOL-FF 3/6 F15 #7941, MOUSSOL- FF 3/6 F-5 #7942, STHAMEX 2% F6 Multi-purpose detergent foam, STHAMEX-SV/HT 1% F5 #9142, TRAINING FOAM-N 1% F-0 #9141 33 Wood Environment & Infrastructure Solutions UK Limited CAS 90583-18-9 90583-25-8 N/a N/a 4292-10-8 EC Substance name Chemical group 939-265-0, 292-216-9 Sulfuric acid, C12-14 (even numbered)-alkylesters, compds. with triethanolamine Alkylsulfate 292-224-2 919-131-8 944-611-9 224-292-6 Sulfuric acid, mono-C612-alkyl esters, sodium salts Alkylsulfate Fatty alcohol polyglycol ether sulfate, sodium salt Alkylsulfate Reaction mass of Cisodecyl and Cisoundecyl sulphonatosuccinate Alkylsulfate (carboxymethyl)dimethy l-3-[(1oxododecyl)amino]prop ylammonium hydroxide Detergent Supplier and Product Name Dafo Fomtec AB: Enviro 3% ICAO, Enviro USP OneSeven of Germany GmbH: OneSeven Foam Concentrate Class A vs FOCUM: Silvara APC 3x6 Unifoam Bio Yellow BASF: Emulphor FAS 30 Respondol ATF 3-6% vs FOCUM: Silvara 1 (1%), Silvara ZFK (0.5%) Siloxanes A limited number of siloxanes were identified in this task, this might be because the usage of this substance group is still in the phase of development. This is further explained in the following. Only one substance belonging to siloxanes could be identified by CAS number. This substance is a mixture of siloxanes and silicones (CAS 117272-76-1). It was found in products by Denko, namely: 1% AFFF; 3% AFFF; 6% AFFF; Alcohol AFFF 3% - 6% Single or Double Strength. Judging by the name, it could be that these substances were used in combination with fluorinated substances. However, for the sake of completeness the substance is named although it is not used as a PFAS-replacement. This information is shown in the table below, where also the chemical structure is shown. Table 3.3 Siloxanes (identified by CAS) incl. CAS/EC identifier, the substance name, chemical group and the supplier and/or product name CAS EC 117272-761 601-468-4 Substance name Chemical group Siloxanes and Silicones, 3-hydroxypropyl Me, ethers with polyethylene glycol mono-Me ether Siloxanes Supplier & Product Name Chemical structure 1% AFFF Denko 3% AFFF Denko 6% AFFF Denko Alcohol AFFF 3% 6% Single or Double Strength Denko In addition, publications by Hetzer et al. presented various sugar-based siloxanes for which CAS-numbers are not available. For a better understanding, in Figure 3.2 a sugar-based siloxane, as presented by Hetzer et al., is shown. It is important to note that these substances are used without further addition of PFAS substances. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 34 Wood Environment & Infrastructure Solutions UK Limited The most recent publication by these researchers states that siloxane-based firefighting foam concentrate shows an extinguishing performance which significantly surpasses the commercial PFAS-free foams (whereby the actual product is not named) and nearly meets the performance of the PFAS-containing AFFF in fire suppression tests based on the NATO standard fuel F-34 (class B fire). However, no commercial product containing these substances was identified in this task. Regarding their persistency, some siloxanes are known SVHC, having identified PBT and/or vPvB properties (cyclic D4, D5, D6) and others (linear) are currently undergoing PBT-assessment (e.g. octamethyltrisiloxane). In this context, the publications highlight that the formation of the desired product and its purity were verified after the filtration process. No more information is available at this time. Figure 3.2 Sugar-based siloxane as described by Hetzer et al. For more information on these substances please refer to the individual publications (Hetzer, R. et al. ; Hetzer, R. et al. 2014; Hetzer, R. H. und Kmmerlen 2016; Hetzer, R. H. et al. 2015). Proteins Regarding protein-based foams also only one substance with a CAS number could be identified. This belongs to silk-based protein hydrolysate (CAS 306-235-8). However, the associated product/foam manufacturer was not identified. Some SDS mention proteins from horn and hoof (National Foam) or hydrolysed protein (Gepro Group PROFOAM 806G). In these cases, no CAS number was given. The sources mentioning horn and hoof-based proteins also recommended that these should not be used because of the risk of epizootic diseases. Task 1.3: Substance identification - PFAS Generally, most information on PFAS in fire-fighting foams was found in the scientific literature. This is partially due to the fact that SDS and supplier information only indicate general terms like "fluorinated surfactant" without naming a CAS number and/or referring to propriety information. Environmental agencies mostly also cite scientific literature, so this information overlaps with substances already identified in the review of scientific literature. This is also true for information from legislation (REACH, Stockholm, Basel Convention). When searched in pubmed and google scholar, the following search terms were used: ("fluorochemical*" OR "per- and polyfluoroalkyl" OR "perfluoroalkyl" OR "polyfluoralkyl" OR "fluorinated" OR "PFAS") AND ("fire fighting" OR "airport" OR "fire") As of April 2019, this search yielded 86 hits. Those publications were mostly highly relevant, and the substance details were extracted into excel sheets relevant for the next working steps. An additional source of information is case studies and monitoring activities. However, these are considered to be of less importance because mostly only a very limited variety of PFAS substances was covered. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 35 Wood Environment & Infrastructure Solutions UK Limited Additionally, when environmental/human samples are considered, for fluorinated foams, also environmental and biological degradation processes need to be considered. For example, it is known that perfluorosulfonamides, undergo abiotic degradation as well as in vivo and in vitro biotransformation (DanEPA 2015). With regards to the substances identified in the scientific literature, for a large share it was not possible to find a CAS/EC number. Sixty-three substances were identified by CAS/EC number, while around 213 were only identified by substance name/structure. This lack of CAS numbers may be due to the fact that those substances have been described for the first time by the respective author or are perhaps polymeric substances that do not necessarily have CAS numbers. In general, these numbers might also indicate that a lot of substances have been used that are currently poorly known. The following information relates only to those substances that were fully identified in terms of CAS/EC, substance name and/or acronym. Based on the CAS-identified PFAS-substances that were/are used in AFFF the following grouping is possible, indicated in brackets is the number of CAS-identified substances: Unsubstituted long chain PFAS (14); Unsubstituted short chain PFAS (8); Substituted short and long chain PFAS (12); Fluorotelomers (22); and Others (7). Long Chain PFAS The group of long chain PFAS (defined by OECD as perfluorosulfonic acids (PFSAs) with C6 and perfluorocarboxylic acids (PFCAs) with C8) encompasses the following substances: PFSAs with C6 PFHxS (C6); PFHpS (C7); PFOS (C8); PFNS (C9); PFDS (C10); and PFUnDS (C11). As can be seen in the table below, the identified sulfonic acids exhibit chain length up to 11 perfluorinated carbons. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 36 Wood Environment & Infrastructure Solutions UK Limited Table 3.4 PFSAs (identified by CAS) with C6 incl. CAS/EC identifier, the designation, the acronym and the supplier and/or product name CAS 355-46-4 EC Designation (synonyms) Acronym 206-587-1 Perfluorohexane sulfonic acid PFHxS 375-92-8 206-800-8 perfluoroheptane sulfonic acid PFHpS 1763-23-1 217-179-8 Perfluorooctanesulfonic acid PFOS 68259-12- N/a 1 Perfluoronone sulfonic acid PFNS 335-77-3 206-401-9 Perfluorodecanesulfonic acid PFDS 749786- N/a 16-1 Perfluoroundecan sulfonic acid PFUnDS Supplier and Product Name Ansul AFFF Ansulite 3M LightWater Angus Fire, N/a Angus Fire, 2000 ; Niagara 1-3, Angus Fire, 1997; Forexpan Angus Fire, 2007; Hi Combat A TM 3M, 2005; ATC-603 Light water ATC3 3M, 1999; FC-203FC Light water Brand AFFF 3M 1999 3M 1992 3M 1993 3M 1998 (slightly different shares) 3M 1989 3M 1988 3M 1992 3M 1993 3M 1998 (slightly different shares) 3M 1989 3M 1988 3M AFFF ("PFSAs have been components of 3M AFFF from the 1970s to 2001") 3M LightWater FC-203FC 3M, 2005; ATC-603 Light water ATC3 3M, 1999; FC-203FC Light water Brand AFFF 3M 1992 3M 1993 3M 1998 (slightly different shares) 3M 1988 3M 1989 Ansul Ansulite AFFF Angus Fire, N/a Angus Fire, 2000 ; Niagara 1-3, Angus Fire, 1997; Forexpan Angus Fire, 2007; Hi Combat A TM Hazard Control Technologies, Inc., 2003 F-500 Dr. Sthamer STHMEX-AFFF 3% 3 M Lightwater PFSAs have been components of 3M AFFF from the 1970s to 2001 3M Ansul AFFF Angus Fire, N/a Fomtec MB 5 No product/supplier is mentioned; Publications are based on environmental samples June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 37 Wood Environment & Infrastructure Solutions UK Limited The identified PFCAs encompass the following substances: PFCAs with C8: PFOA (C8); PFNA (C9); PFDA (C10); PFUnDA (C11); PFDoDA (C12); PFTrDA (C13); PFTeDA (C14); and PFOcDA (C18). The carboxylic acids exhibit chain length up to 18 perfluorinated carbons. All of the substances were identified in various "old" products (newest product is from 2007) from different manufacturers. This can be seen in the table below. Table 3.5 PFCAs (identified by CAS) with C8 incl. CAS/EC identifier, the designation, the acronym and the supplier and/or product name CAS 335-67-1 375-95-1 EC Designation (synonyms) 206-397-9 Perfluorooctanoic acid Acronym PFOA 206-801-3 Perfluorononanoic acid PFNA Supplier and Product Name Ansul AFFF Ansulite 3M LightWater Angus Fire, N/a Angus Fire, 2000 ; Niagara 1-3, Angus Fire, 1997; Forexpan 3M, 2005; ATC-603 Light water ATC3 3M, 1999; FC-203FC Light water Brand AFFF 3M 1999 3M 1992 3M 1993 3M 1998 (slightly different shares) 3M 1989 3M 1988 OneSeven B-AR ARC Milj Towalex plus Towalex 3x3 Towalex 3% super Towalex 3% master Sthamex AFFF-P 3% FC-203FC Light Water 3M Ansul AFFF Ansulite 3M LightWater Angus Fire, N/a Angus Fire, 2000 ; Niagara 1-3, Angus Fire, 1997; Forexpan OneSeven B-AR ARC Milj Towalex 3x3 Towalex 3% master Hazard Control Technologies, Inc., 2003 F-500 June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 38 Wood Environment & Infrastructure Solutions UK Limited CAS 335-76-2 EC Designation (synonyms) 206-400-3 Perfluorodecanoic acid 2058-94-8 218-165-4 Perfluoroundecanoic acid 307-55-1 206-203-2 Perfluorododecanoic acid 72629-948 276-745-2 Perfluorotridecanoic acid 376-06-7 N/a Perfluorotetradecanoic acid 16517-116 240-582-5 Perfluorostearic acid Acronym PFDA PFUnDA PFDoDA PFTrDA PFTeDA PFODA Supplier and Product Name Ansul AFFF Ansulite 3M LightWater 3M FC-203FC Light Water Fomtex Arc 3x3 Towalex plus Towalex 3x3 Towalex 3% master 3M LightWater 3M LightWater FC-203FC Ansul Ansulite ANSUL Ansulite 6 % AFFF (Formula 1559-22 ICAO-B) Ansul AFFF Ansulite 3M LightWater Sthamex F-15 Towalex 3% master PFCAs were primary components in early 3M AFFFs from 1965 up to 1986 3M AFFFs from 1965 up to 1987 Ansul AFFF FC-203FC Light Water 3M No product/supplier is mentioned; Publications are based on environmental samples Short chain PFAS Short chain PFAS were also identified in this study, namely: PFSAs with C<6: PFEtS (C2); PFPrS (C3); PFBS (C4); and PFPeS (C5). The list below shows that the identified sulfonic acids cover chain lengths from C2-C5. Table 3.6 CAS 354-88-1 423-41-6 PFSAs (identified by CAS) with <C6 incl. CAS/EC identifier, the designation, the acronym and the supplier and/or product name EC Designation (synonyms) Acronym N/a Perfluoroethane sulfonic PFEtS acid N/a Perfluoropropane sulfonic acid PFPrS Supplier and Product Name 3M AFFFs Shorter chains C2-C3 PFSAs used in from 1988 to 2001 3M AFFFs Shorter chains C2-C3 PFSAs used in from 1988 to 2001 June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 39 Wood Environment & Infrastructure Solutions UK Limited CAS 375-73-5 EC Designation (synonyms) 206793-1 Perfluorobutanesulfonic acid Acronym PFBS 2706-91-4 220301-2 Perfluoropentane sulfonic acid PFPeS Supplier and Product Name Ansul AFFF Ansulite 3M LightWater Angus Fire, N/a Angus Fire, 2000 ; Niagara 1-3, Angus Fire, 1997; Forexpan Angus Fire, 2007; Hi Combat A TM 3M, 2005; ATC-603 Light water ATC3 3M, 1999; FC-203FC Light water Brand AFFF 3M 1999 3M 1992 3M 1993 3M 1998 (slightly different shares) 3M 1989 3M 1988 No product/supplier is mentioned; Publications are based on environmental samples Also carboxylic acids have been identified. Contrary to the sulfonic acids, the carboxylic acids were only found starting from C4. PFCAs with < C8: PFBA (C4); PFPeA (C5); PFHxA (C6); and PFHpA (C7); In the table below, the short chain PFCAs are shown. Table 3.7 CAS 375-22-4 PFCAs (identified by CAS) with <C8 incl. CAS/EC identifier, the designation, the acronym and the supplier and/or product name EC Designation (synonyms) 206-786-3 perfluoro-n-butanoic acid Acronym Supplier and Product Name PFBA Ansul AFFF Ansulite 3M LightWater Angus Fire, N/a Angus Fire, 2000 ; Niagara 1-3, Angus Fire, 1997; Forexpan Angus Fire, 2007; Hi Combat A TM 3M, 2005; ATC-603 Light water ATC3 3M, 1999; FC-203FC Light water Brand AFFF OneSeven B-AR ARC Milj Towalex 3x3 Towalex 3% master Sthamex AFFF-P 3% June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 40 Wood Environment & Infrastructure Solutions UK Limited CAS 2706-90-3 307-24-4 375-85-9 EC Designation (synonyms) 220-300-7 Perfluoropentanoic acid Acronym PFPeA 206-196-6 Perfluorohexanoic acid PFHxA 206-798-9 Perfluoroheptanoic acid PFHpA Supplier and Product Name 3M LightWater FC-203FC 3M 1999 3M 1992 3M 1993 3M 1998 (slightly different shares) 3M 1989 3M 1988 Angus Fire, 2000 ; Niagara 1-3, Angus Fire, 1997; Forexpan Ansul AFFF Ansulite Ansul AFFF Ansulite 3M LightWater Angus Fire, N/a Angus Fire, 2000 ; Niagara 1-3, Angus Fire, 1997; Forexpan 3M, 2005; ATC-603 Light water ATC3 3M, 1999; FC-203FC Light water Brand AFFF 3M 1999 3M 1992 3M 1993 3M 1998 (slightly different shares) 3M 1989 3M 1988 OneSeven B-AR ARC Milj Towalex plus Towalex 3x3 Towalex 3% super Towalex 3% master Sthamex AFFF-P 3% Ansul AFFF Ansulite 3M LightWater Angus Fire, N/a Angus Fire, 2000 ; Niagara 1-3, Angus Fire, 1997; Forexpan Angus Fire, 2007; Hi Combat A TM Angus Fire, 2004 Tridol S 3 % 3M, 2005; ATC-603 Light water ATC3 3M, 1999; FC-203FC Light water Brand AFFF FC-203FC Light Water 3M OneSeven B-AR ARC Milj Towalex 3x3 Towalex 3% master Sthamex AFFF-P 3% In general, both short and long chain PFAS were identified as substances used in AFFF. One author highlights that PFCAs were primary components in early 3M AFFFs from 1965 up to 1986 (Barzen-Hanson und Field 2015). Derivates of perfluoroalkyl sulfonic PFAS (also PASF-based substances) All the named substances above are characterized by a perfluorinated alkaline carbon chain that is connected to a sulfonic- or carboxylic acid head group. In other PFAS substances, this head group is also equipped with additional chemical groups. This group is also called perfluroalkane sulfonyl fluoride substances (PASF), as June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 41 Wood Environment & Infrastructure Solutions UK Limited their synthesis is based on perfluroalkane sulfonyl fluoride. This can be for example an amide (sometimes methylated or ethylated). The chemical formulae of this group can be summarised as: Perfluoroalkane sulfonyl fluoride (PASF) = CnF2n+1SO2F; and PASF-based derivates = CnF2n+1SO2-R, where R = NH, NHCH2CH2OH, etc. However, in most cases, these substances were not found when the actual foam was tested but rather when environmental samples were tested. In addition, some of the substances are also known to be environmental transformation products. Other substances are raw materials for surfactant and surface protection products (EtFOSE and N-MeFOSe) (Buck et al. 2011). In this sub group, the following substances were found: PFOSaAm; C7-FASA (PFHpSA); C8-PFSiA (PFOSI); EtFOSAA; EtFOSE; FBSA; FOSA; FOSAA; FOSE; N-MeFOSA; N-MeFOSE; PFBSaAm; N-[3-(Dimethyloxidoamino)propyl] -3,3,4,4,5,5,6,6,7,7,8,8,8-Tridecafluor-1-octanesulfonamid; and (Carboxymethyl)dimethyl [3- (gamma-omega-perfluor-1-C6-14- Alkansulfonamid)propyl)ammonium. In addition, some of those compounds are known PFOS-precursors (for example PFOSaAm, EtFOSAA, PFOSI, EtFOSE). Table 3.8 Identified derivates of perfluoroalkyl sulfonic PFAS (also PASF-based substances) CAS 13417-01-1 167398-54-1 EC 236-513-3 N/a Designation (synonyms) PPerfluoroalkyl sulfonamido amines Acronym PFOSaAm Perfluoroheptane sulfonamidoethanol C7-FASA (PFHpSA) Supplier and Product Name National Foam ; Ansulite; 3M lightwater; 3M 3 M Lightwater was used from 1988 until 2001 OR Ansul (telomerbased foam) June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 42 Wood Environment & Infrastructure Solutions UK Limited CAS EC 647-29-0 N/a 2991-50-6 / 1336-61-4 221-061-1 4151-50-2 223-980-3 68298-12-4 N/a 2806-24-8 N/a 754-91-6 212-046-0 10116-92-4 N/a 2355-31-9 N/a 24448-09-7 246-262-1 68555-77-1 271-455-2 80475-32-7 279-481-6 Designation (synonyms) N/a Acronym C8-PFSiA (PFOSI) N-Ethyl perfluorooctane sulfonamidoacetic acid EtFOSAA N-Methyl perfluorooctane sulfonamidoacetic acid EtFOSE NMethylperfluorobutanes ulfonamide FBSA perfluorooctane sulfonamido acetic acid FOSAA Perfluorooctane sulfonamide FOSA N/a FOSE N-methyl perfluorooctanesulfona midoacetic acid N-MeFOSA N-Methyl perfluorooctane sulfonamidoethanol N-MeFOSE perfluoroalkyl sulfonamido amines PFBSaAm N-[3- N/a (Dimethyloxidoamino)p ropyl] - 3,3,4,4,5,5,6,6,7,7,8,8,8- Tridecafluor-1- octanesulfonamid Supplier and Product Name 3M 1988 3M 1989 No product/supplier is mentioned; Publications are based on environmental samples No product/supplier is mentioned; Publications are based on environmental samples No product/supplier is mentioned No product/supplier is mentioned; Publications are based on environmental samples No product/supplier is mentioned; Publications are based on environmental samples No product/supplier is mentioned; Publications are based on environmental samples No product/supplier is mentioned; Publications are based on environmental samples No product/supplier is mentioned; Publications are based on environmental samples No product/supplier is mentioned; Publications are based on environmental samples Dupont, Forafac 1183 June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 43 Wood Environment & Infrastructure Solutions UK Limited CAS EC 133875-90-8 N/a Designation (synonyms) Acronym (Carboxymethyl)dimeth N/a yl [3- (gamma-omegaperfluor-1-C6-14Alkansulfonamid)propyl )ammonium (inneres Salz) Supplier and Product Name Dupont, Forafac 1203 In addition to the tables above, the identified substances and their respective chemical relationship can be visualised in terms of a hierarchical clustering. This is shown in the figure below. Figure 3.3 Hierarchical clustering of the identified short-, long-chain and substituted PFAs substances Fluorotelomers Fluorotelomers are defined by having an additional non-fluorinated spacer between the perfluorinated alkyl chain and the charged head group (denotated as number of perfluorinated carbons: number of nonfluorinated carbons). The fully identified substances (i.e. by CAS/EC number) are shown in Table 3.9. As shown in the table below, the 22 identified fluorotelomers cover a wide range of positively/negatively charged head groups or combinations of those. Most of the fully identified substances, exhibit the xx:2 structure, where two non-fluorinated carbon atoms are inserted between the perfluorinated carbon chain and the head group. However, in the case of fluorotelomer betaines also xx:1:2 and xx:3 are found. In the June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 44 Wood Environment & Infrastructure Solutions UK Limited latter case, three non-fluorinated carbon atoms are inserted between the perfluorinated carbon chain and the head group. In the case of the xx:1:2 substances, an additional fluorinated carbon is inserted between the perfluorinated alkyl chain and the non-fluorinated spacer. Based on the manufacturing dates that are cited in the respective publications, it can be assumed that the use of fluorotelomers in fire-fighting foams began later than the use of traditional PFAS substances without a non-fluorinated spacer. The following head groups have been identified: Alkylbetaine (AB); Betaine (B); Carboxylic acid (CA); Hydroxy (OH); Thioamido sulfonates (TAoS); Unsaturated carboxylic acid (UCA); Sulfonamido betaines (SaB); Sulfonamide amine (SaAm); and Thio hydroxy ammonium (THN+). Table 3.9 Fluorotelomer (identified by CAS) substances incl. CAS/EC identifier, the designation, the acronym and the supplier and/or product name CAS EC 34455-35-1 N/a 53826-13-4 N/a 70887-84-2 N/a 278598-45-1 N/a Designation (synonyms) 10:2 Fluorotelomer sulfonamide alkylbetaine Acronym 10:2 FTAB 10:2 Fluorotelomer carboxylic acid 10:2 FTCA 10:2 fluorotelomer unsaturated carboxylic acid 10:2 FTUCA Fluorotelomer sulfonamido betaines 12:2 FtSaB Supplier and Product Name F-500, Hazard Control Tech., 1997 National Foam 2005 National Foam 2007 National Foam 2008 Fire Service Plus AFFF 2011 National Foam 20032008 No product/supplier is mentioned; Publications are based on environmental samples No product/supplier is mentioned; Publications are based on environmental samples 3M Ansul, 2006 Ansul Anulite ARC June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 45 Wood Environment & Infrastructure Solutions UK Limited CAS 757124-72-4 EC 816-391-3 Designation (synonyms) Fluorotelomer sulfonates Acronym 4:2 FTS 1432486-88-8 N/a 4:2 fluorotelomer thioamido sulfonates 4:2 FtTAoS 171184-02-4 N/a 171184-14-8 34455-29-3 N/a 252-046-8 5:1:2 fluorotelomer betaine 5:1:2 FTB 5:3 fluorotelomer betaine 6:2 Fluorotelomer sulfonamide betaine 5:3 FTB 6:2 FTAB 647-42-7 211-477-1 6:2 Fluorotelomer alcohol 6:2 FTOH Supplier and Product Name Angus Fire, 2004 Tridol S 3% Ansul 2002 Anslite 3% AFFF-DC-6 Hazard Control Tech 1197 F-500 National Foam Ansul AFFF formulations Angus Fire, 2004 Tridol S Ansul, 2002 Ansulite 3% AFFF DC-3 Ansul, 2006 Ansul Anulite ARC Hazard Control Tech., 1997 F-500 Chemguard Ansul Angus 3M Ansul, 2002 Ansulite 3% AFFF DC-3 Buckeye 2009 Buckeye AFFF 2004 3M Buckeye Chemours, STHAMEX -AFFF 3% F-15 #4341 Dupont Forafac 1157 Dr. Sthamer, 3M National Foam F-500, Hazard Control Tech., 1997 (Foam 1) Angus Fire, 2004 Tridol S Angus Fire, 2000 Niagara 1-3 Chemours No product/supplier is mentioned; Publications are based on environmental samples June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 46 Wood Environment & Infrastructure Solutions UK Limited CAS 27619-97-2 EC 248-580-6 Designation (synonyms) Acronym 6:2 Fluorotelomer Sulfo nate 6:2 FTS 1383438-86-5 N/a 88992-47-6 N/a 6:2 fluorotelomer sulfonamide amine 6:2 FtSaAm 6:2 fluorotelomer thioether amido sulfonic acid 6:2 FtTAoS 88992-46-5 N/a 171184-03-5 N/a 171184-15-9 N/a 27854-31-5 N/a 6:2 fluorotelomer thio hydroxy ammonium 7:1:2 fluorotelomer betaine 7:3 fluorotelomer betaine 6:2 FtTHN+ 7:1:2 FTB 7:3 FTB 8:2 Fluorotelomer carboxylic acid 8:2 FTCA Supplier and Product Name Dr. Richard Sthamer GmbH & Co. KG STHMEX-AFFF 3% Hazard Control Tech., 1997 F-500 Angus Fire, 2004 Tridol S 3 % Angus Fire, 2000 ; Niagara 1-3, Angus Fire, 1997; Forexpan Angus Fire, 2004 Tridol S 3 % Ansul, 2002 Ansulite 3 % AFFF - DC-4 Ansul, 2006; Ansul Anulite ARC National Foam 2005 National Foam 2007 National Foam 2008 (slightly different shares) 3M, National Foam 2005 National Foam 2007 National Foam 2008 (slightly different shares) Angus Fire, 2004 Tridol S Ansul 1986 Ansul 1987 Angus Fire, 2000 Niagara 1-3 Ansul, 2002 Ansulite 3% AFFF DC-3 Ansul 2009 Ansul 2010 Chemguard 2008 F-500, Hazard Control Tech., 1997 3M 3M Buckeye 2009 Buckeye Ansul, 2002 Ansulite 3% AFFF DC-3 F-500, Hazard Control Tech., 1997 June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 47 Wood Environment & Infrastructure Solutions UK Limited CAS EC 34455-21-5 N/a 39108-34-4 254-295-8 1383439-45-9 N/a 171184-04-6 N/a 171184-16-0 N/a Designation (synonyms) 8:2 Fuorotelomer sulfonamide betaine Acronym 8:2 FTAB Fluorotelomer sulfonates 8:2 FTS 8:2 fluorotelomer thioamido sulfonates 8:2 FtTAoS 9:1:2 fluorotelomer betaine 9:3 fluorotelomer betaine 9:1:2 FTB 9:3 FTB Supplier and Product Name National Foam, F-500, Hazard Control Tech., 1997 National Foam 2005 National Foam 2007 National Foam 2008 (slightly different shares) Fireade Ansul, 2002 Anslite 3 % AFFF - DC-5 Hazard Control Tech., 1997 F-500 Angus Fire, 2000 ; Niagara 1-3, Angus Fire, 1997; Forexpan National Foam 2005 National Foam 2007 National Foam 2008 Chemguard, Ansul, 2006; Ansul Anulite ARC; Ansul, 2002 Ansulite 3% AFFF DC-3 Angus Fire, 2004 Tridol S Angus Fire, 2000; Niagara 1-3 Hazard Control Tech., 1997 F-500; 3M Buckeye AFFF 2004 Buckeye 2009 Buckeye 2009 3M 1988 3M 1989 3M 1993A 3M 1993B 3M 1998 3M 2001 Ansul, 2002 Ansulite 3% AFFF DC-3 In addition to this table, a hierarchical clustering was elaborated. This is shown in the figure below. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 48 Wood Environment & Infrastructure Solutions UK Limited Figure 3.4 Hierarchical clustering of identified fluorotelomers Other PFAS substances In some cases, perfluorinated substances that do not belong to any of the named groups (long-/short-chain PFAS, fluorotelomers, and derivates of PFAS) were identified (Others). These substances are shown in the table below. Also shown below is the substance Dodecafluoro-2-methylpentan-3-one, a fluorinated ketone. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 49 Wood Environment & Infrastructure Solutions UK Limited Figure 3.5 Chemical structure of Dodecafluoro-2-methylpentan-3-one, a fluorinated ketone Table 3.10 Other per- or polyfluorinated substances (identified by CAS) incl. CAS/EC identifier, the designation, the acronym and the supplier and/or product name CAS 1280222-90-3 756-13-8 161278-39-3 70969-47-0 70829-87-7 13269-86-8 EC 480-310-4 616-243-6 / 436-710-5 500-631-6 N/a N/a 236-267-7 Designation (synonyms) Acronym ammonium 2,2,3 trifluor-3-(1,1,2,2,3,3hexafluoro-3trifluormethoxypropoxy) , propionate ADONA Dodecafluoro-2methylpentan-3-one Poly(1,1,2,2-tetrafluoro1,2-ethanediyl), fluoro--2-[3((carboxylatomethyl) dimethylammonio)prop ylaminosulfonyl]ethyl- Thiols, C8-20, gammaomega-perfluoro, telomers with acrylamide Sodium p-perfluorous nonenoxybenzene sulfonate N/a N/a Thiols, C8-20, gammaomega-perfluoro, telomers with acrylamide OBS Bis(trifluorovinyl)ether N/a Supplier and Product Name Mentioned in annex_xv_svhc_ec_206397-9_pfoa_11549 as a substitute. However, no other source for this information. 3M NOVEC TM 1230 PROFOAM Profilm AFFF Towalex 3% master No product/supplier is mentioned; Publications are based on environmental samples Fire-extinguishing foam cited in Nordic working paper Conclusions from task 1 In this substance identification process, three substance classes, that are/were used in firefighting foams, were considered: fluorine-free replacements, PFAS substances, and fluorinated but not-PFAS alternatives. The main outcomes of this task are as follows: June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 50 Wood Environment & Infrastructure Solutions UK Limited For the latter substance class (fluorinated but not-PFAS alternatives) no substances were found, as also confirmed by experts; In the case of PFAS substances, various carboxylic/sulfonic short- and long chain PFAS were found. Additionally, also a variety of fluorotelomers. These substances differ in chain length and substitution and only a relatively small amount of these substances could be identified by CAS/EC number. Furthermore, other PFAS substances were found, that do not belong to any of the named PFAS-categories; and The identified fluorine-free PFAS-replacements can be grouped into four classes: hydrocarbons, detergents, siloxanes and proteins. For the latter two classes, the gathered information and the amount of identified substances are relatively small. In the case of the siloxanes, the usage of these substances in firefighting foams is still under development. In contrast to this, a variety of hydrocarbons (around 24) and detergents (33) were identified, that are used as a replacement for PFAS-substances. In summary, a large number of highly diverse PFAS substances were found in the context of use in firefighting foams. This could be an indication of extensive replacement chemistry that was initiated due to industry and regulatory concerns about the potential health and environmental impacts of long-chain PFAS and lately also short-chain PFAS. Chemical definitions of the identified substances which could be used for a possible future restriction Any regulatory action on chemical substances/substance groups relies on a precise chemical identification. In the following the identified PFAS-substances have been checked to confirm whether they are covered by the general classification of per- and polyfluoroalkyl substances (PFASs) by the OECD, which itself is based on the commonly agreed terminology for nomenclature of PFASs (Buck et al. 2011). In the case of the PFCAs, chemically defined as CnF2n+1-COOH, the substances identified in this task, AFFFrelated PFAS-substances, would be covered. This is also true for the sulfonic homologues (PFSA, defined as CnF2n+1-SO3H). Fluorotelomers-based substances are chemically defined by having a non-perfluorinated spacer between the perfluorinated carbon chain and a polar head group. The most known homologues of this subgroup are those that have a two carbon atom spacer (defined as CnF2n+1-C2H4-R). This definition is also given in the OECD report ("Working towards a global emission inventory of PFASs: focus on PFCAS status quo and the way forward"). In this task, multiple substances belonging to this group were identified, varying in the perfluorinated chain length. However, homologues with a spacer of three non-fluorinated carbon atoms (for example 7:3 FTB) were also identified, thus the definition would need to be enlarged to CnF2n+1-CmHm+1-R, so that substance with a variable chain length could be included. In addition fluorotelomers with a non-fluorinated and an additional single-fluorinated carbon were identified (for example 7:1:2 FTB). In order to include such substances, the chemical definition for these homologues would need to be (CnF2n+1-CHF-CmHm+1-R). The derivates of PFSA substances are chemically defined by having an additional chemical moiety connected to the sulfonic headgroup (CnF2n+1-SO2-R). All of the identified substances identified in this task would be covered by this definition. The identified substances grouped under the term "others" show diverse chemical structures. The only feature that is common to all of them is a perfluorinated substructure. However, in analogy to the perfluorinated ethers like ADONA (CnF2n+1-O- CmF2m+1), the substance Dodecafluoro-2-methylpentan-3-one (a ketone) could be defined by CnF2n+1-CO- CmF2m+1. The following table summarises the named PFAS classifications, the generalised chemical structures, and the minimal number of carbon atoms of AFFF-related PFAS substances. It is observable, that the common sub June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 51 Wood Environment & Infrastructure Solutions UK Limited unit is a perfluorinated ethyl-group (-C2F4- or -C2F5)16. Based on that, the definition that would be needed to be to cover the all relevant AFFF-related PFAS substances would be based on these particular -C2F4- or C2F5sub groups. Table 3.11 Overview of the PFAS classification, generalised chemical structures, and minimal number of Catoms of substances that were identified as being used in AFFF PFAS classification (Buck et al. 2011) PFCAs PFSAs I PFSAs II Fluorotelomer-based substances I Fluorotelomer-based substances II Fluorotelomer-based substances III Perfluoroalkyl ether-based substances Perfluoroalkyl ether-based substances Generalised chemical structure CnF2n+1-COOH CnF2n+1-SO3H CnF2n+1-SO2-R CnF2n+1-C2H4-R CnF2n+1-CmHm+1-R CnF2n+1-CHF-CmHm+1-R CnF2n+1-O- CmF2m+1 CnFn+1-CO- CmFm+1 Minimal number of C-atoms as identified in AFFF 4 2 4 4 4 4 2 2 In the following, a proposal for the definition in the form of substance identity, that could be used for a potential restriction, is made. For this, in the following table, the definition of PFOA as stated in the restriction (Entry 68 to Annex XVII to REACH) and a draft version of the possible definition for the restriction on PFASsubstances found in AFFF is shown. In addition, the definition in the "Information Document accompanying the "Call for evidence supporting an analysis of restriction options for the PFAS group of substances (fluorinated substance(s))" as published in the context of the RMOA has been used. Table 3.12 Comparison of the substance identification as in the PFOA restriction and a proposal made for the PFAS-substances in AFFF. Perfluorooctanoic acid (PFOA) Per- and polyfluoroalkyl substances (PFAS) CAS No. 335-67-1 CAS No. various EC No. 206-397-9 EC No. various and its salts. Any related substance (including its salts and polymers) having a linear or branched perfluoroheptyl group with the formula C7F15directly attached to another carbon atom, as one of the structural elements. Any related substance (including its salts and polymers) having a linear or branched perfluorooctyl group with the formula C8F17- as one of the structural elements. Any substance having at least two perfluorinated carbons with the formula CnF(2n+1)- (n2) directly attached to any chemical group, as one of the structural elements. [This is a provisional definition that would need to be tested in terms of its implications as part of the consultation on any future restriction proposal, and 16 -C2F4- if incorporated in the chemical structure of the PFAS substance or -C2F5 when attached terminaly to the structure. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 52 Wood Environment & Infrastructure Solutions UK Limited The following substances are excluded from this designation: - C8F17-X, where X = F, Cl, Br. - C8F17-C(=O)OH, C8F17-C(=O)O-X or C8F17CF2-X (where X = any group, including salts). taking into account the conclusions of the PFAS working group.] In the following, the proposed definition is discussed in the context of whether it is comprehensive enough to avoid any existing or new PFAS being used in fire-fighting foams. For this the publicly available ECHA database has been checked using its advanced search feature based on structural elements. Based on the proposed definition, any PFAS substance that contains -CnF2n+1 (n2) or -CnFn+1 (n2) as one of the structural elements would be covered. Substances with only one -CF3 moiety would not be covered; however in this project no PFAS-substance with only a single-CF3 moiety has been identified. In addtion, this group is used, for example, in certain drugs and pigments. A fluorine to chlorine replacement is for example found in F-53B (6:2 chlorinated polyfluorinated ether sulfonate), a novel mist suppressant used as a replacement in metal plating (mainly in China see Du et al., 2016) . However, based on the entire structure this substance would also be covered by the definition proposed above. 1-Chloro-1,2,2,2-tetrafluoroethane (HCFC-124 , CAS No 2837-89-0) is a substance used in refrigerants as replacements for "older" chlorofluorocarbons. HCFC-124 is also used in gaseous fire suppression systems as a replacement for bromochlorocarbons. This particular substance would be not covered by the definition; however its potential usage in AFFF is questionable as it is gaseous. A search for this sub structure (-CClF3 or (Cl)C(F)(F)F) gave nine hits. A search for bromine (Br)C(F)(F)F) resulted in three hits. The limited amount of hits, does, in a first approximation, show how many substances would not be covered by a possible restriction as elaborated above. However, the data is limited to the information publicly available in the ECHA database. Also a replacement of fluorine atoms by hydrogen is observed in some substances (fluorotelomers). However, the fluorotelomers in this project would all be covered. An addtitional search in ECHA based on the -CHF-CF317 substructure gave 15 hits. Taken together, the proposed definition is very broad and should prevent existing or new PFAS being used in fire-fighting foams. However, when flouorine is replaced by, for example, chlorine, bromine or hydrogen, the resulting substances would not be covered. It should be noted that this definition has been developed specifically in the context of fire fighting foams. This does not imply that it would be an appropriate definition for any other possible restriction on PFAS in other uses. 17 SMILES (C(F)C(F)(F)F) June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 53 Wood Environment & Infrastructure Solutions UK Limited Bibliography for Section 3 Barzen-Hanson, K. A., Field, J. A. (2015): Discovery and Implications of C2 and C3 Perfluoroalkyl Sulfonates in Aqueous Film-Forming Foams and Groundwater. Environmental Science & Technology Letters, 2(4), 95-99. Buck, R. C., Franklin, J. , Berger, U. , Conder, J. M., Cousins, I. T., de Voogt, P. , Jensen, A. A., Kannan, K. , Mabury, S. A. and van Leeuwen, S. P. (2011), Perfluoroalkyl and polyfluoroalkyl substances in the environment: Terminology, classification, and origins. Integr Environ Assess Manag, 7: 513-541. doi:10.1002/ieam.258 Du, Z., Deng, S., Liu, D., Yao, X., Wang, Y., Lu, X.,Yu, G. (2016). Efficient adsorption of PFOS and F53B from chrome plating wastewater and their subsequent degradation in the regeneration process. Chemical Engineering Journal, 290, 405-413. doi:https://doi.org/10.1016/j.cej.2016.01.077 Harding-Marjanovic, K. C., Houtz, E. F., Yi, S., Field, J. A., Sedlak, D. L., Alvarez-Cohen, L. (2015): Aerobic Biotransformation of Fluorotelomer Thioether Amido Sulfonate (Lodyne) in AFFF-Amended Microcosms. Environmental science & technology, 49(13), 7666-7674. Hetzer, R., Kmmerlen, F., Blunk, D. Auf dem Weg vom Siloxantensid zum fluorfreien AFFF. Hetzer, R., Kmmerlen, F., Wirz, K., Blunk, D. (2014): Fire testing a new fluorine-free AFFF based on a novel class of environmentally sound high-performance siloxane surfactants. Fire Safety Science, 11, 1261-1270. Hetzer, R. H., Kmmerlen, F. (2016): The Extinguishing Performance of Experimental Siloxane-Based AFFF. Hetzer, R. H., Kmmerlen, F., Blunk, D. (2015). Fire Testing of Experimental Siloxane-Based AFFF: Results from New Experiments. Paper presented at the Conference Paper, Suppression, Detection and Signaling Research and Applications Symposium (SUPDET 2015), Orlando (Florida, USA). ECD 2018: Toward a new comprehensive global database of per- and polyfluoroalkyl substances (PFASs): Summary report on updating the OECD 2017 List of per- and polyfluoroalkyl substances (PFASs). Available at: https://www.oecd.org/officialdocuments/publicdisplaydocumentpdf/?cote=ENV-JMMONO(2018)7&doclanguage=en Wang, D. Z., Goldenman, G., Tugran, T., McNeil, A., & Jones, M. (2020). Per- and polyfluoroalkylether substances: identity, production and use. Retrieved from Copenhagen: https://doi.org/10.6027/NA2020-901. Available at: http://urn.kb.se/resolve?urn=urn:nbn:se:norden:org:diva-5872. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 54 Wood Environment & Infrastructure Solutions UK Limited 4. Task 2. Market analysis 4.1 Introduction The main aim of this task is to estimate the tonnages of fluorine-based and fluorine-free fire-fighting foams manufactured and placed on the market in the EU. The different functions (e.g. film-forming, surfactants, solvents) provided by different components of fire-fighting foams and the type of fires for which their use is recommended is also discussed. In the following, the approach, in particular the specific literature sources and consultation responses contributing to this task, are briefly described. Then, the results are presented, outlining the available market information on PFAS in fire-fighting foams and their alternatives. 4.2 Approach This task involved a combination of a targeted stakeholder consultation and a review of relevant literature and statistical sources. Literature review A literature review of information on tonnages of PFAS-containing and fluorinated fire-fighting foams has been conducted. This focused on keyword searches on google and a systematic review of information from key organisations in the field, including ECHA, UNEP, Emerging contaminants EU, Fire Industry Association and others, as well as companies active in the sector. The specific literature sources used are presented, along with the results, below. Consultation As discussed in Section 2, 33 stakeholders have provided written responses to the consultation questionnaire and several others have provided additional input following the study workshop. Of these, 26 have provided responses relevant to the market analysis. Statistical sources Relevant statistics providing quantities of production and trade of products in the EU have been screened, notably the Eurostat Prodcom database. However, the breakdown of the data in these sources is not sufficiently detailed to distinguish specific types of fire-fighting foams (or even foams from other fire-fighting preparations)18. 18 NACE codes are the statistical classification of economic activities (including production quantities and values of specific products) in the European Union. These were screened to identify relevant codes including fire-fighting foams. The most relevant code covers "Preparations and charges for fire-extinguishers; charged fire-extinguishing grenades" (code 20595250); however this does not distinguish between foams and other fire-fighting preparations, let alone different types of fire-fighting foams. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 55 Wood Environment & Infrastructure Solutions UK Limited 4.3 Results: PFAS in fire-fighting foams Tonnages and values Current status of knowledge in the literature The information identified in the literature is shown in Table 4.1. Most of this data relates to amounts of PFOS or "PFOA-related compounds" specifically. However, according to information gathered in the framework of the Stockholm Convention19 these long chain PFAS have already been increasingly (in the case of PFOS even completely) replaced by shorter chain PFAS for use in fire-fighting foams, so these data are likely out of date or only reflect a small share of the current market. Data on foams based on a wider range of PFAS has not been identified, except one figure: in 2015, 8,500 tonnes of fluorotelomers were used in fire-fighting foams globally20. The data is also presented in different ways, including quantity used, produced, in stock or purchased. Much of it relates to the EU or specific EU Member States, but some values for other countries are also shown, for reference. 19 For PFOS: UNEP (2018) Draft report on the assessment of alternatives to perfluorooctane sulfonic acid, its salts and perfluorooctane sulfonyl fluoride, UNEP/POPS/POPRC.14/INF/8. For PFOA: UNEP (2018) Report of the Persistent Organic Pollutants Review Committee on the work of its fourteenth meeting - Addendum to the risk management evaluation on perfluorooctanoic acid (PFOA), its salts and PFOA-related compounds, UNEP/POPS/POPRC.14/6/Add.2. 20 FLUORINE-FREE FIRE-FIGHTING FOAMS (3F) - VIABLE ALTERNATIVES TO FLUORINATED AQUEOUS FILM-FORMING FOAMS (AFFF), White Paper prepared for the IPEN by members of the IPEN F3 Panel and associates, POPRC-14, Rome 17-21 September 2018. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 56 Wood Environment & Infrastructure Solutions UK Limited Table 4.1 Overview of quantitative data from literature on the market of PFAS in fire-fighting foams Location UK Germany Netherlands Europe Europe Europe Product PFOS PFOS PFOScontaining AFFFs Quantity used for firefighting foam Quantity produced 65 tonnes (16% of total) 25 tonnes (87% of total) PFOSF for manufacture of AFFFs 10,000 tonnes PFOA-related compounds 50-100 tonnes Quantity in stock for firefighting foam Quantity purchased 75% of the 25 million purchased still unused 25,000,000 over 20 years PFOA-related compounds (as impurities or constituents) 15-30 tonnes "Fire-fighting foam (monomers)" 1.13-3.81 tonnes Data year Source Original source 2001 2010 20 years up to 2009 UNEP (2016) [1] UNEP (2016) [1] Goldenman G. et al. (2019) [2] RIVM (2009). Estimation of emissions and exposures to PFOS used in industry. Report 601780002/2009. In total from 1970 to 2002 2014 2015 UNEP (2016) [1] UNEP (2018) [6] Annex XV Restriction Report -- Proposal for a restriction substance name: PFOA, PFOA salts and PFOA-related substances, version 1.0 (German and Norwegian competent authorities). Available from: https://echa.europa.eu/documents/10162/e9 cddee6-3164-473d-b590-8fcf9caa50e7 Report of the Persistent Organic Pollutants Review Committee on the work of its fourteenth meeting unclear Goldenman G. et al. (2019) [2] Ministry of Infrastructure and Environment of Netherlands and Public Waste Agency of Flanders (2016). Inventory of awareness, June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 57 Wood Environment & Infrastructure Solutions UK Limited Location Europe World Canada Norway Product (details unclear) PFOS Fluorotelomers PFOScontaining AFFFs PFOScontaining AFFFs Quantity used for firefighting foam Quantity produced Quantity in stock for firefighting foam Quantity purchased Data year 90 tonnes 8,500 tonnes ("fire-fighting foams account for ~32% of the annual global tonnage of fluorotelomer production) 300 tonnes of fire-fighting foams, containing 3 tonnes of PFOS 21 tonnes 2011 2015 2006 2005 Source Original source approaches and policy: Insight in emerging contaminants in Europe. UNEP (2016) [1] IPEN (2018) [3] "Global Markets Insights", 2016 UNEP (2016) [4] UNEP (2018) [5] Switzerland PFOScontaining AFFFs 1,000 tonnes of fire-fighting foams, containing 10 tonnes of PFOS 2007 UNEP (2016) [4] June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 58 Wood Environment & Infrastructure Solutions UK Limited Location Product Quantity used for firefighting foam Quantity produced Quantity in stock for firefighting foam Quantity purchased Data year Source Original source China PFOSF 200 tonnes 2006 UNEP(2016) [4] Japan AFFF 19,000 tonnes 2016 UNEP(2016) [4] Sources: [1] `Pentadecafluorooctanoic acid (PFOA, Perfluorooctanoic acid), its salts and PFOA-related compounds DRAFT RISK PROFILE', UNEP-POPS-POPRC11CO, 2016 [2] Goldenman G. et al., `The cost of inaction: A socioeconomic analysis of environmental and health impacts linked to exposure to PFAS', 2019 [3] FLUORINE-FREE FIRE-FIGHTING FOAMS (3F) - VIABLE ALTERNATIVES TO FLUORINATED AQUEOUS FILM-FORMING FOAMS (AFFF), White Paper prepared for the IPEN by members of the IPEN F3 Panel and associates, POPRC-14, Rome 17-21 September 2018. [4] Draft consolidated guidance on alternatives to perfluorooctane sulfonic acid and its related chemicals, UNEP-POPS-POPRC.12-INF-15. [5] Report on the assessment of alternatives to perfluorooctane sulfonic acid, its salts and perfluorooctane sulfonyl fluoride, UNEP/POPS/POPRC.14/INF/13 [6] Report of the Persistent Organic Pollutants Review Committee on the work of its fourteenth meeting, UNEP-POPS-POPRC.14-6, 2018 June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 59 Wood Environment & Infrastructure Solutions UK Limited Tonnages of fluorosurfactants used in fire-fighting foams production According to data provided by Eurofeu, five foam manufacturers representing approximately 60-70% of the EU market purchase approximately 335 tonnes of fluorosurfactants per annum in the EU (data collected in 2018). These data include 7 specific known fluoro-compounds and 3 unknown fluoro-compounds (see Table 4.2). They are used to produce fire-fighting foam concentrates or liquid ready-for-use agents (pre-fill for fixed firefighting systems and/or portable extinguishers). According to the same Eurofeu data, the concentration of the fluoro-compound in the fire-fighting foam concentrates range between 0.1% and 45% (no average value was given). It should be noted that the identity of the substances with the largest tonnages was not specified in these data as the data were confidential. Based on the approximate share of the market reflected in these data, it is estimated that the total tonnage of fluorosurfactants used in fire-fighting foams in the EU is approximately 480-560 tonnes per year21. This is consistent with the total tonnage of PFAS-based fire-fighting foams estimated further below, and an average concentration of fluorosurfactants in the foams of around 2-3% (as suggested by various stakeholder responses to the consultation). Table 4.2 Tonnage of fluorosurfactants purchased for the production of fire-fighting foams by manufacturers participating in the 2018 Eurofeu survey Fluoro-compound CAS number 1-Propanaminium,N-(carboxymethyl)-N,Ndimethyl-3-[[(3,3,4,4,5,5,6,6,7,7,8,8,8tridecafluorooctyl)sulfonyl]amino]-,inner salt 34455-29-3 1-Propanaminium, 3-amino-N-(carboxymethyl)N,N-dimethyl-N-[[(gamma-omega-perfluoro-C6C16-alkyl)thio]acetyl] derives., inner salts 80475-32-7 2-methyl-2 - [(1-oxo-3 - [(3,3,4,4,5,5,6,6,7,7,8,8,8tridecafluorooctyl) thio] propyl) amino] -1propanesulfonic acid, sodium salt 62880-93-7 2-hydroxy-N,N,N-trimethyl-3[(3,3,4,4,5,5,6,6,7,7,8,8,8-tridecafluorooctyl)thio]-1Propanaminium, chloride (1:1) 88992-45-4 2-Propenamide, telomer with 4[(3,3,4,4,5,5,6,6,7,7,8,8,8-tridecafluorooctyl)thio]-1butanethiol ) unknown 2-Propenoic acid, telomer with 2-propenamide and 4-[(3,3,4,4,5,5,6,6,7,7,8,8,8-tridecafluorooctyl)thio]1-butanethiol, sodium salt unknown 2-Propenamide, telomer with 3,3,4,4,5,5,6,6,7,7,8,8,8-tridecafluoro-1-octanethiol 76830-12-1 unknown C-6 fluorinated substances unknown unknown 1 unknown unknown 2 unknown Tonnes per year 21.1 Share of the total market 6% 17.2 5% 0.5 <1% 0.2 <1% 0.2 <1% 0.3 <1% 0.9 17.1 138.6 138.6 <1% 5% 41% 41% 21 According to Eurofeu, the data is expected to cover 60-70% of the EU market. The total market has been estimated by dividing 335 tonnes by 70% (lower end of range) and by 60% (upper end of range), respectively. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 60 Wood Environment & Infrastructure Solutions UK Limited Fluoro-compound CAS number Tonnes per year Share of the total market Total (2018 Eurofeu survey) 335 Total EU market (extrapolated) 480-560 [1] Source: Wood 2019 based on data provided to the authors by Eurofeu. Notes: Substances marked as unknown have not been revealed by the individual manufacturers to preserve commercially sensitive information. [1] According to Eurofeu, the data is expected to cover 60-70% of the EU market. The total market has been estimated by dividing 335 tonnes by 70% (lower end of range) and by 60% (upper end of range), respectively. Results were rounded to two significant figures. Sales of fire-fighting foams by user sector Eurofeu also provided figures on the yearly sales of PFAS-based fire-fighting foams to various user sectors in Europe, based on a 3-year average (2016-2018). Six Eurofeu member companies22 have provided data. In total, they sell 13,669 tonnes of PFAS-based fire-fighting foams per year. Of these, an estimated 8,200 are employed in fixed systems and 5,500 in mobile systems23. The split by sector is detailed in Figure 4.1 below. This shows that chemical/petrochemical is by far the largest user sector (59%), but municipal fire brigades, marine applications, airports and military applications also account for significant volumes24. Ready-for-use products only account for a very small share of PFAS-based foams according to this data. The majority of this category are fire extinguishers although not all foam fire extinguishers use ready-for-use foams, according to personal communications with Eurofeu). However, some stakeholders have suggested that the number of fire extinguishers using PFAS-based foams could be significant. An estimate is provided in the following subsection. 22 Dr. STHAMER Hamburg, Auxquimia (Perimeter Solutions), Solberg Scandinavia, Dafo Fomtec, Orchidee, Johnson Controls (aka Tyco) 23 The number of companies that provided a response on whether the foams are used in fixed or mobile systems is lower than those that provided a response for the sectoral overview, therefore in the original data the total tonnage of the former is lower than the latter. To fill this gap, the tonnages for both fixed and mobile systems have been inflated so that their total matches the total in the sectoral split. The original values were 5.010 tonnes for fixed systems and 3,350 tonnes for mobile systems (total 8,360 tonnes). 24 According to personal communication with Eurofeu, there is some uncertainty in the data available to foam manufacturers about the precise distinction between user sectors. This is because although certain products may be marketed primarily for a specific user sector, it is not always known to whom the products are ultimately sold through traders and vending companies, and what they ultimately use it for (particularly for large users active across several sectors). Generally "chemical/petrochemical" is expected to include offshore oil and gas platforms (in addition to refineries and other facilities storing, processing or transporting flammable liquids), while "marine applications" refers to the shipping industry. However, due to the above uncertainty some of the tonnage for marine applications may also reflect use in offshore oil and gas platforms. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 61 Wood Environment & Infrastructure Solutions UK Limited Figure 4.1 Split of PFAS-based fire-fighting foams by sector Ai rports 9% Mi l i tary 6% Ready for use products 1% Ma ri ne a pplications 12% Muni cipal fire bri ga des 13% Chemi cal/ p e tro ch emical 59% Source: Wood 2019 based on data provided to the authors by Eurofeu. Eurofeu estimate that the data they provided based on an internal survey covers roughly 70% of the EU market. It is therefore estimated that the total annual EU use of PFAS-based fire-fighting foams could be in the order of 20 thousand tonnes25. Additional estimate of use in fire extinguishers Three different sources for the number of fire extinguishers using PFAS-based fire-fighting foam in in the EU were identified: 1. Eurofeu provided the European Commission with a position paper which estimates that there are approximately 76 million fire extinguishers in the EU, approximately 15 million of which use PFASbased fire-fighting agents; 2. Through individual communication with TSF (a German consultancy specialised in firefighting services), it has been estimated26 that, in the whole of the EU, between about 60 million and 90 million fire extinguishers using PFAS-based foam currently exist, but note that this is a high-level estimate based on extrapolation from German data and expert judgement, so the Eurofeu estimate is likely more accurate; and 25 Calculated as 13,669 tonnes divided by 70% and rounded to the closest thousand tonne. 26 The values have been extrapolated from data from bvfa - Bundesverband Technischer Brandschutz e. V. (German Federal Association of Technical Fire Protection) for fire extinguisher sold in Germany in 2016 as follows. Tonnages of major additional fire extinguisher manufacturers that are not part of bvfa have been added to the bvfa data by TSF. This yields the estimate that approximately 2,2 million fire extinguishers are sold every year in Germany, with an average lifetime of 20-25 years, which suggests that roughly 50 million units are currently present in Germany. Dividing this figure by the German population (82 million), a value of 0.6 fire extinguishers per capita is obtained. This value is then multiplied by the population of each country to estimate the number of fire extinguishers in each of them (population Netherlands: 17 m, population France: 67 m, population Belgium: 11,5 m, population United Kingdom: 60 m, population Ireland: 5 m, population Austria: 9 m, population Switzerland: 8,5 m, population rest of Europe: 500 m). Finally, the value obtained is multiplied by the share of PFAS foam-based fire extinguishers on the total of fire extinguishers in each country as estimated by TSF (Germany: 35%, Netherlands: 55%, France: 55%, Belgium: 45%, United Kingdom: 25%, Ireland: 25%, Austria: 45%, Switzerland: 45%, rest of Europe: 10%). This yields the following number of fire extinguishers using PFAS-based foam per country: Germany: 17 million units; Netherlands: 6 million units; France: 22 million units; Belgium: 3 million units; United Kingdom: 10 million units; Ireland: 1 million units; Austria: 2 million units; Switzerland: 2 million units; Rest of Europe: 30 million units. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 62 Wood Environment & Infrastructure Solutions UK Limited 3. The REACH restriction proposal for PFHxA27 states based on personal communication with one stakeholder and on data from the German Federal Association for Technical Fire Safety (bvfa), that in Germany roughly 600 000 hand held fire extinguishers containing AFFF are placed on the market per year, so it is possible that in Germany 6 - 12 million and EU-wide 40 - 80 million extinguishers are in use (i.e. in circulation in total rather than on an annual basis). Given the same underlying data source (bvfa) was used and similar results were obtained, it is likely that this is in fact the same estimation as source number 2 above, with slightly different assumptions. Based on the figures above, the following estimates the total tonnage of PFAS-based fire-fighting foam in fire-extinguishers in circulation, as well as the annual tonnage placed on the market. The Eurofeu position paper quotes 6-9 litres as the typical size of a fire extinguisher. According to TSF (based on bvfa data), the size can range between 2 and 9 litres; Multiplication of 6-9 litres with the estimated 15 million fire extinguishers yields a range of 90135 million litres (wider range: 30-810 million litres using 2-9 litres and 60-90 million fire extinguishers) of PFAS-based fire-fighting agents used in fire extinguishers. This would be equivalent to about 90,000-135,000 tonnes (wider range 30,000-810,000 tonnes)28 of PFASbased fire-fighting agents currently present in fire extinguishers in the EU, or ca 3,600-6,750 tonnes (wider range 1,200-35,000 tonnes) of PFAS-based fire-fighting agents sold in fire extinguishers in the EU annually29; and According to personal communication with Eurofeu, the PFAS-based fire-fighting agents in fire extinguishers are either foam concentrate already mixed with water, or a capsule of foam concentrate that is mixed with water when the extinguisher is triggered. That means that only a small share of the fire-fighting agent in the extinguisher is PFAS-based foam concentrate, and the concentration of PFAS in the fire-fighting agent is much lower (2-5g per 6-9 litre extinguisher, or 0.02-0.08%, according to the Eurofeu position paper) than for the foam concentrates discussed above. To make the 3,600-6,750 tonnes per year of PFAS-based firefighting agents in fire extinguishers comparable to sales of PFAS-based foam concentrates by sector (presented in the previous subsection), they need to be converted: Conservatively assuming that foam concentrates account for 10% of the fire-fighting agent for fire extinguishers would imply some 360-675 tonnes of PFAS-based foam concentrates are used annually in fire extinguishers in the EU28.30 Lastly, to sense check this result, it is compared to the tonnage of ready-for-use products estimated in the previous sub-section: Based on Eurofeu data, it was estimated that the total annual EU use of PFAS-based firefighting foams in the EU is at least 14,000 tonnes but it could be up to around 20,000 tonnes. Figure 4.1 (also based on Eurofeu data) puts the share of ready-for-use products at 1%, so the annual tonnage of ready-for-use products is around 140-200 tonnes.31; This is somewhat lower than the estimated 360-675 tonnes of PFAS-based foam concentrates used in fire extinguishers. However, the data appear to be consistent because Eurofeu specified that not all foam fire extinguishers are included in the category "ready-for-use foams"; and 27 https://echa.europa.eu/registry-of-restriction-intentions/-/dislist/details/0b0236e18323a25d 28 Assuming a density of approximately 1kg/l. 29 Calculated by dividing the total tonnage present by the average lifetime of 20-25 years, as indicated by TSF. 30 Calculated as: 3,600 tonnes of PFAS-based fire-fighting agents * 10% = 360 tonnes of PFAS-based foam concentrate. Similarly for the higher end of the range 6,750 tonnes * 10% = 675 tonnes. 31 Calculated by multiplying the total tonnage of fire-fighting foams (14,000-20,000 tonnes) with the share of ready for use products (1%). June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 63 Wood Environment & Infrastructure Solutions UK Limited Even if the share of ready-for-use products was higher than suggested by Eurofeu (Figure 4.1), the total tonnage across all sectors would not be significantly affected by the addition of a few hundred tonnes of ready-to-use products, as it was only estimated at an accuracy in the order of magnitude of thousands of tonnes in this report.. Other information on tonnages from the consultation The following additional information on tonnages was provided in the consultation: Additional fire-fighting foam manufacturers (not covered by Eurofeu's internal survey) provided figures for three different products they manufacture where the PFAS Carboxymethyldimethyl3-[[(3,3,4,4,5,5,6,6,7,7,8,8,8-tridecafluorooctyl)sulphonyl]amino]propylammonium hydroxide (CAS number 34455-29-3) and 6:2 FTS are used (i.e. all three products use both substances combined). The three products are employed in different sectors: The first is used by the respondents' customers in airport and marine applications. Of this foam, 700,000 litres are manufactured/imported and 200,000 litres are sold in the EU every year; The second is used in oil and gas, marine, chemistry and municipal fire fighters applications. 450,000 litres of this product are manufactured/imported in the EU and 250,000 litres are sold every year in the EU; The third product is used in the oil and gas and marine sectors. 250,000 litres of this foam are manufactured/imported and 100,000 litres are sold every year in the EU; and These volumes are additional to the Eurofeu data presented above. The three foams in sum account for 550,000 litres of annual sales in the EU. Assuming a density of approximately 1kg/l, this would be equivalent to about 550 tonnes of foam that can be added to the Eurofeu total (but would already be included in the EU total extrapolated from Eurofeu data). Hover, given the exact sector split is not known, they have not been added to the sector breakdown. One respondent operating in the field of industrial safety, in particular dedicated to technical support and training, stated that they manufacture 5,000 litres per year of a foam containing a C6 fluorine compound, which is used only for training purposes. As above, this is additional to the Eurofeu data, but has not directly been added because the tonnage or density is not known; One respondent operating in the oil and gas sector provided figures for four fire-fighting foams they purchase; two of these contain poly(1,1,2,2-tetrafluoro-1,2-ethanediyl),alpha fluoroomega-2-(3-((caboxylatomethyl)dimetylammonoi)propylaminosulfonyl)ethyl, whereas the other two contain different PFAS that have not been specified: The two products containing poly(1,1,2,2-tetrafluoro-1,2-ethanediyl),alpha fluoro-omega-2(3-((caboxylatomethyl)dimetylammonoi)propylaminosulfonyl)ethyl are used in the offshore oilrig and refinery sectors for spills32, accidents and function tests in process plant fires and trainings. They purchase less than 5 tonnes per year of each of these foams and employ less than 5 tonnes in each instance of use; The third product is used in the offshore oil and refinery sectors in cases of spills, accidents and function tests in alcohol fires. Similarly to the previous, less than 5 tonnes are bought every year and less than 5 tonnes are employed in each instance of use; and 32 AFFF are in some cases also used as prevention in spills that have not (yet) caught fire. See for instance: https://www.nrl.navy.mil/accomplishments/materials/aqueous-film-foam June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 64 Wood Environment & Infrastructure Solutions UK Limited A volume between 30 tonnes and 70 tonnes of a fourth product is purchased every year by the respondent, but no other details have been provided regarding the use of this foam. One respondent operating in industrial safety for the oil refineries, chemicals and petrochemicals sectors provided figures for one foam based on the C6 fluorine compound, which is used for training exercises on large hydrocarbon fires. They purchase 5 tonnes per year of this product and typically employ it 100 days a year; and Another respondent operating in the oil refineries, chemicals and petrochemicals sectors provided figures for one product they purchase, which can be used for almost all class B fires. They purchase between 20 and 60 tonnes per year of this foam and in 75% of cases, fires are extinguished with less than 400 litres of foam concentrate. Respondents quoted prices for PFAS based fire-fighting foams in the range from 2 to 30 per litre for concentrates. For those PFAS based fire-fighting foams for which data on tonnage and price is available, the weighted average price is around 3 per litre, but note that these products reflect only a small share of the total market, so this estimate is uncertain. Some consultation responses suggest that generally speaking, foams providing a higher performance often contain a higher concentration of PFAS which is associated with a higher cost. Number of sites using fire-fighting foams No specific data on the number of sites using fire-fighting foams (PFAS-based or fluorine-free) was available. However, in order to estimate the order of magnitude of user sites, the total number of sites in some of the main user sectors can be considered: Chemicals/petrochemicals: There are over 10,000 establishments covered under the EU's Seveso III Directive33. One of the main accident scenarios linked to most Seveso-regulated substances is related to fires. Many other facilities with flammable fuels and chemicals below the Seveso Directive thresholds will also require firefighting equipment; Marine applications: Over 1,200 commercial seaports operate in the EU34 and Europe's maritime traffic is responsible for some 15,000 seagoing vessels35; Airports: There are 401 commercial airports in the EU-2836, many of which will have multiple fire-fighting foam storage/use equipment; Municipal fire brigades: There are over 50,000 public fire brigades in the EU, excluding those covering airports and private brigades covering industrial risks37; and Military: In the European Economic Area, there are about 239 military airbases. Based on the above, there are likely to be several tens or potentially hundreds of thousands of facilities using (or at least possessing) fire-fighting foams. In addition, there are likely many other sites possessing fireextinguishers using fire-fighting foams. 33 Analysis and summary of Member States' reports on the implementation of Directive 96/82/EC on the control of major accident hazards involving dangerous substances, Final report, https://op.europa.eu/en/publication-detail/-/publication/26c9aa63-523e-11e7a5ca-01aa75ed71a1. 34 European Commission (2013): Europe's Seaports 2030: Challenges Ahead. Available at : https://ec.europa.eu/commission/presscorner/detail/en/MEMO_13_448. 35 In early 2019, the total world fleet stood at 95,402 ships. Europe accounted for 16% of container port traffic (as a proxy for the share of global vessels relevant to Europe). Source: UNCTAD Review of Maritime Transport 2019. Available at https://unctad.org/en/PublicationsLibrary/rmt2019_en.pdf. 36 Eurostat: Number of commercial airports (with more than 15,000 passenger units per year) [avia_if_arp], Data for 2017. 37 FEU statistics, https://www.f-e-u.org/career2.php June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 65 Wood Environment & Infrastructure Solutions UK Limited Conclusions In conclusion, based on information provided by Eurofeu and additional manufacturers, it has been estimated that at least 14,000 tonnes, but probably around 20,000 tonnes of PFAS-based fire-fighting foams are sold in the EU annually. The main application is the chemical and petrochemical industry, which employs 59% of these foams. This is followed by municipal fire brigades, marine applications, airports and the military. The foams are used in fire incidents, spills, tests and training exercises. There are likely several tens or potentially hundreds of thousands of facilities using (or at least possessing) fire-fighting foams, not counting those only using fire-extinguishers. Prices for PFAS based fire-fighting foams range from 2 to 30 per litre for concentrates, with the average estimated at around 3 per litre (subject to significant uncertainty). Functions provided in the foams and types of fires the foams are used for According to the consultation, the PFAS-based fire-fighting foams find application in a broad range of sectors, such as aviation, marine, oil and gas, offshore oil, refineries, chemicals and railways38. The main function of the PFAS contained in the foam is to act as a surfactant, i.e. to form a film over the burning liquid surface in order to prevent flammable gases from being released from it. This is a particularly relevant feature that enables applications in industrial fires - for example tank fires, where large quantities of flammable liquid are stored. They are used for training purposes and in a variety of fire incidents, from small fires to the above-mentioned large tank fires, and can be applied both with mobile and semi-stationary equipment. 4.4 Fluorine-free fire-fighting foams Tonnages and values Current status of knowledge in the literature No information on tonnages and values of fluorine-free fire-fighting foams has been identified in the literature review. Sales of fire-fighting foams by user sector Consultation with Eurofeu provided figures on the yearly consumption of fluorine-free firefighting foams in various sectors in Europe, based on a 3-year average (2016-2018), highlighting a total use of 6,553 tonnes per year. Of these 6,553 tonnes, 2,134 are utilised in fixed systems and 4,418 in mobile systems39. The split by sector is detailed in Figure 4.2 below. Notably, it varies considerably from that of PFAS-based foams, with a much larger share used by municipal fire brigades but a much smaller share in the chemical/petrochemical sectors. 38 A respondent responsible for railway maintenance stated that PFAS-based foams are used in railways; the use of fire-fighting foams is particularly relevant for fire-protection in railway tunnels. The reason is that railways can carry various chemicals and other dangerous goods and, if they catch fire in tunnels, it is particularly critical and fires can be much more difficult to extinguish. 39 The number of companies that provided a response on whether the foams are used in fixed or mobile systems is lower than those that provided a response for the sectoral overview, therefore in the original data the total tonnage of the former is lower than the latter. To fill this gap, the tonnages for both fixed and mobile systems have been inflated so that their total matches the total in the sectoral split. The original values are 1,259 tonnes for fixed systems and 2,605 tonnes for mobile systems (total 3,864 tonnes). June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 66 Wood Environment & Infrastructure Solutions UK Limited Figure 4.2 Yearly use of fluorine-free firefighting foams by sector. Ai rports 8% Mi l i tary 2% Ready for use products 1% Ma ri ne a pplications 16% Muni cipal fire bri ga des 44% Chemi cal/ p e tro ch emical 29% Source: Data provided to the authors by Eurofeu. Notes: The majority of the `ready for use products' are fire extinguishers. However, not all foam fire extinguishers use ready-for-use foams. Eurofeu estimate that the data they provided based on an internal survey covers roughly 70% of the EU market. It is therefore estimated that the total EU use of fluorine-free fire-fighting foams could be in the order of 9 million tonnes40. Other information on tonnages from the consultation The following information on tonnages was provided in the consultation. Information on which chemical group of alternatives (based on the grouping established in the substance identification, see Section 3) is also listed. Additional fire-fighting foam manufacturers (not covered by Eurofeu's internal survey) stated that they manufacture/import a total of 1,250,000 litres and sell 380,000 litres of PFAS-free foams (based on hydrocarbon surfactants) per year in the EU. Assuming a density of approximately 1 kg/l, this would be equivalent to about 380 tonnes of foam that can be added to the Eurofeu total (but would already be included in the EU total extrapolated from Eurofeu data). Hover, given the exact sector split is not known, they have not been added to the sector breakdown; One respondent operating in fire protection for oil refineries/storage, chemicals, petrochemicals and municipalities provided figures for three types of fluorine-free foams (chemical groups of alternatives unknown) used for different purposes: The first is used by the respondent for exercise and testing of fixed systems (i.e. not for firefighting), about 12-20 times per year at 300-10,000 kg per use. They purchase 15,00030,000 kg of this foam per year; The second is used by the respondent for testing of proportioning systems (i.e. not for firefighting), typically 4-6 times per year, with 1,000-6,000 kg used in each instance. They purchase 10,000 kg of this product per year; and 40 Calculated as 13,669 tonnes divided by 70% and rounded to the closest million tonnes. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 67 Wood Environment & Infrastructure Solutions UK Limited The third was due to start testing in autumn 2019, therefore they did not yet have any experience on real fires with this foam. It is expected that this product will be used about 50 times per year, with 1-400 kg used in each instance. One respondent operating in the field of industrial safety, particularly dedicated to technical support and training, provided figures for two different fluorine-free foams, both used for training purposes: The first (a product shown to contain detergents according to the substance identification task) is used by the respondent for hydrocarbon fires in the oil and gas sector, with a typical frequency of 150 days per year. They purchase 4,000 kg of this product per year; and The second (chemical group of alternatives unknown) is used by the respondent for alcohol fires, about 30 days a year. They purchase 1,000 kg of this foam per year. One respondent providing training in the safety sector gave figures for one type of fluorinefree foam (a product shown to contain detergents according to the substance identification task). This is used only for training purposes on fires of different sizes and in various sectors, such as airports, oil and gas and marine. They purchase 1,200 kg of this product a year and typically use it around 4 hours per week, depending on the training activity; One respondent active in the airport sector provided figures for one fluorine-free foam (a product shown to contain hydrocarbon surfactants and detergents according to the substance identification task), which is used for all aircraft applications and training activities. They purchase 3,600 litres of this foam a year. Approximately 300 litres are used each month, with a typical use of 15 minutes per month; Another respondent working in the airport sector stated that they purchase 5,000 litres per year of a fluorine-free foam (chemical group of alternatives unknown), which is used only for training and system testing; and Additional respondents have stated they use fluorine-free foams based on hydrocarbon surfactants and detergents in aviation, offshore oil installations and onshore terminals and refineries, without specifying quantities. Respondents quoted prices for fluorine-free foams ranging from 0.7 to 10 per litre. For those fluorine-free fire-fighting foams for which data on tonnage and price is available, the weighted average price is around 3 per litre, but note that these products reflect only a small share of the total market, so this estimate is uncertain. Although the range is lower and the average is similar to prices of PFAS-based foams (see above), some respondents suggested that fluorine-free foams are around 50% more expensive than comparable foams containing fluorine. However, fluorine-free foams are still predicted to have a growing presence on the market, due to increasing regulations/controls on fire-fighting training and testing. Conclusions Based on information provided by Eurofeu and additional manufacturers, it has been estimated that at least some 7,000 tonnes, but probably around 9,000 tonnes of fluorine-free firefighting foams are sold in the EU annually. A breakdown by chemical group of alternatives (based on the grouping established in the substance identification) is not available, but consultation responses suggest that the main alternatives used are based on hydrocarbon surfactants and detergents. The split by sector of use varies considerably from that of PFAS-based foams, with a much larger share used by municipal fire brigades but a much smaller share in the chemical/petrochemical sectors. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 68 Wood Environment & Infrastructure Solutions UK Limited Prices for fluorine-free foams range from 0.7 to 10 per litre, with the average estimated around 3 per litre (subject to significant uncertainty). Functions provided in the foams and types of fires the foams are used for The fluorine-free fire-fighting foams considered in this analysis are specifically those that can potentially be used as alternatives to the PFAS-based foams. As such, they are potentially used in the same applications. The consultation responses specifically indicated that fluorine-free alternatives are currently used for training, process fires, alcohol fires and fuel fires, as well as for testing proportioning systems and are applied both with fixed and mobile equipment. When it comes to the application of the products, no significant differences between fluorine-based and non-fluorine foams have been highlighted from a market perspective, but this is analysed in more detail in the analysis of alternatives (see Section 7). The substance identification (Task 1) identified the following groups of substances that PFAS-free firefighting foams are based on: hydrocarbons, siloxanes, protein foams, detergents. All of these groups largely mimic the function of fluoro-surfactants in the PFAS-based fire-fighting foams, for instance hydrocarbon foams use hydrocarbon surfactants41, siloxanes are also primarily used in fire-fighting foams to function as surfactants42 and detergents are by definition surfactants. 4.5 Summary of results The table below summarises some of the key results that have been discussed in more detail above. Table 4.3 Summary of key preliminary market analysis results Tonnage of foam used [1] Tonnage by substance / Substances most commonly used Breakdown of tonnage by use sector Prices Revenues [2] PFAS-based fire-fighting foams Fluorine-free alternatives 14,000-20,000 tonnes per year 7,000-9,000 tonnes per year 480-560 tonnes of fluoro-surfactants used annually in EU. Breakdown of tonnage for 8 substances available (see Table 4.1 and directly below the table), but for majority of tonnage the substances are not known. No quantitative data. Main alternatives used are based on hydrocarbon surfactants and detergents. Specific products are discussed in Section 9(analysis of alternatives). Chemical/Petrochemical: 59% Municipal fire brigades: 13% Marine applications: 11% Airports: 9% Military: 6% Ready for use products: 1% Chemical/Petrochemical: 29% Municipal fire brigades: 44% Marine applications: 16% Airports: 7% Military: 2% Ready for use products: 1% Average (uncertain): 3 Reported range: 2 to 30 per litre Average (uncertain): 3 Reported range: 0.7 to 10 per litre Best estimate: 60 million Potential range: 28-600 million Best estimate: 27 million Potential range: 5-90 million 41 See for example: https://www.fomtec.com/fluorine-free/category38.html or https://www.chemguard.com/about-us/documentslibrary/documents/Martin2009ReebokEcoguardpresentation2010-10-11.pdf. 42 See for example: https://www.nfpa.org/-/media/Files/News-and-Research/Resources/Research-Foundation/Symposia/2016SUPDET/2016-Papers/SUPDET2016Hetzer.ashx?la=en. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 69 Wood Environment & Infrastructure Solutions UK Limited PFAS-based fire-fighting foams Fluorine-free alternatives Functions provided and types of fires used for Surfactant to form a film over the burning surface. Particularly relevant for fire involving flammable liquids (Class B fires). Consultation suggests it is used both in training and true emergency responses. Those fluorine-free foams considered alternatives to PFAS-based foams in principle provide the same (or a similar) function. Consultation suggests it is used both in training and true emergency responses, but in some cases in training only. Trends Rapid shift from PFAS towards fluorine-free foam in recent years, expected to continue. Notes: [1] The original data from Eurofeu covers approximately 70% of the market, therefore this has been inflated to reflect the whole market. The lower end of the range represents the original data, whilst the upper end represents the extrapolation to the whole market. [2] The best estimate is based on the upper end of the quantity range and a weighted average price of 3/litre. The potential range is based on the lower end of the quantity range multiplied with the lower end of the price range, and the upper end of the quantity range multiplied with the upper end of the price range. An average density of 1 kg/litre has been assumed. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 70 Wood Environment & Infrastructure Solutions UK Limited 5. Task 3. Assessment of the emissions and hazard of fluorine-free foams 5.1 Introduction The focus of this task is to estimate the emissions of PFAS and of the constituents of the alternative fluorinefree fire-fighting foams to the environment, broken down by environmental compartment (atmospheric, aquatic, and terrestrial environments) and the possible uptake by humans via the consumption of food and water. Task 3 also covers the hazard (and risk, to the extent possible) to human health, the environmental and humans via the environment of the fluorine-free foams43. The development of emission estimates is expected to follow the relevant guidance provided by ECHA44. During the inception meeting it was clarified that the study should help to understand the emission pattern throughout the life cycle so that releases can be compared across foam products. For example, how much foam is used; how much of it is collected; how much is then incinerated; do the foams contaminate other environmental compartments and if so, how much ends up in each compartment? Therefore, rather than using risk assessment models such as EUSES, a source-flow approach has been applied. Due to the persistent nature of PFAS and non-threshold effects, releases of PFAS are of primary importance, and these are to be considered a proxy for exposure, as discussed at the inception meeting. The starting point for this task, therefore, has been to focus on releases and to compare those amongst PFAS-based foams and the alternatives. It was agreed at the inception meeting that, only if the alternatives are particularly hazardous for the environment should modelling be considered45. One further point to note is that the emission estimates that have been developed are intended to provide an illustrative assessment to help better understand the material flow and key emission compartments. The findings presented here are not a detailed risk assessment and are not presented within any geographical disaggregation based on identified sites in the European Union. 5.2 Approach Development of the source-flow model Based on guidance from ECHA, the UNECE inventory guidebook46, and OECD Emission scenario document for AFFF a basic source-flow model has been developed to make use of the data from Task 1 and 2 (as a Microsoft Excel workbook). The development of this source-flow approach began with a consideration of what might be the key life-cycle stages and what kinds of emissions may occur at each life-cycle stage, which has incorporated the approach used within the PFOA restriction dossier under REACH. 43 The terms of reference also refer to those associated with any non-PFAS fluorinated alternatives, if they exist. However, as confirmed in this study, such alternatives have not been identified. 44 See available guidance documents at: https://echa.europa.eu/guidance-documents/guidance-on-reach 45 If it is decided that modelling of exposure is useful the type of modelling usually applied for exposure estimation within risk assessment of chemicals is based on fugacity (i.e. the propensity for a substance, based on its physicochemical properties - such as the octanol-water partition coefficient and Henry's law constant), to move from one environmental medium to another. In this case the partitioning between interstitial water and organic carbon within the soil matrix will be of high significance, when foams are used for land-based fires and runoff is not contained by a bund. Comparison with reliable measured data is a useful validation of the model method used. 46 https://www.eea.europa.eu/themes/air/emep-eea-air-pollutant-emission-inventory-guidebook/emep June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 71 Wood Environment & Infrastructure Solutions UK Limited Based on this analysis the model development began with four basic life-cycle stages where it was possible for emissions to occur, or material to flow through into the next life cycle stage: Formulation of the fire-fighting foam concentrate. This includes consideration of the PFAS and fluorine-free substances used as surfactants within the foam concentrate. Note, that it was assumed that the life-cycle begins at this stage rather than the manufacture of the surfactants themselves. This distinction is made on the basis that the manufactured surfactants may have multiple applications, not limited to only fire-fighting foams. The full range of possible applications for a given PFAS or fluorine-free surfactant is outside the scope of the current study; Storage. Storage is considered a key life cycle stage with quantities of foam concentrate reaching expiry before active use47. During storage of foam concentrate it may be possible for leaks or spillages to occur, which directly contribute to environmental emissions. However, for usage sites (airports, refineries, terminals, industrial sites and military sites), appropriate risk management systems will generally be in place meaning that such leaks/spillages can be contained from direct release and will more likely act as an input to the waste/waste water system (e.g. sewers). Efficacy and management of materials put to sewer are further managed under waste; In-use. Active use of fire-fighting foams forms likely the most important life-cycle stage. The model developed defines two types of use. Firstly `training' exercises, which are assumed to happen within contained conditions (i.e. bunding / capture systems are in place to capture and retain runoff)48; and secondly `live' incidents which assumes no containment and full loss to the environment (following the approach adopted with the PFOA Annex XV dossier)49; and Waste. The waste cycle includes two key pathways. Firstly, incineration of any expired stocks of foam concentrate. Secondly waste water treatment works, processing of materials from leaks/spillage during storage, plus some runoff from training exercises. Formulation of the fire-fighting concentrate The model has been designed to allow calculation of both quantities of fire-fighting foams manufactured within the European Union, and quantities of finalised fire-fighting foam concentrate imported and used in the EU. Only quantities manufactured within the European Union are assumed to lead to emissions and exposure at the formulation stage. The PFOA Annex XV dossier assumes default worst case emission rates of 2.5% w/w to air, 2% w/w to water (assumed to be waste water system rather than direct release) and 0.2% to soil as a direct release from spillages / deposition during manufacture. In the absence of better data, the same release rates have been applied to the non-fluorinated alternatives. Storage Following manufacture and sale, the fire-fighting foam concentrates will pass into the storage phase of the life-cycle. A proportion of the annual sales will also go directly into use (see in-use phase), with the remainder 47 BiPRO, 2010, Study on waste related issues of newly listed POPs and candidate POPs - comments that the average lifespan of firefighting foams is 15 years. 48 It is recognised based on the stakeholder engagement that the standard of containment for training run-off has in the past not been optimal. However, because of the concerns raised around substances such as PFOS, it can be expected that the standards in use currently are a significant improvement upon standards from the early 2000s. 49 ECHA, 2018, `Background document - to the Opinion on the Annex XV dossier proposing restrictions on Perfluorooctanoic acid (PFOA), PFOA salts and PFOA-related substances', ECHA/RAC/RES-O-0000006229-70-02/F and ECHA/SEAC/RES-O-0000006229-70-03/F June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 72 Wood Environment & Infrastructure Solutions UK Limited held in store, sometimes for several years. Data on leakage rates / spillages was not identified during the study, and therefore a value based on expert judgement of 1% of total stocks has been applied. In-use phase The "in-use" phase of the model was then further refined to incorporate different kinds of use and application and how these may affect the type of emission and usage rate (i.e. use at airports vs municipal fire brigades for example). This included data from Eurofeu (gathered as part of Task 2) on industry sector splits, and data from Brooke et al (2004)50 which highlighted that most of the fire-fighting foam in the private sector is used for training (93% w/w). In the absence of better data, it was assumed that, for public fire brigades, use will predominantly be focused on live incidents with a smaller quantity used for training, assumed to be 93% on live incidents and 7% on training. Data from BiPRO (2010)51 and Buser et al (2009)52 quote usage rates of between 15% and 20% annually53 The source-flow model therefore assumes usage rates of 17.5% for the majority of sectors. However, for the public fire service sector a usage rate of 50% per annum has been used54. The justification for this modification is that based on a survey of UK fire authorities public fire services primarily use fire-fighting foams for live incidents a quicker turnaround of stockpiles may be expected. A usage rate of 50% assumes a high rate of use for quantities purchased annually, with stockpiling of 50% to safeguard against larger emergency events where greater quantities of foam may be needed. Finally, for training exercises, a factor has been added for the efficacy of bunding / control measures designed to manage run-off of fire-fighting waters during the training exercise. Extremely limited data was available on these aspects and therefore best estimates have been made based on expert judgement. Efficacy of the bunding for terrestrial applications was extrapolated to estimate ranges from 90-97% (assuming captured waters are passed to sewer / on site waste water treatment)55, while for marine applications it is assumed all run-off is permitted to be released directly to sea with no capture and control. For live incidents we have used the values quoted within the REACH Annex XV dossier for PFOA, which assumes a 100% release (which should be considered a worst-case scenario), split evenly between surface waters and soil. Table 5.1 provides further details of how quantities of fire-fighting foam has been manipulated. 50 Brooke et al (2004), "Environmental risk evaluation report: Perfluorooctanesulphonate (PFOS), Report produced for the England and Wales Environment Agency. 51 BiPRO (2010), "Study on waste related issues of newly listed POPs and candidate POPs", Commission report under framework ENV.G.4/FRA/2007/0066. 52 Buser et al (2009), `Substance flow analysis of PFOS and PFOA in Switzerland. Environmental Studies 0922. Federal Office for the Environment, Bern. 53 BiPRO 2010 base their estimates on usage rates against a survey of UK fire authorities completed by RPA in 2004. This suggested that annually 15% of total stocks are used across all sectors (public and private). Usage rates by municipal fire and rescue services were higher at between 40% and 50%. Buser et al 2009 base their estimates on remaining stocks of PFOS within all sectors (public and private services) using 20% of all stocks annually. To maintain a steady flow of business it is assumed that both public and private brigades will replace stocks as use occurs, so replacement foam would be purchased annually. 54 RPA, (2004), "Risk reduction strategy and analysis of advantages and drawbacks for PFOS", Report on behalf of Defra. 55 Responses from the stakeholder engagement stated that 100% of training run-off is expected to be captured and retained, however, further statements from fire-fighters indicated that full capture is challenging and not always possible. The model therefore makes an assumption that minor losses will occur equivalent to 3% in the best cases, and at worst 10% for sectors with less well-defined sites of use and capture. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 73 Wood Environment & Infrastructure Solutions UK Limited Table 5.1 Industry splits and usage rates based on data from Eurofeu and Brooke et al (2004)* Sector Percentage share of total Annual usage rates (of total quantity sold annually) Live incidents (as a percentage of total use) Training (as a percentage of total use) Efficacy of bunding/control measures for training Military 6% 17.5% 7% 93% 90% Civil Aviation 9% 17.5% 7% 93% 97% Municipal Fire Services 13% 60% 93% 7% 90% Chemical/petrochemical 59% 17.5% 7% 93% 97% Marine Applications 12% 17.5% 7% 93% 0% Ready to use 1% 17.5% 100% 0% N/A applications *For live incidents a 100% release is assumed split evenly between releases to surface water and soil. In the case of marine applications this is a 100% release to sea. Waste phase All material not lost directly to the environment during use will enter the waste phase through a variety of pathways (i.e. capture of run-off; spillages/leaks during storage entering on-site drains; unused foam concentrate which has expired), highlighting this phase's importance in the overall control and release to environment. The waste phase of the model aggregates the quantities of specific substances from different pathways to calculate total quantity per substance within the overall waste phase. This is then managed either by incineration (for end of life unused stocks) or waste water treatment works for retained runoff, losses to sewer from spillage/leakage during storage56. The model then applies two factors, firstly a distribution factor (as Koc57) taken from REACH registration dossiers to understand how the substance partitions between liquid and sludge phases of the waste water process. Then secondly an efficacy factor is applied to reflect how successfully the waste water process destroys the substance, and how much remains unchanged as a direct release to environment. Data on the efficacy of waste water treatment works against named substances was very limited for nonfluorinated alternatives. For the PFAS-based surfactants used in fire-fighting foam concentrates the efficacy is expected to be very low. The model assumes an efficacy of zero with all PFAS substances passing to environment unchanged. For the hydrocarbon-based alternatives, some are readily biodegradable, while others with more complex organic structures may be more resistant to degradation. For non-fluorinated alternatives the efficacy ranges from 99% for substances such as alcohols, and as low as 50% for aromatics. The model assumes all waste sludges are then applied to farmland as a release to soil. Note, that while we recognise that this is a common waste management practice for sewage sludge, this is not the case across the EU (for example the application of sewage sludge to land in Denmark is banned). The model acts as a high-level assessment of which compartments are the most important for emissions and key variables affecting emissions. No geopolitical splits are applied to the data for importance of environmental compartments in different Member States. 56 It is assumed that the sites in question will store these materials in secure areas with either bunding or on-site drainage. If there is a spillage/leak it is assumed that it will be contained and enter the waste systems. 57 Koc = Is a normalised partition coefficient used to calculate how much of a given substance will adsorb to organic matter. It is used as a measure for mobility of a given substance (primarily within terrestrial environments) but can be used as a measure of partitioning between liquid phases and organics within a wastewater treatment works. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 74 Wood Environment & Infrastructure Solutions UK Limited In terms of the proportion of material sent to waste water treatment works and proportion sent for incineration, only limited information was available. It is assumed that all retained run-off water, and losses from spillage/leakage to drain on controlled sites are sent to either onsite WWTWs or municipal WWTWs dependent on the site. The use of incineration would be retained for unused expired fire-fighting foam concentrate, but on this matter, there is conflicting information. A number of references (RPA, 2004; Buser et al 2009; and BiPRO, 2010) suggest usage rates of around 15-20% of existing stocks per annum, with an AFFF shelf-life of up to 15 years, which would suggest all foam concentrate is used before expiration (on average). Discussions held at the 2018 POPs Review Committee (POPRC) meeting on exemptions for PFOA (its salts and related-compounds), included comments from a number of NGOs that significant quantities of expired foam concentrate was destroyed, particularly from private fire brigades, where live use was much less common. The assumed usage rate of 15-20% per annum of existing stocks is an average across all sectors of use. This means that there will be installations with potentially far lower usage rates annually, increasing the potential for quantities to reach expiry before use. However, no data has been identified to quantify the amounts sent for incineration beyond commenting that waste water treatment is likely to be the dominant method for management of material in the waste cycle based on the outputs of the source-flow calculations. The model developed for the current study is a high-level assessment using the available references (including usage rates and shelf-life) meaning that the model assumes no material is sent for incineration. Section 8.2 (subsection j. Emissions from disposal of legacy foams) provides some further insight to incineration of PFAS. This notes that, in general, PFAS emissions from incineration are not well studied. However, the chemistry of PFAS makes it resilient to thermal destruction. The US EPA (2019)58 comments on studies (from 2004 and 2014) that showed for PFOA temperatures of 1,000 Celsius and residence time of 2 seconds were sufficient to destroy the PFOA. Kemi (2016)59. comments that more widely for PFAS compounds temperatures of at least 1,100 Celsius are needed, and that longer-chain PFAS species are more readily destroyed (potentially breaking down to shorter chain PFAS compounds), with the CF4 species the most resilient. For CF4 chemistry temperatures of 1,400 Celsius are required, with the breakdown products including carbon dioxide and hydrogen fluoride. As a side note, the industrial emissions directive (2010/75/EU) requires waste incineration plants to operate at temperatures of at least 850 Celsius with residence time of at least two seconds. This would cover standard municipal waste incineration plants. For elevated temperatures >1,000-1,400 Celsius this is likely to require more specialised commercial hazardous waste incineration, noting that a more limited fleet of specialised high-temperature operators exist across Europe. Summary of assumptions applied to the model Table 5.2 provides a summary of all factors applied within the model that manipulates the flow of substances from formulation to waste cycle, including emissions at different life-cycle stages. Table 5.2 Summary of factors applied to data Life cycle stage Description Value Formulation Emissions during formulation of firefighting foam concentrates 2.5% w/w to air; 2% w/w to waste water; 0.2% to air Storage Lifespan of concentrate 15 years Reference PFOA Annex XV dossier - assume same values for non-fluorinated alternatives. BiPRO (2010) 58 US EPA, 2019, `per and polyfluoroalkyl substances (PFAS): Incineration to manage PFAS waste streams', USEPA innovation report. 59 https://www.kemi.se/global/rapporter/2016/report-11-16-strategy-for-reducing-the-use-of-higly-fluorinated-substances-pfas.pdf June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 75 Wood Environment & Infrastructure Solutions UK Limited Life cycle stage Description Storage Annual leak rate / spillage In-Use - Training Industry sector splits In-Use - Training Usage rates annually In-Use - Training Efficacy of capture systems for run-off In-Use - Live incidents Emission to environment Waste cycle Efficacy of incineration Waste cycle Waste cycle Partitioning for liquid/sludge Efficacy of treatment Waste cycle Final disposal. Value 1% w/w of total stocks See Table 5.1 Reference Assumed value based on expert judgement. Eurofeu and Brooke et al (2004) See Table 5.1 BiPRO (2010) and Posner (2019) See Table 5.1 Assumed to be 100%; 50% surface water, 50% soil. For Marine applications 100% sea. 99%. Note for PFAS based foams could be lower, but in lieu of data assume 99% for all substances, and use of high temperature waste incineration Based on Koc values per substance Assumed value based on expert judgement. PFOA Annex XV dossier. Assumed value based on expert judgement. REACH Registrations Varies. For PFAS based substances assumed efficacy is zero. For hydrocarbons assumed efficacy varies from 50% - 99% depending on complexity and physicochemical properties. Assume treated effluent is direct release to surface water. Assume treated sludge is placed on farm land as direct release to soil. Feedback from workshop. Expert judgement. Selection of products and substances for emission estimation The selection process for named non-fluorinated substances was intended to identify those substances found in the products most commonly used, and where the hazards for human health and environment were of the greatest concern. To identify these substances a four-step process was followed as detailed below: Step 1 - Collation of all substances The outputs of Task 1 identified 168 non-fluorinated fire-fighting foam commercial products. In practice the surfactant action of the non-fluorinated products required the use of more than one substance, with most products therefore using a combination of named substances. Furthermore, the same substance is often found in multiple products across different manufacturers. However, the named substances identified could be broadly grouped into four categories (as identified in Task 1): Proteins; Siloxanes; Hydrocarbons; and Detergents. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 76 Wood Environment & Infrastructure Solutions UK Limited Step 2 - Most common products Based on the market analysis and stakeholder engagement from Task 2, the most commonly named products in use were given priority and screened in for the final selection. Based on analysis of the "screened in" set, the highest priority products (most commonly named five) were passed into the next phase. This included: Respondol ATF 3/6 - manufactured by Angus Fire; Moussol FF 3x6 - manufactured by Sthamer; Orchidex Bluefoam - manufactured by Orchidee; Re-healing foam RF11% - manufactured by Solberg; and Re-healing foam RF3x6 ATC - manufactured by Solberg. Step 3 - Final selection of substances Once the prioritised set of products was identified, the composition of products was identified (using safety data sheets) and hazard classification based on CLP. Using this approach those substances with hazard classifications relating to human or environmental toxicity were selected for use in the source-flow model. Table 5.3 provides details of the specific substances where emission estimates have been developed. Note where ranges have been provided the upper limit has been used for the calculations as a conservative estimate. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 77 Wood Environment & Infrastructure Solutions UK Limited Table 5.3 Final selection of substances (substances highlighted in blue selected) - see also footnotes at end of table. Product Respondol ATF 3/6 Respondol ATF 3/6 Respondol ATF 3/6 Respondol ATF 3/6 Substance 1-dodecanol 1-tetradecanol 1-butoxy-2-propanol Sulfuric acid, monoC8-10 (even numbered)-alkyl esters, sodium salts Respondol ATF 3/6 1,2-propanediol Respondol ATF 3/6 Sodium laureth sulphate Moussol FF 3x6 ALKYLAMIDOBETAINE (SAME EC BUT OTHER CAS) Moussol FF 3x6 1,2-ETHANDIOL Category Detergent Detergent Hydrocarbon Detergent Hydrocarbon Detergent Detergent D Hydrocarbon CAS number 112-53-8 112-72-1 131-66-8 5338-42-7 57-55-6 8891-38-3 61789-40-0 107-21-1 Concentration in product % w/w 0.1 to 1 0.1 to 1 4 to 10 1 to 4 4 to 10 to 4 <5 <10 Hazard classification Eye Irritant. 2 Aquatic Acute 1 Aquatic Chronic 2 Eye Irritant. 2 Aquatic Chronic 1 Skin Irritant. 2 Eye Irritant. 2 Degradation and fate* Short lived in air (<24 hours) and soil, likely to volatise from water to air. Short lived in air (<24 hours) and soil (5.5 days), likely to volatise to air from water and wet soil but remains in dry soil until degraded. (E) Likely to be short lived in air and soil, as an alcohol it should denature in water and would be expected to volatise. Skin Irritant. 2 Eye Damage. 1 ECHA database of registered substances under REACH (ECHA DB): Water: 92% degraded after 30 days. Not classified kin Irritant. 2 Eye Damage. 1 Aquatic Chronic 3 Skin Irritant. 2 Skin Sensitiser. 1 Eye Irritant. 2 Aquatic Chronic 3 Acute Toxicity. 4 * STOT RE 2 When released to air will exist solely in the vapour phase, half-life in air is short (32 hours), Highly mobile in soil, but less likely to volatise, breakdown in soil processes important (<60 days). In water does not bind to suspended solids but remains in aqueous phase. Testing at WWTWs suggests readily breaks down in water. ECHA DB: notes that based on distribution modelling that the primary receiving environment is water. Based on REACH dossiers suggests it is readily biodegradable in water. ECHA BD: Half-life in water (at 25C) is 15 days; in sediment at (at 25C) is 4.5 months. Half-life in soil (at 25C) is 30 days. When released to air will exist solely in vapour phase, halflife in air is short (48 hours), Highly mobile in soil, but less likely to volatise, breakdown in soil processes important (half-life is <12 days). In water does not bind to suspended solids but remains in aqueous phase. Half-life in water was <14 days at 8 Celsius. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 78 Wood Environment & Infrastructure Solutions UK Limited Product Moussol FF 3x6 Substance 2-(2BUTOXYETHOXY)ETHA NOL Moussol FF 3x6 ALKYLAMIDOBETAINE Moussol FF 3x6 TRIETHANOLAMMONI UM-LAURYLSULFATE Orchidex BlueFoam 3x4 107-21-1 Ethandiol (vgl. Glykol) 5 - < 10 % Orchidex BlueFoam 3x6 Orchidex BlueFoam 3x3 9 D-Glucopyranose oligomeric C10-16- alkyl glycosides 2-(2Butoxyethoxy)ethanol Orchidex BlueFoam 3x5 Ammonium laureth sulfate Orchidex BlueFoam 3x7 Re-Healing Foam RF1 1% Re-Healing Foam RF1 1% Ammonium alkyl C10C16 sulphate sucrose ( - ) 1-propanaminium, 3amino-N- Category Hydrocarbon Detergent Detergent Hydrocarbon Detergent Hydrocarbon Detergent Detergent Hydrocarbon Detergent CAS number 112-34-5 147170-44-3 85665-45-8 107-21-1 110615-47-9 112-34-5 32612-48-9 68081-96-9 57-50-1 61789-40-0 Concentration in product % w/w <10 <5 <10 5 - < 10 % 1 - < 5 % 15 - < 20 % 1 - < 5 % 1 - < 5 % >1% 10% Hazard classification Eye Irritant. 2 Acute Toxicity. 4 Skin Irritant. 2 Eye Damage. 1 Acute Toxicity. 4 STOT SE 3 (respiratory tra...) (Inhalation) Aquatic Chronic 3 Acute Toxicity. 4 Skin Irritant. 2 Eye Damage. 1 Acute Toxicity. 4 STOT SE 3 Aquatic Chronic 3 Acute Toxicity. 4 * STOT RE 2 Skin Irritant. 2 Eye Damage. 1 Eye Irritant. 2 Skin Irritant. 2 Eye Irritant. 2 Skin Irritant. 2 Eye Dam. 1 Not classified Skin Irritant. 2 Skin Sensitiser. 1 Degradation and fate* Half-life in air is short (<5 hours). Within soils will be highly mobile but readily biodegradable. In water will not bind to suspended solids (remains in aqueous phase). Readily biodegradable in water. ECHA BD: Half-life in water (at 25C) is 15 days; in sediment at (at 25C) is 4.5 months. Half-life in soil (at 25C) is 30 days. (E) Would expect this compound to be readily biodegradable in water. Half-life likely to be days-weeks (<30 days) When released to air exists solely in vapour phase for air, half-life in air is short (48 hours), Highly mobile in soil, but less likely to volatise, breakdown in soil processes important (half-life is <12 days). In water does not bind to suspended solids but remains in aqueous phase. Half-life in water was <14 days at 8 Celsius. ECHA DB: Half-life in air <5 hours; fully biodegrades in water. Half-life in air is short (<5 hours). Within soils will be highly mobile but readily biodegradable. In water will not bind to suspended solids (remains in aqueous phase). Readily biodegradable in water. (E) Only limited data available, review of multiple SDS all comment that this substance is readily biodegradable in water. Half-life likely to be days-weeks (<30 days) (E) Would expect this compound to be readily biodegradable in water. Half-life likely to be days-weeks (<30 days) (E) Readily biodegradable. ECHA BD: Half-life in water (at 25C) is 15 days; in sediment at (at 25C) is 4.5 months. Half-life in soil (at 25C) is 30 days. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 79 Wood Environment & Infrastructure Solutions UK Limited Product Re-Healing Foam RF1 1% Re-Healing Foam RF1 1% Re-Healing Foam RF1 1% Re-Healing Foam RF1 1% Re-Healing Foam RF1 1% Re-Healing Foam RF1 1% Re-Healing Foam RF1 1% Substance (carboxymethyl)-N,Ndimethyl-, N-coco acyl derivs., hydroxides, inner salts ( - ) 2-(2butoxyethoxy)ethanol (01-2119475104-44) sodium octyl sulphate ( - ) sodium decyl sulphate ( - ) 1-propanaminium, N(3-aminopropyl)-2hydroxy-N,Ndimethyl-3-sulfo-, Ncoco acyl derivs., hydroxides, inner salts ( - ) amides, coco, N-[3(dimethylamino)propy l] ( - ) amides, coco, N-[3(dimethylamino)propy l], N- oxides ( )sucrose ( - ) D-glucopyranose, oligomers, decyl octyl glycosides ( - ) Re-Healing Foam RF1 1% sulfuric acid, monoC12-14-alkyl esters, compds. with triethanolamine ( - ) Re-Healing Foam RF1 1% alpha-sulfo-omegahydroxy-poly(oxy-1,2- ethanediyl), C9-11 Category Hydrocarbon Detergent Detergent Detergent Detergent Detergent Detergent Detergent Detergent CAS number Concentration in product % w/w Hazard classification Eye Irritant. 2 Aquatic Chronic 3 Degradation and fate* 112-34-5 142-31-4 142-87-0 20% 10% <3% Eye Irritant. 2 Skin Irritant. 2 Eye Damage. 1 Skin Irritant. 2 Eye Damage. 1 Aquatic Chronic 3 Half-life in air is short (<5 hours). Within soils will be highly mobile but readily biodegradable. In water will not bind to suspended solids (remains in aqueous phase). Readily biodegradable in water. ECHA DB: Half-life in air 42 hours. Expected to fully biodegrade in water. ECHA DB: Half-life in air 32 hours. Expected to fully biodegrade in water (92% after 30 days). 68139-30-0 10% Eye Irritant. 2 ECHA DB: Will biodegrade in water, 71% degraded after 28 days at 20 Celsius. 68140-01-2 68155-09-9 68515-73-1 <0.2% 1% <3% 90583-18-9 10% 96130-61-9 <3% Skin Irritant. 2 Eye Damage. 1 Aquatic Chronic 1 Acute Toxicity. 4 Skin Irritant. 2 Eye Damage. 1 STOT RE 2 Eye Damage. 1 Acute Toxicity. 4 Skin Irritant. 2 Eye Damage. 1 Aquatic Chronic 3 Pre-Registration process (E) Would expect this compound to be readily biodegradable in water. Half-life likely to be days-weeks (<30 days) ECHA DB: Sewage sludge test showed 93% degradation after 28 days. ECHA DB: half-life in air <5hours; In soil and water fully biodegrades based on OECD test protocols. (E) Would expect this compound to be readily biodegradable in water. Half-life likely to be days-weeks (<30 days) (E) Would expect this compound to be readily biodegradable in water. Half-life likely to be days-weeks (<30 days) June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 80 Wood Environment & Infrastructure Solutions UK Limited Product Substance Category CAS number Concentration in product % w/w Hazard classification Degradation and fate* alkyl ethers, sodium salts ( -) Re-Healing Foam RF3x6 ATC sucrose ( - ) Hydrocarbon 57-50-1 >1% Not classified (E) Readily biodegrades Half-life in air is short (<5 hours). Within soils will be highly Re-Healing Foam RF3x6 ATC 2-(2butoxyethoxy)ethanol Hydrocarbon 112-34-5 20% Eye Irritant. 2 mobile but readily biodegradable. In water will not bind to suspended solids (remains in aqueous phase). Readily biodegradable in water. Re-Healing Foam RF3x6 ATC Starch Hydrocarbon 9005-25-8 >1% Not classified (E) Biodegradable Re-Healing Foam RF3x6 ATC Cocamidopropyl hydroxysultaine Detergent 68139-30-0 <2.5% Eye Irritant. 2 ECHA DB: Will biodegrade in water, 71% degraded after 28 days at 20 Celsius. * All degradation and fate data is based on Pubchem (https://pubchem.ncbi.nlm.nih.gov/), the ECHA database of REACH registered substances (ECHA DB) (https://echa.europa.eu/information-on-chemicals/registered-substances), or in cases where no information was found had been based upon expert judgement (E) June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 81 Wood Environment & Infrastructure Solutions UK Limited Step 4 selection of PFAS substances Additionally, based on the outputs of the Task 2 market research and stakeholder engagement, the highest tonnage PFAS based substances were also selected for modelling in the source-flow model. This included the following two substances: Table 5.4 PFAS based substances for selection Fluoro-compound 1-Propanaminium,N-(carboxymethyl)-N,Ndimethyl-3-[[(3,3,4,4,5,5,6,6,7,7,8,8,8- tridecafluorooctyl)sulfonyl]amino]-,inner salt 1-Propanaminium, 3-amino-N(carboxymethyl)-N,N-dimethyl-N-[[(gammaomega-perfluoro-C6-C16-alkyl)thio]acetyl] derives., inner salts CAS number 34455-29-3 80475-32-7 Tonnes per year Share of the total market 21.1 6% 17.2 5% Extrapolation of activity data The outputs from Task 2 provided valuable information on which non-fluorinated products are most commonly in use. However, data on specific quantities per product was largely incomplete. Therefore, a different approach was needed to help develop emission estimates. Data provided by Eurofeu (which represents 60-70% of foam producers) provided data for total quantities of PFAS-based and non-fluorinated based products as an aggregated total. This has been further extrapolated to derive estimated total EU sales of 20,000 tonnes of PFAS-based concentrate annually, and 9,000 tonnes of non-fluorinated alternatives annually (see Section 4). The stakeholder engagement also identified 12 manufacturers of non-fluorinated alternatives. The aggregated 9,000 tonnes has therefore been allocated equally across all 12 manufacturers, and further disaggregated based on number of products per manufacturer. This approach allows a fair assessment of the source-flow of material and order of magnitude estimates. The key limitation however is that some products will likely be used more widely than others. Suitable market data to provide specific quantities per product was unavailable. 5.3 Results and analysis Key messages from emission source-flow model The source-flow model has been used to produce emission estimates for 10 unique non-fluorinated substances (noting that two substances appear in multiple products, and further that alkylamidobetaine is listed with two different CAS numbers suggesting minor variation of the specific chemistry); as well as two PFAS-based substances. The non-fluorinated alternatives include a combination of hydrocarbons and detergents as defined by the selection methodology. Tables 5.5 and 5.6 provide summary overviews (as percentage ratios) of the key emission compartments and life-cycle stages for emissions. The initial overview of Table 5.5 highlights that fresh surface water and soil are the key receiving environmental compartments. Furthermore, Table 5.6 highlights that, for non-fluorinated substances, live incidents are the major point of release, while for PFAS the waste phase is the key life-cycle stage for June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 82 Wood Environment & Infrastructure Solutions UK Limited emissions, primarily from losses associated with releases at WWTPs. The major reason for this difference is that, while non-fluorinated foams are readily expected to degrade within WWTPs (thus lowering the importance of the waste cycle), PFAS based foams are expected to undergo little or no degradation within WWTPs. Table 5.5 Overview of ratios for emissions by different environmental compartment for all life-cycle stages combined. Substance group Non-fluorinated alternatives (range) Non-fluorinated alternatives (mean average) 1-Propanaminium,N-(carboxymethyl)-N,N-dimethyl-3[[(3,3,4,4,5,5,6,6,7,7,8,8,8tridecafluorooctyl)sulfonyl]amino]-,inner salt 1-Propanaminium, 3-amino-N-(carboxymethyl)-N,Ndimethyl-N-[[(gamma-omega-perfluoro-C6-C16alkyl)thio]acetyl] derives., inner salts *includes releases from WWTPs after treatment. Air 9 - 18% 14% 9% Fresh surface water* 33 -37% 35% 51% Marine waters 10 - 15% 13% 8% Soil 30 - 45% 38% 32% 9% 30% 8% 53% Table 5.6 Overview or ratios for emissions by different life-cycle stages Substance Group Non-fluorinated alternatives (range) Non-fluorinated alternatives (mean average) PFAS based substances (mean average) Formulation 9 - 18% 14% 9% Storage and Training 12 - 18% 15% 9% Live 40 - 62% 52% 30% Waste 1% - 35% 19% 52% Further examination of the data helps elaborate on the summary findings within Tables 5.5 and 5.6, with the following key points to help add context to the overview tables: Management of runoff during training The data from Brooke et al (2004) highlights that, aside from municipal fire brigades, the major use of firefighting foams is for training purposes. Feedback from the stakeholder consultation indicated that at least in some Member States and applications there will be local or national-level regulations in place governing containment and prevention of release of fire-fighting foam or firewater runoff to the environment, although it is not clear whether this is comprehensive. One possible exception is training for marine applications, where the more limited options likely means full loss of all firewater runoff to the marine environment. The treatment scenarios developed in Task 4 on remediation costs (see Section 6.3) suggest that for large infrastructure installations (e.g. airports, petrochemical facilities, and fire-fighter training complexes) the site should be engineered to allow for a 100% capture of materials used in the training activity. Furthermore, for live emergencies at such sites where larger volumes may be used and are expected to be handled, capture of firefighting water should be done as soon as practicable and safe. However, also note that, for live incidents, the releases of firefighting foams are very situation-specific and site-specific, and , in reality, it may not be possible to retain all runoff from fire-fighting. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 83 Wood Environment & Infrastructure Solutions UK Limited The specific kind of engineered options (hard surfaces, bunded areas, on-site drainage systems, etc.) will vary from site to site and the specific kind of operation being undertaken. As a further example of the practical application of how a given site may be managed, the UNECE good practice guidelines provide some further insight60: "There are several possible types of systems for the retention of contaminated firefighting water. The systems can be installed permanently (i.e. pre-installed water barriers or permanent retention basins, if necessary with pumping installations) or be provided as mobile facilities (i.e. fire-fighting water barriers, hoods and sealing pads, mobile storage tanks)." Firewater run-off can then be pumped into tanks and transported e.g. by trucks to treatment facilities. There are several short case studies of fire incidents with a description of retention and disposal of fire-water in Annex 1 of the UNECE good practice guidelines. One further consideration is the management of fire-fighting foam or firewater runoff at either on-site waste water treatment works or municipal waste water treatment plants. Again, this is likely to vary from site to site and is determined in part by the frequency of training and quantities of material that need to be managed. On-site treatment plants would incur a significant cost in the construction and operational phases, as well as requiring a minimum level of throughput to make operations practical. In some cases (e.g. petrochemical works) it is possible that sites already have on-site WWTPs for other purposes and are able to manage firewater runoff as and when needed. In other cases where training is less frequent (e.g. only quarterly / twice a year) use of municipal waste water treatment plants under environmental permitting is more likely. However, also note that where firewater runoff enters drains and is sent to municipal waste water treatment plants, the environmental permits may require some pre-treatment steps. For example, these could include the use of sediment traps to remove solids, an oil/water separator and possibly a granular activated carbon filter before discharge. As a conclusion a distinction needs to be drawn between uses for training purposes and uses for live incidents, noting the potential for greater control over runoff from training compared to live incidents. A review of the evidence suggests that at national level there are regulations in place in several countries over the design and management of fire-fighting runoff for training, and best practice guidelines for live incidents. However, further data on how comprehensive the coverage of these measures is across the whole EU and their practical implementation has been more difficult to obtain, and, based the evidence analysed, it is not possible to conclude that substantial quantities of runoff could not be released to the environment across Europe, particularly from live incidents.. Processing of substances in waste water Once within the waste water process two key factors determine how the substances identified are managed. Firstly partitioning (as Koc) and secondly the efficacy of the works to successfully destroy the chemical before release. The Log Koc values have been used a measure to help understand partitioning. In practice, the lower the Koc Value the more `water-loving' the substance, and the less likely it is to partition into the sludge phase. Table 5.7 provides log Koc values for a range of substances to provide an indicative guide. 60 https://www.unece.org/fileadmin/DAM/env/documents/2017/TEIA/JEG_MTGS/UNECE_Safety_Guidelines_and_Good_Pract ices_for_Fire-water_Retention_14_Nov_2017_clean.pdf June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 84 Wood Environment & Infrastructure Solutions UK Limited Table 5.7 log Koc values for a set of solvents, POPs and PFAS based substances as indicative guide to partitioning against Koc values. Substance Acetone Butanol Perfluorobutane sulfonic acid (PFBS) Perfluorooctanoic acid (PFOA) Perfluorohexane sulfonic acid (PFHxS) Perfluorooctanesulfonic acid (PFOS) Endosulfan Endrin Methoxychlor Polychlorinated biphenyls (PCBs) Poly aromatic Hydrocarbons (PAHs) Substance type Solvent Solvent PFAS PFAS / POP PFAS / candidate POP PFAS/POP Pesticide / POP Pesticide / POP Pesticide / Candidate POP POP POP Log Koc (l/kg) 0.24 0.84 1.0 1.3 - 2.4 1.8 2.5 - 3.1 3.3 4.09 4.9 5.5 6.2 Partitioning Hydrophilic Hydrophilic Hydrophilic Hydrophilic Hydrophilic Mixed Mixed Hydrophobic Hydrophobic Hydrophobic Hydrophobic Table 5.8 log Koc values for non-fluorinated substances included within Task 3. Substance 1,2-ETHANDIOL Triethanol AmmoniumLaurylsulfate sodium decyl sulphate ( - ) Sodium laureth sulphate Alkylamidobetaine sulfuric acid, mono-C12-14alkyl esters, compds. with triethanolamine ( - ) 1-dodecanol amides, coco, N-[3(dimethylamino)propyl] ( - ) amides, coco, N-[3(dimethylamino)propyl], N- oxides ( - )sucrose ( - ) 1-tetradecanol CAS number 107-21-1 85665-45-8 142-87-0 68891-38-3 147170-44-3 90583-18-9 112-53-8 68140-01-2 68155-09-9 112-72-1 Log Koc (l/kg) 0.0 1.88 2.09 2.20 2.81 3.19 3.30 3.82 3.82 4.53 Partitioning Hydrophilic Hydrophilic Mixed Mixed Mixed Hydrophobic Hydrophobic Hydrophobic Hydrophobic Hydrophobic June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 85 Wood Environment & Infrastructure Solutions UK Limited Table 5.8 provides the log Koc values for non-fluorinated substances which range from 1.8 to 4.5, with the exception of 1,2 ethanediol which has a Koc value of zero. This means that while these substances are soluble, for many of them there is a greater tendency to partition to the sludge phase. The log Koc values for the two PFAS species are 1.5 and 3.8, which means the partitioning is more mixed, with the CAS 34455-29-3 species having much greater solubility and mobility. This places greater onus on the releases from WWTPs, noting that the efficacy of WWTPs for PFAS based substances is expected to be poor. The other major factor is the efficacy of the works itself to irreversibly destroy specific substances. For the hydrocarbon-based alternatives, waste water treatment works could be expected to have a high level of efficacy, particularly against substances like 1,2 ethanediol which will readily disassociate. For detergentbased alternatives the efficacy may be less than for hydrocarbons, although overall efficacy is expected to be high (70%). By contrast waste water treatment efficacy against PFAS substances is expected to be poor with close to zero effectiveness. This makes partitioning particularly important for evaluating final emission of PFAS substances. Summary conclusions The overviews presented within Table 5.5 and 5.6 illustrate that significant use occurs for training purposes, with an assumption applied that runoff is largely retained and treated within waste water treatment works (although also noting that feedback from the study workshop and literature review highlights efficacy of WWTPs for PFAS substances is poor). For the non-fluorinated alternatives, the effectiveness of WWTPs is relatively good, minimising the emission which is split between surface water and soil. The effectiveness of the WWTPs to irreversibly destroy the named non-fluorinated substances, increases the importance of live incidents - where there is a direct release without treatment. For the PFAS-based substances there is a similar process with the majority of retained fire-water run-off from training sent for treatment at WWTPs. However, the efficacy is expected to be poor, with WWTPs ineffective at treating PFAS, meaning direct release to surface water / soil depending on the partition coefficient. Waste is thus the most important life-cycle stage for the PFAS substances (shown in Table 5.6). A further consideration within the results is the magnitude of emissions to different environmental compartments. Review of the data highlights a further two key points. Firstly, the PFAS-based surfactants are effective at low concentrations within the fire-fighting concentrate ( 3% w/w based on data from the stakeholder engagement), while the hydrocarbon/detergent alternatives are potentially less effective, meaning greater concentrations are needed within the concentrate product (aggregate of all substances within a given product equates to 10-20% w/w). Secondly, for the nonfluorinated alternatives a combination of substances is needed together to be effective. Based on the market analysis and stakeholder engagement, a small set of substances are used across multiple different manufacturers. This means that while the non-fluorinated fire-fighting foams make up approximately one third of the market, the volumes of alternative surfactants can be greater than their PFAS counterparts because of the greater concentration needed. By way of example: Taking uncertainty into account the emissions of alkylamidobetaine (CAS 61789-40-0) are estimated as 9.5 tonnes to water and 8 tonnes to soil annually for the European Union. This is based on an assumed annual sale of 86 tonnes (within different products); and As means of comparison, the PFAS surfactant 1-Propanaminium,N-(carboxymethyl)-N,Ndimethyl-3-[[(3,3,4,4,5,5,6,6,7,7,8,8,8-tridecafluorooctyl)sulfonyl]amino]-,inner salt (CAS 3445529-3) has annual sales of 21.5 tonnes (within different products) and estimated emissions to water of 3.3 tonnes and to soil of 1.8 tonnes annually across the EU. This reflects potentially higher emissions of the non-fluorinated alternatives, primarily due to greater concentrations within the product itself. However, it is important to recognise that emission alone is not an June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 86 Wood Environment & Infrastructure Solutions UK Limited indicator of impact, and the degradation rates, potential for bioaccumulation, and harmful effects also need to be considered. The next sub-section provides a consideration of the hazards for non-fluorinated alternatives, before the final sub-section in this chapter combines the emission estimates with hazard data to consider potential risks from exposure via uptake / man-via-the environment pathways. Review of hazards In this sub chapter the hazards of the identified fluorine-free alternative substances have been assessed based on their PNEC (Predicted No Effect Concentration). As highlighted in ECHAs guidance document on information requirements and chemical safety assessment (Chapter R.10: Characterisation of dose [concentration]-response for environment)61, the PNEC represents "the concentration of the substance below which adverse effects in the environmental sphere of concern are not expected to occur". Mostly, PNEC values are derived from acute and chronic toxicity single-species or multi-species data. To extrapolate from this data, an empirical assessment factor is necessary to make assumptions for the entire ecosystem. In combination with predicted environmental concentration (PEC) values PNECs are used to calculate a risk characterisation ratio. For this the PEC is divided by the PNEC, thus if the PNEC exceeds the PEC, it can be concluded that there is no environmental risk based on the concentration of the observed substance. However, in this project, the sole consideration of a PNEC value is not advisable, based on the uniqueness of PFAS substances. In an ecotoxicological assessment, this uniqueness is for example expressed by the fact that they are not biodegradable. ECHA's guidance document highlights that the "degradation of organic substances in the environment influences exposure and, hence, it is a key parameter for estimating the risk of long-term adverse effects on biota"62. Thus, in the following not only PNECs but also data on biodegradation and bioaccumulation is considered. It should be noted that the following considerations are not meant as a full risk assessment; they are meant rather as an indicative comparison of the identified substances among each other and against the fluorinated substances. Based on their REACH registration dossiers it was possible to identify most of the PNECs, biodegradation and bioaccumulation data of the fluorine-free alternative substances and the selected fluorinated substances. In the following table an overview of the substances, their respective products, CAS numbers, PNECs, bioconcentration factors (BCFs), and biodegradation assessments are given. Due to the focus of this project the PNECs for freshwater and soil were considered. Table 5.9 Overview on substances used in fluorine-free fire-fighting foams and one substance used in a fluorinated foam. Shown are the product, CAS/EC, PNECs, and the used reference. The respective lowest PNECs are highlighted in bold. Substance 1-dodecanol 1-tetradecanol Sodium laureth sulphate Product Respondol ATF 3/6 Respondol ATF 3/6 Respondol ATF 3/6 CAS 112-53-8 PNEC aqua (freshwater ) mg/L PNEC soil (mg/kg soil dw) Biodegradation (... biodegradable in water) Bioaccumulat ion (BCF) Reference 0.001 0.132 Readily 750 ECHA RD 112-72-1 0.0063 0.428 Readily 1000* ECHA RD 68891-38- 0.24 3 0.0917 Readily waived ECHA RD 61 https://echa.europa.eu/documents/10162/13632/information_requirements_r10_en.pdf 62 https://echa.europa.eu/documents/10162/13632/information_requirements_r7b_en.pdf June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 87 Wood Environment & Infrastructure Solutions UK Limited Substance Product CAS PNEC aqua PNEC soil Bio- Bio- Reference (freshwater (mg/kg degradation (... accumulat ) mg/L soil dw) biodegradable ion (BCF) in water) Alkylamidobetaine Moussol FF 3x6 61789-400 0.0032 0.0419 Readily 71* ECHA RD Re-Healing Foam RF1 1% 1,2-ethandiol Moussol FF 3x6 107-21-1 10 1.53 Readily waived ECHA RD Orchidex BlueFoam 3x4 Triethanolammoni um-laurylsulfate Moussol FF 3x6 85665-458 0.017 0.042 Readily waived ECHA RD sodium decyl sulphate ( - ) Re-Healing Foam RF1 1% 142-87-0 0.095 0.2445 Readily waived ECHA RD amides, coco, N-[3(dimethylamino)pr opyl] ( - ) Re-Healing Foam RF1 1% 68140-012 No data amides, coco, N-[3- Re-Healing 68155-09- 0.0059 3.68 Readily (dimethylamino)prop Foam RF1 1% 9 yl], N- oxides ( - )sucrose ( - ) No data ECHA RD sulfuric acid, monoC12-14-alkyl esters, compds. with triethanolamine ( - ) Re-Healing Foam RF1 1% 90583-189 0.012 0.083 Readily No data ECHA RD 1-Propanaminium,N(carboxymethyl)-N,Ndimethyl-3[[(3,3,4,4,5,5,6,6,7,7,8, 8,8tridecafluorooctyl)sulf onyl]amino]-,inner salt AFFF 34455-293 0.0326 0.00133 Not readily 450 ECHA RD 1-Propanaminium, 3amino-N(carboxymethyl)-N,Ndimethyl-N[[(gamma-omegaperfluoro-C6-C16alkyl)thio]acetyl] derives., inner salts AFFF 80475-327 0.009 1.17 Not readily Explanatory note: Waived means, that the test was not required due to the results of other tests. *An asterisk means, that this value was extrapolated based on calculations. No data ECHA RD It is observable that the two fluorinated substances (CAS 34455-29-3 and 80475-32-7) are the only substances that are "not readily biodegradable in water" (data on biodegradation in soil is not available in the registration dossier)63. In addition, the substance with CAS 34455-29-3 also has the lowest PNEC for soil, meaning that, at concentrations higher than 1,33 g/kg (ppb) a risk cannot be excluded. The combination of this value and with its relatively low PNEC for freshwater (0.0326 mg/l), shows, that this substance exhibits 63 https://echa.europa.eu/de/registration-dossier/-/registered-dossier/17549/1 June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 88 Wood Environment & Infrastructure Solutions UK Limited more hazard to the environment than any of the non-fluorinated substances. This finding is also supported by the fact that the treatment at WWTPs is ineffective (as shown in the previous subchapter). In terms of partitioning the fluorinated substance CAS 34455-29-3 has a log koc of 1.5, suggesting strong partitioning to treated effluent within WWTPs and release to surface water. Use during live incidents is assumed to be released equally to surface water and soil. This may suggest that the bigger impact for soils would come from live incidents. However, some of the alternatives have both relatively low PNECs and relatively high biodegradation and/or bioaccumulation data. This is true for two alcohols (1-dodecanol and 1-tetradecanol). However, in comparison to the two fluorinated substances listed in Table 5.8, both of the non-fluorinated substances are readily biodegradable due to the rapid metabolism of long-chain fatty alcohols in fish, mammals and microorganisms (based on information taken from their registration dossiers). That means that, even if the substance is emitted to the environment in the context of a release from WWTPs or live incidents, it will be biodegraded rapidly. Furthermore, as highlighted in the previous section, based on these properties it could be expected that waste water treatment plants would have a high level of efficacy for the destruction of these substances. Taken together, this review of hazards based on PNECs and data on biodegradation and bioaccumulation shows, that the two fluorinated substances should be considered of higher priority compared to the nonfluorinated substances when it comes to hazards and potential risks to the environment. This is due to the PFAS being both non-biodegradable and having relatively low PNECs for water and soil. Some of the alternative substances exhibit low PNECs, however, this needs to be considered in the context of their ready biodegradation. Further discussion on the hazards of the shortlisted alternatives can be found in Section7.5. Further considerations for exposure via uptake from food This final sub-section considers both the outputs of the emission model and the hazard assessment to identify further thoughts on the potential human exposure via uptake from food. This section is intended to provide first thoughts as a high-level review. Further work would be needed to assess the risks associated with specific sites or food production pathways, and that is beyond the scope of the current study. The output of the emission model highlighted that, because the major use of fire-fighting foams is dominated by training, the efficacy of bunding/control measures is critical in preventing direct release to the environment. Secondly, the capacity of waste water treatment plants to successfully remove and/or destroy substances and prevent emission to environment is key to limiting their release to the wider environment. The review of hazards highlighted that the fluorinated compounds have very low biodegradability and, in at least one case, very low PNEC values for soil. Furthermore, based on feedback from the workshop, the efficacy of waste water treatment plants against fluorinated compounds is typically poor. This suggests that the first major conclusion that can be drawn is that the PFAS-based compounds represent a greater risk to uptake and exposure than the non-fluorinated alternatives. Further review of the non-fluorinated alternatives highlighted a number of compounds (see Table 5.8) that also have very low PNEC values for water and soil (albeit higher than their fluorinated counterparts). The emission model also highlighted that the efficacy of the non-fluorinated substances as surfactants is typically poorer than fluorinated substances and thus greater concentrations are needed within the fire-fighting foam concentrate. This means that the potential emissions are higher, particularly where the same substance is used in multiple products by different manufacturers (i.e. in aggregate). One further important consideration therefore could be in cases where fire-fighting foams are used multiple times at the same location. The emission model suggests that the majority of use would be for training. For those substances with particularly low soil PNECs and lower biodegradation properties a concern could be that, if the control measures are less effective in some locations, releases could repeatedly `shock' soil microflora and fauna (i.e. the release has toxic effects upon the soil, with secondary or repeated releases before the microflora and fauna communities have a chance to recover). The removal of such biological June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 89 Wood Environment & Infrastructure Solutions UK Limited degradation pathways from the soil could also have knock-on consequences for the biodegradation of the substance itself, meaning that persistence may be greater than the values quoted within Table 5.8. Based on consideration of these factors and in examination of the emission model alkylamidobetaine (CAS 61789-40-0) could be one such substance that meets these criteria, i.e. use concentrations (based on review of available SDS) are up to 10% w/w of the concentrate. It is used in at least four products by different manufacturers suggesting in use quantities could be significant. It also has PNEC values for fresh water of 0.0032 mg/l and soil of 0.0419 mg/kg dw (which can be considered low). In instances of sites with repeated use for training and less well-established control measures, effects for soil could highlight a need for further investigation. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 90 Wood Environment & Infrastructure Solutions UK Limited 6. Task 4 - Remediation costs and technologies 6.1 Introduction The aim of this task is to determine the techniques most likely to be used for the remediation of PFAS from fire-fighting foams and fluorine-free alternatives in soil, surface water and drinking water, as well as the associated costs. In the following, the approach is briefly described before the results are presented. 6.2 Approach A combination of inputs to the targeted stakeholder consultation (see Section 2, literature review, results of the stakeholder workshop (see Section 2.4) and expert knowledge have been used in this task. The stakeholder workshop included a breakout group focused on remediation. This provided an overview of insights from key stakeholders and is presented first to frame the subsequent analysis. The remainder of the analysis follows a six-step approach: Step 1: "Remediation" and "clean-up" are defined and discussed to provide a basis for the subsequent analysis; Step 2: Contamination scenarios relevant to AFFF applications are reviewed with a focus on fire-fighting activities of liquid fuel fires which have been highlighted as the key use of AFFF in the market analysis. The potential for contamination resulting from use of alternative, fluorinefree foams is reviewed; Step 3 is a discussion on the "point of treatment" at a remediation site. The different options considered as point of treatment are source area, groundwater plume and end point treatment; Step 4: Applicable drivers to engage in active remediation or clean-up/treatment are evaluated; Step 5: While every impacted site is in some fashion unique, there are similarities related to the fate and transport of relevant PFAS compounds that produces a limited number of available and reliable remediation/treatment technologies. A more commonly used set of treatment/remediation options or a combination of those is identified and discussed in this step; and Step 6: The identified options are evaluated with respect to associated costs based on contamination scenarios and industry/expert knowledge. 6.3 Results Stakeholder workshop During the stakeholder workshop, breakout group 3 discussed PFAS remediation and associated costs and the available and feasible technologies. The following questions were presented and discussed during the workshop: Which technologies are most commonly/likely applied for the remediation of soil and water contaminated by PFAS or alternative fire-fighting foams? What are the differences in remediation practices between PFAS-containing foams and fluorine-free foams and between fire training exercises and true emergency responses? June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 91 Wood Environment & Infrastructure Solutions UK Limited Are there cases where remediation is not necessary, not technically feasible or not economically viable? What approaches are used to manage regular run-off and storm-water run-off and what restrictions exist on discharge concentrations/volumes and treatment prior to discharge? Which additives, degradation-products or by-products of fire-fighting foams need to be considered, for both PFAS foams and alternatives? and What are the current regulatory drivers to engage in remediation (e.g. permits for training activities and discharge, Water Framework Directive EQS for PFOS)? Stakeholders provided input on site clean-up and remediation related to PFAS as summarised by the following statements that intend to give a general perspective on remediation with respect to PFAS resulting from historical impacts at legacy sites and newly released PFAS-compounds during recent fire-training exercises or live fire events. Remediation at legacy sites with PFAS contamination is very difficult to address; Remediation costs are highly site specific; There is a lack of technical options for soil remediation; Since soil and water remediation is generally expensive, containment of fire-fighting waste water and treatment before it reaches soil and groundwater is critical; and Clean-up after a live event should happen as soon as possible after the incident, specifically when PFAS foams were used. Some stakeholders suggest clean-up and complex treatment is not always necessary after the use of fluorine-free foams, although due to the presence of contaminants from the fire including liquid fuel and incidental materials and compounds that were affected or released during the fire, it is often required after live incidents regardless of the foam used. Step 1: What is what: Definition of "remediation" versus "clean-up" Remediation Remediation pertains to legacy contamination that historically occurred from fire-fighting or training activities using AFFF products. Remediation in this sense would only include PFAS-impacted sites, because remediation cannot be anticipated at this point for replacement substances (e.g. fluorine-free foams). It is assumed that substances that are of concern for human health and the environment, based on toxicology, fate and transport, or other legal/relevant drivers, will not be used in alternative fluorine-free foam products. Task 3 (see Section 5) has shown that the substances contained in fluorine-free alternatives exhibit lower concern than PFAS used in fire-fighting foams, due to their lower hazards and rapid biodegradation. Should fluorine-free foams become a burden in the future, and themselves require soil and/or groundwater remediation beyond the constituents of the fuels that have been extinguished, an evaluation needs to be conducted then. So far, no cases have been identified where remediation has been required due to contamination from fluorine-free alternatives. In the use scenarios considered in this assessment, typically remediation sites include a soil source zone where the actual fire-fighting activity has been carried out. PFAS compounds present in shallow soils tend to leach with infiltrating precipitation to greater depth in the soil column eventually reaching groundwater. Once groundwater has been impacted, huge dilute plumes tend to form. Groundwater plumes are large because PFAS compounds are very mobile in the subsurface and because of the very low concentration June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 92 Wood Environment & Infrastructure Solutions UK Limited thresholds that are relevant to human health and the environment64. Contaminated groundwater is in itself a concern since groundwater is a sensitive and important receptor. The critical use of groundwater can include groundwater extraction for drinking water for human consumption, for agricultural irrigation of crops, or for watering of farm animals. Groundwater can also become - directly or indirectly - surface water by extraction and surface discharge or by groundwater/surface water interaction in rivers, streams or lakes. Typically, remedial activities are driven by regulatory processes and include the use of remediation target levels or follow a risk-based approach. The number of PFAS compounds that currently "drive the market" are few in comparison to the number of potential PFAS compounds known and likely present at a remediation site. At the same time, there are only a few PFAS compounds that are in the centre of attention based on the magnitude of their production and use, here for AFFF products. As a consequence, the number of PFAS compounds that have been researched with respect to their toxicology, fate and transport in the environment, and effects on human health and the environment is relatively small. Only about a couple dozen individual compounds have been sufficiently studied. In many European countries, there are only a few PFAS compounds that are regulated with respect to their allowable concentrations in drinking water, ground water, surface water and soil65. In December 2019, the European Commission and European Council agreed to set parameters for PFAS under the Drinking Water Directive (98/83/EC). Member States will be able to choose either a parameter of 0.1 g/l for the sum of PFAS listed in Annex III of the Directive, or of 0.5 g/l for the totality of PFAS once technical guidelines for monitoring this parameter are developed. To address concerns related to groundwater, a pilot exercise was launched in 2017 which resulted in ten PFAS being added to a "list facilitating Annex I and II review" (a list of possible substances to be considered for additional regulation in the future review of the Groundwater Directive annexes) and two PFAS to be added to a first voluntary watch list. Clean-up Clean-up relates to new incidents or accidents such as planned training activities or emergency response actions, respectively. Currently, it should be assumed that training activities with PFAS-containing foams are largely conducted at fully contained training facilities so that fire-fighting water can be completely captured and addressed with thorough treatment, as discussed in Section 5.3. However, there might be exceptions where release to the environment from training occurs, and there are still emergency responses where AFFF material is used. Clean-up of an emergency response site would need to happen as soon as possible after the fire is controlled and the site is safe to enter to reduce the potential or the amount of PFAS able to infiltrate into the soil matrix. Environmental sampling from affected soil and/or water (surface water and/or groundwater) might need to occur to determine follow-on actions to remove unacceptable concentrations. The potential processes and technologies used for remediation and clean-up are discussed further in Step 5 ("Treatment technologies and treatment scenarios - soil and water") below. 64 ITRC Fact Sheet; Environmental Fate and Transport for Per- and Polyfluoroalkyl Substances, March 2018. 65 Concawe Report, Environmental fate and effects of poly- and perfluoroalkyl substances (PFAS), June 2016. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 93 Wood Environment & Infrastructure Solutions UK Limited Figure 6.1 Overview of "Remediation" vs. "Clean-up" REMEDIATION Resulting from historical activities; Legacy site/area; Large groundwater plume; Additionally impacted receptors; Multiyear site activities; Can include remediation infrastructure and O&M programme; Very expensive; and Technologies used and costs highly site specific. CLEANUP Resulting from recent activities; Often still operating site; Impact initially "only" surficial; Contaminants geographically confined; Can be accomplished in short timeframe; Engineered systems/facilities possible, mobile equipment possible; Reasonable costs (much lower than remediation costs); Technologies used and costs more plannable; and Costs fuel and foam driven. Step 2: Contamination scenarios: PFAS-containing foams and fluorine-free foams PFAS-containing foams For PFAS-containing foams at legacy sites, contamination patterns normally include soil, both unsaturated and saturated, to be impacted by PFAS at higher concentrations, because the PFAS entry point into the subsurface occurs from above ground in most scenarios, specifically for fire-fighting and training events. PFAS leaching to greater depths in the soil column by infiltrating precipitation eventually reaching groundwater is commonly observed at legacy sites. Leaching is supported by the physicochemical characteristics of PFAS. PFAS in shallow soils can also be transported via overland flow by storm water run-off during precipitation events. Storm water would either infiltrate into the ground at an area geographically separated from the original fire-fighting activities, or storm water run-off can directly discharge to a surface water body such as a river, stream, or lake, or it can be captured in a storm-/ waste water treatment facility. Historically, storm- or waste water facilities were not required to analyse for PFAS compounds. It can be assumed that most PFAS have passed untreated through a treatment works without awareness of the operator allowing for PFAS to spread to the wider environment66. The PFAS-laden soils in the source area continue to be an emission source for groundwater contamination for many years, if not decades. Once PFAS-compounds have reached the aquifer or a water-bearing unit, those compounds tend to migrate laterally and in a hydraulically downgradient direction with limited retardation from the soil matrix and negligible, if at all occurring, breakdown through biotic or abiotic processes in the aquifer67. As a consequence, PFAS tend to generate large plumes in groundwater. Acceptable PFAS threshold concentrations are extremely low, and plumes can be many kilometres long. In the Veneto region, Italy, a PFAS-production facility contaminated an area spanning more than 200 square km68. Various scenarios can result from PFAS-impacted groundwater. Groundwater could be extracted and used as drinking water. Extracted groundwater could also be used for irrigation of agricultural land. In addition to soil and groundwater impacts, surface water could be impacted from historically contaminated soils by means of surface water run-off. Under certain hydrogeological conditions, groundwater can become surface water or interact with surface water in brooks, creeks, streams, or river beds. PFAS-contaminated surface water is a major concern under the Water Framework Directive with an extremely low Environmental 66 Nordic Council of Ministers, The Cost of Inaction - A socioeconomic analysis of environmental and health impacts linked to exposure to PFAS, 2019. 67 Concawe Report, Environmental fate and effects of poly- and perfluoroalkyl substances (PFAS), June 2016. 68 World Health Organization, Keeping our water clean: the case of water contamination in the Veneto Region, Italy, 2016. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 94 Wood Environment & Infrastructure Solutions UK Limited Quality Standard (EQS) for PFOS (annual average EQS for PFOS is 0.65 ng/l)69. PFAS-impacted ground or surface water can become a challenge when they enter a water treatment works at privately owned locations (e.g. oil and gas sites or airports) or public treatment works, as indicated above. In most cases PFAS are not analysed for in water treatment works and the presence or absence of PFAS are consequentially unknown. PFAS would require in most, if not all, cases, a separate treatment step in the water treatment works with potential requirements for additional pre-treatment (e.g. high dissolved organic carbon (DOC) can be a problem in treating PFAS) and retrofitting of the treatment works at a substantial cost. Fluorine-free foams Based on the definition of "remediation" and "clean-up" there would not be a remediation scenario that includes fluorine-free foam compounds as of now. For one, replacement products are fairly new to the market and possible/potential impacts from fluorine-free foams to the wider environment has not yet caused adverse effects. The current expectation is that replacement products (alternatives to AFFF) do not have the potential to contaminate soil and/or groundwater in a way that remediation can be assumed or predicted to be needed. The analysis of alternatives (see Section 7.5) has shown that the substances contained in shortlisted fluorine-free alternatives (i.e. a set of alternatives considered likely to be used) exhibit lower hazards than PFAS and rapid biodegradation. Even if those alternative substances have the potential to contaminate soil and groundwater, remediation scenarios/technologies are hard to define. Remediation in most EU countries is risk-driven. That risk from alternative products cannot reasonably be anticipated at this point to develop a "remediation scenario" including treatment technologies and associated costs. There was anecdotal evidence presented by one stakeholder at the workshop that fluorine-free foam caused emulsification of the run-off water in a water treatment works. Should emulsification be a recurring issue for use of fluorine-free foams, then a separate treatment step to break up the emulsion would need to be included at the water treatment works as a retrofit at an additional cost. Also, an anecdotal example was presented from another stakeholder that a permit was granted where 5,000 litres of firewater runoff from fluorine-free foams could be discharged directly to a sewer after "only" a fuel separator step. Step 3: Point of treatment - source area, site hydraulic control, plume, and "end-of-pipe" As described previously under fire-fighting scenarios using AFFF-containing products, PFAS compounds experience a fate and transport that can be generalised for most occurrences and described as follows (see figure70 below). At the location of the active fire-fighting activity PFAS-laden waters enter the subsurface resulting in PFASimpacted soils - the source area (No. 1). The source area typically holds the greatest PFAS mass. Precipitation supports leaching of PFAS compounds in the unsaturated soil column to greater depth (No. 2) in the soil column eventually reaching groundwater which is then the starting point of a PFAS plume in groundwater (No. 3). Depending on the fuel that was extinguished, PFAS have a tendency to accumulate with free phase products71 at the water table intersection. The plume will extend in the direction of and grow with groundwater flow as more PFAS-mass leaches from the source area. Eventually the plume might grow to a size extending past the property boundary (airport, O&G refinery, etc.) migrating off-site. The PFAS plume size might have grown in size and extended into areas where groundwater extraction could occur for domestic (No. 9), commercial or public use (No. 10) including private drinking water wells, agricultural 69 Directive 2000/60/EC of the European Parliament and of the Council establishing a framework for the Community action in the field of water policy. 70 Wood E&I Solutions, 2017. 71 Common petroleum hydrocarbon-based fuels are lighter than water (light non-aqueous phase liquids - LNAPL) and accumulate at the water table intersection when they are released to the environment at large enough quantities. "Free phase" refers to a fuel layer on the groundwater table. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 95 Wood Environment & Infrastructure Solutions UK Limited irrigation and livestock feeds, and drinking water production facilities. Stormwater runoff from a fire training area or live fire incident can migrate in various directions predominantly following land surface morphology (No. 5). In consequence, surface water runoff can spread PFAS contamination in directions beyond groundwater flow. Stormwater runoff can directly or indirectly occur via some sort of controlled or uncontrolled overland flow or through underground utilities. Damaged/leaking utility structures can be locations where PFAS could enter the subsurface at a point that is in only limited relation to the actual firefighting area. Stormwater or surface runoff could eventually discharge to a surface water body such as the sea, a lake or pond, or a stream, river, creek or brook (No. 6). Sediments at the bottom of surface water structures including the surface water runoff ditches, drains, channels, ponds, lakes, or the sea can have PFAS-laden sediments as precipitated solids as part of the surface water feature (No. 7). Figure 6.2 Overview of PFAS fate and transport from use of fire-fighting foams The point of treatment can be selected based on economic considerations. The investment in Euros spent per mass unit of PFAS removed is largest in the source area (No. 1). The absolute PFAS mass removed is greater in the source area when comparing to groundwater extraction and subsequent treatment. Also, PFAS mass removed in the source area will not be available to support plume growth in groundwater. The point of treatment can also be based to protect a sensitive receptor such as a drinking water (domestic No. 9, commercial, or public No. 10). Here an end-of-pipe technology would treat the PFAS-impacted and extracted groundwater to acceptable levels prior to use or distribution. Hydraulic control of a site could be critical to prevent contaminants to extend beyond the property boundary (No. 4). A series of extraction wells or a drainage wall/trench near the property boundary would ensure that PFAS-impacted groundwater does not extend beyond the property boundary by groundwater flow. The extraction well gallery or drainage would need to be installed perpendicular (as far as possible) to the groundwater flow direction and be long enough to cover the plume width. In most, if not all, cases, remediation of an entire PFAS-plume in groundwater is economically not viable since PFAS plumes are extremely large and, in comparison to other contaminants such as hydrocarbons or chlorinated solvents, they are a concern at very low concentrations. Source area treatment: Unsaturated and saturated soils are typically treated/remediated by means of excavation and disposal / incineration. Here the largest PFAS mass is typically removed from the subsurface in a short amount of time with a high effectivity, efficiency and potentially long-lasting reduced environmental impact (depending on the end disposal route, e.g. if the leachate from the landfill is correctly collected and treated or if the incineration uses temperatures high enough to reliably destroy PFAS). June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 96 Wood Environment & Infrastructure Solutions UK Limited Hydraulic site control: To eliminate off-site migration of PFAS-contaminated groundwater, impacted groundwater is extracted at the site boundary through one or more extraction wells or a drainage structure. The extraction process eliminates or greatly reduces the mass flux across the property line. While the hydraulic containment system is not able to recover PFAS-impacted groundwater that has already migrated to off-site areas, it can greatly reduce the potential impact on receptors that could be downgradient, including neighbouring properties or sensitive points of use such as private or public drinking water wells or agricultural use wells or surface water structures. "End-of-pipe" treatment: In the event that PFAS contaminated groundwater is extracted for human use or consumption or for agricultural use, groundwater would need to be treated after extraction. Commercially available treatment technologies to recover PFAS molecules from water include adsorption technologies such as granular activated carbon (GAC) or resins (regenerable and non-regenerable). Reverse osmosis can also be used to treat extracted groundwater. Short-chain PFAS can be more resilient to some of these treatment technologies, so that more rigorous measures are required for effective treatment (e.g. a secondary treatment step using a resin that is optimised to retain the specific short-chain PFAS compounds, or higher temperature incineration). This is discussed in more detail in Step 5 on treatment technologies. Step 4: Drivers for active measures - why is clean-up / remediation required? For PFAS-containing foams, specifically at legacy sites with historical releases/impacts, remediation is warranted and likely required by regulatory agencies when sensitive receptors (including groundwater) are threatened or already impacted. Guidance levels for up to a dozen or so individually identified PFAS compounds (including PFOS, PFOA, PFHxS, etc.) have been developed in various European countries72,73 and parameters for the sum of certain listed PFAS (0.1 g/l) for the totality of PFAS (0.5 g/l, once technical guidelines for monitoring this parameter are developed) have been developed for the Drinking Water Directive. For legacy sites in various European countries a risk-based remediation approach would be implemented by describing the risk to relevant receptors based on analytical data collected from environmental media such as soil, surface water and/or groundwater. In some instances, animal/fish or vegetation samples are collected and analysed to evaluate PFAS migration in the food chain at different trophic levels. If a risk to a receptor is not acceptable, active measures would need to be initiated. The level of effort related to an active measure and the measure or combination of measures itself is highly site specific and depends on the level of impact to the site and the sensitivity of the impacted or threatened receptor, amongst other drivers. Case studies on "contamination from use of aqueous film-forming foams" are presented in the report of Nordic Council of Ministers74 and summarised in the table below. Table 6.1 Nordic Council report case studies of PFAS contamination from AFFF use Site Kallinge-Ronneby Military and Civilian Airbase, Sweden Contamination Contamination source Detected PFAS contamination in the outgoing water from one of two municipal waterworks which supplied water to around 5,000 people. PFHxS, PFOA and PFOS were sometimes 100-300 higher in the contaminated water source (e.g. up to 8,000 ng/l for PFOS). Blood samples showed significant human exposure via drinking water. The source of the contamination was identified as the fire drill site located in the nearby military airport where AFFF containing PFOS had been used since the 1980s, then other PFAS-based AFFF since 2003 and fluorine-free foams since 2011. 72 Concawe Report, Environmental fate and effects of poly- and perfluoroalkyl substances (PFAS), June 2016. 73 NICOLE, PFASs Summary, January 2016. 74 Nordic Council of Ministers, The Cost of Inaction - A socioeconomic analysis of environmental and health impacts linked to exposure to PFAS, 2019. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 97 Wood Environment & Infrastructure Solutions UK Limited Site Contamination Contamination source Jersey Civilian Airport, Channel Islands 78 properties were within the plume area. Groundwater in 36 of these properties tested positive for PFOS. Although at some of the sites, concentrations of PFOS have shown signs of decline, they have remained at high levels for seven years in private wells (up to 98,000 ng/l). The airport's fire-training site was identified as the origin of the contamination. In 1991, the fire training site started using AFFFs to meet the requirements of UK Airport Fire Services. The foam used at the site during training exercises was discharged regularly without monitoring, dissolving into the ground and rainwaters. Contamination subsequently found its way into the aquifer and bay. Schiphol Airport, The Netherlands In July 2008, an error in the sprinkler-system at a hangar released 10,000 litres of AFFF, containing 143 kg of PFOS, into the surrounding environment. This fed into a larger reserve of waste water (100 million litres) kept in five reserve reservoirs, several of which leaked and caused substantial contamination of the soil and surface water. The water resources were found to contain over 12 times the average amount of PFOS otherwise found in several reference sites in the Netherlands. Source: Nordic Council of Ministers, The Cost of Inaction - A socioeconomic analysis of environmental and health impacts linked to exposure to PFAS, 2019. Clean-up is driven to a large degree by the flammable liquid itself, the soot, water and "dirt" in general terms that contribute to the fire-fighting water runoff and its potential to impact the environment. The foam used might just be another component that will need to be captured and treated, specifically under the scenario of a fluorine-free foam use. As discussed above, it is assumed that fluorine-free foams will not be persistent, mobile and toxic at levels that will require remediation (e.g. legacy site) when they enter the environment. For training activities facilities including the associated water treatment works should be engineered to account for 100% collection of all fluids including fuel and foams that the fire training water can be cleaned and treated accordingly before releasing treated waters back to the larger environment. Should a fire have been extinguished during training or a live event using AFFF foam then it is advisable to clean-up the firefighting water promptly after the incident. Depending on the location of a live fire and the foam used, soil samples should be collected from areas where fire water runoff could have percolated into the subsurface to evaluate the presence or absence of PFAS compounds and their concentrations. Depending on the soil analytical results a need for soil exchange might be indicated. After a live fire event, regulatory communication and agreement is required for subsequent steps in the clean-up procedure to reach acceptable site conditions that will not create or leave a risk to human health or the environment. One stakeholder shared a scenario where clean-up seemed to be challenging. Fire-fighting activities in close vicinity to open water bodies (such as sea or lake) make it close to impossible to recover fire-fighting water runoff discharged into the sea or lake. To avoid runoff entering the sea, engineering solutions would be required as much as that is possible. For facilities in close proximity to large water bodies, one could possibly design berms and a drainage system to recover fire-fighting water in case a fire should truly occur. However, it might also be prudent to switch to less environmentally critical, fluorine-free, foams. Step 5: Treatment technologies and treatment scenarios - soil and water Treatment technologies75 Remedial options or treatment technologies available to address PFAS contamination are limited based on the specific physicochemical properties of these compounds. Many of the commonly used remedial 75 ITRC Factsheet, Remediation Technologies and Methods for Per- and Polyfluoroalkyl Substances, March 2018. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 98 Wood Environment & Infrastructure Solutions UK Limited treatment technologies are not effective because of the low volatility, and the molecular stability resisting oxidation, reduction or microbial degradation. Current full-scale proven and reliable remediation technologies are limited to the following76: Soil: Excavation followed by: o Landfilling; and o Incineration. Confinement/capping. Groundwater: Pump and Treat followed by: o Adsorption on granular activated carbon (GAC); o Adsorption on resin (regenerable and non-regenerable); and o Reverse osmosis (clean water application). Commonly used soil remediation technologies include excavation and landfilling or incineration, and soil capping. For coarser grained soil, soil washing can be an option which is in use at sites featuring the right geological setting. However, soil washing water will require subsequent treatment, and the finer soil fraction needs to be treated in a different fashion (landfilling, incineration). Water treatment (including groundwater, surface water, and storm-/ waste water) typically include adsorption of PFAS compounds from the aqueous matrix onto an adsorbent such as granular activated carbon (GAC), or resins (non-regenerable or regenerable). The relative and absolute loading capacity of adsorption media for PFAS is low, requiring more adsorbent than when compared to other contaminants such as hydrocarbons or chlorinated solvents. Spent adsorbents need to be regenerated or incinerated at high temperature (>1,000 to 1,200C). As discussed in more detail below, GAC or resin treatment can be effective for both long-chain and short-chain PFAS, but they are less efficient for short-chain PFAS. Soil excavation and landfilling does not destroy the actual compounds of concern, but rather shifts the problem to a different geographic location. Landfilling includes hauling PFAS-impacted soils via truck or in limited instances on rail or boat to a landfill. Transport is energy consuming and bears its own risks such as accidents leading to spilling PFAS-contaminated material. Landfill space in Europe is becoming increasingly more limited because it contradicts environmental policy objectives to landfill impacted soils and permitting of new landfills lags behind required capacities. Also, landfills that accept PFAS-impacted soils need to address PFAS in landfill leachate which requires monitoring and in consequence some sort of water treatment technology for PFAS in the leachate. Regular landfills are reluctant to accept PFAS-containing soils, and disposal costs increase accordingly for landfills accepting PFAS-containing materials. Incineration of soils is an energy intensive process, furthermore due to the very stable C-F bond in PFAS, incineration of PFAS contaminated soil requires temperatures of at least 1,100C to degrade PFAS to carbon dioxide and hydrogen fluoride77, however, also note that shorter chain PFAS (C4) are even more resilient (than longer chains) and need higher temperatures closer to 1,400oC to achieve full breakdown. For incineration at temperatures below 1,100oC it has not yet been determined what is produced from incineration of PFAS78. However, this combination of technologies (excavation and then landfilling or 76 Discussed technologies were highlighted at the stakeholder workshop and are also based on expert assessments such as NICOLE and Concawe. The number of full-scale proven or commercialized technologies is still limited for PFAS. 77 UNEP, 2012 in: https://www.kemi.se/global/rapporter/2016/report-11-16-strategy-for-reducing-the-use-of-higly-fluorinatedsubstances-pfas.pdf 78 https://www.kemi.se/global/rapporter/2016/report-11-16-strategy-for-reducing-the-use-of-higly-fluorinated-substances-pfas.pdf June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 99 Wood Environment & Infrastructure Solutions UK Limited incineration) are proven technologies to address source zone remedial needs at the site level. Capping PFASimpacted soils reduces or eliminates the potential of precipitation leaching PFAS compounds from soil to groundwater. While capping does not remove or destroy any of the contamination it allows for an effective management of emission reduction from the soil body. Soil caps could include an engineered cap as commonly used in landfill scenarios. Engineered caps utilising for example clay will require monitoring and potentially maintenance work to be conducted when the cap degrades over the following years or decades. Immobilisation of PFAS is another potential treatment technology to treat PFAS-contaminated soils. Most immobilisation procedures are applied to soils that have been excavated (ex-situ). Immobilisation aims to reduce leachability of PFAS compounds when coming in contact with water such as from precipitation. Immobilisation can be accomplished through solidification or stabilisation. To achieve stabilisation products such as RemBindTM or MatCARETM can be used. Bench-scale or pilot testing are required to confirm desired performance parameters of the products. With immobilisation/stabilisation technologies the contaminant itself has not been destroyed but rather reduced in its mobility in soil. There is no or only limited long-term field experience with the longevity of the immobilisation. At the end, immobilised and disposed of/landfilled soils will require monitoring to confirm continued immobilisation and allow for corrective action should PFAS leaching occur. Pump and Treat (P&T) is a standard technology utilised in contaminated land management practice to extract impacted water from the subsurface. Water extraction can be accomplished through individual wells equipped with down-well pumps that deliver the water to the surface where subsequent treatment can take place. Extraction of groundwater can also be accomplished through engineered and constructed drainage features. A drainage wall consists of a linear structure mostly perpendicular to groundwater flow extending into the groundwater table to a depth equal to or greater than the impacted water-bearing unit. Part of the drainage wall/structure also is an extraction well or vault to collect and pump water to the surface. The drainage wall is constructed of material featuring a grain size greater than the surrounding soil material so that the drain itself has a higher/better hydraulic conductivity thus allowing groundwater to preferentially flow into and inside the drainage structure. Groundwater that has been extracted from the subsurface is transferred via pumps into a treatment unit that customarily includes pre-treatment steps followed by the actual PFAS-treatment technology. Most pretreatment steps include addressing geochemical limitations/challenges necessary to be addressed for the actual subsequently-occurring PFAS removal to work optimally. This could include iron precipitation, settlement tanks for fine material, removal of "other" total or dissolved organic matter that could compete during PFAS adsorption, specifically on GAC, or other co-existing contaminants that require treatment such as heavy metals. In typical environmental applications today PFAS removal from the water stream occurs through an adsorption technology. Adsorption media include GAC, regenerable resins, and non-regenerable resins. GAC can originate from a variety of sources and actual products are many. Ideally bench-scale and/or pilot testing would be conducted to identify the optimal GAC for adsorption of the PFAS mix present in water for the specific project. Bench-scale and/or pilot testing would also be done to identify a suitable resin to treat PFAS-containing waters. For the resin the selection of a non-regenerable or a regenerable product must be made. Nonregenerable resins would adsorb more PFAS mass absolute per unit of resin when compared to regenerable resins. However, non-regenerable resins once spent need to be dealt with off-site either in a landfill or through destruction via high-temperature incineration. Ion-exchange resins contain positively charged and resin-bound functional groups that stoichiometrically bind negatively charged ions such as PFAS anions. Functional groups that form the exchange unit for PFAS can be tailored to fit certain PFAS mixtures as they are generally observed in groundwater contamination. Resins are suitable for high flow rates and low concentrations. Upon exhausting the exchange capacity of the resin, regenerable resins can be back-washed with sodium chloride solution, ethanol, (hot) water or other benign solvents. Resin regenerate is a lowvolume concentrate with high PFAS concentrations that will need to be addressed. High temperature June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 100 Wood Environment & Infrastructure Solutions UK Limited incineration is one option to destroy the PFAS molecules in the regenerate. It is advisable to test the optimal exchange/adsorptive media for water treatment on a site by site basis. Not only water geochemistry but also secondary considerations might be critical to the selection of the optimal treatment media. The treatment of longer chain (>C8) PFAS molecules using adsorbing technologies such as GAC or resins works with a higher efficiency than parallel treatment of shorter-chain PFAS (<C8) molecules. Longer-chain PFAS molecules preferentially adsorb to GAC and/or most resins. For the effective treatment of longer- and shorter-chain PFAS molecules, it might be necessary to preferentially target in a first treatment step the longer-chain PFAS molecules, for example using GAC. GAC retains longer-chain PFAS molecules with a higher efficiency resulting in an "early" breakthrough of shorter-chain PFAS compounds. These compounds will need to be treated with a follow-up secondary treatment step such as a (regenerable or non-regenerable) resin. This second adsorbent can be optimised to retain the specific short-chain PFAS compounds. Diligent monitoring of individual PFAS-compounds' concentrations is important to maintain process control and optimal treatment conditions including change out of GAC or resin. It is important to conduct bench-scale testing or even field pilot tests to evaluate and discern the most effective and cost-efficient treatment technologies or combination of treatment technologies for the PFAS-mix existing at each site. Reverse osmosis is a filtration technology that includes a semi-permeable membrane to remove ions, molecules or larger particles. Water to be treated is forced under pressure to pass through a membrane where the purified water passes through the membrane which rejects ions and unwanted compounds as solute on the pressure side of the treatment process. For PFAS treatment the low-volume solute would contain the PFAS compounds and other rejected ions and molecules. The solute is a concentrate which requires further treatment such as incineration. Reverse osmosis is generally applied in pure water applications to produce potable water. Reverse osmosis is normally not used in contaminated land applications where general water quality and chemistry is more complex, diverse and challenging. Research shows that these types of membranes are typically more than 90 percent effective at removing a wide range of PFAS, including shorter chain PFAS79. The use of RO membranes is a widely accepted filtration technique. One study reports use of thin film composite polyamide RO membranes, where 99% removal of PFOS was achieved with several types of membranes at concentrations >1 mg/l. RO is normally used in the drinking water industry for removal of PFAS and other contaminants80. The relevant factor in effective and efficient RO treatment is described to be the pore size of the membrane used in the filtration process81. Additional groundwater treatment technologies exist. Research and development have been underway for several years now to study PFAS destruction technologies that fully mineralise PFAS compounds. Complete destruction of PFAS molecules seems to be the best approach to end the commercial and environmental liability associated with PFAS contamination. While there are a few promising technologies, none of those are quite field ready at full-scale or the commercial level. These technologies include ozonation, chemical oxidation, electrochemical oxidation, plasma destruction, and sonochemistry. These technologies are only referenced here but not further discussed since (longer term) full-scale data are still missing and experience with costs and treatment performance is not available. Very recently a soil bacterium was described as having the demonstrated ability to break down PFAS molecules. While the bacterium has successfully degraded PFAS under laboratory conditions, field applications, if ever possible, are likely years away. Nevertheless, successful application of microorganisms in in-situ applications would be a cost-effective, efficient and sustainable approach to address PFAS contamination. 79 https://www.epa.gov/sciencematters/reducing-pfas-drinking-water-treatment-technologies 80 Concawe Report, Environmental fate and effects of poly- and perfluoroalkyl substances (PFAS), June 2016. 81 Rahman et al., Behaviour and fate of perfluoroalkyl and polyfluoroalkyl substances (PFASs) in drinking water treatment: A review, Water Research 50 (2014) 318 - 340. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 101 Wood Environment & Infrastructure Solutions UK Limited Treatment scenarios Subsequently, scenarios have been developed for a legacy site remediation and for a live event emergency response clean-up both including AFFF, i.e. PFAS compounds as driver substance. Fire training areas should be designed and engineered facilities that allow for a 100% capture of materials used in the training activity. Captured fluids from training activities should run through a series of designed and engineered treatment steps that could include a sediment trap, an oil/water separator and possibly a granular activated carbon filter before discharge. In training scenarios with AFFF foams the GAC filter might have to be larger sized and might require more frequent change out to address the limited loading capacity of PFAS on GAC. Emergency responses at airports, refineries or other large facilities housing or handling large volumes of flammable liquid fuels that include use of AFFF products will need to capture firefighting water as soon as practicable and safe. The combined fluids and solids that result from a live fire event need to be captured, collected and separated in relevant fractions and further processed. In general, should AFFF foams have been used in the fire-fighting effort, all waste streams could be potentially contaminated with PFAS. Professional judgement or analytical testing will provide information to render recommendations for subsequent handling and/or disposal of individual waste streams. For retained and collected fluids, a variety of treatment steps could be required to separate phases (fines/solids vs. liquids; oil vs. water) such as sedimentation tanks and an oil/water separator. The separated aqueous phase will require treatment to reduce total petroleum hydrocarbons (TPH) and PFAS concentrations, and possibly also other compounds, depending on the incident. Temporary storage of captured firefighting waters in large size tanks is advisable to characterise the water via laboratory analysis. Based on laboratory results, an appropriate treatment unit or treatment train can be configured and delivered to the site for (batch) treatment of the captured and stored water. For legacy sites requiring active remediation measures, risk-based decision making will support a remedial approach including the relevant points of treatment and the combination of applied technologies to reduce the risk from the site to an acceptable level. In very general terms this could include source area treatment via soil remediation (as discussed above) and hydraulic containment of the site. In addition, there could be additional treatment of impacted receptors at the point of use via an "end-of-pipe" approach which in most cases includes adsorption of PFAS or use of reverse osmosis. It seems economically not viable to decontaminate the entire PFAS groundwater plume associated with a legacy site. The larger PFAS plume itself will likely become a socio-economic burden for future generations needing to deal with existing PFAS background levels. Step 6: Cost of remediation / treatment: soil and water Overview of approach The following remediation cost estimates associated with legacy "PFAS sites" were developed based on market-typical unit prices for remedial activities and industry experience with these types of projects. In addition, treatment costs were discussed and provided by individual stakeholders at the workshop. Further expert organisations such as NICOLE and Concawe discuss and review remediation costs associated with PFAS legacy sites82,83. It also needs to be emphasised that the cost ranges presented for remediation are based on bottom-up calculations with assumed project scenarios such as volume and/or area of PFAS impacted soils, or PFAS concentrations in extracted groundwater in combination with an assumed water extraction rate for a pump and treat system. 82 Nordic Council of Ministers, The Cost of Inaction - A socioeconomic analysis of environmental and health impacts linked to exposure to PFAS, 2019. 83 Nicole Working Group - Emerging Pollutants, sub-group remediation, Prague Workshop, November 2014. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 102 Wood Environment & Infrastructure Solutions UK Limited While the presented costs provide a robust high-level estimate of how expensive a PFAS soil and/or groundwater remediation project might be, there are various drivers in the parameter set of site remediation that can greatly increase project costs. Site specific factors such as "other" contaminants that compete for GAC adsorption, required pre-treatment of geochemical reasons such as high iron or manganese, subsurface soils that cannot reasonably be excavated because they consist of rock, and the PFAS spectrum present in the extracted water cannot reasonably be included in cost scenarios. Hence it should be highlighted that a real project might not be as straight forward. Also, regulatory requirements with respect to likely site-specific remedial target levels have a great influence on the total cost, because each additional concentration reduction of treatment target levels increases (eventually exponentially) the associated costs per unit of water treated or the volume of soil that needs to be excavated and disposed of. The estimated remediation costs also do not reflect a full site decontamination but include rather a measure or combination of measures that reduces the risk emanating from the impacted site to an acceptable level of risk for human health and the environment under a general site use scenarios. The estimated costs were compared in a top down fashion with existing PFAS remediation projects as much as those are available for cost comparison. The costs do not include any consulting fees, bench-scale or pilot testing associated with remedial investigations / feasibility studies or remedial design and planning or monitoring requirements to confirm the selected measure to be properly functioning and reaching and maintaining the desired remedial objective. Also not included in the projected costs are repairs or replacement of remedial infrastructure beyond what might be considered "normal" O&M activities. A general groundwater monitoring programme is also not included in the costs. Long-term groundwater monitoring is part of a remediation project to measure plume size and stability over the course of the ongoing project. Specifically, when a full decontamination has not been part of remedial action, long-term monitoring confirms successful implementation of selected measures such as a pump and treat system. For the various reasons stated above, the following estimates should be considered "rough estimates" that provide order-of-magnitude cost ranges associated with PFAS remediation. Soil For the scenario "soil excavation and landfilling" and "soil excavation and incineration", a volume range for the impacted soil volume that needed to be excavated was estimated to be between "30m by 30m by 3m deep" and "75m by 75m by 5m deep" as conservative lower and higher values. It is very possible that there will be smaller or (much) larger excavation areas/volumes, but those would rather be on the edge of the likely spectrum. For excavation and landfilling, the absolute concentration or the PFAS compound spectrum does not play an extremely critical role, specifically for "excavation and incineration" because it does not impact the unit costs for treated soil. Typical transportation costs for excavated PFAS-laden soils to the landfill or the incineration facility are included in the unit costs. These transportation costs will change project by project based on the distance of the project site to the landfill or incineration facility or the difficulty to reach the excavation area. For the soil capping scenario, the same source area footprint range (30m by 30m; and 75m by 75m) was used for cost comparison with the excavation options. Cap construction includes prepping of the site and installation of geotextiles to eliminate meteorological water percolation through the PFAS-impacted soil volume. The geomembrane is covered with a 30 to 50-cm thick layer of compactable, clean soil cap. For the scenario of "soil capping", monitoring of the soil cap is required, together with associated maintenance and repair work, as needed, plus a groundwater monitoring programme to document the effectiveness of the soil cap with respect to vertical PFAS migration and desired emission reductions from the capped soils to groundwater. This groundwater monitoring program is cap-specific and does not include a site- or plumewide groundwater monitoring programme. For the monitoring programme, a 10-year, a 20-year, and a 30year scenario were calculated. However, in reality, the soil cap and groundwater quality need to be monitored June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 103 Wood Environment & Infrastructure Solutions UK Limited for as long as the PFAS-laden soils remain at the site. Possibly at one point in time the monitoring frequency could be reduced if trends and concentrations in groundwater are stable enough. One workshop stakeholder reported costs for soil incineration in the range of 400 to 600 per ton. Table 6.2 Cost estimation of soil remediation Technology Capex (Unit Costs) Opex (Unit Costs) Source Area Volume 30m x 30m by 3m deep to 75m x 75m by 5m deep Low High Low High Construction Cost Excavation and 100/t 350/t --- --- 0.5 - 18 million off-site disposal Excavation and 500/t 750/t --- --- 2.5 - 38 million incineration Capping Construction + 10 Year M&M Construction + 20 Year M&M Construction + 30 Year M&M Cap construction 75/m 150/m --- --- 0.07 - 0.85 million 0.07 - 0.85 million 0.07 - 0.85 million Cap monitoring --- --- 10,000/ 50,000/ 0.10 - 0.5 million 0.20 - 1.0 million 0.30 - 1.5 million and maintenance year year Groundwater well 50,000 200,000 --- --- 0.05 - 0.2 million 0.05 - 0.2 million 0.05 - 0.2 million network (cap- specific) Groundwater --- --- 20,000/ 60,000/ 0.20 - 0.6 million 0.40 - 1.2 million 0.60 - 1.8 million monitoring (cap- year year specific) Capping - Total 0.42 - 2.2 million 0.72 - 3.2 million 1.0 - 4.3 million Capex: Capital investment cost. Opex: Operational cost over the lifetime of the measure. M&M: Maintenance and monitoring Source: Wood estimates based on previous experience. Groundwater For remediation cost estimates associated with groundwater treatment, groundwater extraction with an adsorption technology was used. Costs for granular activated carbon were used for the water treatment estimates, because granular activated carbon has been used more frequently. The average water flow rate was estimated to be between 10 m/hr and 75 m/hr and with PFAS concentrations ranging between 10 g/l and 100 g/l. System flow rates are influenced by the width and depth of the plume that needs to be addressed and the hydrologic permeability for groundwater. PFAS concentrations in the extracted groundwater could be lower than 10 g/l, but could also be (much) higher than 100 g/l. As discussed above, the lower and upper values for flow and concentration are not intended as minimum and maximum values, but rather to create cost scenarios at the lower and upper spectrum of typical costs. The likelihood of lower and (much) larger costs does exist84. The construction of a series of extraction wells is required to provide an extraction well network that produces hydraulic control of the site at a strategic line in the field or at the property boundary or upgradient of a receptor such as a surface water body that requires protection. The network of extraction wells can be 84 Zblin, Sonderdruck aus Handbuch Altlastensanierung und Flchenmanagement (HdA), PFC-Grundwassersanierungen: Stand der Technik und Kosten, Mrz 2018. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 104 Wood Environment & Infrastructure Solutions UK Limited replaced with a drainage wall/trench for groundwater extraction from the wall/trench. In both scenarios extracted groundwater is pumped to a treatment system that was specifically designed to address the geochemical and "other" relevant parameters that require pre-treatment before PFAS compounds can be effectively removed from the aqueous matrix. The well field needs to be connected to the treatment unit and with a discharge point after treatment to dispose of the treated water. The well field and system will need to be connected via piping, require electrical powerlines and possible remote sensing in the wells or remote telemetry to communicate malfunctioning equipment to the operator wirelessly. For long term treatment the treatment system is likely to be housed in a specifically designed and constructed building, shed or container. Industry values for the adsorption of PFAS onto GAC or resin can be used to estimate - for these concentration and flow scenarios - how much carbon might be spent just based on mass loading capacities. As stated for soil treatment it is likely that there are legacy sites that require a smaller groundwater treatment system than that in the estimation range but likely there are also sites requiring (much) larger treatment units. Table 6.3 Cost estimation of groundwater remediation Technology Capex (Unit Costs) Opex (Unit Costs) Low High Low High Construction + Construction + Construction + 10 Year O&M 20 Year O&M 30 Year O&M Pump and Treat Well field OR 100,000 750,000 --- --- drainage wall /site /site construction 0.10 - 0.75 million 0.10 - 0.75 million 0.10 - 0.75 million Infrastructure 250,000 1,000,00 --- --- construction /site 0 /site 0.25 - 1.0 million 0.25 - 1.0 million 0.25 - 1.0 million Operation and --- --- 85,000 950,000/y 0.85 - 9.5 1.7 - 19.0 2.6 - 28.5 maintenance /year ear million million million Pump & Treat - Total 1.2 - 11.2 million 2.0 - 20.8 million 2.9 - 30.3 million Capex: Capital investment cost. Opex: Operational cost over the lifetime of the measure. O&M: Operation and maintenance. Source: Wood estimates based on previous experience. Drinking water Reverse osmosis (RO) was included to provide a sense what cost might be included to treat impacted groundwater that is considered for drinking water use, specifically in a larger scale public drinking water works. Reverse osmosis is normally not considered appropriate for contaminated land remediation projects but rather for clean water applications that still contains impurities. Membranes of RO systems are prone to fouling when the water quality is too poor. RO is electricity intensive and leaves a rejectate that has higher PFAS concentrations which needs to be treated either over GAC filters or otherwise addressed as a PFAScontaining waste that needs to be properly disposed of. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 105 Wood Environment & Infrastructure Solutions UK Limited Table 6.4 Cost estimation of drinking water remediation Technology Capex (Unit Costs) Low High Opex (Unit Costs) Low High Reverse Osmosis System 150,000 750,000 --- --- construction/ /site /site extension Construction + 10 Year O&M Construction + 20 Year O&M Construction + 30 Year O&M 0.15 - 0.75 million 0.15 - 0.75 million 0.15 - 0.75 million Operation & --- --- 275,000 1.3 Mio 2.75 - 13.0 5.5 - 26.0 million 8.25 - 39.0 maintenance /year /year million million Reverse Osmosis - Total 2.90 - 13.8 million 5.7 - 26.8 million 8.4 - 39.8 million Capex: Capital investment cost. Opex: Operational cost over the lifetime of the measure. O&M: Operation and maintenance. Source: Wood estimates based on previous experience. For European sites the Nordic Council of Ministers report85 describes remediation costs associated with contamination from PFAS ranging from several hundred thousand up to 40 million with one high-cost example for the Dusseldorf Airport, Germany estimating a total remediation cost of up to 100 million. In comparison to the costs provided in this report with the Nordic report remediation costs for PFAS-impacted sites (such as airports) will total from the single digit millions to the lower double-digit millions. For Schipol Airport 50 000 m of impacted soil were removed at a cost of 600-800/m. As described in previous sections there is a variability in costs for soil remediation depending on factors such as amount of PFAS spilled, presence of other contaminants, the volume of soil that has been contaminated, the type of soil, the environmental setting of the impacted site, and the receptors impacted or threatened. In the Nordic report cost ranges are given for three airports where costs were modelled. The modelled costs included both water and soil remediation using different methods and different levels of allowable remaining concentrations. The modelled cost ranges spanned from 2.1-24 million (Kristiansand Airport) over 0.4-7.1 million (Harstad/Narvik Airport) to 0.41-8.1 million (Svalbard Longyearbyen). While the remediation technologies were not reflected in the Nordic report those costs are consistent with the estimated cost range as developed in this report. 85 Nordic Council of Ministers, The Cost of Inaction - A socioeconomic analysis of environmental and health impacts linked to exposure to PFAS, 2019. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 106 Wood Environment & Infrastructure Solutions UK Limited PART 3 - ECHA STUDY 7. Task 1: Analysis of alternatives to PFAScontaining fire-fighting foams 7.1 Introduction This task covers the technical feasibility, economic feasibility and availability of alternatives to PFAScontaining fire-fighting foams. For any given Annex XV restriction proposal, the analysis of alternatives (AoA) is a key part of the dossier - it drives the scope of the socio-economic analysis (SEA) and is a key consideration when determining the ultimate regulatory action. The results will feed into the pre-RMOA and (pre) Annex XV dossier report. The various stages undertaken for this task are explained in more detail below. 7.2 Approach The AoA and SEA has been undertaken in line with ECHA's guidance on the preparation of an Annex XV dossiers and with ECHA's guidance on socio-economic analysis in the context of restrictions. The AoA focuses on alternative products that could fulfil the required function delivered by PFAS in FFF. The approach covered: Technical feasibility. Including, but not necessarily limited to aspects such as: Comparison between the function provided by PFAS-containing foams and their alternatives; Performance (efficacy) to fight various types of fires, including liquid fuel fires ("Class B" fires); Required machinery/equipment/storage tanks; and Uses where alternatives do not meet (fully or partially) the required performance standard and why. Economic feasibility. Including, but not necessarily limited to aspects such as: Annualised cost for an assessment period that takes into account the investment cycle in the industry; Cost difference of bringing forward investment(s); Required amounts/loadings of alternative foams; Price per litre or kg of concentrate; Shelf life; Machinery/equipment/storage tanks changes; Any need for specific training to use the alternative foams; Possible savings to users in fire-fighting; Training (e.g. benefits of being able to practice with the alternative foams with minimal cleaning requirement); and June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 107 Wood Environment & Infrastructure Solutions UK Limited Possible immediate clean up after fire made unnecessary or less expensive. Availability of alternatives Whether and when alternatives are available in the required quantities. If not, expected time to reach the necessary quantities. Environmental and health risks of alternatives Assessment of inherent properties of alternatives with regard to potential environmental and health risk. The assessment includes key properties used for identification of substances of very high concern under REACH: CMR (Carcinogenic, Mutagenic or toxic to Reproduction) properties - for the assessment it is investigated if substances included in the products are classified according to these properties (either by a harmonised classification or self-classification); and PBT (Persistent, Bioaccumulative and Toxic) or vBvP (very Bioaccumulative and very Persistent) - information obtained from safety data sheets of the products. Assessment of GreenScreen profiles of the products. A GreenScreen CertifiedTM Standard for Firefighting Foam has recently been published86 and four Firefighting Foams have been evaluated following the GreenScreen standard87. All are assigned the GreenScreen level bronze. Two of the example products described in more detail in this section have been evaluated using the Greenscreen standard. The AoA has been undertaken in the following six steps: Step 1 - Literature review on fluorine-free products identified in the Commission study; Step 2 - Consultation of stakeholders; Step 3 - Preparation of shortlist of alternatives and a list of example substances; Step 4 - Additional information gathering and assessment of example alternatives; Step 5 - Assessment of illustrative cases; and Step 6 - Final analysis of alternatives. 7.3 Initial screening and consultation results Task 1 of the Commission study identified all the fluorine-free alternative products currently available on the market. Information on these fluorine-free alternatives was found by conducting a wide review of the literature and market analysis of products currently manufactured and available on the market. However, this list did not tell exactly which products are currently being used in the EU and was consequently supplemented with information from the consultation responses on in-use alternatives. The total number of fluorine-free alternative foam products identified in Task 1 (substance ID) was 168, produced by 38 different companies globally. The substances that are being used to produce these alternatives show similarities across different companies/products. A mixture of substances is typically used instead of PFAS in various percentage combinations for each of the fluorine-free foam alternatives (including solvents and surfactants) to attain the necessary foam/film forming functions of the product. 86 https://www.greenscreenchemicals.org/resources/entry/fff-standard-resource 87 https://www.greenscreenchemicals.org/certified/products June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 108 Wood Environment & Infrastructure Solutions UK Limited Step 1 - Literature review on fluorine-free products The list of all fluorine free products (from the Commission study, Task 1 substance ID) acted as a starting point for the analysis of alternatives. The first step was a literature review of SDS (Safety Data Sheets), publications, reports and product data sheets for each of these fluorine free products to extract data on technical/economic properties and availability. Based on the results from the stakeholder questionnaire information relevant to each of the criteria described above were captured in a spreadsheet. Based on these initial results, the following patterns emerged for the fluorine free alternatives. The availability of data in the public domain indicated that: Most manufacturers provide information about their products via product information sheets, technical data sheets and/or material safety data sheets. From these sources, information on application ranges (e.g. sector, fire class), compliance with international performance standards and some technical parameters such as foam expansion ratio and degradation rate can be retrieved; More generic (not product-specific) information about the overall performance and use of alternative fluorine-free foams and their comparison to PFAS-containing foams is available from reports published by public agencies, in the scientific literature, opinion and marketing articles from industry stakeholders. However, these often do not provide the level of detail required on the technical and economic feasibility of specific alternative products; According to the manufacturers' specifications, fluorine-free foams are available for both class A and class B fires. Some products, e.g. Expandol from Angus Fire or Ecopol from Bio-Ex are specified for use for both class A and B fires depending on concentration and application method; Fluorine-free foams are either recommended as low, medium or high expansion foams88, or the same product can be used with different expansion ratios depending on use concentration and equipment, e.g. the H-930 synthetic multiexpansion foam concentrates from Auxquimia; Some literature reviews (e.g. the IPEN position report by Allcorn et al. 2018) suggest that fluorine-free foams are viable alternatives to PFAS-containing foams across many sectors, however there is no general consensus to suggest that a single type of foam meets all needs encountered by end users; and Liquid fuel fires of large atmospheric storage tanks89 require foams capable of flowing on large burning liquid surfaces and sealing against hot metal surfaces to prevent reignition. The development of suitable test criteria for large storage tanks and fluorine-free foams is still ongoing under the LASTFIRE project90. A list of the international standards, and the available information on the compliance criteria for these standards is provided in Appendix 5. Please note that a single product can be compliant with multiple UL/ICAO/EN standards. The European Standards of EN 1568 Part 1-4 test foam products for both extinguishment and burnback performance on liquid fuel fires for both non-polar (Part 1-3) and polar, watermiscible (Part 4) fuels. The EN 1568 is not a pass-or-fail standard; products are allocated grades of 88 The expansion ratio is the ratio of volume of foam formed to the volume of solution used to generate the foam. As an example, an 8:1 expansion ratio means 800 l of finished foam were created from 100 l of foam solution. High expansion foams have an expansion ratio in the range 200:1 to 1000:1, medium expansion foam have an expansion ratio in the range 21:1 to 200:1 and low expansion foam have an expansion ratio in the range 2:1 to 20:1 (as defined by the US standard NFPA 11 and NFPA 11 A). 89 There is no specific definition of a "large" storage tank. The LASTFIRE projects used a 100 m (ca. 11 m in diameter) and 10 m high tank to perform a large scale test. Tests with tanks with diameters of 30 m or even larger are recognised as ideal tank sizes to simulate realistic conditions, but such tests are also assessed to be too expensive to conduct. 90 http://www.lastfire.co.uk/default.aspx?ReturnUrl=%2f June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 109 Wood Environment & Infrastructure Solutions UK Limited performance, i.e. for Part 3, Grade 1-4 is used for extinguishing performance and Grades A-D for burnback resistance. For Part 4, Grade 1-2 for extinguishing performance and Grades A-C for burnback resistance. Grade 1A is the highest achievable grade for both tests. As shown in the examples below, alternatives are available with the A1 grade for both Part 3 and Part 4. Step 2 - Consultation of stakeholders Information gathered on fluorine-free alternative products from data sheets and the literature review was supplemented with the stakeholder consultation responses. The consultation questionnaire used to gather information from targeted stakeholders (see Section 2) was designed to help gather information to feed directly into the delivery of this task, specifically: Specific alternative foam products, the chemical identity of these products, and whether these are currently on the market in the EU; Availability of alternatives, including the volumes produced, sold, used; and key trends and drivers; Technical feasibility of alternatives, i.e. compliance with performance standards, differences in volumes and frequency of use required; and Economic feasibility of alternatives, e.g. the costs of changing equipment, the saving through avoided remediation. In total 33 written responses were received for the targeted stakeholder consultation. Of these, 19 provided information on alternative foam products. These responses included input from individual manufacturers, users of foams (from airports, oil and gas industry, and chemical facilities), national authorities and academic/training professionals. Of these, 17 responses provided details of specific `alternative' products available. In addition, input was received on alternatives in general, for example from the responses of key trade associations (both EU and US), as well as previously published reports and analyses from national authorities91, research and testing information92, and special interest groups93. The responses received from stakeholders have generated useful information that has fed into and enabled the AoA. A brief summary of the observations from the analysis of the consultation responses is provided below. In terms of the chemical identity of alternative products, in most cases, where alternative foam products were named, the specific chemical components were either not known or not divulged (e.g. citing trade secrets). In some cases (e.g. Bio-Ex's `BIO' foams, and Auxquimia's EE3 foam), the general class of chemicals was indicated, and in some cases (e.g. AngusFire products), the specific chemical components were named. Where possible, the information provided on chemical identity has fed into the overall AoA for this study; In terms of availability of alternatives, from the responses received as part of the consultation, ~80 specific products currently in use were identified. The specific foam products identified in the consultation responses are provided in the table in Appendix 6. As a preliminary check of these products, we cross-referenced those identified with the list of substances in Section 3 (Substance ID). The vast majority of the specific products indicated to be in use from the 91 KEMI (2015) Chemical Analysis of Selected Fire-fighting Foams on the Swedish Market 2014 92 Published testing data, as provided by LASTFIRE: www.lastfire.co.uk/ 93 IPEN (2019) The Global PFAS Problem: Fluorine-Free Alternatives as Solutions, https://ipen.org/documents/global-pfas-problemfluorine-free-alternatives-solutions June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 110 Wood Environment & Infrastructure Solutions UK Limited responses by manufacturers, users and authorities, are captured under Section 3. The list of specific foam products identified in the consultation responses (see Appendix 6) has been used to further prioritise and inform the shortlist of products considered for more in-depth analysis. All respondents to the consultation who provided information on the availability of alternative foam products reported that the foams are manufactured and used in the EU. Therefore, no information on relative or absolute amounts of foam derived by importing from outside the EU was available. A small number of manufacturers and users reported the volumes of some specific products produced, sold, or purchased in the EU, as well as the approximate value of these sales/purchases. It is not possible to comment on any broad observations from these small number of responses. These results have been used to supplement other information gathered (e.g. literature and the market analysis) to inform the more in-depth analysis; A small number of users indicated that the trend in their demand for foams has remained stable over the past 10 years, while one user (in the oil/gas/chemicals sector) noted that they expect an increase in demand as they switch further in favour of alternatives. Again, it is difficult to draw conclusions from a relatively small number of responses; In terms of the technical feasibility of alternatives, the responses received varied considerably for different individual foams, in terms of their perceived overall performance, and the compliance standards used to test their performance. The results obtained for the specific individual foam products have been be used to supplement the information already gathered in Section 3 (Substance ID); In terms of differences in volumes needed between alternatives and PFAS-containing foams, most responses suggested that there is not a difference between `traditional' and `alternative' foams. However, one user in the oil/petrochemicals sector suggests that the alternative foams need 30-50% more volume for the same performance. Again, the volume of foam needed depends on a variety of interdependent parameters and it is therefore not possible to draw general conclusions on required volumes. A number of respondents identified and discussed perceived critical uses or applications of foams where alternatives are lacking and PFAScontaining foams cannot be replaced; and In terms of economic feasibility of alternatives, a small number of responses were received providing details of costs of the alternative foam products, and their required loading, but very limited data was received on costs of replacing equipment. Similarly, limited quantitative data was provided on the potential savings associated with switching to alternatives. In conclusion, the stakeholder consultation questionnaire responses yielded useful information that complement the data already gathered as part previous tasks. 7.4 Preparation of example list of alternative fluorine-free products Step 3 - Preparation of shortlist of alternatives In order to undertake a more in-depth analysis for a selected number of alternative products, a list of the most common alternative fluorine-free products, that are widely used in the EU, has been generated. These provide a starting point which can be compared to the risk, performance and cost of PFAS-based products, as discussed in more detail under other tasks within this study and that of the Commission. Alternative techniques could be changes in demand for flammable fuels which would reduce the need for AFFFs. Application of e.g. electric aircraft and phase out of hydrocarbon fuels for vehicles would reduce the needs for AFFFs, but are by the authors of this report not considered feasible alternative solutions in the short term. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 111 Wood Environment & Infrastructure Solutions UK Limited The selection of fluorine-free products for further analysis has been based on the following criteria: Use - The use of the products has been reported by several stakeholders, ensuring that the products analysed are commonly used in the EU as alternatives for PFAS-containing foams; Chemical group - The products represent different chemical groups according to the grouping in Task 1 of the DG ENV study, i.e. hydrocarbons, detergents, siloxanes and proteins. Some products may contain a combination of substances from these groups; Technical feasibility - The products do actually represent alternatives/replacements for PFAScontaining foams, including in critical situations (with large fires). Technical feasibility also considers the combination of the foam concentrate, the application system and the application rate to establish whether the alternative is a viable replacement. Case studies of critical applications serve as a starting point for successful replacement of PFAS-containing foams with fluorine-free alternatives. Training foams have been excluded as they are already available and widely used for all applications. ; Manufacturers - The products originate from different manufacturers; Availability - The products are known to be on the market in the EU and are available without further R&D delays or costs; and Complementarity - The products cover jointly all major applications of PFAS-containing foams and can be used in different conditions. For the October 2019 workshop, an initial shortlist with 30 products from 8 manufacturers was generated (Appendix 6). The initial shortlist was presented at the workshop, and participants were asked which were the most commonly used and viable. On the basis of the workshop feedback, further review by the study team and responses from stakeholders, a list of products for further analysis was generated. This is shown in Table 7.1 along with a justification of why these specific products have been chosen. For each of the manufacturers, one or two products in the product range has been selected for the more detailed assessment. The selection has been based on the available information on the feasibility of using the alternatives with particular emphasis on products demonstrated as viable alternatives to PFAS-containing foams in airports and the petrochemical sector. The information provided in Table 7.1 is supplemented with two representative case studies in section 7.6. The remaining products on the shortlist presented at the workshop were from the manufacturers Auxquimia (EE-3 Newtonian Training foam, and Unipol-FF), Fomtec (the Enviro product range) and the 3F Company (Freedol SF). None of the companies have answered the questionnaire and only limited information on the feasibility has been obtained from the stakeholder consultation. These products were not included in the list, but this does not indicate that these products are considered less efficient alternatives to the PFAS-based foams, merely that less information on the feasibility of using these foams was available for the assessment. Seven substances have been selected in order to strike a balance between ensuring variety in coverage of alternatives and depth of analysis that is possible. It is important to note that during the substance identification task of the Commission study, a group of potential alternative fluorine-free products, the siloxane-based alternatives, were identified. These have not been identified as being widely used and, furthermore, at the stakeholder workshop, concerns were raised by governmental stakeholders in relation to PBT and/or vBvP properties of some siloxanes. They have therefore not been selected from the more detailed analysis. One protein-based product, PROFOAM 806G from the company Gepro has been mentioned to be in use during the stakeholder consultation. However, specific data on users, application or feasibility have not been provided by the stakeholder consultation and the manufacturer and products cannot be identified. Protein- June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 112 Wood Environment & Infrastructure Solutions UK Limited bases foams are marketed by Profoam srl (PROVEX AR 6-6), Angus PFAS based foams (TF 3 and TF90 for training purposes) and Dr Stahmer (Foamousse product range). No information on these products has been provided for the stakeholder consultation but one product from the Foamousse product range has subsequently been added to the example list in the table below. Table 7.1 Example list of products for further analysis Product name Manufacturer Respondol ATF 3-6% Angus fire Re-Healing Foam RF1 1% Solberg Re-Healing Foam RF3x6 ATC Solberg Moussol FF 3x6 Dr. Sthamer Foammousse 3% F-14 Dr. Sthamer Chemical group(s) Hydrocarbons and detergents Hydrocarbons and detergents Hydrocarbons and detergents Hydrocarbons and detergents Protein Current use sector of the product where PFASbased products are currently used Petrochemicals processing, storage and transport of hydrocarbons and polar solvents Petrochemicals offshore oil installations and onshore terminals and refineries Aviation Aviation Petrochemicals According to manufacturer: Petroleum industry and on oil tankers Reason for shortlisting Applicable for all types of flammable liquid fires Widely used detailed information on the feasibility of using the substances as alternatives for PFAS-based products in the petrochemical sector provided in Case 2 Widely used detailed information on the feasibility of using the substances as alternatives for PFAS-based products in the aviation sector provided in Case 1 Widely used in several major EU airports Best available example of protein-based products Other marketed fluorine- free products from the manufacturer for hydrocarbon fires JetFoam ICAO-C (aviation) JetFoam ICAO-b (aviation) Syndura (aviation, forestry) 8 other products in the Re-Healing Foam RF product range A number of products in the Sthamex product range (municipal fire services, aviation, training foams) Training foam N (training) vaPUREx LV 1% F10 (extensive fires of non-polar liquids) vaPUREx LV ICAO B 3% F-10 (aviation) Ecopol Premium Bioex Hydrocarbons and detergents Aviation Mentioned by manufacturer and other stakeholders, as applicable for hydrocarbon fires, all types of flammable polar solvent liquids and applicable for tank fire fighting BIO FOR BIO FOAM 5 and 15 (storage facilities, marine) BIO T3 and BIO T6 (training foams) Ecopol F3 HC, Ecopol A June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 113 Wood Environment & Infrastructure Solutions UK Limited Product name Manufacturer Orchidex BlueFoam 3x3 Orchidee Chemical group(s) Hydrocarbons and detergents Current use sector of the product where PFASbased products are currently used Aviation Reason for shortlisting Has according to stakeholder response substituted for AFFF for one of the biggest airports in Germany Other marketed fluorine- free products from the manufacturer for hydrocarbon fires Other products in the Orchidex Bluefoam product range 7.5 Properties of shortlisted products Step 4 - Additional information gathering and assessment of shortlisted alternatives Additional information on the technical and economic feasibility and availability of shortlisted products has been collected through both the earlier literature review step and further follow-up with stakeholders. The properties of the shortlisted products are listed in the following tables and are further used in the socioeconomic impact analysis in Chapter 8. The full chemicals composition of the products is in general not available. The following tables indicate the substances listed in the safety data sheets i.e. the constituents classified as hazardous. It should be noted that not all human health or environmental hazard endpoints (e.g. endocrine disrupting effects) have necessarily been assessed in detail for each component by the foam manufacturers. Therefore, it should be kept in mind that the conclusion on risks in the tables below are based on the information provided in the product safety data sheets and hence other hazards may become evident in the future. A comprehensive list of identified substances in alternatives is provided in Section 3. Table 7.2 Respondol ATF 3-6% Product name Manufacturer Chemical group Chemical composition Proposed PFAS foam substitution (as specified by manufacturer) Technical feasibility Applications areas (as specified in technical specification) Compliance with international performance standards Respondol ATF 3-6% Angus Fire Hydrocarbons and detergents. Substances listed in safety data sheet: 1-dodecanol 1-tetradecanol propylene glycol monobutyl ether disodium isodecyl sulfosuccinate sulfuric acid, mono-C8-10-alkyl esters, sodium salts reaction mass of C-isodecyl and C-isoundecyl sulphonatosuccinate. Replacing traditional AFFF and FFFP foam concentrates as well as fluoroprotein foam. Class B hydrocarbon fuels at 3% and polar solvent fuels at 6%. Class A fuels (as wetting agent). Used in high risk situations where hydrocarbons (such as oils, gasoline, diesel fuel, and aviation kerosene) are stored, processed, or transported and/or polar solvents (such as alcohols, ketones, esters, and ethers) are stored, processed, or transported. EN 1568 Part 3 and 4; Highest approval rating on all fuels using all waters; 1A/1A - 1A/1A - 1A/1A. (see Appendix 5) June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 114 Wood Environment & Infrastructure Solutions UK Limited Product name Economic feasibility: Availability: Risks: Examples of use experience and performance compared to PFAScontaining foams Critical uses/applications where product do not meet (fully or partially) the required performance standard and why Need for changes in equipment Unit price Unit price as compared with PFAScontaining foam for same application Relative volume required to achieve comparable/best possible performance Storage, shelf-life Frequency of foam replacement Volume manufactured, sold and used in the EU Production capacity in the EU Respondol ATF 3-6% Used within the petroleum industry. No further details available. Marketed for use in Power and Industry (other than petrochemical), municipal fire brigades and forestry The product is not intended for the aviation sector for which the manufacturer markets other products (JetFoam and Syndura product ranges) The corresponding 3-3% product has passed Lastfire test in fresh water and sea water. Stakeholders have indicated that fires in very large tanks are still challenging In general no need for replacement of equipment, but adjustment and in some case change of components No data No data No data Max. continuous storage temperature 49 C (no performance loss after thawing), min. 10 years. Depending on application and difficult to compare with the PFAScontaining . Commonly, the foam is used continuously for training and system testing as well, thus not requiring replacement. No data No data CMR properties Other potential human health concern PBT or vPvB properties Other environmental risk concern Substances in the product do not meet the CMR criteria Hazard classification of some constituents: H315 - Causes skin irritation. H319 - Causes serious eye irritation. H302 - Harmful if swallowed No other health concern identified The product does not meet the PBT or vPvB criteria. Hazard classification of some constituents: -dodecanol (EC No 203-982-0; CAS No 112-53-8): H400 - Very toxic to aquatic life -tetradecanol (EC No 204-000-3; CAS No 112-72-1): H410 - Very toxic to aquatic life with long-lasting effects -dodecanol (EC No 203-982-0; CAS No 112-53-8): H411 - Toxic to aquatic life with long-lasting effects GreenScreen level Sodium laureth sulphate (EC No 500-234-8; CAS No 68891-38-3): H412 - Harmful to aquatic life with long lasting effects Level bronze[1]. Level Bronze Screening Requirements are[2] 1. Each intentionally added chemical compound present above 0% by weight (>0 ppm) and each impurity present at or above 0.01% by weight (100 ppm) in the product is screened with GreenScreen List TranslatorTM. 2. Each screened chemical compound in the Product Inventory has a GreenScreen List Translator TM score of LT-P1, LT-UNK, and/or NoGSLT. No LT-1 scores are permitted in certified products. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 115 Wood Environment & Infrastructure Solutions UK Limited Product name Respondol ATF 3-6% 3. Product-level acute aquatic toxicity testing results in LC50 and/or EC50 values >10 mg/l for each of the following groups of organisms: fish, aquatic and invertebrates, and algae. Conclusion on risks As the substances are not classified with CMR properties and do not meet the PBT/vPvB criteria, the overall risks are considered lower than the risks of PFAS-based products. Some constituents are classified toxic or very toxic to aquatic life, for one constituent with long-lasting effects. References: [1] https://www.greenscreenchemicals.org/certified/products [2] https://www.greenscreenchemicals.org/images/ee_images/uploads/resources/GSCFirefightingFoamStandardV1.0_FINAL.pdf?cachebuster :38 Table 7.3 Re-Healing Foam RF3x6 ATC Product name Manufacturer Chemical group Chemical composition Proposed PFAS foam substitution (as specified by manufacturer) Technical feasibility Applications areas (as specified in technical specification) Equipment Compliance with international performance standards Examples of use experience and performance compared to PFAScontaining foams Economic feasibility: Critical uses/applications where product do not meet (fully or partially) the required performance standard and why Need for changes in equipment Unit price Unit price as compared with PFAScontaining foam for same application Re-Healing Foam RF3x6 ATC Solberg Hydrocarbons and detergents Substances listed in safety data sheet: 2-(2-butoxyethoxy)ethanol starch sucrose 1-propanaminium, N-(3-aminopropyl)-2-hydroxy-N,N-dimethyl-3sulfo-, N-coco acylderivs., hydroxides, innersalts Replacing traditional AFFF and FFFP foam concentrates as well as fluoroprotein foams Class B hydrocarbon fuels at 3% and polar solvent fuels at 6% Class A fuels Aspirating or non-aspirating devices EN 1568 Part 3 and 4; levels not indicated ICAO Levels B and C (see Appendix 5) Airport Fire Service, both airport rescue firefighting and training. Examples: Used at Copenhagen Airport. Fulfilling the need of an alcohol resistant foam. Also used by the Melbourne Metropolitan Fire Brigade (MFB) on class B fires; Based on MFB's experience, Solberg RF3x6 foam concentrate performs just as well as the previously used fluorinated AFFF concentrate (IPEN 2019). None identified within aviation. Several stakeholders indicate that the performance standards required by the ICAO were developed for PFAS-based foams, are outdated and/or are not covering the multiple applications within the aviation sector. For this reason(s), several airports conducted internal testing schemes before implementation of PFAS-free foams. No identified. In the case of Copenhagen Airport, the investment in fire trucks was not strictly conditioned by the foam replacement, but the coincident introduction of new trucks and foam was seen as a cumulative benefit. Appr. 5/l Range from similar to +20%. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 116 Wood Environment & Infrastructure Solutions UK Limited Product name Relative volume required to achieve comparable/best possible performance Storage, shelf-life Frequency of foam replacement Re-Healing Foam RF3x6 ATC No difference or differences/larger volumes depending on application. In certain applications, a 6% foam (ICAO Level C) has been found to work better than a 3% mixture (ICAO Level B). 1.7 to 49 C (no quality loss after thawing), 20 years Depending on application. Commonly, the foam is used continuously for training and system testing as well, thus not requiring replacement. Availability: Risks: Volume manufactured, sold and used in the EU Production capacity in the EU CMR properties Other potential human health concern PBT or vPvB properties Other environmental risk concern Conclusion on risks Produced in Norway and Spain No data Substances in the product do not meet the CMR criteria Hazard classification of one constituent: H319 - Causes serious eye irritation. According to SDS, due to insufficient data no statement can be made whether the components fulfil the criteria of PBT (vPvB criteria not addressed) Hazard classification of one constituent: 1-propanaminium, N-(3-aminopropyl)-2-hydroxy-N,N-dimethyl-3sulfo-, N-coco acylderivs., hydroxides, innersalts (EC No 268-761-3; CAS No 68139-30-0): H411 - Toxic to aquatic life with long-lasting effects Substances in the product do not meet the CMR criteria. No statement can be made on whether the components fulfil the PBT criteria. One constituent is toxic to aquatic life with long-lasting effects. Table 7.4 Re-Healing Foam RF1 1% Product name Manufacturer Chemical group Chemical composition (according to SDS) Proposed PFAS foam substitution (as specified by manufacturer) Technical feasibility Applications areas (as specified in technical specification) Re-Healing Foam RF1 1% Solberg Hydrocarbons and detergents Substances listed in safety data sheet: d-glucopyranose, oligomers, decyl octyl glycosides sodium octyl sulphate sodium decyl sulphate alpha-sulfo-omega-hydroxy-poly(oxy-1,2-ethanediyl), C9-11 alkyl ethers, sodium salts 1-propanaminium, N-(3-aminopropyl)-2-hydroxy-N,N-dimethyl-3sulfo-, N-coco acyl derivs., hydroxides, inner salt amides, coco, N-[3-(dimethylamino)propyl] 1-propanaminium, 3-amino-N-(carboxymethyl)-N,N-dimethyl-,N-coco acyl derivs., hydroxides, inner salts amides, coco, N-[3-(dimethylamino)propyl], N-oxides sucrose 2-(2-butoxyethoxy)ethanolsulfuric acid, mono-C12-14-alkyl esters, compound with triethanolamin Replacing traditional AFFF and FFFP foam concentrates as well as fluoroprotein foams Petrochemicals sector - offshore oil installations and onshore terminals and refineries Class B hydrocarbon fuels (not intended for polar solvent fuels) Class A fuels June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 117 Wood Environment & Infrastructure Solutions UK Limited Product name Economic feasibility: Availability: Risks: Compliance with international performance standards Examples of use experience and performance compared to PFAScontaining foams Critical uses/applications where product do not meet (fully or partially) the required performance standard and why Need for changes in equipment Unit price Unit price as compared with PFAScontaining foam for same application Relative volume required to achieve comparable/best possible performance Storage, shelf-life Frequency of foam replacement Volume manufactured, sold and used in the EU Production capacity in the EU CMR properties Other potential human health concern PBT of vPvB properties Other environmental risk concern Conclusion on risks Re-Healing Foam RF1 1% EN 1568 Part 3 (see Appendix 5) Used at offshore facilities in Norway. Partially implemented at onshore facilities as well According to data sheet, the product is not intended for use on Class B polar solvents fuels. Diverging opinions among stakeholders: Specific applications related to large storage tanks in the petroleum industry (e.g. terminals and oil refineries) may require PFAS-based foams. However, the use of PFASfree foams has also been assessed as safe for sub-ground large storage tanks. One stakeholder noted that testing and qualification of non-PFAS foams and obtaining the necessary military approvals for use in all vessels / fire-fighting systems will take many years, and the associated costs will be very high. The experience with the case from the Norwegian offshore sector (Equinor, case 2) is that at a few facilities, adjustment of equipment was necessary, but usually, the same equipment was used and additional costs for new equipment were not necessary. Furthermore, substitution was done in relation to scheduled maintenance stops, turnarounds or during upgrades, thus not imposing further additional costs to the company. Approx. 5.0-5.5/l Case 2 indicates approx. 30% more expensive than PFAS products Same volumes, no difference to PFAS foams -10 to 50 C (no quality loss after thawing), 20 years Depending on application. Commonly, the foam is used continuously for training and system testing as well, thus not requiring replacement. Available in EU (tonnage not known) Manufactured in the EU: no data Sold in the EU: no data Used in the EU: no data Substances in the product do not meet the CMR criteria Hazard classification of product: H315 - Causes skin irritation H318 - Causes serious eye damage. Hazard classification of some constituents: H302 - Harmful if swallowed H314 - Causes severe skin burns and eye damage According to SDS, due to insufficient data no statement can be made whether the components fulfil the criteria of PBT and vPvB Hazard classification of one constituent: amides, coco, N-[3-(dimethylamino)propyl] ( - ) (EC No 268-771-8; CAS No 68140-01-2): OH400: Very toxic to aquatic life The constituents of the product do not meet the CMR criteria. Due to insufficient data no statement can be made on whether the constituents fulfil the PBT and vPvB criteria. One constituent is very toxic to aquatic life. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 118 Wood Environment & Infrastructure Solutions UK Limited Table 7.5 Moussol FF 3x6 (F-15) Product name Manufacturer Chemical group Chemical composition Proposed PFAS foam substitution (as specified by manufacturer) Technical feasibility Applications areas (as specified in technical specification) Compliance with international performance standards Examples of use experience and performance compared to PFAScontaining foams Economic feasibility: Availability: Critical uses/applications where product do not meet (fully or partially) the required performance standard and why Need for changes in equipment Unit price Unit price as compared with PFAScontaining foam for same application Relative volume required to achieve comparable/best possible performance Storage, shelf-life Frequency of foam replacement Volume manufactured, sold and used in the EU Production capacity in the EU Moussol FF 3x6 (F-15) Dr. Sthamer Hydrocarbons and detergents Substances listed in safety data sheet: 1,2-ethandiol 2-(2-butoxyethoxy)ethanol triethanolammonium-laurylsulfate alkylamidobetaine Replacing alcohol-resistant AFFF. Polar (water-miscible) and non-polar hydrocarbons as well as mixtures of the two (class A and B fires). Can be used as a low, medium and high expansion foam. DIN EN 1568: Part 3 (Heptane): IIIB/IIID, Part 1: Medium ex. - Part 2: High ex. ICAO Low expansion foam - Level B DIN EN 3 21A (see Appendix 5) Used within aviation, for example in Sweden, by Swedavia, and in the UK at Heathrow Airport. Swedavia is a state-owned company that owns, operates and develops Sweden's national basic infrastructure of airports. The product is used at all Swedish airports as well as for all aircraft applications at Heathrow airport including training. The foam has been tested and fulfils the requirements of International Civil Aviation Organization, European Aviation Safety Agency and the International association of fire and rescue service. One stakeholder states that the foam must be used aspirated, which reduces throw length. This may result in accessibility problems, for examples for large tanks. Other critical applications may be tank pit scenarios and large puddle fires (>400 m). No data No data Product costs about half of the corresponding PFAS-based foam, but approx. double volume is needed, thus the costs are the same. More storage capacity is required though. Depending on application. -5 to 50C (without quality loss below the specified frost resistance limit) Shelf life of >10 years, if stored according to recommendations 10 years Produced in Germany, data on volume considered confidential by manufacturer No data Risks: CMR properties Other potential human health concern Substances not classified with CMR properties Hazard classification of product; H319 - Causes serious eye irritation. Hazard classification of one constituent: H302 - Harmful if swallowed H319 - Causes serious eye irritation. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 119 Wood Environment & Infrastructure Solutions UK Limited Product name PBT of vPvB properties Other environmental risk concern Conclusion on risks Moussol FF 3x6 (F-15) H373 - May cause damage to kidneys through prolonged or repeated exposure if swallowed. Substances in the product do not meet the PBT/vPvB criteria Hazard classification of one constituent: Triethanolammonium laurylsulfate (EC No 288-134-8; CAS No 8566545-8): 412: Harmful to aquatic life with long-lasting effects C As the constituents are not classified with CMR properties and do not meet the PBT/vPvB criteria, the overall risks are considered lower than the risks of PFAS-based products. One constituent is classified harmful to aquatic life with long-lasting effects. Table 7.6 FOAMOUSSE 3% F-15 Product name Manufacturer Chemical group Chemical composition Proposed PFAS foam substitution (as specified by manufacturer) Technical feasibility Applications areas Economic feasibility: Compliance with international performance standards Examples of use experience and performance compared to PFAScontaining foams Critical uses/applications where product do not meet (fully or partially) the required performance standard and why Need for changes in equipment Unit price Unit price as compared with PFAScontaining foam for same application Relative volume required to achieve comparable/best possible performance FOAMOUSSE 3% F-15 Dr. Sthamer Protein Is a low expansion protein foaming agent based on natural re-growing protein carriers, foam stabilisers and antifreezing compounds. Substances listed in safety data sheet: iron-(ii)-sulfate-7-hydrate ammoniumchloride Not specified Typically used in non-polar hydrocarbon fires in the petroleum industry and on oil tankers In particular used in the marine sector. Has the advantage that the product is compatible with black steel and does not require equipment made from stainless steel or plastics (same for other protein-based products). Has been in use for many years and not developed as an alternative to the PFAS-containing foams. Designed for the use with all mobile and stationary low expansion foam equipment and systems for fighting fires of class A + B. EN 1568 part 3 (heptane) Mainly used in the marine sector Only applicable for smaller fires and not applicable for e.g. the aviation sector and other sectors with higher requirements. No data Not specified but the price is indicated as relatively low Lower No data June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 120 Wood Environment & Infrastructure Solutions UK Limited Product name Availability: Risks: Storage, shelf-life Frequency of foam replacement Volume manufactured, sold and used in the EU Production capacity in the EU CMR properties Other potential human health concern PBT of vPvB properties Other environmental risk concern Conclusion on risks FOAMOUSSE 3% F-15 A shelf life of >10 years, if stored according to the manufacturer's recommendations No data Produced in Germany, data on volume considered confidential by manufacturer No data Substances in the product do not meet the PBT/vPvB criteria Hazard classification of some constituents: H302 - Harmful if swallowed H315 - Causes skin irritation H319 - Causes serious eye irritation Substances do not meet the PBT/vPvB criteria of REACH None of the constituents have hazard classification for environmental effects As the constituents are not classified with CMR properties and do not meet the PBT/vPvB criteria, the overall risks are considered lower than the risks of PFAS-based products. The product is particularly applied in the marine sector, where volumes used for training are discharged directly to the sea. None of the constituents have hazard classification for environmental effects. Table 7.7 Ecopol Premium Product name Manufacturer Chemical group Chemical composition Proposed PFAS foam substitution (as specified by manufacturer) Technical feasibility Applications areas (as specified in technical specification) Compliance with international performance standards Examples of use experience and performance compared to PFAScontaining foams Ecopol Premium BIOex SAS Hydrocarbons and detergents Substances listed in safety data sheet: 2-(2-butoxyethoxy)ethanol Ethandiol Alkyl Sulfate Sodium octyl sulphate Equivalent to AFFF (certified 1A / 1A - EN 1568-3) and burn back resistance equal to fluoroprotein foams ECOPOL PREMIUM can substitute for FILMOPOL range from same company (other products from the company can substitute for other PFAS-based products) Industrial fires: landfills, plastics, tyres, etc. Hydrocarbon fires: fuel, diesel oil, petrol, kerosene, etc. Polar solvent fires: alcohols, ketones, ethers, etc. Urban fires: waste bins, furniture, textiles, etc. Effective at Low, Medium and High Expansion EN 1568 - 1: Conforms EN 1568 - 2: Conforms EN 1568 - 3: 1A / 1A (highest level) EN 1568 - 4: 1A / 1A (highest level) Oil industry: LASTFIRE Forest fire standards: CEREN Certificate Certification in progress : UL 162 / GESIP (see Appendix 5) According to producer's datasheet is used in the oil and chemical industry, pharmaceutical industry, aviation, marine, and fire and rescue service. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 121 Wood Environment & Infrastructure Solutions UK Limited Product name Economic feasibility: Availability: Risks: Critical uses/applications where product do not meet (fully or partially) the required performance standard and why Need for changes in equipment Unit price Unit price as compared with PFAScontaining foam for same application Relative volume required to achieve comparable/best possible performance Storage, shelf-life Frequency of foam replacement Volume manufactured, sold and used in the EU Production capacity in the EU Ecopol Premium Used in industrial uses for tank fire fighting. Further details not available. Diverging opinions among stakeholders. One stakeholder notes that the product is not technically feasible for large scale tank fire fighting, high-hazard industry manufacturing, oil tankers fire suppression systems, large spillage of flammable liquids One stakeholder indicated that re-building of firefighting or fire protection systems would be very costly, but no detailed information is provided. 3.5 EUR/l Approximately the same effective price One stakeholder responds 30 - 50% more volume needed. -30C to 60C, 10 years warranty Depending on application. Commonly, the foam is used continuously for training and system testing as well, thus not requiring replacement. Production in EU: 700,000 l/year; Sale in EU: 500,000 l/year No data CMR properties Other potential human health concern PBT of vPvB properties Other environmental risk concern GreenScreen level Conclusion on risks Substances not classified for CMR properties Hazard classification of one constituent: H318 - Causes serious eye damage. No PBT or vPvB properties identified None of the constituents are classified with regard the environmental hazards. Level Bronze. Level Bronze Screening Requirements are 1. Each intentionally added chemical compound present above 0% by weight (>0 ppm) and each impurity present at or above 0.01% by weight (100 ppm) in the product is screened with GreenScreen List TranslatorTM. 2. Each screened chemical compound in the Product Inventory has a GreenScreen List Translator TM score of LT-P1, LT-UNK, and/or NoGSLT. No LT-1 scores are permitted in certified products. 3. Product-level acute aquatic toxicity testing results in LC50 and/or EC50 values >10 mg/l for each of the following groups of organisms: fish, aquatic and invertebrates, and algae. As the constituents are not classified with CMR properties and it does not meet the PBT/vPvB criteria, the overall risks are considered lower than the risks of PFAS-based products Table 7.8 Orchidex BlueFoam 3x3 Product name Manufacturer Chemical group Chemical composition Orchidex BlueFoam 3x3 Orchidee Hydrocarbons and detergents Substances listed in safety data sheet: L2-(2-butoxyethoxy)ethanol, diethylene glycol monobutyl ether ethanediol, ethylene glycol June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 122 Wood Environment & Infrastructure Solutions UK Limited Product name Proposed PFAS foam substitution (as specified by supplier) Technical feasibility Applications areas (as specified by supplier) Compliance with international performance standards Examples of use experience and performance compared to PFAScontaining foams Critical uses/applications where product do not meet (fully or partially) the required performance standard and why Economic feasibility: Availability: Need for changes in equipment Unit price Unit price as compared with PFAScontaining foam for same application Relative volume required to achieve comparable/best possible performance Storage, shelf-life Frequency of foam replacement Volume manufactured, sold and used in the EU Production capacity in the EU Orchidex BlueFoam 3x3 alcohols, C10-16,ethoxylated, sulfates,ammonium salts D-glucopyranose oligomeric C10-16-alkyl glycosides ammonium lauryl sulfate alcohols, C10-16,ethoxylated dodecanol -1 Products can be seen as 1:1 replacement on Sthamex AFFF and Moussol Products or other AR or usual AFFF products. Appropriate foaming is needed - as for all PFAS-free products - which can usually be realised with the equipment to hand. On systems the nozzles/sprinklers needs changing. Main strength on non-polar liquids. Aviation, petrochemical sector For all uses till tanks > 15 m diameter. EN 1568 - 3: 1B EN 1568 - 4: 1A / 2B Oil industry Lastfire (Heptane), ICAO Level B (see Appendix 5) Indicated by supplier that one of the biggest airports in Germany has changed to the product. After tests with their trucks to test the capabilities for their dosing-system, the airport has decided to change all trucks to PFAS-free and has now started a project to change also all systems. Indicated by supplier that fires in substances like isopentane (with low boiling points of 28C) are difficult and PFAS-containing foams may have an advantage. This could according to the supplier be overcome with a higher application-rate and/or more technical changes to technique and equipment. In the view of supplier and experience from dozens of tests done in the past 10 or more years it's generally possible to change 99.9 % of all current scenarios to PFAS-free. Indicated by supplier as normally none. Some information from airport in Germany that changes of trucks may be needed, but not indicated it this concerns adjustment or actual changes in equipment. Depending on concentration, the price in sales is in the range 2.5 - 6.0/l No data According to supplier, if there might be a gap, it's in between 5-10 % in the extinguishing-time for PFAS-containing products in regard to mainly unpolar and secondly polar liquids. In tests, nearly 1:1 results were found, but this is strongly depending on the fuels and additives. No data 5-15 years Stakeholder (not the manufacturer) estimates volume sold in the EU at 800 t/year No data Risks: CMR properties Other potential human health concern PBT of vPvB properties June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 Substances not classified with CMR properties Hazard classification of several constituents: H302 - Harmful if swallowed H318 - Causes serious eye damage H319 - Causes serious eye irritation H315 - Causes skin irritation Product has not been tested according to SDS 123 Wood Environment & Infrastructure Solutions UK Limited Product name Other environmental risk concern Conclusion on risks Orchidex BlueFoam 3x3 Hazard classification of one constituent: Ammonium lauryl sulfate (EC No 218-793-9; CAS No 2235-54-3): H412 - Harmful to aquatic life with long lasting effects. None of the constituents are classified with CMR properties. Due to lack of information it cannot be concluded if the constituents fulfil the PBT and vPvB criteria. One constituent is harmful to aquatic life with long lasting effects. 7.6 Representative case studies where fluorine-free alternatives are already in use in the EU Step 5 - Assessment of illustrative cases An important issue in identifying the feasibility of alternatives is the consideration of the process that is involved in adopting the alternative, including systems that need to be changed and considerations such as additional training of users. Substitution examples from companies that are already using alternatives therefore act as a key starting point or proof of principle that a transition is (or is not) possible and the main costs and benefits from real world examples. In order to better understand the options and challenges of replacing PFAS-containing AFFFs, two cases where PFAS-containing AFFFs have been successfully replaced are described in more detail in the following case study examples. Case 1 Aviation sector - Copenhagen Airport in Denmark94 Foam used In general, the majority of firefighting foam is used for testing and training at airports. Only a very small percentage is used operationally for emergency response at live events. At Copenhagen airport, the same fluorine-free foam (Solberg Re-healing foam RF3x6 ATC fluorine-free foam) is used for training and emergency response. Timeline in the shift from PFAS foams to fluorine free-foams In 2003, the airport recognised PFAS in the run-off firewater from the airport's training area and its burn pit. This resulted in restrictions on use of PFAS-containing AFFF and later, in 2006, all training with PFAS foams stopped; In 2008, testing with fluorine-free foams was started. Re-Healing foams from Solberg were identified as suitable alternatives; and In 2009, the airport conducted additional tests required by the ICAO ARRF working group. All tests (ICAO foam test and test according to the US Mil-Spec protocol, including the NFPA 403), were passed by the fluorine-free foam carrying airport crash tenders. The results from the UK CAA/ICAO tests also showed that CAFS (Compressed Air Foam System; application of foam 94 Case description is based on the following sources: IPEN position paper 2018 (https://ipen.org/sites/default/files/documents/IPEN_F3_Position_Paper_POPRC-14_12September2018d.pdf) IPEN position paper 2019 (https://ipen.org/sites/default/files/documents/the_global_pfas_problem-v1_5_final_18_april.pdf) Kim T. Olsen, 2017, Crashtender med skumkanoner (https://beros.dk/skum/Kim_Thorbjoern_Olsen_CPH.pdf) Personal communication with Kim T. Olsen, 2019 June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 124 Wood Environment & Infrastructure Solutions UK Limited with non-aspirating turret)95 were about 40% more efficient in fire extinction compared to aspirated foams. CAFS with PFAS and PFAS-free foams were both shown to be efficient. The PFAS-free foam was implemented jointly with three new airport crash tenders (specialised firefighting trucks designed for use in aircraft rescue and firefighting at aerodromes) with CAFS on all low-pressure outlets. Challenges Along with the implementation of the new firefighting trucks, the training of the firefighters with the new equipment and foams was a crucial issue and initial testing and training caused additional costs (exact cost estimates are unknown). Also, the different viscosity of the PFASfree foam caused some initial challenges, which were later solved by the adjustment of equipment; and Some of the old trucks continued to be in use and, even though the tanks were cleaned thoroughly, a contamination of the PFAS-free foam with PFAS occurred initially. Costs of replacement Upon implementation of the new fluorine-free alternative, testing and training required ~5,000 litres foam/year. However, with some modifications to the equipment and training, the volume has now been reduced to 3,000 litres foam/year. Optimal efficiency was found at a 6% foam concentration (ICAO Level C) instead of 3% (ICAO Level B), thus larger foam volumes may still be used in certain situations; Costs incurred in the replacement comprised mainly costs for destruction of PFAS-containing foams and additional training and testing. More specific cost estimates were not available in this case. However, it should be noted that the foam supplier also had an interest in supporting the implementation of the PFAS-free foam and carried out some of the foam testing and covered the additional costs; and The investment in new airport crash tenders (specialised fire engines designed for use in aircraft rescue and firefighting) was not strictly linked to the foam replacement, but the coincident introduction of new trucks and foam was seen as having a cumulative benefit. Benefits Copenhagen Airport is still working on the remediation of previous pollution from PFAS foams. In 2014, works on clean-up, containment and reconstruction of the fire training area were started and required an initial investment of more than 15 million. Currently, the maintenance of the drainage system around the fire training ground costs more than 1.5 million per year and this expenditure is expected to continue for at least the next 80 years. The biggest benefit of switching to a fluorine-free alternative foam is that rainwater and firewater runoff can be discharged though the normal sewer system to the municipality's waste water treatment, thus avoiding long-term clean-up issues and remediation costs in the future. 95 The difference between aspirating and non-aspirating equipment is that the aspirating device mixes air in the foam/water solution within the nozzle or foam maker, whereas non-aspirating devices do not. Typical examples of non-aspirating devices are water/fog nozzles, water spray heads and conventional sprinkler heads (Ansul Technical bulletin no. 55, https://www.ansul.com/en/us/DocMedia/F83115.pdf). June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 125 Wood Environment & Infrastructure Solutions UK Limited Figure 7.1 Training at Copenhagen airport with crash tender. Picture courtesy of Kim T. Olsen, Copenhagen Airports A/S. (https://beros.dk/skum/Kim_Thorbjoern_Olsen_CPH.pdf). Case 2 Petrochemical sector - Offshore production in Norway96 Foams used Equinor, representing 80% of all production on the Norwegian Continental Shelf and equivalent to 50% of total production for the North Sea, have managed to substitute PFAS-containing foams with PFAS-free foams at almost all installations. The substitution is close to completion for ~40 offshore installations and is ongoing for five onshore facilities (terminals and an oil refinery). Fire-fighting foams at offshore installations are used for multiple applications including training, system testing and emergency response of live events. At most facilities, Re-healing RF1, 1% foam from Solberg is used, while some older facilities use Re-healing RF1 3% foam. For a few installations (where there is risk of methanol fire), alcohol resistant foam was used. The 1% and 3% foam products are used for petroleum fires and were chosen because they are regarded as a drop-in replacement for fluorinated AFFF. For methanol fires specifically, Solberg Re-Healing Foam RF3x6 ATC (alcohol resistant foam) is used. Basically, all foam is used for training and systems testing as emergency responses are seldom (have not occurred since the implementation of the substitution). Environmental discharges may also occur due to accidental spills. The crude oil and products are stored in caverns i.e. underground storage tanks. The typical size is 50,000 - 280,000 m3 for crude oils and 10,000 - 50,000 m3 for products. The caverns are filled up with fluids to prevent them from catching fire. 96 Case description based on the following sources: IPEN position paper 2019 (https://ipen.org/sites/default/files/documents/the_global_pfas_problem-v1_5_final_18_april.pdf) Personal communication with Lars Ystanes, Equinor, 2019 June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 126 Wood Environment & Infrastructure Solutions UK Limited Timeline in the shift from PFAS foams to fluorine free-foams In 2010-2012, development and testing of a 1% fluorine-free firefighting foam was carried out as a collaborative project between Solberg Scandinavian and Equinor (named Statoil at that time). The driver for the replacement was concern of the environmental consequences of PFAScontaining firefighting foam released to the sea; In December 2012, the Re-healing RF1, 1% foam (RF1) was first used successfully on the offshore installation Kvitebjrn; In 2013, the RF1 foam was technologically approved for use by Statoil after an approval and verification process; In 2014, approval for starting the multi-use transition project was obtained, with the aim of implementing the new foams at all Norwegian operated installations with 1% foam systems; By September 2016, 30 of 31 Equinor assets had successfully implemented use of RF1 foam; and In 2018, Solberg launched a modified 1% RF1, with lower viscosity at low temperatures and with a yellow environmental classification (compared to red classification for RF1)97 called RF1AG. This product went into operational use in 2018 on all new offshore installations. Challenges During the substitution implementation, several technical issues occurred which had to be resolved using additional testing by Equinor: During full-scale testing with RF1, a break-down of the foam proportioner occurred which was initially linked to corrosion related to the use of the RF1 foam. Further investigation identified another reason for the break-down and it was concluded that RF1 had no influence on the foam proportioners; RF1 has a higher density and viscosity compared to the previously used AFFF. Higher density may be a problem for installations with substandard foam pumps. However, most Equinor installations were able to handle the increased viscosity and density with only minor system adjustments. At one installation, the pumps were not able to handle RF1 and the solution for this installation is still under evaluation; and Initial uncertainties related to the temperature tolerance of the foam have been removed. The products currently used have a freezing tolerance down to -19C and acceptable low viscosity at ambient temperature. Costs of replacement For Equinor, the total costs of substitution of PFAS-containing foams at about 40 offshore installations and five onshore facilities has been estimated to be approximately 7 million. This estimate does not include costs related to R&D, and regulatory approval costs, which were undertaken in this case by the foam supplier (Solberg). At a few facilities, adjustment of equipment was necessary, but usually, the same equipment was used and new equipment (and associated cots) was not necessary. These total headline costs can be broken down further to include the following: 97 Environmental colour marking system in Denmark and Norway of The Harmonised Offshore Chemical Notification Format under the OSPAR Convention 1992 indicating substances that should be considered candidates for substitution. "Red" substances may only be used in limited amounts and shall be substituted. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 127 Wood Environment & Infrastructure Solutions UK Limited The cost for support in the multi-use phase has been estimated at 2,500 working hours in the period from August 2013 to September 2016, corresponding to a total cost of approx. NOK 3.5 million (approx. 360,000). This included activities such as planning of implementation together with the supplier, preparation of information letters, support team, follow up on technical issues, etc; The cost related to replacement of foam in storage ranges from 50,000 to 500,000 for the biggest oil installations, corresponding to tank storages of 20 - 120 m3. In total, approximately 1,100 m3 of foam was replaced over a 3 year period, resulting in a rough cost estimate of 1,100,000 litre * 5 /litre = 5.5 million. Substitution has always been done in relation to scheduled maintenance stops, turnarounds or during establishing new equipment, thus not imposing further additional costs to Equinor. Note that replacement costs listed here are not due to a higher price of alternative, but due to the costs of replacing the PFAS-based foams in storage (costs of alternatives as compared to the PFAS-based foams); Additionally, the cost related to destruction/incineration of old the PFAS-based foam contributed a further approx. 1 million to the transition costs (~1,000,000 litre * 1 /litre); and Costs of decontamination of equipment were not significant and no fire-fighting equipment or storage tanks were replaced as part of the decontamination process. The storage tanks were drained empty to >99% and the PFAS-based foams handled as waste (destruction/incineration as indicated above). Washing water containing low levels of PFAS was discharged to the sea or waste water treatment plants. Compared to continuous use of PFAS, it was considered that the small discharges of washing water were insignificant. Costs of alternatives The costs of the new foams as compared the PFAS-based foams used before varied between +5% to +30%, depending on foam type/application. For the majority of the foams, the costs increased by +30% and the overall costs increase was slightly below +30%. Benefits At onshore installations, PFAS foams have either been released during operations at the harbour or collected as hazardous waste water at the process plants. The disposal of hazardous waste water, consisting of appr. 1% foam and 99% water meant a significant cost item before the substitution. Waste water containing fluorine-free foams is treated at the biological waste water treatment plants of the onshore installations; Before the substitution, PFAS-containing AFFF were always discharged to the sea during training and system test at Equinor's offshore installations. The use of PFAS-free foams now means a significantly reduced environmental impact. The annual discharge of PFAS-based foams to the sea was reduced from 3-4 tonnes to (almost) zero; In 2014, Norwegian authorities required standard environmental documentation for all firefighting foam used in high volumes. Since Equinor have been successful in transitioning to PFAS-free foams, there is now a general pressure driving the Norwegian market towards the use of PFAS-free foams; and Equinor recognise the substitution as a good investment to be in position for future regulatory changes, but they also see value in reducing their chemical footprint and strengthening their market position as substitution leaders. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 128 Wood Environment & Infrastructure Solutions UK Limited Figure 7.2 Firefighting training with foams at offshore platforms in Norway (picture courtesy of Lars Ystanes, Equinor) 7.7 Overall analysis of alternatives Step 6 - Final summary This section of the report draws together all of the information gathered under the previous tasks to produce an overall assessment of the technical feasibility, economic feasibility, and availability of alternatives to PFAS- containing fire-fighting foams. A summary for the seven evaluated alternative substances is in Table 7.9. Furthermore, reference is made to the two case stories from the aviation and petrochemicals sector, above. The seven products are selected from a list of more than 30 products marketed as alternatives to AFFFs, but are considered to be representative of the products on the market for the most sensitive uses of AFFFs for liquid hydrocarbon fires and of products that are in actual use (rather than others which may be marketed but actual use is unknown). Technical feasibility Aviation Alternatives have successfully replaced the PFAS-containing foams in a number of airports. Based on the stakeholder consultation, three different products from three manufacturers have been reported to have replaced applications of AFFF in airports in Denmark (Copenhagen, Re-healing foam RF3x6 ATC), Germany ("one of the biggest airports", Orchidex BlueFoam 3x3, Sweden (Arlanda and other airports, Moussol 3/6-FF), and the UK (Heathrow, Moussol FF 3x6). The alternatives are used for all applications. According to the IPEN report "Fluorine-free firefighting foams (3F) viable alternatives to fluorinated aqueous film-forming foams", all of the 27 major Australian hub airports have transitioned to fluorine-free firefighting (F3) foams, as have the following major hub airports: Dubai, Dortmund, Stuttgart, London Heathrow, and Manchester, Copenhagen, and Auckland98. 98 Fluorine-free firefighting foams (3F) viable alternatives to fluorinated aqueous film-forming foams (AFFF), IPEN Stockholm Convention POPRC-14, Rome, September 2018 June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 129 Wood Environment & Infrastructure Solutions UK Limited A case story from Copenhagen Airport demonstrates that some testing, modification of equipment and training has been required. The entire transition period was 6 years. Investment in new fire trucks took place at the same time, but this was not directly required due to the foam replacement. It has been indicated by stakeholders that some airports voiced concerns over efficacy and changes of equipment, but no specific information has been obtained. The same certification tests apply for all airports in Europe and the successful transition in several airports indicates that it should be possible for others. Some alternatives comply with the highest ratings of N 1568,1A/1A for both Part 3 and 4. One stakeholder noted that high ambient temperatures can influence the performance of foams as demonstrated in an incident in Dubai. However, as mentioned above all 27 major Australian hub airports have transitioned to fluorine-free firefighting (F3) foam indicating that PFAS-free foams are also being applied at high ambient temperatures. One stakeholder (a supplier of AFFF and alternatives) with experience in transition in a German airport states that that experience from a large number of tests done in the past 10 or so years indicates it is possible to change 99.9 % of all current scenarios to PFAS-free products. Upstream petrochemical sector Equinor, the largest operator on the Norwegian continental shelf, has successfully replaced AFFF in about 40 offshore installations and five onshore facilities. At a few facilities, adjustment of equipment was necessary, but usually the same equipment was used and new equipment was not necessary. At one installation, the pumps were not able to handle the alternative. The company had some challenges with the density and viscosity of the alternative foams initially used compared to the traditionally used AFFF, e.g. by lower ambient temperatures. This was solved by modifications of the alternative product. The shift took approximately eight years from the first tests to when the modified alternative was introduced on all installations. Municipal fire brigades and forestry PFAS-free alternatives are readily available for these areas and, as shown in Task 2, account for more than 60% of the total market. No data on costs of substitution specifically for these application areas have been provided in the stakeholder consultation or identified in the literature. Marine applications A wide range of PFAS-free foams are marketed for marine applications and it has not been indicated by any stakeholders that there might be particular challenges in changing to PFAS-free foams apart from the general need for adjustment and testing of equipment. One of the example products is a low expansion protein-based foam which is typically used in non-polar hydrocarbon fires in the petroleum industry and on oil tankers. It has the advantage that the product is compatible with black steel and does not require equipment made from stainless steel or plastics (and the same is the case for other protein-based products). It is designed for use with all mobile and stationary low expansion foam equipment and systems for fighting fires of classes A and B. Military applications Alternatives are less well established in the military sector, but it has been indicated by stakeholders that alternatives are considered to be feasible, although not many have yet been certified or implemented by users. The military applications are similar to those seen in airports and municipal fire brigades and the foams used are, after the necessary testing and adjustment of equipment, considered to be useful for military applications as well. As an example, the IPEN publication on "Fluorine-free firefighting foams (3F) viable alternatives to fluorinated aqueous film-forming foams (AFFF)" states that the Danish and Norwegian armed forces have moved to PFAS-free foams. The specific foams used have not been identified, but these are thought to be foams from major producers. As mentioned before, one stakeholder noted that testing and June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 130 Wood Environment & Infrastructure Solutions UK Limited certification of PFAS-free foams and obtaining the necessary military approvals for use in all vessels / firefighting systems will take many years, and the associated costs will be very high. However, this has not been confirmed by other stakeholders. Petrochemical processing and large storage tank farms Use areas where PFAS-free alternatives have not been fully tested, is in the downstream petrochemical sector (refineries and steam crackers) and large storage tank facilities. In particular, for large storage tank fires, combatting these fires requires foams capable of flowing on large burning liquid surfaces and sealing against hot metal surfaces to prevent reignition. The development of suitable test criteria for large storage tanks and fluorine-free foams is ongoing under the LASTFIRE project. Several of the shortlisted products in this report have been tested and reported to be in compliance with the LASTFIRE criteria. According to a presentation by Nigel Ramsden, LASTFIRE, at the stakeholder workshop on 24 September 2019, it has been shown that PFASfree foams can provide equivalent performance to C6 foams and provide appropriate performance for hydrocarbon fires in a number of test conditions: When used with NFPA application rates for the following applications: Tank fires ~15m+ diameter (no reason to doubt results can be extrapolated to >25m+): o Conventional pourer standard application rates; o Aspirating monitor99; and o "Non aspirating" monitor with appropriate foam characteristics. Tank fires ~60m+ diameter No reason to doubt results can be extrapolated to >80m +) or bund fires: o Foam pourer. When used at lower rates than NFPA using CAF application: Tank fires ~15m+ diameter (no reason to doubt results can be extrapolated to >25m+): o Monitor application. Tank fires ~80m+ diameter (no reason to doubt results can be extrapolated to >100m +) or bund fires: o Foam pourer. It is stated in the presentation that test results for some conditions are still missing and LASTFIRE is going to work on these issues: specifically, polar solvent tests - foam application from longer distances, other foams/combinations of foam/application methods, tactics for life safety situations and optimising properties. As indicated above, it can be concluded that even in large tanks alternatives can be applied, but the safety margin may be lower than for the PFAS-based foams. According to stakeholders, the largest risks are associated with fires in large tanks of crude oil because of the higher risk of boil-over. One stakeholder mentioned that fires in large tanks of ~40m are however very rare in the EU and they could not identify any such fires in Europe in the last 10 years. A recent study by the Fire Protection Research Foundation (USA) determined the fire extinguishment and burnback times for five fluorine-free foams (FFF) and one short chain C6 Aqueous Film Forming Foam formulation (AFFF) as a function of application rate and foam discharge density for a range of test 99 Fire fighting monitors are a controllable high-capacity water jet used for manual or automatic fire fighting June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 131 Wood Environment & Infrastructure Solutions UK Limited parameters including foam quality/aspiration, fuel type, water type and fuel temperature100. In summary, the authors conclude that PFAS-free foams have come a long way but there is still a lot more to learn about their capabilities and limitations. Furthermore, they conclude: "As of today, FFFs are not a "drop in" replacement for AFFF. However, some can be made to perform effectively as an AFFF alternative with proper testing and design (i.e., with higher application rates/densities)."100 No specific cases with successful 100% transition in installations with large tanks have been identified. According to stakeholders some examples exist where PFAS-free foams are used for the majority of applications but PFAS-based foams are still stored for use in emergency situations with large tank fires. A reported challenge in petrochemical processing and storage tank farms is the presence of tanks with different liquids that may require different alternatives because one alternative cannot be used for all the liquids. One supplier indicated that in some instances in the petrochemical industry two different alternatives could be required whereas another manufacturer indicated that even more than two may be required if many different liquids are stored. As reported elsewhere, in the chemical/petrochemical sector approximately 93% of the foam volume is used for training. Most of the manufacturers provide PFAS-free training foams that mimic the AFFF and which are used for training. One manufacturer indicated that the PFAS-free training foams were not used in live-fire training ("hot training") As indicated in Task 2, PFAS-free alternatives account for 19% of the volume used in the chemical/petrochemical sector, but a major part of this is likely to be for training purposes. Availability A large number of alternatives are available from at least eight manufacturers. Most of these manufacturers also manufacture AFFFs and the alternative product range is often designed to match the product range of AFFFs. As demonstrated with the successful transition in many airports, products from several manufacturers are applicable for replacing the AFFF for the same application. Only limited information on actual production volumes for the individual products has been available from manufacturers because this information is generally considered confidential. The PFAS-free alternatives currently represent 32% of the market and this share is growing. Based on interviews with three manufacturers of fire-fighting foams in Europe, it can be concluded that there is currently overcapacity in Europe e.g. one of the manufacturers indicated they are running at 10-20% of their capacity. One manufacturer indicated that they have also extra capacity for emergency situations. All three manufacturers estimated that the necessary volumes of alternatives could be supplied within a short time (one to a few years). All EU manufacturers are also formulators and the alternative products are formulated from common bulk raw materials for cleaning and washing agents, food products, etc. and not specifically produced for the alternative firefighting foams. The manufacturers indicated that raw materials are available in sufficient quantities. According to the manufacturers and other information from stakeholders, the main challenge in the transition would not be to meet the demand for those alternatives already on the market, but to develop alternatives for application areas where replacement is still challenging. Health and environmental risks For the shortlisted products, none of the components included in the Safety Data Sheets are classified with CMR properties. For most of the products, the Safety Data Sheets indicate that the products or components do not meet the PBT/vPvB criteria of REACH. For two products, it is reported in the Safety Data Sheet that sufficient data are available for assessing whether the components fulfil the PBT and vPvB criteria. None of the products, however, include substances demonstrated to be PBT or vPvB substances. The classification of the components of assessed alternatives indicates that other classified effects are "Causes skin irritation" 100 Back, G.G., Farley, J.P. (2010). Evaluation of the fire protection effectiveness of fluorine free firefighting foams. Fire Protection Research Foundation. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 132 Wood Environment & Infrastructure Solutions UK Limited (H302), "Causes serious eye irritation" (H319) and "Causes skin irritation" (H315). Many of the products do not include substances classified with environmental effects whereas others include one or more substances classified "Harmful to aquatic life with long lasting effect" (H412). It should be recognised, however, that not all human health or environmental hazard endpoints have necessarily been assessed in detail for each component by the foam manufacturers (for example, endocrine disrupting effects). Economic feasibility The available data indicates that the most significant one-off costs to transition to fluorine-free foams are associated with the following: Replacement of foams in storage. For Equinor, the costs of replacement of AFFFs was 5/l corresponding to 5.5 million; Destruction of replaced AFFFs. In addition to costs of about 1/l for the destruction of the replaced AFFFs, corresponding to a total of 1 million; Decontamination of equipment. The available cases do not indicate significant costs of decontamination of equipment. The equipment has typically been drained and decontaminated by cleaning with washing water which was discharged to waste water or surface water. However, the costs of cleaning of equipment will depend on the requirements as to the decontamination level and discharge of cleaning water. According to information from manufacturers, it may in some instances be less expensive to change part of the equipment than to clean it especially for stationary equipment. Stakeholders have reported, the requirements are different between Australia and New Zealand resulting in large differences in the costs of decontamination of equipment (specific data have not been obtained); Management of the transition process. Reported at 0.36 million for Equinor i.e. less than 10% of total transition costs; R&D and regulatory approval costs. These costs are usually covered by the manufacturers of foams and reflected in the price of the alternative foams; Adjustment and replacement of equipment. The available cases indicate that the costs of replacing equipment has been small in comparison to the cost elements listed above. According to stakeholders, extra storage capacity is not always required; and Training in the use of new products. The available cases do not indicate additional training costs; these are covered by the costs of testing and adjustment of equipment. Regarding the effective price of alternatives, three interviewed manufacturers of PFAS-based foams and alternatives consider that the effective price is more or less the same and within +/- 20%. In accordance with this, additional recurrent costs for alternatives used in the aviation sector, stakeholders have reported that the effective price of the alternatives (taking efficiency of alternative into account) is more or less the same as the price of the AFFF used before the transition. The case from the offshore sector reports extra costs varying between +5% and +30% depending on application with total extra costs slightly below +30% as compared with the AFFFs used before. This may reflect the more diverse scenarios in the off-shore petroleum sector. The reported shelf lives of alternatives range from >10 years to 20 years. Shelf life of PFAS-based foams is reported to be typically between 10 years and 20 years (to a maximum of 30 years)101. In general, the shelf life of the alternatives does not seem to be shorter than the shelf life of PFAS-based foams and no extra costs, as a consequence of differences in shelf life, have been indicated by stakeholders. 101 Proposal for a restriction: Perfluorohexane sulfonic acid (PFHxS), its salts and PFHxS-related substances https://echa.europa.eu/documents/10162/a22da803-0749-81d8-bc6d-ef551fc24e19 June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 133 Wood Environment & Infrastructure Solutions UK Limited The main advantages of using alternatives in the aviation sector are that the rainwater and firewater runoff from training grounds can be discharged though the normal sewer system to the municipality's waste water treatment system, thus avoiding long-term clean-up issues and remediation costs in the future. The case from Copenhagen airport demonstrates that works on clean-up, containment and reconstruction of the fire training area were started and required an initial investment of more than 15 million, and currently, the maintenance of the drainage system around the fire training ground costs more than 1.5 million per year and this expenditure is expected to continue for at least the next 80 years. At offshore installations, training foams are typically discharged directly to the sea and it is not considered feasible to avoid this discharge by collecting and treating the AFFF-containing firewater. As indicated above, the costs of destruction of PFAS-based foams is about 1/litre (a more detailed description of destruction costs is provided in section 10.2). The costs of destruction of the PFAS-based foams is likely to be incurred in any case when the foams expire (exceed their shelf life). In the past the PFASbased foams were also used for training which meant that stocks were used before they reached the end of their shelf life. According to information from stakeholders it is today common to store PFAS-based foams which have reached their shelf-life whilst waiting for a less expensive solution for disposal. In a scenario where PFAS-based foams are used for emergency situations and PFAS-free foams are used for training, a cost of about 1/litre for destruction of the PFAS-based foams by the end of their service life should be expected. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 134 Wood Environment & Infrastructure Solutions UK Limited Table 7.9 Evaluation of potential alternatives by application area Parameter Technical feasibility Availability Current and future availability Timeframe Questions Can alternatives perform the same functions as the PFAS-based foams for same application Will it require changes (in processes, equipment, storage facilities, training, etc.)? Is it available in the required tonnage / amount in the EU / worldwide? How fast could enterprises make the switch? What would be the downtime, if any? Airports Off-shore facilities Petrochemical industry and large tank farms Municipal fire brigades Marine applications Training: Yes Actual fires: Yes Training: Yes Actual fires: Yes Most training scenarios: Yes Large-scale fires: Not demonstrated for some situations Training: Yes Actual fires: Yes Training: Yes Actual fires: Yes Adjustment of equipment, tests, training required. In some instances there may be a need for new equipment and increased storage capacity Yes Meeting market requirements not considered a challenge as transition is expected to take some years Yes Meeting market requirements not considered a challenge as transition is expected to take some years Yes for most training No - further tests of alternatives required for actual emergency situations in large tank farms and some other installations No challenge for training foams Further development required for large tank farms Yes Yes Meeting market requirements not considered a challenge as transition is expected to take some years Meeting market requirements not considered a challenge as transition is expected to take some years June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 135 Wood Environment & Infrastructure Solutions UK Limited Parameter Risks Human health Risk to the environment Assessment of net risk Questions Information on the hazards: properties causing the concern for the substance to be restricted / other properties. Information on risks related to properties causing the concern for the substance to be restricted / other properties. Information on other risks related to the alternatives. Information on the hazards: properties causing the concern for the substance to be restricted / other properties. Information on risks related to properties causing the concern for the substance to be restricted / other properties. Information on other risks related to the alternatives. Would the alternative result in a sufficient reduction in the net risk? Are there new risks associated with the alternative? Airports Off-shore facilities Petrochemical industry and large tank farms Municipal fire brigades Marine applications None of the constituents of the alternatives meet the CMR criteria. Classification of constituents of alternatives does not point to any significant health concern. This assessment is based on hazard information identified in safety data sheets for relevant products. The safety data sheets include constituents with a hazard classification, and the conclusion that the alternatives do not meet the CMR criteria are considered robust for the foams evaluated in more detail. However, there was insufficient information to conclude whether the underlying test/endpoint data was equivalent for these substances and the alternative products compared to the PFASbased products Some constituents are classified with hazard phrases such as harmful if swallowed and causes serious eye irritation and occupational exposure should be reduced by use of adequate protective equipment, but this would likely apply to any fire-fighting foam. PFAS are very persistent with a potential for exposure of humans via the environment. Shortchain PFAS accumulate in edible parts of plants and the accumulation in food chains is unknown102 In general, there is a high level of uncertainty as to whether the ongoing exposure to low concentrations of short-chain PFAS may cause adverse effects in organisms. It is therefore very difficult to estimate longterm adverse effects in organisms. The constituents of alternatives are in general not persistent, and exposure via the environment is not considered to be of concern based on data currently available. For some alternatives, data are not sufficient to conclude that they do not include persistent constituents. Alternatives do not generally meet the PBT or vPvB criteria. For some of the alternatives, data were not sufficient to determine whether some constituents are persistent. Many of the alternatives include constituents classified as toxic or very toxic to aquatic life. Short-chain PFAS are very persistent with high mobility in environmental media and high potential for longrange transport. * The constituents of the alternatives are in general not identified as persistent or of having a high potential for long-range transport and for accumulating in the environment. However, there was insufficient information available to conclude whether the underlying test/endpoint data was equivalent for these substances and the alternative products, compared to the PFAS-based products. In general, alternatives do not contain very persistent substances and are considered likely to provide a reduction in the net risk. The main constituents of alternatives are typically used in cleaning and washing agents, food, etc. Overall, no significant new risks have been identified based on the available information. However, not all human health or environmental hazard endpoints have necessarily been assessed in detail for each component by the foam manufacturers (e.g. endocrine disrupting effects). Additionally, the level of information 102 Short-chain perfluoroalkyl acids: environmental concerns and a regulatory strategy under REACH. Brendel et al. 2018. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC5834591/pdf/12302_2018_Article_134.pdf June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 136 Wood Environment & Infrastructure Solutions UK Limited Parameter Economic feasibility Net costs Questions Net compliance and other costs (taking into account both increases and decreases in costs) faced by actors in each link of the supply chain. Airports Off-shore facilities Petrochemical industry and large tank farms Municipal fire brigades Marine applications available on the risk posed by some alternatives is insufficient to conclude whether the underlying test/endpoint data was equivalent compared to the PFAS-based products. One off costs: The main costs of transition are reported to be costs of replacement of PFAS-containing foams in storage and destruction of these foams (such costs would not normally have been incurred outside of normal replacement after 10-20 years). Total costs of replacement and destruction is approximately 6/l. Costs of decontamination of equipment have been mentioned by stakeholders as potentially significant, but actual cases do not indicate significant costs of decontamination. Recurrent costs: Extra costs of foams are reported to be in the range of 0 to +30%. Economic feasibility of the alternatives. Alternatives have successfully been implemented by many users Alternatives have successfully been implemented by some users Alternatives have successfully been implemented for training purposes; for specific applications alternatives are not available Alternatives have successfully been implemented by many users Ability of the different actors to pass costs down the supply chain. High (no competition with competitors outside the EU) Medium (some competition with competitors outside the EU) Medium (some competition with competitors outside the EU) High (no competition with competitors outside the EU) Trade and wider economic and employment effects. No effect expected No significant effect expected No significant effect expected No effect expected Uncertainties. What is the level of uncertainty in the assessment of the feasibility, risks and economic viability of alternatives? High certainty High certainty Note: * Short-chain perfluoroalkyl acids: environmental concerns and a regulatory strategy under REACH. Brendel et al. 2018. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC5834591/pdf/12302_2018_Article_134.pdf Medium certainty - many different and complex scenarios High certainty Alternatives have successfully been implemented by many users Low (significant competition with competitors outside the EU) No significant effect expected High certainty June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 137 Wood Environment & Infrastructure Solutions UK Limited 8. Task 2: The socio-economic impacts of substitution of PFAS-containing fire-fighting foams 8.1 Aims and scope of the SEA The aim of the SEA Along with an analysis of alternatives, the socio-economic analysis is key to understanding the potential impacts of a restriction. This is intended to evaluate whether a proposed restriction (if one is adopted) provides the best practical option to manage the risks, and if the benefits of controlling the risks identified do not generate disproportionate costs. The primary objectives of this task were to assess the socioeconomic impacts of an EU-wide restriction or total ban of the use of PFAS-containing fire-fighting foam to inform the pre-RMOA and pre-Annex XV dossier. Definition of the "baseline" scenario The baseline scenario describes the situation in the absence of any further regulatory management options (RMOs). It reflects the current market situation, but also any anticipated changes in the absence of the proposed RMOs. It was used to compare restriction scenarios (defined in the next sub-section), to ensure that the SEA evaluates the impacts of the RMOs being assessed. More details are provided in the market analysis (see Section 4), but the key points are below. It is estimated that currently some 14,000-20,000 tonnes (likely closer to the upper end of the range) of PFAS-based fire-fighting foams are sold per year in the EU and used in various sectors including chemicals/petrochemicals, municipal fire-fighting, marine, airports, military, railways and fire extinguishers. Their use is particularly important and widespread where there is a risk of Class B fires, i.e. where flammable liquids are present. They are used for fire-fighting, but in some cases also for training and testing of equipment; Some 9,000 tonnes per year of fluorine-free foams are already used in most of the same applications, although the split by sector varies from that of PFAS-based foams. Several stakeholders, including manufacturers of fire-fighting foams, have indicated that the use of fluorine-free foams has been increasing, particularly in applications where PFAS-based foams can be very easily replaced (e.g. training). This trend is expected to continue in the future to some extent (even in the absence of any restriction on PFAS-based foams). Some stakeholders also noted that containment of fire-water run-off, particularly from training, has been increasing and that this has likely reduced emissions of PFAS significantly; In addition, there are significant existing stocks of PFAS containing foams which have been already purchased. These may need to be disposed of and replaced. The total quantum of these stocks is uncertain, but are estimated as follows: Annual sales of PFAS-based foams are estimated at between 14,000-20,000 tonnes per year; Current annual sales of fluorine-free foams are estimated at 7,000-9,000 tonnes per year. Historically, this demand would have been served by PFAS containing foams, hence the total annual sales of PFAS-based foams could have been some 21,000-29,000 tonnes; June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 138 Wood Environment & Infrastructure Solutions UK Limited The shelf life of PFAS-based foams is reported to be typically between 10 and 20 years (and up to a maximum of 30 years)103. Given that foams may be used before the end of their shelf life, the actual lifetime of foams could be shorter. BiPRO 2010 suggests that the average lifespan of fire-fighting foams is 15 years, which appears consistent with the above information104; and Given that between 14,000 and 29,000 tonnes of PFAS-based foam have historically been replaced per year, and assuming an average lifespan of foams of 15 years, indicates that the existing European stocks of PFAS-based foam may be between 210,000 and 435,000 tonnes105. These volumes of stock are used in the SEA calculations. Identification and definition of the assessed regulatory management options Two main restriction scenarios are considered in the following analysis: Scenario 1: Restriction (ban) on the placing on the market of PFAS-based FFF. The use of legacy foams, i.e. foams already in stock at producers' or users' sites, is still permitted. So, under this scenario, new sales would be prevented but existing stocks could be used and run down incrementally. Scenario 2: Restriction (ban) on the placing on the market and the use of PFAS-based FFF. In addition to a restriction on sale, legacy foams, i.e. foams already in stock at producers' or users' sites, should be disposed of safely. So, under this scenario, both new sales would be prevented, and existing stocks would need to be disposed of and replaced with new volumes of fluorine-free foams. For both scenarios, the socio-economic implications of different conditions of the restriction are discussed. This includes uses/sectors and the merits of possible exemptions, transition periods, application of specific Risk Management Measures (RMMs) for specific uses of fire-fighting foams, as well as permitted residual PFAS concentrations in foams. 103 Proposal for a restriction: Perfluorohexane sulfonic acid (PFHxS), its salts and PFHxS-related substances https://echa.europa.eu/documents/10162/a22da803-0749-81d8-bc6d-ef551fc24e19 104 BiPRO, 2010, Study on waste related issues of newly listed POPs and candidate POPs 105 A lifespan of 15 years means that each year, 1/15 of the stocks are replaced. So, if between 14,000 to 29,000 tonnes are replaced per year, then the stock is 15 times that tonnage. Multiplying annual replacement tonnages with 15 yields the above estimates. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 139 Wood Environment & Infrastructure Solutions UK Limited 8.2 Analysis of the impacts Overview The two figures below summarise the main effects (i.e. anticipated responses from the supply chains along with associated impacts) resulting from the two restriction scenarios. These are identified based on literature review, the targeted stakeholder consultation, and discussions with the steering group. The large text in the solid green boxes summarises each effect in a brief headline, the smaller hollow boxes provide some additional commentary. The numbered boxes at the end of each chain represent the ultimate impacts to be assessed. These ultimate impacts are discussed one by one in the following subsections. Figure 8.1 Map summarising potential effects of a restriction on the placing on the market of PFAS-based fire-fighting foams Restriction on placing on the market Cleaning of a equipment Costs and remaining contamination Use of alternatives As stocks are depleted b Other options e.g. eliminating the need for firefighting foams if possible Technical performance Implications of performance of alternatives, equipment changes Economic e feasibility Price differences, cost for new products Emissions Comparative emissions of PFAS and alternatives h Availability Supply /demand balance i Other impacts E.g. trade, employment c Fire safety Economic/HSE impacts of any reduced effectiveness d Use patterns To achieve comparable / acceptable performance Environmental / f health impacts Relative impacts: PFAS vs alternatives Remediation and g cleanup Relative costs: PFAS vs alternatives June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 140 Wood Environment & Infrastructure Solutions UK Limited Figure 8.2 Map summarising potential effects of a restriction on the use of PFAS-based fire-fighting foams Restriction on the use Disposal of legacy foams Including 'safe' treatment, e.g. incineration Cleaning of equipment (as discussed above) Use of alternatives (as discussed above) Environmental / j health impacts E.g. emissions from disposal Technical feasibility k / availability Capacity shortages of disposal facilities (e.g. incinerators) Economic feasibility l Cost of disposal June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 141 Wood Environment & Infrastructure Solutions UK Limited a. Cleaning of equipment: costs and remaining contamination A restriction on the placing on the market of PFAS-containing fire-fighting foams (Scenario 1) would allow users to continue using their stocks of foams, but once they are depleted, users would be forced to switch to alternative (fluorine-free) foams. A restriction on the use of PFAS-containing fire-fighting foams (Scenario 2) would require this switch to happen immediately when the restriction comes into force (or before). During the storage of PFAS-containing foams, fluorinated surfactants settle on the walls of the tanks as well as in pipe and hose lines of fire-fighting equipment. These would leach into any new foams filled into the equipment and therefore contaminate the new fluorine-free foams with PFAS, leading to continued PFAS emissions106. In order to control these emissions, equipment previously used for PFAS foams may be required to meet a minimum concentration limit of remaining PFAS, which can potentially be achieved through cleaning. This sub-section discusses the feasibility of achieving a certain (yet to be determined) concentration of PFAS through the cleaning of equipment, with a focus on the associated cost. The analysis of alternatives has concluded that currently available cases of transformation to fluorine-free foams do not indicate significant costs of decontamination of equipment (including disposal of the liquid used for cleaning), with relatively simple methods being applied. However, the costs of cleaning of equipment will depend on the contamination thresholds requirements. According to information from manufacturers, it may in some instances be less expensive to change part of the equipment than to clean it, especially for stationary equipment, so this is also discussed below. Techniques identified to clean PFAS-containing foam from equipment are: The use of hot water and detergents in a 32-stage legacy foam decontamination process (stakeholder consultation response). This technique is reported to result in all appliances achieving PFAS levels below 1000ppt and one-third of appliances being below 70ppt. An independent body oversees the process and measures the PFAS concentrations achieved. The approximate cost of this process is 12,300107 per appliance.; and For stainless steel tanks, glass fibre reinforced plastic and polyethylene tanks, following the discarding of the foam, tanks are rinsed with hot water (50-60C) and then filled again with hot water for at least 24 hours108. This process is repeated three times in both the tank and any foam carrying pipes and fittings, and the water from these rinsing operations passed into the sewage system and treatment plant. This is recommended in some government guidance109. No information could be identified concerning the costs of this technique or the remaining contamination levels achieved. Several stakeholders commented on the feasibility of cleaning techniques to remove PFAS-containing foams from equipment. One stakeholder considered achieving PFAS contamination levels below 100 ppb to be unrealistic in most cases (from the stakeholder workshop) and one stakeholder considered it to be almost impossible to achieve a contamination level of zero in a one-digit ppb framework with another stakeholder also commenting that the cleaning of systems and equipment is unlikely to bring the level of residual PFAS to zero. One stakeholder that has transitioned to fluorine-free foams (in the petrochemicals sector) reported that they had aimed for and achieved a level of 0.001% (10,000 ppb). To put this into context, the average 106 Bavarian Ministry of the Interior, Sport and Integration, and Bavarian Ministry of the Environment and Consumer Protection: Environmentally friendly use of fire-fighting foams. Available at: https://www.bestellen.bayern.de/application/eshop_app000000?SID=578672032&ACTIONxSESSxSHOWPIC(BILDxKEY:%27stmuv_all_000 01%27,BILDxCLASS:%27Artikel%27,BILDxTYPE:%27PDF%27) [In German] 107 Conversion rate of 1 EUR = 1.62470 AUD applied. It is assumed that this cost includes treatment of the waste water generated, although the stakeholder response did not specify that. 108https://www.bestellen.bayern.de/application/eshop_app000000?SID=578672032&ACTIONxSESSxSHOWPIC(BILDxKEY:%27stmuv_all_00 001%27,BILDxCLASS:%27Artikel%27,BILDxTYPE:%27PDF%27 [In German]. 109https://www.bestellen.bayern.de/application/eshop_app000007?SID=147496132&ACTIONxSESSxSHOWPIC(BILDxKEY:%27stmuv_all_00 001%27,BILDxCLASS:%27Artikel%27,BILDxTYPE:%27PDF%27) [In German] June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 142 Wood Environment & Infrastructure Solutions UK Limited concentration of PFAS in PFAS-based fire-fighting foams is some 2-3% (20-30 million ppb). One stakeholder commented that the level of cleanliness achieved by cleaning techniques would vary depending on the equipment and material being cleaned. The need to accommodate an allowance for residual legacy PFAS even after equipment has been cleaned was also discussed. Stakeholders also commented on how cleaning techniques and costs may be impacted by different PFAS contamination thresholds. Where contamination threshold levels are set high, following the cleaning of equipment, a higher level of residual PFAS-containing foam would be allowed to remain (compared to if a lower threshold limit were set). One stakeholder therefore considered the implementation of a high contamination threshold to be "pointless", due to its reduced effectiveness in eliminating PFAS emissions. With a low contamination threshold level, a lower level of residual PFAS-containing foam will be allowed to remain in equipment following cleaning and cleaning will be more costly than if a higher threshold level were set. Also, where contamination levels cannot be achieved through cleaning, equipment will need to be replaced at a cost. Equipment replacement is more likely to occur where threshold levels are set low. There are potentially significant costs associated requirements for cleaning or replacement of equipment, if a low threshold is set for residual PFAS concentrations (following use of the alternatives in the same equipment as PFAS-based products). The market analysis (see Section 4.3) estimated that there are likely to be several tens or potentially hundreds of thousands of facilities with equipment that contains fire-fighting foams. If all of these require extensive cleaning using techniques such as the decontamination process described above (and costing 12,300 per appliance), the costs of cleaning could be in the region of 1 billion (based on an assumed 100,000 appliances needing cleaning). If a less stringent threshold concentration is used, the costs would potentially be significantly lower. However, insufficient information is available to develop a more robust estimate of these costs. Regulation in Queensland, Australia, allows for threshold concentrations for replacement foam stocks to be 10ppm (mg/l) for PFOA/PFHxS and 50ppm (mg/l) for PFOA110. Additionally, one stakeholder commented that newer C6 foams are purer and have lower concentrations of impurities than older C6 foams and suggested that different threshold levels for different PFAS-containing foams may be required. For confirmation that threshold levels have been achieved, cleaning techniques may need to be professionally endorsed or, following cleaning, the presence and concentration of remaining PFAS tested. Stakeholder responses reported some concern over the suitability of existing methods to measure and detect the presence and concentration of remaining PFAS. One stakeholder reported that measuring very low concentrations e.g. at ppb-concentration was not possible. One stakeholder suggested that following cleaning, an assessment should be undertaken at an accredited laboratory for verification that threshold levels have been achieved. Stakeholder responses suggested that laboratories are able to analyse down to a level of 30-150 ppb. In the REACH restriction on PFOA, a concentration limit of 25 ppb of PFOA including its salts or 1,000 ppb of one or a combination of PFOA-related substances was adopted, based on the capabilities of analytical methods according to the RAC's opinion on the restriction dossier. Information on the cost of analysis was not provided. A cost analysis concerning the measurement of cleaning success could therefore be done as part of this analysis. Where threshold limits cannot be achieved through cleaning techniques or where cleaning techniques are too difficult or too costly to achieve, the replacement of equipment is likely to be required. The cost of replacing equipment will vary across industries and appliances. Table 8.1 provides an example of the potential costs for the replacement of fire extinguishers, where cleaning techniques do not succeed in attaining threshold concentration levels, or the cleaning process costs more than the cost of replacement. It is assumed that these costs represent only the replacement cost of the equipment and do not include the replacement cost of equipment plus foam, nor the cost of disposal of the old equipment. Figures for the total number of fire extinguishers existing and currently using PFAS-based foam have been obtained from the 110 Obtained from stakeholder consultation. Also available online here: https://www.qld.gov.au/environment/pollution/management/disasters/investigation-pfas/firefighting-foam/policy-overview June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 143 Wood Environment & Infrastructure Solutions UK Limited Market Analysis (the lower end of the range is based on a Eurofeu position paper and the higher end considered a more uncertain high-level estimate based on extrapolation from German data and expert judgement). The stakeholder consultation also revealed that the cost for a new extra foam tank in a fire truck is 35,000 for a fire brigade providing industrial fire protection. However, information of the number of existing foam tanks containing PFAS fire-fighting foam was not provided and therefore cost analysis for their replacement has not been estimated. Table 8.1 Estimated costs for the replacement of fire extinguishers in the whole of the EU 1 per replacement extinguisher 3 per replacement fire extinguisher 5 per replacement fire extinguisher 15 million fire extinguishers to be replaced 15 million 45 million 75 million 90 million fire extinguishers to be replaced 90 million 270 million 450 million Note that these costs do not include the cost of foam disposal from cleaning. Estimated costs of fire extinguishers were obtained from stakeholder consultation and it is not clear whether the costs of fire extinguisher replacement include the cost of alternative fire-fighting foam, as well as the equipment. Costs of fire extinguishers range from 1-5, and have been interpreted as low (1), medium (3) and high (5). All fire extinguishers are assumed to cost the same regardless of size and capacity. Overall, stakeholders considered the cleaning of equipment to be a costly operation, but little quantification of costs was provided in the consultation, making it difficult to undertake a cost analysis. Several users have already transitioned from using PFAS-containing firefighting foams to PFAS-free firefighting foams. Several consultees report there to be no significant costs associated with new equipment required. Although some stakeholders also report the replacement of fire-extinguishing systems and the cleaning of equipment to be costly. The cost of cleaning existing equipment will likely depend upon how effective cleaning techniques are for each appliance, as well as on the threshold contamination levels set. Where equipment cannot be sufficiently cleaned to meet threshold contamination levels (yet to be determined), replacement will be required. b. Other options and their impacts This section discusses what other responses to a restriction than using alternatives are likely (if any), and their socio-economic impact. Theoretically, in response to PFAS-based fire-fighting foams becoming unavailable, users could respond by eliminating the need for the use of fire-fighting foams. As discussed in the market analysis, the main application for PFAS-based fire-fighting foams are class B fires (flammable liquids and gases). Hence, to eliminate the need for fire-fighting foams would (in principle) require stopping the use of flammable liquids or gases, or accepting a situation where fires are less well controlled than at present. While this may be possible in a limited number of specific applications where they are not crucial, it seems unlikely in most cases. The consultation has also not specified any likely other responses than using alternatives. Therefore, no other options are considered. c. Fire safety: impacts of technical performance of alternatives Both scenarios 1 and 2 would lead to a transition to alternative foams. The transition associated with Scenario 2 would be faster as existing stock would need to be disposed of at the same time. The key socio-economic issue under both scenarios is the likelihood of fires being extinguished effectively and without delay, compared to the situation using PFAS based foams. The key issues in the technical feasibility of alternatives are three -fold. First, do the alternatives effectively put out fires so that life, environment and property are not at additional risk? Second, if so, are there delays in the duration over which the alternatives can address these fires, considering the technical ability to deliver greater volumes of foams to the fire? Third, do the alternatives have relevant and reliable safety standards so June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 144 Wood Environment & Infrastructure Solutions UK Limited that downstream users can purchase and use these alternatives with confidence, making allowance for testing in users' specific systems? This sub-section discusses the difference in the fire safety performance through the use of alternative firefighting foams. These effects are quantified where possible, and drawn out qualitatively where not. This section draws directly on the analysis of alternatives (AoA). As in previous sections, whilst the AoA started with a long-list of some 30 alterative foam products, it focussed on a subset of seven judged to be illustrative of the efficacy of these. The evidence below focusses on these specific products but refers to wider evidence were relevant. Table 8.2 provides a summary of the key information. Table 8.2 Effectiveness of alternatives - summary Alternative Respondol ARF 3-6% RE-healing foam RF3X6 ATC RE-healing foam RF1-1% Attained performance standards? Yes - 2 (EN 1568 Parts 3 and 4) Yes x 4 (EN 1568 Parts 1 and 2, and ICAO Levels B and C)) Yes - 1 (EN 1568 Part 3) Information from `real world' use None Identified Yes - Copenhagen Airport & Norwegian Offshore oil sector and Melbourne Fire Brigade. Yes - Norwegian Offshore oil sector. Moussol FF 3X6 (F15) Foam Mousse 3% F15 Epocol Premium Orchidex Blue Foam 3x3 Yes x 5 (DIN EN 1568: Part 3 (Heptane): IIIB/IIID, Part 1: Medium ex. Part 2: High ex. ICAO Low expansion foam - Level B DIN EN 3 21A). Yes (x1) (EN 1568 Part 3 heptane) Yes x 6 and 1 in progress. EN 1568 - 1: Conform EN 1568 - 2: Conform EN 1568 - 3: 1A / 1A EN 1568 - 4: 1A / 1A Oil industry: LASTFIRE Forest fire standards: CEREN Certificate Certification in progress : UL 162 / GESIP). Yes x 4 (EN 1568 Parts 3 and 4, Oil industry: LASTFIRE, ICAO Level B)) Yes -Swedavia, Heathrow Airport (UK), Norwegian Petrochemical sector. None identified (but consultation has confirmed this is in use) None identified (but consultation has confirmed this is in use) Yes - German airport are reported to be using the product. Additional stakeholder information Can be used for use in `all types of flammable liquid fires'. Has been in used in Municipal Fire Brigade applications - both in training and operational fires. Consultees state this alternative can be used at offshore oil installations and onshore terminals and refinery. Has been in use at Heathrow Airport (UK) since 2012. See case study. Consultees state this alternative is largely used in marine applications and is only used for smaller fires (unsuitable for aviation, for example). Manufacturer states this alternative can be used in all sectors: airports, marine, military, chemicals, oil and gas, municipal fire fighters and from fixed mobile and CAFs. Hydrocarbon fires, all types of flammable polar solvent liquids Consultees indicated this as a possible substitute for large tank fires, but further testing was necessary. Consultees indicated potential for additional volumes and/or time to suppress fires may occur for some fuel types, but for others, the performance is the same as for PFAS foams. Effectiveness of foams The central finding, based on evidence from the analysis of alternatives, the stakeholder consultation and the workshop is that from a technical standpoint, no stakeholder concluded that alternatives are not technically feasible, at least for the majority of uses. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 145 Wood Environment & Infrastructure Solutions UK Limited As noted in the AoA, in aviation several airports have successfully transitioned, as have Municipal Fire Brigades and companies active in offshore oil and gas operations and the marine sector. Evidence indicates that one segment - liquid fuel fires of large atmospheric storage tanks - is a concern for consultees. Large scale tests for fluorine free foams are ongoing and not yet complete, partly because the scale and cost of these tests. However PFAS-free foams have provided equivalent performance to C6 foams during hydrocarbon tank fires of 15, 60 and 80m diameter (during LASFIRE testing). Performance depends on application rate and equipment, but one stakeholder suggested that there is no real reason why these results cannot be extrapolated to bigger tanks (100m) or bund fires. More testing is required to prove performance of alternatives under some conditions. To date, no real-world examples of a successful transition in installations with large tanks are identified. Consultation has noted that, as such, AFFFs are still used when large fuel areas need to be extinguished quickly or in sprinkler systems. The available evidence suggests that elsewhere technically feasible fluorine free foams have been developed, are commercially available and have been used to the satisfaction of users. This transition has not occurred without some technical challenges (and cost) and has required testing in each users' system. Additional volumes of foam, compared to PFAS-based products, have been necessary, but not uniformly. Several users have identified - and overcome - technical issues. These related to temperature tolerance of alternatives and the viscosity of foams. Some changes to foam delivery systems, nozzles and some additional storage capacity has been required. Speed of fire suppression (making allowance for additional volumes required) Limited detailed information was obtained on this specific aspect. One respondent highlighted there could be a 5-10% gap in the extinguishing time, but that this "mainly" concerned polar liquids. Other consultees noted that equivalent volumes were required and these yielded equivalent performances, but this was not consistently reported. Others noted additional volumes of fluorine free foams, compared to PFAS based products in at least some applications. Some consultees highlight that this was a particular concern with small extinguishers. Whilst one respondent noted that, in general, fluorine free foams are less flexible for users, because they have less margin for error in the proportioning (i.e. volumes required), in their application type and of ease of use. However, other consultees provided feedback of use in specific applications (aviation), including an example of where a fluorine-free foam worked satisfactorily despite deliberate inappropriate application methods as part of testing procedures. Standards The analysis of alternatives (Section 7.5) provides a list of specific international compliance standards for the various commercially available products, with more details for each shortlisted product above. Appendix 5 provides more detail on each of these standards. Foams are developed to meet specific standard requirements and it is important to note that tests used for standardisation and certification of PFAS-based foams are not necessarily appropriate for fluorine-free foams. Stakeholders highlighted during the consultation workshop that current testing protocols have often been designed with PFAS-based foams in mind. These testing protocols may not be adequately tailored to reflect the fire-fighting ability of fluorine-free foams, because the same application methods may not always be applied and read-across between different burning fuels may not be straightforward. Therefore, it is inherently challenging to compare the two types purely based on certification. Some fluorine-free foams are however capable of meeting standard firefighting certifications applicable to PFAS-based foams and this has been demonstrated in cases where some airports and municipal fire brigades for example have successfully transitioned to fluorine-free foams. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 146 Wood Environment & Infrastructure Solutions UK Limited d. Use patterns of alternative fire-fighting foams to achieve comparable/acceptable performance This section discusses the impacts associated with the use patterns of alternative fire-fighting foams and includes discussion on: (a) the quantity of alternative foams needed to achieve either comparable performance or performance that is acceptable from the standpoint of safety to PFAS foams. (b) different specific application methods and equipment used. a) Quantity of foams needed to achieve comparable/best possible performance The available evidence does not permit a quantitative estimate for the comparative volumes of fluorine free foams required, for each application and with specific foams. However, the consultation allow a range to be specified. The same approach is used for the availability assessment below. It is important to note that the available quantitative information received - despite extensive attempts for specific information and for clarification - was very limited. Based on the available data, the range specified was between no change in volume and up to a maximum of 100% additional foam required, note the 100% volume estimate was specified by just one consultee and it is understood that this relates to use in one application. The available information is not sufficient to conclude these are isolated cases. As noted in the previous section, this does not apply to liquid fuel fires of large atmospheric storage tanks/large scale tank fires. Here, consultation indicates that large scale testing is still needed to confirm performance. The details on specific shortlisted products - which are known to be in use within the EU (based on stakeholder consultation) - are set out below. Table 8.3 Use patterns of alternatives - summary Alternative Respondol ARF 3-6% RE-healing foam RF3X6 ATC RE-healing foam RF1-1% Moussol FF 3X6 (F-15) FOAMMOUSSE 3% F-15 Epocol Premium Orchidex BlueFoam 3x3 Comparative volumes required vs PFAS containing foam No specific data has been supplied, despite attempts to obtain this via consultation. Variable depending on application ("drop in replacement, with no additional volumes required in offshore oil installations, onshore terminals and refinery). No difference to PFAS based foams (evidence available for some applications only). Volumes vary depending on application. From no difference to up to c. double the volume required in some applications. No information available. Range depending on application. Whilst stakeholder data is limited and relates to just one consultee, the potential ranges specified were between 30 - 50% greater volumes required. It is not clear whether the latter figure is only in exceptional circumstances. Consultation data unclear - potential need for up to 10% additional volumes. b) Specific application method for the foams or equipment used (if different for alternatives compared to PFAS-based foams) Several respondents report that for fluorine free foams used in sprinkler applications, special sprinkler nozzles have to be installed, which included "special low expansion nozzles". For extinguishers, consultees noted that greater expansion is required for PFAS free foams. Therefore, depending on the extinguisher, pressure may need to be increased and different nozzles required. Respondents also referred to challenges associated with temperature tolerance and viscosity of alternative foams. These appeared to have been satisfactorily resolved. Another noted that, as the chemical nature of the fuel varies, more than one agent may need to be stocked by users so that they may be able to deal with fires of different types on any one site. This was reported to be a reflection of a lower level of "flexibility" in Fluorine free foams. This has logistical, training and safety implications for users. The correct foam agents will June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 147 Wood Environment & Infrastructure Solutions UK Limited need to be stocked, in appropriate locations, with ease of access along with processes and training to ensure users cannot use incorrect foam agents, particularly in fast moving emergency situations. Again, further specific information was not available to enable conclusion as to whether this risk applies differently to specific user sectors. e. Impacts associated with the economic feasibility of alternatives This section discusses the economic feasibility of alternatives. There are several elements assessed. First annual foam costs - based on the additional volumes required by industry in any one year, this is evaluated based on the price differences between alternative and PFAS-based foams are evaluated, considering whether additional volumes of the alternative are required to fulfil the same/acceptable functionality. So this is in effect, the cost for one annual replacement "cycle" as foams are used and/or disposed of as they pass their useful life. The net change in foam costs is then estimated. This is relevant for both Scenarios. Second, in Scenario 2 users would no longer be able to use the foam stocks they have purchased. The costs for this stock will have to be written off and new stocks purchased. A range of other costs, associated with testing (and other R&D), storage, technical changes in foam dispensing and/or storage equipment and regulatory approvals are also summarised. The likelihood of whether additional costs would be passed down the supply chain is also considered. Lastly, costs may be partly offset by savings of using alternatives, e.g. from less costly waste management when they reach their expiry date. The assessment is associated with significant uncertainty and this is reflected in the wide ranges presented. There are uncertainties in several input assumptions, summarised in Table 8.4. Existing use of PFAS based foams is between 14,000 and 20,000 tonnes per year. The best estimate used in the analysis is some 18,000 tonnes per year; The average price of existing PFAS-based foam is subject to uncertainty, reflecting the wide range of specific foam compounds used. It is understood that certain compounds are currently available containing high proportions of PFAS and, whilst these are judged to be effective foams, the price for these compounds is well above average, the market assessment noted that these are uncommon. The weighted average used is 3,000 per tonne of PFAS containing foam, as set out in the market assessment. Note the lowest and highest values identified in the market assessment and stakeholder consultation were 2,000 per tonne and up to 30,000 per tonne. The latter figure has a significant effect on the ranges in the socio-economic assessment, but there is insufficient data to conclude the extent of the market currently pay this price per tonne for product; Based on these parameters, the current baseline foam costs are somewhere between 28 million per year and a maximum of up to 600 million per year. The best estimate is current costs of 54million per year (i.e. 3,000 multiplied by 18,000 tonnes); The same uncertainties apply to the average prices per tonne of fluorine free foams. The market assessment concludes, based on information provided via the stakeholder consultation, that fluorine free foams, on average, are likely to be the same price, i.e. around 3,000 per tonne of foam. This value is used in the central estimate. The ranges in the table below are the lowest and highest prices quoted in the consultation, respectively. This indicates that the most expensive fluorine free foam is likely be less expensive than the most expensive current foams. As noted above, this has a significant effect on the result and is subject to particular uncertainty; and Finally, consultees noted a range of different volumes may be required to fulfil the same/acceptable functions. The comparative volumes required differed, depending on the June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 148 Wood Environment & Infrastructure Solutions UK Limited specific application and customer need. Therefore, a range has been used, between a 0% increase and up to 100%more fluorine free product, over and above the volumes required for PFAS-based foams. Costs for one annual cycle of foam replacement (Total EU market) Table 8.4 summarises the assumptions used in the following to estimate annual foam replacement costs. Table 8.4 Annual foam costs - input assumptions Baseline PFAS foam market t/yr Central (L-H) Average price /tonne of foam Weighted average (LH) Current foam costs (PFAS) EU market cost per year Best estimate (L-H) Average price per tonne of foam (Fluorine free alternatives) Additional volumes required % increase over PFAS based foams) L-M-H 18,000 (14,000-20,000) 3,000 (2k-30k) 54m (28m - 600m) 3,000 (0.7k-10k) 0% - 50% - 100% Source: Market assessment, desktop research and stakeholder consultation exercise. Note, the maximum baseline used in the SEA is 21,000 tonnes, rather than the 20,000 in the market assessment due to rounding of volumes used at sector level. Using the assumptions above, Table 8.5 sets out the potential costs expected to be incurred by the EU market as a whole through purchasing volumes of fluorine free foam in an annual cycle. Overall, this suggests demand for alternative foams of between 14,000 tonnes per year and up to a maximum of 40,000 tonnes per year, for the sector as a whole. The associated costs are estimated at between 21 million and 30 million per year, with c. 27 million considered to be the most likely average cost for the EU market as a whole. Again, it is recognised that individual companies/users would incur greater or lower costs per tonne and require differing volumes. The wide ranges in different foam costs indicates whilst the average company may experience some increases in costs, others would experience savings, potentially quite large savings for some very specific market segments. Table 8.5 Scenarios, gross and net foam costs -annual cycle replacement costs for total EU market (m denotes millions) Costs for existing Tonnes of Potential foam costs PFAS based foams alternative required using alternative (EU Market) - best (EU Market) products (EU Market) estimate (Range) (L-M-H) Best estimate (Range) Best estimate 54m 18,000 - 27,000 - 81m (assuming 18,000t) (36m - 540m) 36,000 (13m to 360m) PFAS foam use p/yr) Assuming low PFAS 42m 14,000 -21,000 - 63m foam use (14,000 (28m - 480m 28,000 (10m - 280m) t/yr.) Assuming high PFAS 60m 20,000- 30,000 - 90m foam use (20,000 (40m - 600m) 40,000 (14m- 400m) t/yr.) Source: Market assessment, desktop research and stakeholder consultation exercise. Net change in foam costs (EU market) Best estimate (Range) 27m (-23m to -180m) 21m (-18m to -200 m) 30m (-26m to -200 m) It is important to note that the stakeholder consultation indicated many users had experienced no increase in foams costs and indeed no additional volumes required. The above has been undertaken to assess the potential scale in a best and worst case, using reasonable assumptions in the absence of complete data. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 149 Wood Environment & Infrastructure Solutions UK Limited Costs for stock write off and replacement (Total EU market) In addition to the annual replacement cycle, under Scenario 2 the entire stocks of PFAS foam would need to be disposed of and alternative volumes of foam would then need to be purchased. In the baseline, foam stocks would also have to be replaced once they are used or expired, so the restriction would bring the replacement costs forward. To reflect this, the value of the depreciation of stocks at the point of replacement due to the restriction is also considered. Assuming an even age distribution of stocks of PFAS-based foam and a linear depreciation of foams over their lifetime, the restriction would cut the life of the foams in half on average, and so half of their original purchase value would already have depreciated and should not be considered as a cost of the restriction. The restriction could also cause additional cost of purchasing alternatives instead of PFAS-based foam taking account of both the price differential and the potential difference in volumes required. As above there is significant uncertainty in the input assumptions and these are presented as a possible range of costs. Table 8.6 Quantitative data - economic costs Baseline Existing stocks of PFASbased foam: Average: 322,500 (Between 210,000 tonnes and 435,000 tonnes) Purchase costs (one-off total for whole stock): Average: 970 million (range 420 million to 13 billion) Value of stock depreciated: Average: 485 million (range 210 million to 650 million) (half of purchase cost, assuming even age distribution and linear depreciation) Restriction Scenario Volume of replacement with fluorine-free alternatives: Purchase costs (one-off total for whole stock) : Additional cost of the restriction: Average: 483,750 (Between 210,000 tonnes and 870,000 tonnes) Average: 1.5 billion (range 150 million to 9 billion) Average: 1.0 billion (range-60 million - 8.3 billion) (Purchase cost of replacement minus value of existing stock depreciated) Based on PFAS foam costs of 3,000 per tonne weighted average (with lowest costs of 2,000 and highest of up to 30,000 per tonne) and fluorine-free foam costs of 3,000 per tonne weighted average (with lowest costs of 700 and highest of up to 10,000 per tonne) The cost of the foam itself are only one aspect of the economic considerations of adopting alternatives. Additional transitional costs are described below. It has not been possible, despite attempts to obtain further quantitative information, to estimate costs for the market as a whole. However, several consultees noted that whilst additional costs were incurred, these were not significant and had proved manageable. Available quantitative information is summarised below. Further information is also presented in the case studies. Note that the cost of disposal of stocks of PFAS foam is covered in a later subsection (l. Costs of disposal of legacy foams). Table 8.7 Quantitative data - economic costs Testing costs Storage costs No quantitative data has been obtained via stakeholder consultation, despite several requests for such information. Testing would be associated with costs for sample volumes of Experience in the Norwegian petrochemical sector (Equinor) included additional costs related to purchasing additional volumes of foam, to replace the previous PFAS Costs from technical changes Consultation indicated that new nozzles had been required in several cases. Typical costs for a range of firefighting nozzles are within an approximate range Other costs including regulatory approvals Experience in the Norwegian petrochemical sector (Equinor) indicates costs (labour time) in the region of 360,000 for a range of support in their transition at June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 150 Wood Environment & Infrastructure Solutions UK Limited Testing costs Storage costs Costs from technical Other costs including changes regulatory approvals foam (likely several different containing foams, no of between 5 or less, per a total of 45 sites (so in the products) and with staff time information was provided on piece for simple foam nozzle order of c. 10,000 per site). and training. whether there were costs devices, to c. 30 and up to This would therefore appear implications related to the c.60 for marine firefighting to be an upper bound cost need for additional storage nozzles or "heavy duty for a company transitioning. space.. applicators" and up to c 200 for more specialist equipment [1] Mobile foam units are in the region of 2,700 [2] Notes [1]: Costs derived from search of widely available commercial products. See: https://www.made-in-china.com/products-search/hot- china-products/Water_Foam_Nozzle_Price.html See also https://www.orbitalfasteners.co.uk/products/heavy-duty-foam-dispenser-gun See also: https://www.dortechdirect.co.uk/heavy-duty-pu-applicator-gun-for-expanding- foam.html?gclid=EAIaIQobChMIudKHq9GP5gIVSbDtCh31AATEEAQYASABEgL5S_D_BwE See: https://www.safetyshop.com/lever- operated-nozzle-for-fire-hose.html?gclid=EAIaIQobChMI6cKnwNmP5gIVAuDtCh2KMwErEAQYAiABEgL91PD_BwE&gclsrc=aw.ds See: https://www.fireprotectiononline.co.uk/hv-series-low-expansion-foam-branch- pipes.html?gclid=EAIaIQobChMItqqg_NmP5gIViLbtCh0ImgYXEAQYByABEgIFdvD_BwE [2]: https://simplyextinguishers.co.uk/df130-mobile-foam-units.html?gclid=EAIaIQobChMIn4yv79yP5gIVgpOzCh1- PQghEAkYBiABEgKsIfD_BwE Testing costs Whilst there are several categories of foam designed to address fires from specific fuels, consultation stressed that there are many more different types of overall fire systems, each with slightly different requirements. There is evidence that several downstream users are currently testing fluorine free firefighting foams, and that several others have now successfully transitioned. All stressed the importance of testing the foam compounds. This imposes costs in purchasing (possibly several different types of product), along with storage, training of personnel, performance monitoring and evaluation, disposal and clean-up. Consultees also noted costs from periodic testing of the fluorine-free products once in storage, to ensure that performance is not degraded; this was in the context of some initial uncertainty over shelf life for some products, which now appears to have been addressed. Whilst these costs were acknowledged, the evidence indicates they are one-off, comparatively small and were absorbed by the downstream users. Storage costs (including storage during transition) Whilst technical performance of alternatives was concluded to acceptable in most cases, some noted a "higher sensitivity" of fluorine free foam, compared to PFAS based foam; i.e. they allow for less flexibility in use, requiring multiple types of foam to be stocked. The is associated with costs in purchasing foam, of storage capacity - particularly during a transition when both PFAS based and fluorine-free may have to be stored - as well as some training costs. Where evidence has been provided in the stakeholder consultation, it was noted that these costs were manageable and could be mitigated via phased transition. It was acknowledged these costs are generally greater for fixed than for mobile applications, and where larger volume are used and stored. Costs from technical changes No consultees indicated that a transition from PFAS-based foams to fluorine-free required investment in entirely new foam delivery systems. However, problems have been encountered in specific components: such as proportioner pumps, jets and nozzles for discharge, including the need for replacement nozzles; including low expansion nozzles. These challenges appear to have been caused by differences in foam viscosity. Typical costs for a range of firefighting nozzles are within an approximate range of between 5 or less per piece for simple foam nozzle devices, to c. 30 and up to c. 60 for marine firefighting nozzles or "heavy duty June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 151 Wood Environment & Infrastructure Solutions UK Limited applicators" and up to c 200 for more specialist equipment111. Mobile foam units are in the region of 2,700.112 Other costs These include regulatory approvals and those associated with bringing new products to market. Given that the market assessment noted at least some current use of fluorine free products in all sectors, further adopting fluorine-free foams would appear to be a continuity of an existing transition - so a lot of the initial costs associated with new products development will have already been incurred. Experience in the Norwegian petrochemical sector (Equinor) indicates costs (labour time) in the region of 360,000 for a range of support in their transition at a total of 45 sites (so in the order of c. 10,000 per site). Savings from adoption of fluorine free foam Many stakeholders acknowledged potential for savings from use of fluorine-free foams. The potential savings resulting from a reduction of firewater that requires disposal and hence the costs of disposal as well as from avoided long term liability for site contamination/ remediation and clean-up costs are discussed further in subsection "g. Remediation and clean-up". However, fire-fighting foams may also need to be disposed of when not used at the time of their expiry date. As discussed in more detail in Section "j. Emissions from disposal", incineration is considered the most appropriate disposal option for PFAS-based foams. The disposal method for fluorine-free foam would depend on the hazards of the specific foam. However, in general they are expected to exhibit lower hazards and higher biodegradability, so it is likely that they require less costly disposal methods, such as waste water treatment. While no specific data was available to estimate the disposal cost of fluorine-free foams, the costs of incinerating PFAS-based foams is expected to be typically around 1 per litre (range 0.3 to 11, see Section "l. Costs of disposal" for more detail). As discussed in the emission assessment in Task 3 (Section 5), a number of references suggest usage rates of around 15-20% of existing stocks per annum, with an AFFF shelf-life of up to 15 years, which would suggest all foam concentrate is used before expiration, while other sources suggest that significant quantities of expired foam concentrate is indeed destroyed. If the usage rate of 15-20% per annum of existing stocks is an average across all sectors of use, there will be some installations with potentially far lower usage rates annually that will likely have some foams that reach expiry before use. In the absence of specific data, below the potential costs are shown for 1%, 5% and 20% of annual foam purchases replacing foams that have reached their expiry date113. Note that these figures are hypothetical and are shown to illustrate the potential order of magnitude only: 111 Costs derived from search of widely available commercial products. See: https://www.made-in-china.com/products-search/hot-chinaproducts/Water_Foam_Nozzle_Price.html See also https://www.orbitalfasteners.co.uk/products/heavy-duty-foam-dispenser-gun See also: https://www.dortechdirect.co.uk/heavy-duty-pu-applicator-gun-for-expandingfoam.html?gclid=EAIaIQobChMIudKHq9GP5gIVSbDtCh31AATEEAQYASABEgL5S_D_BwE See: https://www.safetyshop.com/leveroperated-nozzle-for-fire-hose.html?gclid=EAIaIQobChMI6cKnwNmP5gIVAuDtCh2KMwErEAQYAiABEgL91PD_BwE&gclsrc=aw.ds See: https://www.fireprotectiononline.co.uk/hv-series-low-expansion-foam-branchpipes.html?gclid=EAIaIQobChMItqqg_NmP5gIViLbtCh0ImgYXEAQYByABEgIFdvD_BwE 112 https://simplyextinguishers.co.uk/df130-mobile-foam-units.html?gclid=EAIaIQobChMIn4yv79yP5gIVgpOzCh1PQghEAkYBiABEgKsIfD_BwE 113 It is also assumed that all PFAS-based foams are incinerated, although it should be noted that not all PFAS-based foams are currently incinerated when they reach their expiry date (e.g. some of them are used for training), so this is likely an overestimate. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 152 Wood Environment & Infrastructure Solutions UK Limited Total foam purchased per year (tonnes) % of annually purchased foam replacing foams not used (hypothetical) Foam to be disposed of per year (tonnes) Cost of disposal: 0.3/l (low) Cost of disposal: 1.0/l (best estimate) Cost of disposal: 11/l (high) 14,000 (low) 1% (low) 140 42,000 140,000 1,540,000 18,000 (average) 5% (central) 900 270,000 900,000 9,900,000 20,000 (high) 20% (high) 4,000 1,200,000 4,000,000 44,000,000 Sources: Foam tonnage per year based on Eurofeu data (see Section 4.3), disposal costs per litre based on Section 8.2 "l. Costs of disposal". Based on the total foam purchased per year, foam disposal costs per litre and hypothetical shares of foams not used per year, it is estimated that the annual costs of PFAS-based foam disposal could be between some 40,000 and some 40 million, but more likely (as a central estimate) in the order of million Euros. Other potential benefits noted by consultees include emerging concerns over corporate reputation from continued use of PFAS foams and savings from avoided cross contamination of other waste streams, from monitoring, environmental permitting requirements, controls and personal protective equipment. Despite additional stakeholder consultation, and some specific examples of savings, it has not been possible to provide an overall estimate of these savings for the market or average firm. The savings were however noted as "significant" by several consultees. f. Environmental/health impacts of alternatives This section discusses the environmental and health impacts of alternatives to PFAS foams, in comparison with PFAS-based foams. A quantitative comparison of emissions and the associated risk under each scenario was not possible with the available data. The assessment focusses on the overall assessment of risk set out in Section 5 alongside an evaluation of the hazards and risks of most likely alternatives. The evaluation in task 3 concluded, based on analysis of PNECs and data on biodegradation and bioaccumulation, that the two fluorinated substances (used as examples) are of higher environmental concern compared to the non-fluorinated substances when it comes to hazard for the environment. This reflects the former's non-biodegradable nature, along with the relatively low PNECs for water and soil. Some of the alternative substances also exhibit low PNECs, but are readily biodegradable. The assessment in task 3 notes that further work would be needed to assess the risks associated with specific sites or food production pathways. Table 8.8 provides an overview of the hazards of the shortlisted alternatives based on information from the foam Safety Data Sheets (SDS). None of the components included in the Safety Data Sheets are classified with CMR properties. In terms of PBT/vPvB properties, whilst none of the alternatives include substances demonstrated to be PBT or vBvP substances, for two products insufficient data are available and tests had not been concluded for a third. The hazard posed by PFAS foams compared to the constituents of the alternative fluorine-free foams are considered further in Section 5. However, a review of potential hazards based on PNECs, biodegradation and bioaccumulation shows that fluorinated substances (in PFAS-based foams) are of higher priority compared to the non-fluorinated substances (in fluorine-free alternatives) when it comes to hazard to environment. This is due to the fact that some PFAS are not readily biodegradable, are mobile and have relatively low PNECs for water and soil. Some of the substances used in the alternative products do however exhibit low PNECs, but this needs to be considered in the context of biodegradation and so far data is not available to examine these in detail. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 153 Wood Environment & Infrastructure Solutions UK Limited Table 8.8 Overview of key hazards of alternatives based on information from SDS CMR Properties Respondol ATF 3- No 6% Re-Healing Foam No RF3x6 ATC Re-Healing Foam No RF1 1% Moussol FF 3x6 (F- No 15) FOAMOUSSE 3% No F-15 Ecopol Premium No Orchidex BlueFoam No 3x3 PBT or vBvP Criteria? No Uncertain (insufficient data on SDS) Uncertain (insufficient data on SDS) No No No Not tested Other HH concerns indicated in SDS Other Env concerns indicated in SDS Skin and serious eye irritation (H315, H319) None Serious eye irritation (H319) None Skin irritation and eye damage (H315, H318) Aquatic Acute 1 (H400) Serious eye irritation (H319); damage to kidneys if swallowed (H373) Can harm aquatic fauna, can harm bacteria population in WWT plants Harmful if swallowed (H302), skin irritation and serious eye irritation (H315, H319) None Serious eye damage (H318) None Harmful if swallowed (H302) and serious eye irritation (H319) Harmful to aquatic life with long lasting effects (H412). g. Remediation and clean-up This section discusses the economic implications in terms of reduced requirements for remediation potentially resulting from a restriction on PFAS-based fire-fighting foams under Scenario 1 or 2. Both scenarios will require a transition to alternatives. This means that in both Scenarios, emissions of PFAS related to fire-fighting foam use will cease. In Scenario 2 they will cease immediately upon the restriction taking effect, while under Scenario 1 further use, emissions and site-contamination could presumably take place. Emissions of the substances used in the alternatives would likely increase proportionately, assuming no additional containment measures compared to the current use of PFAS-based foams. Remediation Task 4 of the DG ENV study (`Remediation costs and technologies', see Section 0) has assessed the typical costs of remediation of PFAS contamination resulting from the use of fire-fighting foams. The results are summarised in the table below. This shows that the typical costs per site can range from around half a million Euros (only soil remediation required, lower estimate) to just over 100 million (sum of soil excavation and incineration, groundwater pump and treat and drinking water reverse osmosis, higher estimates).114 114 Please note the caveats highlighted in Section 0. Notably, remediation costs are highly site-specific and in certain cases can exceed the ranges provided. The estimates should therefore be considered order-of-magnitude cost ranges. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 154 Wood Environment & Infrastructure Solutions UK Limited Table 8.9 Typical cost per site of remediation of PFAS contamination resulting from the use of fire-fighting foams Compartment Technique Cost Soil Excavation and off-site disposal 0.5 - 18 million Excavation and incineration 2.5 - 38 million Capping 0.42 - 4.3 million Groundwater Pump and treat 1.2 - 30.3 million Drinking water Reverse osmosis Source: Wood 2019, see Section 0 for more details. 2.9 - 39.8 million Task 3 of the DG ENV study (`assessment of emissions and hazard of fluorine-free foams', Section 5) has shown that the substances contained in fluorine-free alternatives exhibit lower concern than PFAS used in fire-fighting foams, due to their lower hazards and more rapid biodegradation. On this basis, Task 4 of the DG ENV study has concluded that it is currently not predicted as likely that remediation will be required as a result of the use of fluorine-free alternatives. Therefore, no remediation costs are expected to be incurred from the use of fluorine-free alternatives, implying potential savings from substitution of PFAS-based foams. It is important to note that the costs refer to the remediation of legacy contamination that occurred from historical fire-fighting and/or training activities. In particular, training activities, which account for the majority of fire-fighting foam use, either already avoid the use of PFAS-containing foams and/or are conducted at contained training facilities, according to current best practice. However, the consultation did not yield information on the extent to which best practice measures are being implemented, or their effectiveness. Task 3 of the DG ENV study has estimated that the current levels of emissions from training are likely relatively low; however historical emissions are understood to have been much higher. Fire-fighting activities typically require more immediate clean-up (discussed further in the next paragraph) rather than long-term PFAS remediation. On this basis, it seems unlikely that the current use of PFAScontaining fire-fighting foams would lead to the same remediation costs as presented for legacy contamination above. In conclusion, the restriction scenarios could eliminate the potential risk of PFAS contamination which could cause costs of up to around 100 million per site. There are large uncertainties in the numbers of sites that may require remediation and remediation costs are very case-specific and would differ significantly across these sites, so the following estimate of total remediation costs caused by the use of PFAS-based fire-fighting foams is indicative only: The market analysis (see Section 4.3) estimated that there are likely to be several tens or potentially hundreds of thousands of sites that use or at least possess fire-fighting foams; If all of these would require remediation (costing some 10s of million per site), the costs of cleaning could be at most in the region of trillions of Euros (based on an assumed 100,000 sites needing remediation); However, in reality only a much smaller number of these sites would use PFAS-based foams in sufficient quantities and without adequate containment and immediate clean-up to require large scale remediation. More information on the total number of sites, real-world use of PFAS per site as well as implementation and effectiveness of best practices in terms of containment and immediate clean-up would be required to assess to which extent remediation is likely to be required in the future as a result of current use of PFAS-based fire-fighting foams; and Therefore, realistically avoided remediation costs are more likely in the order of magnitude of hundreds of millions of Euros (assuming tens of sites requiring remediation at tens of millions June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 155 Wood Environment & Infrastructure Solutions UK Limited of Euros per site) to billions of Euros (assuming hundreds of sites requiring remediation at tens of millions of Euros per site). Clean-up In addition to remediation which is driven by long-term accumulated contamination from historical releases, releases to the environment in the short-term require "clean-up" (as defined by Task 4 of the DG ENV study, see Section 0). According to the stakeholder consultation, there is local or national-level regulation governing the containment or prevention of release of fire-fighting foam or firewater runoff to the environment115. One exception that has been identified is fire-fighting activities in close vicinity to open water bodies (sea, lake), where it is very difficult to recover fire-fighting water runoff discharged into the sea or lake. In the case of the lake, this could lead to remediation being required. This would relate to very specific sites in specific locations, so it would not be appropriate to estimate `typical' remediation or clean-up costs. In the case of the sea (particularly relevant for marine and offshore applications), remediation or clean-up would likely not be feasible, which raises particular concerns over the environmental impact of using PFAS-based fire-fighting foams in these applications. In all other applications, it is assumed that in most cases, the majority of firewater run-off is contained and sent for treatment. Treatment costs for run-off can vary depending on the fire-fighting foam used: Several stakeholders that have transitioned to fluorine-free foam reported that when fluorinefree foam was used, run-off was sent to water treatment, either though the normal sewer system to the municipal WWTPs; directly to on-site waste water treatment; to other biological/chemical/mechanical treatment plants; or even drained directly to sea. One stakeholder reported that all PFAS-containing run off must be treated as a regulated waste which they do using high-temperature incineration; Stakeholders did not provide information on the cost of waste water treatment. These can vary significantly, depending on the contamination of the run-off from the flammable liquid itself, the soot and other contaminants from the fire site. For instance, UNECE 2017116 reports a cost of 1 million for disposal of 2,000 m of firewater contaminated with chemicals in a sewage treatment plant and several chemicals waste disposal facilities, resulting from a fire in a factory in Germany in 2005. This is equivalent to 0.5 per litre, or 0.64 per litre in 2019 prices117. Typical costs for regular municipal waste water treatment are much lower, for instance reported in the range of 0.0002 to 0.0005 per litre by Pajares et al. 2019118 for various municipalities in Southern Europe. Hence, treatment costs for run-off for fluorine-free foam are likely between 0.0002 per litre and around 0.64 per litre. 0.3 per litre is assumed as an average for the purpose of the approximate estimation below; Assuming that PFAS-containing run-off has to be incinerated, and assuming similar incineration costs as reported for the disposal of fire-fighting foams (see Section "l. Costs of disposal"), the costs for treatment of PFAS-containing fire-water run-off could be around 1 per litre (range 115 This was confirmed by stakeholders at least for England/Wales (The Environmental Permitting (England and Wales) Regulations 2010 (EPR 2010)), Sweden (local authority requirements for applications for new operation licenses), France (no details provided), Netherlands (no details provided), Germany ("Lschwasser-Rckhalte-Richtlinie" and the more detailed Bavarian "Guideline foam" which is legally binding in Bavaria and but also applied elsewhere). 116 https://www.unece.org/fileadmin/DAM/env/documents/2017/TEIA/JEG_MTGS/UNECE_Safety_Guidelines_and_Good_Pract ices_for_Fire-water_Retention_14_Nov_2017_clean.pdf 117 2005 value converted to 2019 prices using Eurostat: HICP (2015 = 100) - annual data (average index and rate of change) (prc_hicp_aind). 118 Moral Pajares, E., Gallego Valero, L., & Romn Snchez, I. M. (2019). Cost of urban wastewater treatment and ecotaxes: Evidence from municipalities in southern Europe. Water, 11(3), 423. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 156 Wood Environment & Infrastructure Solutions UK Limited 0.3 to 11 per litre). Hence, treatment costs for run-off of fluorine-free foams could be around 0.7 per litre (range ca 0-11) lower compared to PFAS-based foams.119; and Data on the total amount of fire-water run-off containing fire-fighting foam per year in the EU was not available, but for illustration an example of costs per incident can be calculated. UNECE 2017120 reports five major fire-incidents in which volumes of fire-water used ranged between 2,200 and 38,000 m3. For incidents of this size, the difference in run-off treatment cost would be around 1.5-27 million (range 0-418 million) per incident.121. In cases where fire-water run-off is not contained and further clean-up is possible (i.e. run-off was not discharged to sea), there may be savings from using fluorine-free foams in terms of reduced clean-up costs: When PFAS-based foam is used and contamination of the soil and water occurs then extremely persistent chemicals are involved, which is not necessarily the case with fluorine-free foams. Stakeholders suggested in the consultation that clean-up and complex treatment is not always necessary after the use of fluorine-free foams. This could lead to potential cost savings in some cases; However, Section 0 determined that clean-up is driven to a large degree by the flammable liquid itself, the soot, water and "dirt" in general terms that contribute to the fire-fighting water runoff, rather than the fire-fighting foams. Therefore, a significant difference in clean-up costs between the different types of foam used is difficult to estimate, because the incremental costs of addressing PFAS contamination is difficult to separate from the wider clean-up costs; and Clean-up costs are generally expected to be lower than remediation costs. Based on the estimates of remediation cost per site presented above, as a worst case scenario, clean-up costs can be expected to be a few hundred thousand to a few million Euros per incident. In the absence of more specific data, for illustration of the potential order of magnitude of savings: Assuming several tens of incidents per year using PFAS-based foams where clean-up is required and could be avoided if fluorine-free foams were used, the savings would be in the order of several millions to several tens of millions of Euros. h. Availability of alternatives. This section discusses the supply-demand balance associated with a restriction on PFAS firefighting foams under Scenario 1 and 2. Both scenarios will require a transition to alternatives - the difference is the speed at which this will be necessary. Scenario 1 will result in a slower increase in demand as stocks are used in training and or incidents (or reach the end of their useful life) and are then replaced with new alternatives. 119 Calculated as: Central estimate: 1/l cost of incineration of PFAS-based foams minus 0.3/l cost of waste water treatment for fluorine-free alternatives = 0.7/l cost saving; Low estimate: Waste water treatment could in some cases be more expensive (up to 0.64/l) than incineration (from 0.3/l). In these cases it is assumed that the less expensive option would be chosen and there would not be a saving of using fluorine-free foams compared to PFAS-based foams; and High estimate: The maximum possible difference is in case of the upper end of the range of incineration costs for PFAS-based foams (11/l) minus the lower end of the range of waste water treatment costs for fluorine-free alternatives (0.0002/l) 11/l cost saving. 120 https://www.unece.org/fileadmin/DAM/env/documents/2017/TEIA/JEG_MTGS/UNECE_Safety_Guidelines_and_Good_Pract ices_for_Fire-water_Retention_14_Nov_2017_clean.pdf 121 Calculated as: 2,200 m3 volume of fire-water run-off * 0.7/l treatment cost difference= 1.54 million.38,000 m3 volume of fire-water run-off * 0.7/l treatment cost difference= 26.6 million. These figures are rounded to two significant figures. For the wider range, instead of 0.7l treatment cost difference, 0/l (lower) and 11/l (higher) have been applied. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 157 Wood Environment & Infrastructure Solutions UK Limited Scenario 2 will result a more sudden increase in demand as the whole market disposes of and replaces their existing stocks - potentially over a short timescale - and then require replacement stock, each year. In addition, and over and above the replacement demand, it can be assumed both scenarios will result in an increased short-term demand for testing; again the increase in demand would be greater in scenario 2 given the accelerated transition. The economic and logistical challenges of managing the transition - avoiding contamination in storage tanks and the requirements for disposal, for example - are discussed elsewhere in the SEA. Information on the specific shortlisted substances in the analysis of alternatives is summarised below - quantitative information is limited. These substances are however, illustrative and a subset of a larger range of alternative foams that are commercially available and currently in use. Table 8.10 Availability of alternatives - summary Alternative Respondol ARF 3-6% Produced in the EU Unknown Currently commercially available Yes RE-healing foam RF3X6 Yes Yes ATC RE-healing foam RF1-1% Yes Yes Moussol FF 3X6 (F-15) Yes Yes FoamMousse 3% F-15 Yes Yes Epocol Premium Yes Yes Orchidex BlueFoam (3x3) Yes Yes Source: Market assessment, desktop research and stakeholder consultation exercise. Information on production volumes Not available. Stakeholders have indicated that they would not have a problem meeting increased demand in general terms. As above. As above. As above. As above. 700 tonnes (production and import), 500 sold in EU. Stakeholder (not manufacturer estimates at c.800 t/yr) Stakeholder consultation has provided limited information on production and use volumes of specific foams but the market assessment indicated current supply is in the region of 7,000 to 9,000 tonnes. Anecdotal information from stakeholder consultation notes that "adequate" supply exists and no consultees noted that they had experienced supply constraints in any application. Further discussions with three suppliers indicated current excess production capacity alongside additional capacity for emergencies (not quantified). The consultees noted no constraints with raw material supply. Production and sales data on one shortlisted product, Epocol, was provided as noted above in Table 8.10. This data indicated total production and import capacity of 700tonnes, with sales of 500tonnes. Quantitative information was provided on a small number of other specific products. These are not listed above but were stated by consultees as appropriate for use in several applications, including municipal firefighting, storage facilities and marine applications. For these, total volumes produced and imported into the EU totalled a further 550 tonnes, with sales of 380 tonnes. Qualitative information on the availability alternatives was provided via stakeholder consultation on a wider range of products. A total of 22 were stated as being produced in the EU and all of these were commercially available (either in the EU, globally or both). Note that the substance identification and market assessment identified a larger number of products - in the order of 160 - but more detailed information on only a subset of these was obtained via the consultation and the assessment has focused on products for which stakeholders have indicated actual use is taking place. Using data from the market assessment, Table 8.11 provides a quantitative summary of available information. First, the table provides a summary of existing EU demand for PFAS based firefighting foams. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 158 Wood Environment & Infrastructure Solutions UK Limited This has been split by application, based on Eurofeu survey information. Overall, this indicates current PFAS based foam demand in in the region of 18,000 tonnes per year122, with the largest use in the chemical and petrochemical sector. The second, central, column provides an overview of the volumes of alternative foams that may be expected after a restriction is imposed. This takes into account that additional volumes may be required in some applications. As in the economic feasibility section above, the analysis has been undertaken assuming no change in the volumes required (central estimate), and a 50% and up to 100% increase, respectively in the volume of foam required in all applications. It is not considered likely that this increase will be required uniformly across all applications; indeed the stakeholder consultation indicated that many users experienced no overall increase in the volumes required. Finally, the existing demand - again based on Eurofeu survey data - Is presented on current fluorine-free foam supply in the EU. The disaggregation of demand by sector is based on the proportions specified in the Eurofeu survey. For both PFAS-based and fluorine-free foams, sector specific volumes are subject to greater uncertainty than the overall totals. Table 8.11 "Top down" assessment - annual demand and supply of PFAS and Fluorine free FFF Sector of use Current PFAS foam volumes (t/yr) Central (L-H range (000's)) Existing F- free volumes (t/yr) Chemical/Petrochemical 11,000 (8-12) 2,000 - 2,600 Municipal Fire Brigades 2,000 (2-3) 3,100-4,000 Marine Applications 2,000 (2-2) 1,100-1,400 Airports 2,000 (1-2) 500-600 Military 2,000 (1-2) 100-200 Ready for use products <500 c.100 Total 18,000 7,000 - 9,000 (14 - 20) Source: Market assessment, desktop research and stakeholder consultation exercise. Expected future additional demand for F-Free foams Central (L-H range 000's) 11,000 (8-24) 2,000 (2-6) 2,000 (2-4) 2,000 (1-4) 2,000 (1-4) <500 18,000 (14 - 40) The above information indicates that, for all uses, the volumes of fluorine free alternatives would need to increase to meet the replacement demand as users switch from PFAS containing foams under a restriction. Overall, the increase is likely to be in the order of 18,000 tonnes (i.e. sales of 18,000 tonnes of PFAS foam ceases, to be replaced by 18,000 of fluorine free foams), but potentially up to 40,000 tonnes, per year. Stakeholders indicated that spare foam production capacity exists and that users had not experienced a shortfall in supply. However, Scenario 2 may result in a more sudden and potentially significantly larger demand for fluorine free foams, as existing stocks would need to be disposed of and replaced. As noted above, this could be in the region of between 210,000 tonnes and up to a theoretical maximum of 870,000 tonnes of foam. This heightens the risk of a shortfall in supply, - depending on the timescales of any restriction. Overall, the available evidence clearly indicates a range of alternative foams are currently available on a commercial basis. Moreover, data obtained from stakeholder consultation suggests that in purely 122 Note that the sum of the sectors is not equal to the total due to rounding. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 159 Wood Environment & Infrastructure Solutions UK Limited quantitative terms existing production capacities can accommodate some increase in demand. For Scenario 1, it has not been possible, despite further consultation attempts, to obtain quantitative information on the supply of specific products used in all applications, so whilst it is possible, that a shortfall may arise for a specific market segment, the available evidence does not suggest this would be likely. For Scenario 2 a much greater quantity of alternatives would be needed to replace existing stocks, with the potential for a shortfall in supply. As the largest single use, and with comparatively low current fluorine free sales volumes, the risks of supply constraints may be greater in the chemicals and petrochemical sectors (because this is the sector with greatest use) and in Scenario 2 (because this would require greater volumes to be replaced in the short term). It follows that appropriate transition periods would further ease this risk. Whilst there would be costs associated with increasing supply, the market assessment and economic feasibility sections noted above indicated that, on average, the costs for fluorine free foam, on a unit basis, are comparable to or less than those for PFAS based foams. It appears reasonable that manufacturers could continue to increase supply without significant costs having to be passed to downstream users. The range of suppliers and the number of fluorine free products that currently exist on the market would also serve to limit scope for significant price increases. i. Other impacts Other impacts briefly considered in this section include the potential for impacts on international trade and employment and economic competitiveness. Under Scenario 1, PFAS-containing foams in stock will still be able to be used and therefore the demand for replacement with alternatives will be more gradual. It is therefore unlikely that there will be any substantial impacts on competitiveness, trade and employment. Under Scenario 2, there will be a more sudden and larger increase in EU demand for PFAS-free alternative fire-fighting foams and decrease in demand for PFAS-containing fire-fighting foams (again depending on transition period). Imports of PFAS-containing fire-fighting foams into the EU will therefore decrease and manufacturers (both global and EU) of PFAS-containing foams will see a decrease in EU demand. Whilst effects would be mitigated by the fact that at least some manufactures in the EU are involved in both PFAS and fluorine free foam manufacturing, a potential shortfall in supply - driven by a one off need for stock replacement - may impact imports of fluorine free foam from outside the EU. , Regarding employment, there is no information available on the number of people employed in manufacturing of PFAS-containing fire-fighting foam or manufacturing fluorine-free fire-fighting foam. Overall effects would be neutral or positive, depending on the net effect on volume, Overall, there are unlikely to be any significant macroeconomic impacts from the result of Scenario 1, but with some - albeit temporary risk of increase EU imports under Scenario 2. j. Emissions from disposal of legacy foams During the process of disposing of PFAS-containing legacy foams, emissions occur from several sources. In Scenario 1, it is expected that a low quantity of legacy foam will be required for disposal. This low quantity will relate to `transitional wastage' which occurs when a user has some remaining PFAS-containing firefighting foam in existing equipment, yet their stock of PFAS-containing firefighting foam has depleted to zero. PFAS-containing and PFAS-free fire-fighting foam cannot be combined in the same system. The low level of PFAS-containing foam left in the container will need to be disposed of. The quantity of foam required for disposal under Scenario 1 cannot be accurately quantified as `transitional wastage' will likely vary across industries and appliances. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 160 Wood Environment & Infrastructure Solutions UK Limited In Scenario 2, all existing stocks of PFAS-containing foam will need to be disposed of. This section first discusses the disposal options and identifies the potential emissions associated with these disposal options. The quantity of emissions is then estimated and the impact of these emissions on health and the environment are discussed. Emissions considered relate to both the potential for remaining PFAS compounds as well as the by-products created from disposal. The analysis focusses on the disposal of unused PFAScontaining foams, rather than the disposal of used PFAS-containing foams. Little data and information was obtained from stakeholder consultation, therefore much of this section is based on desktop research. High-temperature incineration would appear the most likely disposal option for PFAScontaining legacy foams123; Existing incineration disposal methods used apply a range of temperatures from around 400-6000C124. The literature also indicates that CF4 requires temperatures above 1,400C to decompose and that CF4 is the most difficult fluorinated organic compound to decompose125; The effectiveness of PFAS compounds to be destroyed by incineration and "the tendency for formation of fluorinated or mixed halogenated organic by-products is not well understood"126; The incomplete destruction of PFAS compounds may result in smaller PFAS or products of incomplete combustion being formed127. These products may not yet have been researched and therefore have the potential to be chemicals of concern128; The complete combustion of PFOS/PFAS will result in CO2, H2O and HF129 and the incineration of PFAS at temperatures of at least 1,100C, usually degrade PFAS to carbon dioxide and hydrogen fluoride130. It has not yet been determined what is produced when PFAS is incinerated at temperatures lower than 1,100C131; Emissions (greenhouse gases and air pollutants) from creating high temperatures for incineration: There are emissions associated with the procurement and delivery of fuel and with incinerator operation (e.g. greenhouse gases and air pollutants such as particulate matter from the combustion of fuels). Associated emissions have not been analysed and it is assumed that the incinerators would continue to operate at the same temperatures regardless of the type of waste they process. Such emissions were not highlighted by stakeholders in the consultation; Leakage during storage and transportation: Incineration processes are typically provided off-site and foams will need to be stored and transported to incineration facilities for disposal or waste equipment to be installed on-site132. During the storage and transportation of PFAScontaining foam it may be possible for spillages or leakages to occur, resulting in environmental emissions. There has not been enough information identified during desktop based research or provided from stakeholder consultation to accurately quantify these emissions; and 123 Derived from stakeholder consultation responses concerning PFAS disposal methods. Note that WWT was also reported as a disposal method, but a judgement was made that these disposal techniques relate to used PFAS-containing firefighting foam rather than unused foam. 124 Obtained from stakeholder consultation. 125 https://www.epa.gov/sites/production/files/2019-09/documents/technical_brief_pfas_incineration_ioaa_approved_final_july_2019.pdf 126 https://www.epa.gov/sites/production/files/2019-09/documents/technical_brief_pfas_incineration_ioaa_approved_final_july_2019.pdf 127 https://www.epa.gov/sites/production/files/2019-09/documents/technical_brief_pfas_incineration_ioaa_approved_final_july_2019.pdf 128 https://www.epa.gov/sites/production/files/2019-09/documents/technical_brief_pfas_incineration_ioaa_approved_final_july_2019.pdf 129 https://www.diva-portal.org/smash/get/diva2:1155115/FULLTEXT01.pdf 130 UNEP, 2012 in: https://www.kemi.se/global/rapporter/2016/report-11-16-strategy-for-reducing-the-use-of-higly-fluorinatedsubstances-pfas.pdf 131 https://www.kemi.se/global/rapporter/2016/report-11-16-strategy-for-reducing-the-use-of-higly-fluorinated-substances-pfas.pdf 132 https://www.serdp-estcp.org/content/download/48955/466822/file/ER18-1593%20Final%20Report.pdf June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 161 Wood Environment & Infrastructure Solutions UK Limited Direct emissions (greenhouse gases and air pollutants) from transportation: Where foams are stored and transported to incineration facilities, direct emissions of carbon and other pollutants (particulate matter, nitrogen oxides, etc.) from vehicles will also occur. Desktop based research revealed a lack of available data regarding the geographical position of PFAScontaining fire-fighting foam manufacturers and users in relation to incineration facilities and little to no information was obtained from stakeholder consultation. It is therefore unsuitable to accurately quantify emissions associated with foam transportation. Overall, PFAS emissions from incineration are not well studied133 and therefore, there is the potential for incineration to be hazardous134. Further research is needed to identify and quantify the emissions produced from the incineration of PFAS, as well as greater research undertaken to understand the thermal properties of PFAS. k. Technical feasibility / availability of disposal options (legacy foams) This section assesses the potential for existing disposal options to feasibly dispose of legacy foams in Scenario 2. The disposal of legacy foams is not considered in Scenario 1, as existing stocks will still be able to be used until they run out. With Scenario 2, a sudden increase in the short-term demand for disposal will likely occur as the whole market will dispose of their stocks to enable replacement. The level of demand for disposal will depend on what transition period is established (yet to be determined). In order to meet the demand, existing disposal options must have the capacity to process the quantities of foam to be sent for disposal. This subsection identifies the disposal options available and discusses their capacity to process and dispose of PFAS-containing foams given a sudden increase. There are several incineration methods available. One stakeholder reported two specific and different incineration methods: cement kiln and plasma arc furnace. A cement kiln operating from around 400C has a retention time of 20 minutes. A cement kiln operating between around 850-1800C has a residence 16-24 seconds (with a minimum of 2 seconds). Estimated costs of PFAS disposal by cement kiln incineration are around 2/l. Another stakeholder who has transitioned to fluorine-free foams also reported that their stocks of PFAS-based foams were incinerated in a cement kiln, but reported costs around 1 per litre. Plasma arc furnace conditions can reach 6000C and have an estimated processing cost of 11/l.135 It would therefore appear that costs are higher for incinerators operating at higher temperatures and there is a potential trade-off between the cost of incineration, effectiveness of PFAS destruction and time, due to higher temperatures being more likely to completely destroy the PFAS. With the sudden increase in short-term demand for incineration, existing disposal methods would need to be sufficient to process the volume of legacy PFAS foams required to be disposed of. Where capacity is insufficient, the storage of the foam will likely be required. The following assumptions are made to derive the capacity for existing incinerators to process PFAS-containing foam and the time it would take to complete this (not taking into account transportation times): The literature indicates that there are 808 incineration facilities across EU28136. These include high temperature hazardous waste incinerators as well as municipal waste incinerators that probably operate at lower temperatures. However, according to the Industrial Emissions Directive137 Article 50, all incinerators need to be designed, equipped, built and operated so that a temperature of at least 850C is achieved for at least two seconds. It is therefore assumed that all 808 incinerators are able to operate at least at 850C. However, as discussed in 133 http://norden.diva-portal.org/smash/get/diva2:1295959/FULLTEXT01.pdf 134 https://www.epa.gov/sites/production/files/2019-09/documents/technical_brief_pfas_incineration_ioaa_approved_final_july_2019.pdf 135 Obtained from stakeholder consultation. Note that it is not clear whether this relates to foam concentrate or other foam types being processed. 136 The Cost of Inaction - http://norden.diva-portal.org/smash/get/diva2:1295959/FULLTEXT01.pdf 137 Directive 2010/75/EU of the European Parliament and of the Council of 24 November 2010 on industrial emissions (integrated pollution prevention and control) June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 162 Wood Environment & Infrastructure Solutions UK Limited the previous sub-section, at least 1,100C (or for some PFAS even at least 1,400C) are required to degrade PFAS to carbon dioxide and hydrogen fluoride and it has not yet been determined what is produced when PFAS is incinerated at lower temperatures. Data was not available to determine the share of EU incineration facilities that achieves 1,100-1,400C; The amount of PFAS-containing legacy foam for disposal is between 210,000 tonnes and 435,000 tonnes (average 322,500 tonnes); Information obtained from stakeholder consultation indicates that an incinerator operating at around 850-1800C can process one tonne of foam per hour and an incinerator operating at around 6000C has a throughput of around 25l per hour. It is assumed that 1kg = 1l; and It is also assumed that incinerators continuously operate with the same processing capacity and at the same temperature, 24 hours a day. Based on the above assumptions, the tables below provide estimates of the time it will take incinerators to dispose of fire-fighting foams based on 808 incinerators having a processing capacity of 25l per hour or one tonne per hour. As discussed above, to ensure adequate destruction of PFAS, it would appear to be preferable to dispose of PFAS-containing firefighting foams at incinerators with higher temperatures (at least 1,100-1,400C). This will therefore reduce the capacity available and increase the time period required for disposal. Table 8.12 Processing time based on existing incinerator capacity processing 25l per hour. Foam to be disposed of (tonnes) Time for foam to be disposed of (hours) Time for foam to be disposed of (days) 210,000 (low) 10,400 400 322,500 (average) 16,000 700 435,000 (high) 21,500 900 Note that all cost values are assumed to represent the cost of disposal of unused PFAS-containing fire-fighting foams and not used PFAS-containing firefighting foam. Source: market assessment, desktop research and stakeholder consultation. Values have been rounded. Table 8.13 Processing time based on existing incinerator capacity processing one tonne per hour. Foam to be disposed of (tonnes) Time for foam to be disposed of (hours) Time for foam to be disposed of (days) 210,000 (low) 260 10 322,500 (average) 400 20 435,000 (high) 540 20 Note that all cost values are assumed to represent the cost of disposal of unused PFAS-containing fire-fighting foams and not used PFAS-containing firefighting foam. Source: market assessment, desktop research and stakeholder consultation. Values have been rounded. Responses from the stakeholder consultation indicate that there is sufficient capacity for disposal of PFAScontaining foams. One stakeholder reports that there is sufficient capacity for disposal, but that getting hightemperature incineration capacities is becoming more difficult. Another stakeholder also reports that sufficient capacity for disposal by incineration is not guaranteed. Capacity for disposal is also likely to depend on the transition period chosen (yet to be determined) and was mentioned in the stakeholder consultation. If June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 163 Wood Environment & Infrastructure Solutions UK Limited the transition period is short, there is the potential for demand for disposal facilities to outstrip supply. A longer transition period is more likely to result in the demand and the quantities sent for disposal being spread over a greater time period. Alternatively, a sector by sector introduction of Scenario 2 could be introduced to also spread the demand for disposal over time and avoid destruction capacity being exceeded138. Note that it is not clear whether stakeholder responses relate to used foams or whether responses relate to the sufficient capacity for the disposal of legacy foams if Scenario 2 were to occur. Additionally, the geographical locations of incinerators, the feasibility of storing and transporting PFAS to destruction facilities as well as the availability of transportation vehicles and labour has not been evaluated due to lack of information from both desktop-based research and stakeholder consultation. Further, the knock -on effects on other sectors requiring use of incineration facilities have not been considered. l. Costs of disposal (of legacy foams) This section discusses the costs associated with the disposal of legacy PFAS-containing firefighting foams under Scenario 2. Costs occur from the disposal process itself, as well as from transportation to disposal facilities and the storage of PFAS-foams. Costs of disposal are not considered to be incurred in Scenario 1, unless `transitional wastage' occurs, where the disposal of some PFAS-containing foam must happen to enable a switch to an alternative. Information and data is unavailable to accurately quantify the amount of `transitional wastage'. This subsection therefore focuses on costs associated with Scenario 2. First, the direct cost of incineration is calculated based on the stocks required for disposal. Costs associated with transportation to incinerators, labour costs and the potential costs of storage are qualitatively discussed. Incineration costs Incineration costs refer to the direct cost charged for the incineration of PFAS waste. Obtained from stakeholder consultation, the costs of disposal by incineration at temperatures between 850-1800C are between around 0.3-1.5 per litre139. Two stakeholders who have transitioned to fluorine-free foams both reported that their stocks of PFAS-based foams have been incinerated at costs of around 1 per litre. For incineration at a higher temperature of around 6000C, a cost of around 11/l is estimated. It is therefore considered more costly to dispose of PFAS-contained foams at incinerators with higher temperatures. Table 8.14 provides estimates of the cost for the disposal based on the total amount of PFAS-containing firefighting foam to be disposed of at 322,500 tonnes (average), 210,000 tonnes (low) and 435,000 tonnes (high). Table 8.14 Estimated costs of disposal Foam to be disposed of (tonnes) Best estimate Cost of disposal (/l): LM-H 0.3 (low) 1.0 (best estimate) 11 (high) 210,000 (low) 63m 210m 2,310m 322,500 (average) 97m 323m 3,547m 435,000 (high) 130m 435m 4,785m Note that all cost values are assumed to represent the cost of disposal of unused PFAS-containing fire-fighting foams and not used PFAS-containing firefighting foam. Source: market assessment, desktop research and stakeholder consultation. Values have been rounded. 138 Obtained from stakeholder consultation. 139 Note that it is not clear overall whether stakeholder consultation responses refer to foam concentrate or another measure of foam. One stakeholder explicitly reports disposal costs at 1 to 1.5/m3 of foam concentrate for high temperature incineration (1,100-1,200C). 1/l is considered a middle value due to stakeholder consultation reporting this is the cost of disposing of old foam. Not all costs were provided in euros and conversion rates have been used. It has also been assumed that 1kg = 1l. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 164 Wood Environment & Infrastructure Solutions UK Limited However, it should be noted that at least part of the PFAS-containing fire-fighting foams would reach their expiry date without being used and therefore be incinerated in any case, just at a later date. For these foams, a restriction on the use of PFAS-based fire-fighting foams would only bring their incineration forward and therefore the incineration cost of fire-fighting foams that would have expired is not additional to the baseline, i.e. not a cost of the restriction. As discussed earlier140, it is not known what share of fire-fighting foams is used before its expiry date, but if reported usage rates of 15-20% per annum of existing stocks is an average across all sectors of use, there will be some installations with potentially far lower usage rates annually that will likely have some foams that reach expiry before use. Hence, an unknown share of the costs are not additional to the baseline and the costs presented in Table 8.14 should be considered a higher boundary of the actual cost of the restriction in terms of the costs of disposal of legacy foams. Transportation costs Stakeholder responses did not identify transportation costs in relation to the costs of disposal. However, it is possible that transportation costs may occur where PFAS-containing fire-fighting foams need to be transported to incinerators off-site. These may include the costs associated with vehicle operation such as fuel costs (which will likely vary across the EU and be dependent on fuel prices) and distance covered between the pick-up point for PFAS and the site for incineration. Desktop based research reveals that Greece has the highest number of incinerators (132), followed by Belgium (100), Italy (100), Germany (93), the UK (87) and Poland (85)141. However, without detailed information concerning the location of PFAS foam users and manufacturers, it is not feasible to derive accurate transportation costs associated with disposal. Storage costs Stakeholder responses referred to storage costs within the context of requiring multiple foams to be stocked, particularly during a transition to PFAS-free foam, rather than within the context of disposal. This cost could be mitigated through phased transition. These costs have not been quantified here. Labour costs Labour costs may be incurred during the collection of PFAS-containing firefighting foams as well as during their transportation to incineration facilities. Stakeholder consultation did not provide any responses relating to labour costs for the disposal of PFAS and these would likely form part of the overall incineration costs. 8.3 Conclusions Table 8.15 below summarises the results for all impacts discussed in this chapter. 140 In the emission assessment in Task 3 (Section 5) and the SEA section on savings from adoption of fluorine-free foams ("e. Impacts associated with the economic feasibility of alternatives"). 141 http://norden.diva-portal.org/smash/get/diva2:1295959/FULLTEXT01.pdf June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 165 Wood Environment & Infrastructure Solutions UK Limited Table 8.15 Impacts Summary of socio-economic considerations for the main expected impacts of potential regulatory management options Economic Social Health/Environmental a. Cleaning of equipment Costs vary by equipment, process and achievable concentration. According to one estimate up to 12,300 per appliance achieving PFAS levels below 1000ppt (1/3 of appliances below 70ppt), which could imply EU total costs in the order of 1 billion, but established simpler methods have also been reported (cost not quantified). None identified. Trade-off between cost for cleaning/replacement and threshold concentrations for remaining PFAS contamination. Replaced equipment and media (e.g. water) used in cleaning process must be disposed of or treated safely to avoid worker or environmental exposure. The replacement of equipment is likely to be required in some cases, depending on the threshold chosen. Replacement costs for extinguishers alone estimated at 15-450 million (EU total). Replacement cost for other equipment not quantified. b. Other risk management options None identified. None identified. None identified. c. Fire safety -impacts of technical performance of alternatives It is not expected that any damages would be caused, see Health/Environmental. This is however still uncertain for large atmospheric storage tanks. None identified. AoA concluded alternatives are technically feasible and successful transitions have been shown in most applications. Further testing required to confirm whether this covers also large atmospheric storage tanks (LAST), the application of most concern. Speed of fire suppression may be slower and application of foams may be less flexible and less easy to use, according to some stakeholders. This has not been shown to be generally the case and resulting health/safety impacts could not be quantified. Wider economic implications None identified. None identified. None identified. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 166 Wood Environment & Infrastructure Solutions UK Limited Impacts d. Use patterns to achieve comparable/acceptable performance using alternatives e. Economic feasibility of alternatives Economic Social Between no change in volume and up to a maximum of 100% additional foam required (additional cost considered in e. below). None identified. In sprinkler applications, special sprinkler nozzles have to be installed (cost not quantified). More than one foam may need to be stocked by users to cover different flammable liquids, with logistical, training and safety implications for users. For both Scenarios: Most likely there is no significant price difference (per litre) between PFAS-based foams and alternatives, but up to 100% more volume may be required (central estimate 50%) to achieve desired performance. This would lead to costs around 27m per year (EU total, central estimate) None identified. Potential additional economic costs for transitioning may include testing costs (not quantified), storage costs, (not quantified) costs from technical changes to delivery systems (e.g. 5-200 pre nozzle or around 2,700 for a mobile foam unit, but generally conceived as manageable), and regulatory approvals (not quantified). Potential savings may include lower foam disposal costs at expiry date (likely order of magnitude 100,000 to several million) lower fire-water disposal costs (covered under g. Remediation and clean-up), avoided cross contamination of waste, reduced regulatory requirements and reduced PPE requirements (not quantified). Additionally for Scenario 2: Costs for existing stock of PFAS-based foams (estimated 210,000-435,000 tonnes) will have to be written off (and new stocks purchased causing an additional cost (central estimate 1.0bn) over the baseline. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 Health/Environmental More than one foam may need to be stocked by users to cover different flammable liquids, with logistical, training and safety implications for users. Wider economic implications None identified. None identified. None identified. 167 Wood Environment & Infrastructure Solutions UK Limited Impacts f. Environmental/health - impacts of alternatives Economic None identified. Social None identified. g. Remediation and clean-up h. Availability of alternatives Potential risk of PFAS contamination could be eliminated, which could save up to around 100 million remediation costs per site. Depending on the extent of containment and immediate clean-up, the number of relevant sites is likely low, but overall savings could still be in the order of magnitude of 100s of millions to billions More information on the total number of sites and real-world implementation and effectiveness of best practices would be required to be more precise. None identified. Treatment of fire-water run-off and short-term clean-up largely driven by other contents of firewater run-off and cost saving estimates are very uncertain. Run-off treatment savings could be 0.7 per litre (range ca 0-11) or 0 to 10s of millions per incident, and clean-up cost savings up to 10s of millions in total. Range of alternatives and capacity to increase production likely available. No significant supply shortages or additional costs expected in Scenario 1. None identified. Scenario 2 may result in a more sudden and potentially significantly larger demand for fluorinefree foams to replace existing stocks of PFAS-based foam. This heightens the risk of a shortfall in supply, - depending on the timescales of any restriction. As the largest single use, and with comparatively low current fluorine free sales volumes, the risks of supply constraints may be greater in the chemicals and petrochemical sectors. Health/Environmental Based on the assessed substances, non-fluorinated alternatives are of lower environmental concern, primarily due to greater biodegradation. A quantitative comparison of risk under each scenario was not possible with the available data. Potential trade-off between remediation cost and remaining PFAS contamination. Wider economic implications None identified. None identified. None expected in Scenario 1. The risk of supply supply-shortages is higher in Scenario 2 (depending on timescales of a restriction), which could potentially lead to additional fire-safety risks. None identified. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 168 Wood Environment & Infrastructure Solutions UK Limited Impacts i. Other impacts j. Emissions from disposal of legacy foams k. Technical feasibility / availability of disposal options l. Costs of disposal Economic None identified. Social Health/Environmental There is potential for employment impacts but significant impact is deemed unlikely and any net effect at the EU level would be negligible. None identified. Wider economic implications Under Scenario 2, a potential shortfall in supply - driven by a one off need for stock replacement - may impact imports of fluorine free foam from outside the EU. None identified. None identified. If the transition period is short, there is the demand for disposal facilities may outstrip supply, leading to potential additional costs and potential for emissions. None identified. Total EU costs estimated at up to 320 million (range up to 60m-4.8bn) depending on the method used (with implications on effectiveness, see Health/Environmental) and the share of foams that would have reached expiry date without use. Additional transport, storage and labour costs may be incurred (not quantified). None identified. High temperature incineration has been identified as main disposal method. There are potential hazards (emissions of hydrogen fluoride and PFAS), but further research is needed to identify and quantify the emissions produced from the incineration of PFAS. Trade-off between temperature of incineration (with lower capacity and higher costs) and effectiveness of PFAS destruction. Overall, there are unlikely to be any significant macroeconomic impacts from the result of either Scenario 1 or Scenario 2. None identified. None identified. If the transition period is short, there is the demand for disposal facilities may outstrip supply, leading to potential additional costs and potential for emissions. Trade-off between temperature of incineration (with lower capacity and higher costs) and effectiveness of PFAS destruction. None identified. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 169 Wood Environment & Infrastructure Solutions UK Limited Scenario 1: Restriction on the placing on the market of PFAS-containing fire-fighting foams Scenario 1 would allow users to continue using their stocks of foams, but once they are depleted, users would be forced to switch to alternative (fluorine-free) foams. The impacts that have been identified as most significant are: Environmental/health benefits: Based on the assessed substances, non-fluorinated alternatives are likely to be of lower environmental concern, primarily due to biodegradation. The environmental and health benefit of the restriction could not be quantified but is expected to be significant; and The annual health-impact in the EEA of exposure to PFAS (from all uses of PFAS, not only fire-fighting foams) has been estimated at 52-84 billion142. It is unclear what share of that is due to their use in fire-fighting foams, but for illustration the PFOA REACH restriction report estimated that fire-fighting foams account for about 2-4% of emissions of PFOArelated substances (a subset of PFAS).143 Cost of transition to using fluorine-free alternatives: As users' stock of PFAS-based foams deplete, they would need to purchase alternative foams. While the cost per litre of the alternatives is likely similar, higher volumes may be required to achieve the desired performance, which has been estimated to incur additional costs (compared to the baseline) of around 27m per year in the EU. The cost would increase gradually as legacy foam stocks are replaced and the 27m per year would be reached once the full annual demand of fire-fighting foams is served by alternatives; Before using alternative foams, equipment that was previously filled with PFAS-based foams needs to be cleaned to avoid contamination of the new foams with PFAS. Cleaning costs are difficult to generalise as they vary by the type of equipment, the cleaning process used and the concentration of remaining PFAS contamination that can be achieved (and that would be allowed). These costs, could be significant. According to one estimate costs could be up to 12,300 per appliance, which could imply EU total costs in the order of 1 billion, but established simpler methods have also been reported (cost not quantified). The replacement of equipment is likely to be required in some cases if cleaning to achieve very low residual PFAS levels (to meet a threshold) is not feasible. Replacement costs for extinguishers alone are estimated at 15-450 million (EU total). Replacement costs for other equipment could not be quantified, but are likely to be more significant than for fire extinguishers. The replaced equipment and especially the media (e.g. water) used in the cleaning process must be disposed of or treated (with further cost or environmental/health implications); Potential additional economic costs for transitioning that could not be quantified as EU totals but may include testing costs, storage costs, costs from technical changes to delivery systems (e.g. 5-200 per nozzle or around 2,700 for a mobile foam unit, but generally conceived as manageable), and regulatory approvals. More than one alternative foam may need to be stocked by users to cover different flammable liquids, leading to potential logistical and training costs; and 142 Nordinc Council of Ministers (2019): The cost of inaction - A socioeconomic analysis of environmental and health impacts linked to exposure to PFAS. Available at: http://norden.diva-portal.org/smash/get/diva2:1295959/FULLTEXT01.pdf 143 0.7-1.4 tonnes per year out of a total across all sources of 18.7-56.7 tonnes per year (see table F.1-1). ECHA (2014): Annex XV restriction report - proposal for a restriction on perfluorooctanoic acid (PFOA), PFOA salts and PFOA-related substances. Available at: https://echa.europa.eu/documents/10162/e9cddee6-3164-473d-b590-8fcf9caa50e7 June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 170 Wood Environment & Infrastructure Solutions UK Limited This may be partly offset by potential savings from lower fire-water disposal costs, avoided cross contamination of waste, reduced regulatory requirements and reduced PPE requirements (not quantified), and lower disposal costs for foams that have reached their expiry date, all due to the potentially lower environmental/health risk of the alternative firefighting foams. Implications of the performance of fluorine-free alternatives: The analysis of alternatives concluded that alternatives are technically feasible and successful transitions have been shown in most applications. However, further testing is required to confirm whether this covers also large atmospheric storage tanks (LAST), the application of most concern around feasibility of alternatives; and The speed of fire suppression may be slower and application of foams may be less flexible and less easy to use (e.g. different foams may be needed for different flammable liquids), in some cases. Benefits of reduced clean-up / remediation: A restriction would eventually eliminate the potential risk of additional PFAS contamination, which could save up to around 100 million remediation costs per site. However, only a small share of sites using fire-fighting foams would release sufficient quantities and without adequate containment and immediate clean-up to require large scale remediation. More information on the total number of sites, real-world use of PFAS per site as well as implementation and effectiveness of best practices in terms of containment and immediate clean-up would be required to assess the extent to which remediation is likely to be required in the future as a result of current use of PFAS-based fire-fighting foams. However, as a very high level estimate for illustration, the potential order of magnitude of avoided remediation could be hundreds of millions of Euros (assuming tens of sites requiring remediation at tens of millions of Euros per site) to billions of Euros (assuming hundreds of sites requiring remediation at tens of millions of Euros per site); Treatment of fire-water run-off and short-term clean-up after the use of fire-fighting foams is largely driven by other contents of the fire-water run-off, rather than the foam used, so potential savings as a result of the restriction are very uncertain, because the incremental costs of addressing PFAS contamination is difficult to separate from the wider clean-up costs: o In most cases, the majority of fire-water run-off is contained and sent for treatment. It has been reported that at least in some cases, run-off can be sent to waste water treatment when fluorine-free foams have been used, whereas it may have to be incinerated when PFAS-based foams are used. Specific cost data was not provided but it is estimated that the difference in treatment cost could be around 0.7 per litre (range 0-11) or 0 to 10s of millions per incident; and o In cases where fire-water run-off is not contained and further clean-up is possible, there may be savings from using fluorine-free foams in terms of reduced clean-up costs, because the alternative fire-fighting foams should not introduce persistent chemicals to the run-off, as would be the case had PFAS-based foams been used144. In the absence of more specific data, for illustration of the potential order of magnitude of savings: Assuming several tens of incidents per year using PFAS-based foams where clean-up is required and which could be avoided if fluorine-free foams 144 As discussed in Sections 5 and 7, fluorine-free alternatives are generally less persistent than PFAS-based foams. However, note that fluorine-free alternatives still contain some hazardous chemicals and the run-off may contain other problematic contents from other sources than the foam used. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 171 Wood Environment & Infrastructure Solutions UK Limited were used, the savings would be in the order of several millions to several tens of millions of Euros per year. It is considered unlikely that a restriction would cause any significant macroeconomic impacts (e.g. employment, trade). Scenario 2: Restriction on the placing on the market and the use of PFAS-based fire-fighting foams This scenario would require the switch to alternative (fluorine-free) foams to happen immediately when the restriction comes into force (or before), and for users' stocks of PFAS-based foams to be disposed of. To avoid duplication of information, the main identified impacts are discussed relative to Scenario 1: Environmental/health benefits: Benefits resulting from a reduction of PFAS emissions would be achieved more quickly in this scenario and therefore also achieve a higher reduction of accumulative PFAS contamination; and There are potential risks (emissions of hydrogen fluoride and PFAS) from the incineration of legacy foams, but further research is needed to identify and quantify the emissions produced from the incineration of PFAS. Cost of disposal of legacy foams: Total EU costs are estimated at up to around 320 million (range up to 60m-4.8bn) depending on the method used and the share of foams that would have reached their expiry date without use (whose disposal is merely brought forward by the restriction, but costs not additional to the baseline). There is a trade-off between the disposal costs and the mitigation of potential environmental risks from disposal (as discussed above); and Additional transport, storage and labour costs may be incurred (not quantified). Cost of transition to using fluorine-free alternatives (other than disposal of legacy foams): The existing stock of PFAS-based foams - an estimated 210,000-435,000 tonnes - would have to be written off (considering depreciation since their purchase), and new stocks would have to be purchased, subject to replacement costs (minus the value of existing stocks already depreciated) estimated at around 1.0 billion (range -60 million145 to 8.3 billion); In addition, as discussed for Scenario 1, purchasing alternative foams is estimated to incur additional costs (compared to the baseline) on an annual basis of around 27m per year. In Scenario 2, these costs would be incurred immediately when the restriction comes into force (or before), whereas in Scenario 1 the costs increase gradually and only reach 27m per year once all stocks are depleted. As the transition is concentrated into a shorter time, supply shortages and associated price increases of alternative foams are somewhat more likely than in Scenario 1, potentially leading to additional costs. However, significant shortages and price increases are not considered very likely in either scenario. As in Scenario 1, this would be partly off-set by savings from lower disposal cost of fluorine-free foams when they reach their expiry date, lower fire-water disposal costs, avoided cross contamination of waste, reduced regulatory requirements and reduced PPE requirements; and 145 I.e. a potential saving of 60 million, if fluorine-free alternatives are cheaper than the PFAS-based foams they replace (possible in some cases but unlikely on average) and no additional volumes are required. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 172 Wood Environment & Infrastructure Solutions UK Limited Costs for cleaning or replacement of equipment and other transitioning costs would also in principle be similar to Scenario 1, but again they would be incurred more concentrated in a shorter time. As these are one-off costs, this would not lead to higher accumulated costs compared to Scenario 1. However, the concentration in a shorter time again poses a greater risk of supply shortages and associated price increases, potentially leading to additional costs. Implications of the performance of fluorine-free alternatives: These are considered to be the same as for Scenario 1, i.e. no negative implications are expected in general (subject to further testing for LAST). Benefits of reduced clean-up / remediation: The reduction of the risk of future remediation or additional/more costly clean-up would be reduced even further in this scenario, given the quicker elimination of PFAS emissions and higher reductions of accumulated PFAS contamination. It is considered unlikely that a restriction would cause any significant macroeconomic impacts (e.g. employment, trade). Cost-effectiveness Following ECHA's approach to the "Evaluation of restriction reports and applications for authorisation for PBT and vPvB substances in SEAC"146, the cost per unit (e.g. kilogram) of emission reduced are presented in the following. It should be noted that both the socio-economic costs and the emission reduction of a potential restriction of PFAS in fire-fighting foams is associated with significant uncertainties and are presented in wide ranges or sometimes indicative orders of magnitude. Not all socio-economic impacts (costs or benefits) could be quantified and often their magnitude will depend on the specific design of the potential restriction (e.g. residual concentration limits). As a result, the cost-effectiveness will be subject to the same uncertainties and can only be calculated as an indicative order of magnitude. Total emission reduction Some 14,000-20,000 tonnes of PFAS-based fire-fighting foams are used annually in the EU (the best estimate used in the SEA is some 18,000 tonnes) and the market analysis suggested these contain an average concentration of fluorosurfactants of around 2-3% (average of 2.5% used as best estimate below). The emission model developed in Section 5 estimated that 26% of the two modelled example PFAS surfactants used in fire-fighting foams are released to the environment. A range was not calculated, so a 50% range around that central estimate is used below. These assumptions yield the following estimate of total annual tonnage of PFAS emissions reduced if the use of PFAS-based fire-fighting foams in the EU were to cease: Table 8.16 Estimate of total annual PFAS emissions from fire-fighting foams Tonnes of foams used per year Concentration of PFAS surfactants in foams Share of PFAS surfactants released into the environment Tonnes of PFAS released Low 14,000 t 2% 13% 36 t Best 18,000 t 2.50% 26% 117 t 146 https://echa.europa.eu/documents/10162/13580/evaluation_pbt_vpvb_substances_seac_en.pdf/af4a7207-f7ad-4ef3ac68-685f70ab2db3 June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 173 Wood Environment & Infrastructure Solutions UK Limited Tonnes of foams used per year Concentration of PFAS surfactants in foams Share of PFAS surfactants released into the environment Tonnes of PFAS released High 20,000 t 3% 39% 234 t Sources: DG ENV study tasks 2 and 3. It should be noted that this cost-effectiveness analysis only considers the reduction of PFAS emissions. The increased emissions of alternatives resulting from a potential restriction is not considered here, but the relative hazards of the alternatives are discussed in other relevant sections of this report (in the hazards and emissions task, the AoA, the SEA and the RMOA). Total cost of emission reduction The main quantified costs (and benefits) of a potential restriction are listed below. Note that this list is for illustrating the approximate cost-effectiveness, but should not be understood as a total summary of costs and benefits. It should be read in conjunction with the SEA conclusions above to put these costs and benefits in context with the appropriate caveats and other unquantified impacts. In particular, benefits from avoided remediation costs have not been included here, because they constitute an environmental benefit rather than a cost of emission reduction. If these were included, they would significantly reduce the total costs (or even result in a net benefit)147. However, they remain an important benefit included in the SEA. In order to compare the costs with annual emission reductions, one-off costs need to be annualised. Annualisation requires the selection of a cumulative time period over which to assess the cost-effectiveness of the restriction. Following ECHA guidance on SEA for restrictions148, this should reflect a typical investment cycle. The typical shelf-life of fire-fighting foams of 15 years (as assumed elsewhere in this report) has been used here, although it should be noted that related equipment may have much longer investment cycles and so a longer period could be used which would reduce the annualised cost. A 4% discount rate has been applied149. The total of annual costs plus annualised one-off costs shows that (at least at the chosen cumulative time period, for the costs and benefits that could be quantified) the one-off costs clearly dominate the balance of overall costs and benefits. Table 8.17 Estimate of total quantifiable cost of a potential restriction on PFAS in fire-fighting foams Cost Low estimate Best estimate High estimate Notes One-off costs Disposal of stocks (only Scenario 2) 210 million 320 million 435 million Range based on central estimate cost per litre and likely range of tonnage to be disposed of. When considering full range of cost per litre, the range of total disposal 147 Avoided remediation cost would be considered a one-off benefit due to the long timescales of accumulated releases that lead to remediation. They could amount to in the range of hundreds of millions to billions of Euros. Annualised over 15 years, using a 4% discount rate, this would be equal to tens to hundreds of millions of Euros per year (annualisation method is described in more detail below). 148 https://echa.europa.eu/documents/10162/23036412/sea_restrictions_en.pdf/2d7c8e06-b5dd-40fc-b6463467b5082a9d 149 The discount rate has been chosen as per the example in the ECHA guidance and as recommended by the European Commission's Better Regulation Guidelines. In accordance with ECHA guidance on SEA for restrictions, the annualised costs is calculated as the annualisation factor multiplied by the one-off costs. The annualisation factor is equal to r(1+r)n /((1+r)n -1), where r is the discount rate and n the cumulative time period. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 174 Wood Environment & Infrastructure Solutions UK Limited Cost Cleaning of equipment Replacement of foam stocks (only Scenario 2) Total one-off costs Annualised total oneoff costs Annual costs Additional volumes of alternative foams Disposal of expired foams Low estimate Best estimate High estimate 100 million (hypothetical 10% of best estimate) 1.0 billion 1.5 billion (hypothetical 150% of best estimate) 320 million 1.0 billion 2.0 billion 100 million (Scenario 1) 630 million (Scenario 2) 9.0 million (Scenario 1) 57 million (Scenario 2) 1 billion (Scenario 1) 2.3 billion (Scenario 2) 90 million (Scenario 1) 210 million (Scenario 2) 1.5 billion (Scenario 1) 3.9 billion (Scenario 2) 130 million (Scenario 1) 350 million (Scenario 2) 21 million (Scenario 1) several millions (Scenario 2) 27 million (Scenario 1) 10 million (Scenario 2) (assumed mid-point between low and high estimate) 30 million (Scenario 1) 20 million (Scenario 2) (assumed value <30 million) - several millions -1 million (assumed mid-point between low and high estimate) -100,000 Notes costs could be 60m - 4.8bn (see Section 8.2 l.). Best estimate based on the only cleaning process (and associated concentration of <1000ppt remaining PFAS achieved) for which a cost was available. Note that costs could be higher in Scenario 2 than Scenario 1, due to the shorter time available for cleaning, but no specific data was available to quantify this. Range based on central estimate prices per tonne of PFAS-based foam and alternatives, and likely range of tonnage of alternatives to be purchased. When considering full possible range of prices per tonne, the range of total replacement cost could be - 60m - 8.3bn (see Section 8.2 e.). As per the notes above, the possible range could be even wider (low estimates 530m lower, high estimates 10.7bn higher). As per the notes above, the possible range could be even wider (low estimates 48m lower, high estimates 960m higher). Under Scenario 2, all PFAS foam stocks are replaced with new alternative foams at the beginning of the assessment period (already covered under the one-off cost replacement of foam stocks" above). These new foams would not expire within the assessment period, but an unknown share would be used and still need to be replaced again with new foams, thus incurring the costs associated with additional volumes again. Therefore, this cost is lower under Scenario 2 but it cannot be quantified by exactly how much. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 175 Wood Environment & Infrastructure Solutions UK Limited Cost Clean-up Low estimate -10s of millions Treatment of fire-water run-off per incident (annual unknown) -10s of millions Total annual costs - 10s of millions (i.e. a benefit) Total annual costs + annualised one-off costs - 10s of millions (Scenario 1) ~0 (Scenario 2) Results rounded to two significant figures. Best estimate High estimate Notes -10 million (assumed mid-point between low and high estimate) -1 million (assumed value close to 0) High estimate based on the assumption that at least in some cases, savings from reduced clean-up will be incurred, so total savings will be somewhat larger than 0. - several millions 0 (assumed mid-point between low and high estimate) several millions (Scenario 1) - several millions (i.e. a benefit) (Scenario 2) 29 million (Scenario 1) 19 million (Scenario 2) ~100 million (Scenario 1) ~200 million (Scenario 2) 160 million (Scenario 1) 370 million (Scenario 2) As per the notes above, the possible range could be even wider (low estimates 48m lower, high estimates 960m higher). Cost effectiveness Based on the above, as a central estimate, it is calculated that the cost effectiveness could be around 850 (Scenario 1) to 1,700 (Scenario 2) per kg of annual reduction of PFAS emissions. This could range from savings in the tens of Euros per kg to costs around 10,000 per kg. Table 8.18 Estimate of cost-effectiveness of the reduction of PFAS emissions from fire-fighting foams Low estimate Best estimate High estimate Total emission reduction per year (kg) 234,000 kg 117,000 kg 36,000 kg Total cost per year () - 10s of millions (Scenario 1) ~0 (Scenario 2) 100 million (Scenario 1) 200 million (Scenario 2) 160 million (Scenario 1) 370 million (Scenario 2) Costeffectiveness - 10s /kg (Scenario 1) 0/kg (Scenario 2) 850/kg (Scenario 1) ~1,700/kg (Scenario 2) 4,600/kg (Scenario 1) 10,000/kg (Scenario 2) Results rounded to two significant figures and reflect the likely range. However, as noted in the previous table, the range could possibly be even wider, from - 10s /kg (both Scenarios) to 31,000/kg (Scenario 1) and 37,000/kg (Scenario 2). Assumptions and uncertainties The above conclusions are subject to a range of assumptions and uncertainties. Assumptions have been made based on the results of other tasks and are discussed in more detail within those tasks. However, the assumptions and uncertainties that could most significantly affect the results are discussed briefly below: Environmental/health benefits of the reduction of PFAS emissions could not be quantified, primarily due to a lack of knowledge about the hazards of PFAS. The estimated emissions of June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 176 Wood Environment & Infrastructure Solutions UK Limited PFAS and hazards of the constituents of alternatives are also subject to a range of uncertain assumptions. Hence, costs and benefits could not be directly compared; Cost of transition are subject to uncertain assumptions about price difference between foams and the quantity of alternative foams needed to achieve the desired performance. Which and how much alternative foam is needed to achieve the desired performance varies on a case by case basis. It has been judged most likely that there is no significant price difference (per litre) between PFAs-based foams and alternatives, and assumed that 50% additional volume of alternatives is needed. If a more/less expensive alternative foam or larger/smaller quantities would be needed to achieve the desired performance, this would increase/decrease the costs of the restriction. Savings related to the transition are sensitive to assumptions about the amounts of foam that would reach their expiry date without use under the baseline; Costs of cleaning and technical changes or replacement of equipment are very case-specific and could largely not be quantified with the available data. This means that the quantified costs of both scenarios are underestimates; It should be noted that there was a divergence in the stakeholder input about technical feasibility of alternatives. A few stakeholders have voiced concerns over the potentially reduced fire safety, at least in specific applications. This means there is a risk of additional health, safety and economic (fire damage) impacts; however our analysis has concluded that they are not the most likely outcome and that LAST are the main application for which there is still further testing required; It is uncertain to what extent current practices involving the use of PFAS-based fire-fighting foams already manage to eliminate the need for significant new remediation requirements under the baseline. This is because most experiences with PFAS remediation relate to legacy contamination resulting from historical emissions before current measures (e.g. containment and clean-up after use) were widely implemented. However, stakeholder input suggests that such measures are likely not 100% implemented or effective. Furthermore the incremental costs of addressing PFAS contamination in short-term clean-up is difficult to separate from the wider clean-up costs involved after fire incidents. In addition, there is a lack of data about the number of sites that use PFAS-based foams in sufficient quantities to potentially require clean-up or large scale remediation. Therefore remediation savings from the transition to fluorine-free alternatives are very uncertain and only illustrative estimates of the potential order of magnitude of such benefits were provided; and There is a wide range (60-4,800 million, with best estimate 320 million) in the potential costs of disposal of legacy foams in Scenario 2, which largely depends on the disposal method used. This is due to uncertainty about the amounts of foam that would reach their expiry date without use under the baseline and the effectiveness of PFAS-destruction at different incineration temperatures and times. There is also uncertainty about the potential emissions and therefore associated environmental/health risks. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 177 Wood Environment & Infrastructure Solutions UK Limited PART 4 - pre-RMOA 9. Task 5. Regulatory management option analysis (pre-RMOA) 9.1 Introduction The aim of the risk management option analysis (RMOA) is to identify the most appropriate regulatory instrument for possible risk management activities to address the concerns related to PFAS used in firefighting foams. As such, it covers a range of different substances that have been identified in Section 3. The structure of this section is based on ECHA guidance150 but has been adapted given its focus on a range of substances. This adapted RMOA format was agreed with the European Commission and ECHA. The RMOA is structured as follows: First, Section 9.2 briefly summarises the concern associated with the use of PFAS. This does not preclude any results on hazards of PFAS based on the (ongoing) work of the PFAS working group, which were not available for inclusion in this report; Section 9.3 puts this into the context of their use in fire-fighting foams in Europe (based on the market analysis in Section 4), and resulting releases to the environment (based on the results from Section 5), in order to assess in which applications and at what scale this use may lead to concerns; Section 9.4 provides an overview of existing measures to assess the extent to which the concerns are already addressed; Section 9.5 then elaborates on the need for potential further regulation at EU level, based on whether the existing measures are sufficient to address the concern; Potential regulatory management options are presented and assessed in Section 9.6. This includes their effectiveness in controlling the risks, considerations relating to alternatives and socio-economic impacts (based on the results of the ECHA study in Sections 7-8 and the assessment of remediation costs in Section 6) and other regulatory considerations (e.g. practicality and monitorability); and Finally, Section 9.7 draws conclusions based on the assessment of regulatory management options and preliminary socio-economic considerations. 9.2 Hazard information Introduction A PFAS working group exists under ECHA's stewardship to assess the hazards associated with PFAS substances, including persistence, mobility, bioaccumulation and toxicity. To avoid duplication with the work 150 Such as the internal RMOA templates used by ECHA, or ECHA (2007) Guidance for the preparation of an Annex XV dossier for restrictions, available from: https://echa.europa.eu/documents/10162/23036412/restriction_en.pdf/d48a00bfcd8d-4575-8acc-c1bbe9f9c3f6 June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 178 Wood Environment & Infrastructure Solutions UK Limited of the PFAS working group an in-depth assessment of the hazards for PFAS substances (as a family of chemicals used for fire-fighting foams) has not been completed under the current study. Therefore, based on the wealth of research that has already been developed, high level comments on the hazards associated with PFAS substances are provided here, in order to support the pre-RMOA and provide context on the need for action at the EU level. Further discussion on the hazards of the non-fluorinated alternatives is provided in Section 5. Overview PFAS is a broad term used to cover approximately 4,700 specific chemical species151 which have a wide range of uses. These uses are principally based around the carbon-fluorine bond which is particularly strong and offers physical properties that include high water and oil repellence152. The same properties mean that many PFAS substances are also highly mobile (within the natural environment) and highly persistent (see Appendix 3). This can create issues where PFAS substances emitted to the environment reach and contaminate important resources such as groundwater. There is evidence to suggest that exposure to PFAS can lead to adverse health effects in humans (by eating or drinking food or water contaminated by PFAS). In particular the US EPA153 highlight studies that indicate the longer chain (C8 PFAS) species PFOS and PFOA can cause reproductive and developmental, liver and kidney, and immunological effects on laboratory animals. Furthermore, both chemicals have caused tumours in animal studies. Their use is already restricted in the EU and elsewhere. Some short-chain PFAS (PFHxS, PFBS, HFPO-DA) have also been listed as SVHCs, based on there being an equivalent level of concern to the named groups of chemicals under the authorisation provisions under REACH (carcinogens, mutagens and reprotoxicants (CMRs) and persistent, bioaccumulative and toxic/very persistent and very bioaccumulative (PBTs/vPvBs) chemicals). The Nordic Council of Ministers154 commented that the annual health-impacts within an EEA exposure study (from all uses of PFAS, not only fire-fighting foams) was estimated at 52-84 billion. This gives an indication of the scale of the issue and magnitude of the potential impacts from the environmental build-up of PFAS. The same study describes remediation costs associated with contamination from PFAS at European sites ranging from several hundred thousand up to 40 million with one high-cost example for the Dusseldorf Airport, Germany estimating a total remediation cost of up to 100 million. Based on the physical properties of PFAS (particularly mobility and persistence) along with identified health effects for some PFAS, PFAS represent a challenging environmental and human health hazard issue. 9.3 Information on tonnage, uses and exposure This section provides an overview of the applications in which PFAS-based fire-fighting foams and fluorinefree alternatives are used, along with associated tonnages (based on the results of Section 4), as well as the resulting releases to the environment (based on the results of Section 5). This is intended to put the hazards discussed in the previous section into context and allow for an assessment of the concern resulting from the use of PFAS-based fire-fighting foams and fluorine-free alternatives. Uses The main function of PFAS contained in fire-fighting foam is to act as a surfactant, that is to form a film over the surface of a burning liquid in order to prevent flammable gases from being released from it as well as 151 OECD, 2018, PFAS database, toward a new comprehensive global database of per and polyfluoroalkyl substances. 152 Buck et al, 2011, `Perfluoroalkyl and polyfluoroalkyl substances in the environment: Terminology, classification and origins', Integrated environmental assessment and management vol 7 issue 4. 153 US EPA, 2019, `Basic information on PFAS', https://www.epa.gov/pfas/basic-information-pfas 154 Nordic Council of Ministers, 2019, `The Cost of Inaction - A socioeconomic analysis of environmental and health impacts linked to exposure to PFAS', http://norden.diva-portal.org/smash/get/diva2:1295959/FULLTEXT01.pdf June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 179 Wood Environment & Infrastructure Solutions UK Limited reigniting. They are therefore used in fires involving flammable liquid (Class B fires) within a range of sectors. Tonnages of foam used by sector are discussed in the next sub-section below. According to the consultation, PFAS-based fire-fighting foams are used for training and testing of equipment, and in many levels of fire hazards, from small fire extinguishers to large tank fires, and can be applied both with mobile and semistationary equipment. Fluorine-free alternatives are in principle used in the same applications and are increasingly replacing PFASbased foams, although with varying market penetration depending on the sector or specific application. In some cases, fluorine-free foams have replaced PFAS-based foams in training and testing (as recommended by some industry best practice guidance documents155) but not in real fire incidents. The substance identification identified the following groups of substances that PFAS-free fire-fighting foams are based on: hydrocarbons, detergents, siloxanes, and protein foams. According to the consultation, foams based on hydrocarbons and detergents appear to be the most frequently used fluorine-free foams. Tonnages PFAS-based fire-fighting foams Based on an extrapolation of data provided by Eurofeu it is estimated that some 20,000 tonnes of PFASbased fire-fighting foams are sold in the EU per year. Of these, about 12,000 tonnes are estimated to be employed in fixed systems and 8,000 in mobile systems156. The split by sector is detailed in Figure 9.1 below. This shows that chemical/petrochemical is by far the largest user sector (59%), but municipal fire brigades, marine applications, airports and military applications also account for significant volumes. Readyfor-use products only account for a very small share of PFAS-based foams according to this data. The majority of this category are fire extinguishers, although not all foam fire extinguishers use ready-for-use foams (according to personal communications with Eurofeu). The annual tonnage of PFAS-based fire-fighting foam used in all extinguishers in the EU has been estimated at 360-675 tonnes (not counting the water that foam concentrates are mixed with in the extinguishers before/during use). 155 See for instance https://www.fffc.org/ 156 All these figures have been extrapolated from the original values provided by Eurofeu, which covered approximately 70% of the market. The number of companies that provided a response on whether the foams are used in fixed or mobile systems is lower than those that provided a response for the sectoral overview, therefore in the original data the total tonnage of the former is lower than the latter. To fill this gap, the tonnages for both fixed and mobile systems have been inflated so that their total matches the total in the sectoral split. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 180 Wood Environment & Infrastructure Solutions UK Limited Figure 9.1 Split of PFAS-based fire-fighting foams by sector Ai rports 9% Mi l i tary 6% Ready for use products 1% Ma ri ne a pplications 12% Muni cipal fire bri ga des 13% Chemi cal/ p e tro ch emical 59% Source: Data provided to the authors by Eurofeu. The use of these PFAS-based foams accounts for an annual consumption of around 480-560 tonnes of fluorosurfactants per year in the EU, based on data provided by Eurofeu. Fluorine-free fire-fighting foams As for PFAS-based foams, based on an extrapolation of data provided by Eurofeu it is estimated that some 9,000 tonnes of fluorine-free foams are sold in the EU per year. Of these, about 3,000 tonnes are used in fixed systems and 6,000 tonnes in mobile systems156. The split by sector is detailed in the figure below. Notably, it varies considerably from that of PFAS-based foams, with a much larger share used by municipal fire brigades (44%) but a much smaller share in the chemical/petrochemical sectors (29%). Figure 9.2 Yearly use of fluorine-free firefighting foams by sector. Ai rports 8% Mi l i tary 2% Ready for use products 1% Ma ri ne a pplications 16% Muni cipal fire bri ga des 44% Chemi cal/ p e tro ch emical 29% Source: Data provided to the authors by Eurofeu. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 181 Wood Environment & Infrastructure Solutions UK Limited Exposure Using a source-flow model and various assumptions that are outlined in Section 5, emission estimates have been developed to provide an illustrative assessment to help better understand the material flow and key emission compartments of fire-fighting foams. The source-flow model has been used to produce emission estimates for 10 unique non-fluorinated substances (hydrocarbons and detergents); as well as two PFAS-based substances. Tables 7.5 and 7.6 provide summary overviews (as percentage ratios) of the key emission compartments and life-cycle stages for emissions. The initial overview of Table 7.5 highlights that fresh surface water and soil are the key receiving environmental compartments. Furthermore, Table 7.6 highlights that, for non-fluorinated substances, live incidents are the major point of release, while for PFAS the waste phase is the key lifecycle stage for emissions, primarily from losses associated with releases at WWTPs. Table 9.1 Overview of ratios for emissions by different environmental compartment for all life-cycle stages combined. Substance group Non-fluorinated alternatives (range) Non-fluorinated alternatives (mean average) 1-Propanaminium,N-(carboxymethyl)-N,N-dimethyl-3[[(3,3,4,4,5,5,6,6,7,7,8,8,8tridecafluorooctyl)sulfonyl]amino]-,inner salt 1-Propanaminium, 3-amino-N-(carboxymethyl)-N,Ndimethyl-N-[[(gamma-omega-perfluoro-C6-C16alkyl)thio]acetyl] derives., inner salts *includes releases from WWTPs after treatment. Air 9 - 18% 14% 9% Fresh surface water* 33 -37% 35% 51% Marine waters 10 - 15% 13% 8% Soil 30 - 45% 38% 32% 9% 30% 8% 53% Table 9.2 Overview or ratios for emissions by different life-cycle stages Substance Group Non-fluorinated alternatives (range) Non-fluorinated alternatives (mean average) PFAS based substances (mean average) Formulation 9 - 18% 14% 9% Storage and Training 12 - 18% 15% 9% Live 40 - 62% 52% 30% Waste 1% - 35% 19% 52% Regarding the emissions by environmental compartment, it should be noted that while the non-fluorinated fire-fighting foams make up approximately one third of the market, the volumes of alternative surfactants can be greater than their PFAS counterparts due to greater concentrations within the product itself, potentially leading to higher emissions of the non-fluorinated alternatives. However, it is important to recognise that emission alone is not an indicator of impact, and the degradation rates, potential for bioaccumulation, and harmful effects also need to be considered (as discussed in the previous section). Regarding the emissions by life cycle stage, it should be noted that the major use of fire-fighting foams is for training purposes. During training exercises, aside from marine applications, it is assumed that the efficacy of bunding and/or other control measures is relatively good. This means much of the fire-fighting concentrate within runoff is contained and sent for final destruction primarily within waste water treatment June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 182 Wood Environment & Infrastructure Solutions UK Limited plants (WWTPs) on-site or off-site. For the non-fluorinated alternatives, the effectiveness of WWTPs is relatively good, minimising the emission which is split between surface water and soil. Because WWTPs are more effective in irreversibly destroying the named non-fluorinated substances, their use in training where run-off can be contained and treated leads to relatively low releases to the environment. This increases the relative importance of live incidents - where there is a direct release without treatment. For the PFAS-based substances, WWTPs is expected to be ineffective at treating PFAS, meaning direct release to surface water / soil depending on the partition coefficient. Waste is thus the most important life-cycle stage for the PFAS substances. 9.4 Overview of current measures International Measures Stockholm Convention The Stockholm Convention on Persistent Organic Pollutants (POPs) includes restrictions on the production and use of a number of specific PFAS, at international level, including some provision for exemptions for the production and use of these compounds for use in firefighting foams. PFOS, its salts and PFOSF are listed under Annex B of the Stockholm Convention, which restricts production and use to specified acceptable purposes and specific exemptions. Upon its initial listing in 2009, an acceptable purpose was put in place for PFOS used in firefighting foams. At the POPRC meeting in 2018, the committee recommended, based on the findings of an assessment of alternatives to PFOS157 , that the acceptable purposes for the production and use of PFOS, its salts and PFOSF for fire-fighting foam be amended to a specific exemption for the use of fire-fighting foam for liquid fuel vapour suppression and liquid fuel fires (Class B fires) already in installed systems, including both mobile and fixed systems, and with the same conditions put in place for PFOA (see below). This exemption was agreed accordingly at the Ninth Meeting of the Conference of the Parties (COP) to the Stockholm Convention in 2019. At the 14th meeting of the POPRC in September 2018 the POPRC recommended listing PFOA, its salts and PFOA-related compounds in Annex A to the Convention with specific exemptions. One exemption specified was for use of firefighting foams containing PFOA already installed in systems including both mobile and fixed systems with specific conditions. Parties to the Convention can register for this exemption if they: i) ensure that FFFs that contain or may contain PFOA shall not be exported or imported except for the purpose of environmentally sound disposal; ii) do not use FFFs that contain or may contain PFOA for training or testing (unless all releases are contained) purposes; iii) by the end of 2022 if possible, but no later than 2025, restrict uses of FFFs that contain or may contain PFOA, to sites where all releases can be contained; iv) ensure all fire water, waste water, run-off, foam and other wastes are managed. This was also agreed accordingly at the 9th COP in 2019. At its fifteenth meeting, the POPRC adopted the risk management evaluation on perfluorohexane sulfonic acid (PFHxS), its salts and PFHxS-related compounds and recommended to the Conference of the Parties that it consider listing the chemicals in Annex A to the Convention without specific exemptions. The listing will not be officially adopted until the next COP meeting in May 2021, and would be officially added to the Annexes of the Convention in 2022. 157 UNEP/POPS/POPRC.14/INF/8 : http://chm.pops.int/TheConvention/POPsReviewCommittee/Meetings/POPRC14/Overview/tabid/7398/Default.aspx June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 183 Wood Environment & Infrastructure Solutions UK Limited EU Regulation The European Union has implemented the POPs Regulation (EC 2019/1021)158 which acts to implement the provisions of the Stockholm Convention across the EU Member States. PFOS was originally included in the restricted substances list of REACH. However, since its addition to the Stockholm Convention in 2009, it has been regulated under the POPs Regulation. PFOS, its salts and PFOSF are listed under Annex I of the POPs Regulation, specifying the following exemptions for unintentional trace contaminants (UTC)159: Substances or preparations (<10 mg/kg); and Semi-finished products or articles, or parts (<0.1 % by weight). An exemption is also foreseen for the use as mist suppressant for non-decorative hard chromium plating. PFOA has been identified under REACH as a SVHC since 2013 and it is restricted under entry 68 of Annex XVII. However, the restriction includes an exemption for PFOA used in concentrated fire-fighting foam mixtures placed on the market before 4 July 2020 and those used in the production of other fire-fighting foam mixtures. There is also an exemption for use in fire-fighting foam mixtures produced before 4 July 2020 and used for training purposes, provided that emissions to the environment are minimised and effluents are collected and safely disposed of. The POPs Regulation is expected to be amended in summer 2020 to include PFOA in Annex I following the listing under the Stockholm Convention (see above). The derogations for firefighting foams proposed under the POPs Regulation are more limited compared to the REACH restriction, as the listing under the Stockholm Convention allows no derogation for use in training; it only allows use of foams in installed systems, only until 2022 (or 2025 at the latest), and only with containment requirements. PFHxS, has, since June 2017, also been listed as an SVHC under REACH and there is an ongoing restriction proposal160 (at the time of writing at the stage of public consultation on the SEAC draft opinion). It is expected that PFHxS will ultimately also be regulated at EU-level under the POPs Regulation, when its listing to the Stockholm Convention is finalised (see above). In December 2019, a proposal161 for a restriction under REACH on PFHxA was published. The proposal includes certain transition periods and derogations for uses in fire-fighting foams. It is proposed that concentrated fire-fighting foam mixtures placed on the market until 18 months after the entry into force of the restriction could still be used in the production of other firefighting foam mixtures until 5 years after the entry into force, except for use of fire-fighting foam for training and (if not 100% contained) testing. There is also an exception for concentrated fire-fighting foam mixtures for certain defence applications until a successful transition to alternatives can be achieved, and for concentrated fire-fighting foam mixtures for cases of class B fires in storage tanks with a surface area above 500 m2 until 12 years after the entry into force. Other international controls In 2016, The Swedish Chemicals Agency (KEMI) published its strategy for reducing the use of PFASs162 beyond solely the implementation of EU legislation. This included specific measures to tackle PFAS in firefighting foams, including a proposal for national regulations covering, for example: Legal requirement for the collection and destruction of fluorine-based fire-fighting foam; 158 https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32019R1021&from=EN 159 There is an exemption for the use in hard chromium plating, although that is not relevant for fire-fighting foams. 160 https://echa.europa.eu/registry-of-restriction-intentions/-/dislist/details/0b0236e1827f87da 161 https://echa.europa.eu/registry-of-restriction-intentions/-/dislist/details/0b0236e18323a25d 162 https://www.kemi.se/global/rapporter/2016/report-11-16-strategy-for-reducing-the-use-of-higly-fluorinated-substances-pfas.pdf June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 184 Wood Environment & Infrastructure Solutions UK Limited Imposing reporting requirements; and Review of exemptions - with the aim of reducing the number of exemptions as much as possible. In some non-EU countries, there are also regulations in place, specifically targeting PFAS in firefighting foams. For example, in Norway163, there are regulations in place that focus on the following: The monitoring and screening of PFAS in the environment in general; The monitoring and clean-up of PFAS polluted soil caused by airport fire drills; A requirement for airports to monitor levels of PFAS at their fire drill sites and propose measures to reduce pollution; and A requirement for airports to screen and report levels of PFAS in their soil, and must propose measures to reduce pollution. In the USA, at federal level, the US EPA has developed and launched a PFAS Action Plan164 to evaluate whether and how to regulate PFAS compounds under various federal environmental programmes (including TSCA). The primary focus of this plan is to reduce environmental and public health concerns when PFAS are released into the environment (e.g., through setting safe drinking water limits and remediation criteria). While the plan specifically references the use of firefighting foams as a key source of PFAS contamination and exposure, it does not set limits or actions specifically at national level for use of PFAS in foams. In December 2019, the Fiscal Year 2020 National Defense Authorization Act (NDAA) was released, which phases out the US Department of Defense's use of PFAS-containing firefighting foam by October 2024 (with an exception for shipboard use) and immediately prohibits the uncontrolled release of fluorinated aqueous film-forming foam (AFFF) and the use of AFFF in training exercises at military installations165. It should be noted that individual States also implement their own measures, and there is a wide variety of approaches, measures, and timescales adopted. As an example of some of the States with the strictest approaches: Washington bans the sale and the use for training purposes of PFAS-based fire-fighting foams from 1 July 2020 (except for oil refineries, chemical plants and uses required by federal law such as aircraft rescue)166; and In California, a bill was proposed to the Senate (but not yet passed at the time of writing) to ban, from the beginning of 2022, the placing on the market of fire-fighting foams with intentionally added PFAS, except for uses required by federal law. It also requires manufacturers to recall products affected by the ban by that date, practically banning the use as well167. In Australia, the biggest source of concentrated emissions of PFAS is from historical use of PFAS-containing fire-fighting foams, particularly at fire-fighting training grounds. The Industrial Chemicals (Notification and Assessment) Act (ICNA Act), requires industry to provide toxicity data for new substances (including PFASs) or products containing new PFASs being introduced into Australia. Based on the level of toxicity and environmental persistence, the National Industrial Chemicals Notification and Assessment Scheme (NICNAS) recommends restrictions on how these substances can and cannot be used168. 163 https://www.oecd.org/chemicalsafety/portal-perfluorinated-chemicals/countryinformation/norway.htm 164 https://www.epa.gov/sites/production/files/2019-02/documents/pfas_action_plan_021319_508compliant_1.pdf 165 https://armedservices.house.gov/_cache/files/f/5/f50b2a93-79aa-42a0-a1aad1c490011bae/3552B8ED0CB74FB28CC88F434EFB306A.fy20-ndaa-conference-summary-final.pdf 166 http://lawfilesext.leg.wa.gov/biennium/2017-18/Pdf/Bills/Senate%20Passed%20Legislature/6413S.PL.pdf?q=20200413062702 167 https://leginfo.legislature.ca.gov/faces/billCompareClient.xhtml?bill_id=201920200SB1044&showamends=false 168 https://www.oecd.org/chemicalsafety/portal-perfluorinated-chemicals/countryinformation/australia.htm June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 185 Wood Environment & Infrastructure Solutions UK Limited Industry Measures Substitution and phase-out As noted in several documents under the Stockholm Convention, for over a decade, a number of alternatives to the use of C8-based fluorosurfactants (containing PFAS) in fire-fighting foams have been developed and are now widely available. These include shorter-chain (C6) fluoro-surfactants, as well as fluorine-free firefighting foams; and other developing fire-fighting foam technologies that avoid the use of fluorine. The use of C8-based AFFF has been largely phased out in favour of these alternatives. For example, it is reported that the volume of AFFF-containing PFOS used in the USA declined from around 21 million litres in 2004 to less than 9 million litres in 2011169. The POPRC officially recognises that a transition to the use of short-chain per- and polyfluoroalkyl substances (PFAS) for dispersive applications such as fire-fighting foam is not a suitable option from an environmental and human health point of view and that some time may be needed for a transition to alternatives without PFAS (POPRC-14/3). In the USA, in 2006, the US EPA launched the PFOA Stewardship Program following concerns raised about the impact of PFOA and long-chain PFASs on human health and the environment, including concerns about their persistence and presence in the environment170. The programme involved eight major companies171 committing to reducing PFOA from facility emissions and product content by 95 percent no later than 2010, and to work toward eliminating PFOA from emissions and product content no later than 2015. All participating companies state in the most recent progress reports, that they met the PFOA Stewardship Program goals172. In Australia, it has been reported that the Department of Defence commenced phasing out its use of PFOS and PFOA-containing fire-fighting foams and switched to `Ansulite', which only contains trace elements of PFOS/PFOA and is only used in emergency situations or in controlled environments to test equipment. Furthermore, PFAS use is also limited by Air Services Australia, a government-owned corporation that provides air traffic control management, which has transitioned away from fluorinated firefighting foam to non-fluorinated firefighting foam including the destruction of remaining stockpiles173. Containment and control In Germany174, it is reported that the regulatory authorities and fire-fighting associations have compiled a leaflet on PFAS in fire-fighting, which has reportedly resulted in an increased awareness of the risks associated with certain PFASs by industry, NGOs and the public. In Norway175 it is reported that fluorine-containing fire-fighting foam has been substituted with fluorine-free alternatives in most civil airports and fluorine-containing foam is no longer in use at fire-fighting training sites with the Norwegian military forces. Furthermore, it is reported that PFAS are being gradually substituted with fluorine free-alternatives in the offshore sector, and the volumes of fluorine-containing foam used in this sector are decreasing. One respondent to the consultation questionnaire conducted for this project reported that the Swedish Petroleum and Biofuels Institute has previously (2011) provided guidance on how to plan and implement the 169 FFFC (2011) Estimated Inventory Of PFOS-based Aqueous Film Forming Foam (AFFF). 2011 update to the 2004 report entitled "Estimated Quantities of Aqueous Film Forming Foam (AFFF) In the United States". Prepared for the Fire Fighting Foam Coalition, Inc. 170 https://www.epa.gov/assessing-and-managing-chemicals-under-tsca/fact-sheet-20102015-pfoa-stewardship-program 171 Arkema, Asahi, BASF, Clariant, Daikin, 3M/Dyneon, DuPont, Solvay Solexis 172 https://www.epa.gov/assessing-and-managing-chemicals-under-tsca/20102015-pfoa-stewardship-program-2014-annual-progress 173 https://www.oecd.org/chemicalsafety/portal-perfluorinated-chemicals/countryinformation/australia.htm 174 https://www.oecd.org/chemicalsafety/portal-perfluorinated-chemicals/countryinformation/germany.htm 175 https://www.oecd.org/chemicalsafety/portal-perfluorinated-chemicals/countryinformation/norway.htm June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 186 Wood Environment & Infrastructure Solutions UK Limited prevention of spillage and secondary containment embankments, methods for emergency response, and for the assessment and preventing product tanks to lift off inside water filled bunds/embankments. It was estimated that ~80 % of the member companies were in compliance with this guidance. The trade association, the Fire Fighting Foam Coalition (FFFC) has published a best practice guidance document for the safe use of firefighting foams for Class B fires176, with the aim to "foster use of foam in an environmentally responsible manner so as to minimize risk from its use". The guidance covers the following aspects of Class B firefighting foam use: Foam Selection - specifying situations where the use of Class B foams is, and is not, recommended, e.g. limiting the use of Class B foams to situations that present `a significant flammable liquid hazard'; Eliminating Foam Discharge - noting that this is not always possible in emergency situations, but emphasising the possibility to achieve this in training and the testing of foam systems and equipment; Training - providing guidance on the formulation of training foams, the design, construction and operation of training facilities; Foam System Testing - including guidance on acceptance tests, conducted pursuant to installation of the system; and maintenance tests (i.e. of firefighting vehicles); Containing Foam Discharge - guidance to prevent discharge to the environment, both for manual and fixed systems; and Firewater and foam concentrate disposal - with an emphasis on incineration but also covering coagulation, flocculation, electro-flocculation, reverse osmosis, and adsorption on granular activated carbon (GAC). Similarly, the Fire Protection Association Australia has published a guidance document on the selection and use of firefighting foams177. This covers, for example, Factors impacting on selection and use - including firefighting performance, environmental impact, system and equipment compatibility; Environmental and firefighting performance indicators; Fluorinated and fluorine-free firefighting foams; and Environmental best practice - including training and system testing and commissioning, fire water effluent, remediation of contaminated soil and water, cleaning/change out of existing foams. The consultation did not yield information on the extent to which these best practice measures outlined by the likes of the FFFC and FPAA are being implemented, or their effectiveness. 9.5 Need for (further) regulatory management Section 9.2 has illustrated that (without precluding any ongoing work or conclusions by the PFAS working group) there are concerns associated with PFAS. Some PFAS have been shown to cause reproductive and developmental, liver and kidney, and immunological effects as well as tumours in animal studies. Many PFAS 176 Covering aqueous film-forming foam (AFFF), alcohol resistant aqueous filmforming foam (AR-AFFF), film-forming fluoroprotein foam (FFFP), alcohol resistant film-forming fluoroprotein foam (AR-FFFP), and fluoroprotein foam (FP, FPAR). 177 FPA Australia (2017) June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 187 Wood Environment & Infrastructure Solutions UK Limited are highly mobile, highly persistent, and have the potential to accumulate within the environment and living organisms. The assessed non-fluorinated alternatives' persistence is considerably lower than PFAS. Section 9.3 has shown that, while in some user sectors PFAS-based foams have been increasingly replaced by fluorine-free alternatives and industry best practice guidance recommends not using PFAS-based foams in training and testing, some 20,000 tonnes of PFAS-based fire-fighting foams are still used annually in the EU in applications involving flammable liquid fires (Class B fires), including testing and training. This use leads to releases to the environment, with fresh surface water and soil being the key receiving environmental compartments. For non-fluorinated substances, live incidents are the major point of release, while for PFAS the waste phase is the key life-cycle stage for emissions, primarily from losses associated with releases at WWTPs. Some PFAS were shown to be ubiquitous contaminants, for instance in arctic wildlife178. Section 9.4 illustrated that the use of certain PFAS substances has been regulated in the past. This has led to the replacement of the regulated (e.g. long-chain) PFAS with fluorine-free alternatives in some cases, but also other PFAS substances (e.g. short-chain PFAS), as illustrated by the fact that the majority of fire-fighting foams used are still PFAS-based. Concerns have continued that shorter chain PFAS substances are also mobile (if not more mobile) than C8 substances and are highly persistent, albeit with potentially lower bioaccumulation179. Some (PFHxS, PFBS, HFPODA) have also been listed as SVHCs, based on there being an equivalent level of concern to the named groups of chemicals under the authorisation provisions under REACH (carcinogens, mutagens and reprotoxicants (CMRs) and persistent, bioaccumulative and toxic/very persistent and very bioaccumulative (PBTs/vPvBs) chemicals). National regulations exist that require the containment of fire-water run-off, but the consultation suggested that containment is rarely 100% effective and there are concerns about the efficacy of removal of PFAS from collected fire-water in WWTP. Industry best practice measures aim to minimise the use and release of PFASbased foams (e.g. ceasing its use in training and testing, as has happened in many locations already) but the consultation suggested that these are not being fully implemented (e.g. the use of PFAS-based foams in training has been reported). Stakeholder input did not allow to conclude on their relative effectiveness. In conclusion, it has been demonstrated that the use of PFAS in fire-fighting foams is associated with a significant environmental concern that does not seem to be adequately addressed by the current measures in place. Even if additional measures were introduced at Member State level (and the consultation has not raised anything suggesting that they will be), there is potential for discrepancies in the definitions and scope of any national restrictions (e.g. definition of substances covered, uses covered, concentration thresholds, transition periods). This has implications not only for the degree to which the environment is protected, but also in terms of ensuring the functioning of the internal market. Different restrictions in different Member States could make it very challenging to market fire-fighting foam products saleable in all Member States. Moreover, due to their high mobility and persistence as well as their proven ubiquity (at least of some PFAS), it appears very likely that PFAS emissions lead to cross-border pollution. Therefore potential further regulatory management on EU-level is likely required. Potential options are discussed in the following section. 9.6 Identification and assessment of regulatory management options This section identifies the different options and assesses their suitability. The assessment follows relevant ECHA guidance180 on Annex XV for restrictions based on the following criteria (ECHA 2007): 178 See for instance Muir, D. et al. (2019): Levels and trends of poly-and perfluoroalkyl substances in the Arctic environment-An update. Emerging Contaminants, 5, 240-271. 179 Cousins et al, 2018, `short-chain perfluoroalkyl acids: environmental concerns and regulatory strategy under REACH', Environmental science Europe vol 30. Appendix 3 180 ECHA (2007) Guidance for the preparation of an Annex XV dossier for restrictions, available from: https://echa.europa.eu/documents/10162/23036412/restriction_en.pdf/d48a00bf-cd8d-4575-8acc-c1bbe9f9c3f6 June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 188 Wood Environment & Infrastructure Solutions UK Limited Effectiveness: Is the option targeted at the effects or exposures that cause the identified risks, capable of reducing these risks to an acceptable level within a reasonable period of time, and proportional to the risk? Practicality: Is the option implementable, enforceable and manageable? Monitorability: Is it possible to monitor the implementation of the option? and Considerations relating to alternatives and socio-economic impacts. It was agreed in discussions with the steering group to assess two main regulatory management options (RMOs): 1) Restriction (ban) on the placing on the market of PFAS-based fire-fighting foams (hereafter referred to as Scenario 1). The use of legacy foams, i.e. foams already in stock at producers' or users' sites, is still permitted; and 2) Restriction (ban) on the placing on the market and the use of PFAS-based fire-fighting foams (hereafter referred to as Scenario 2). The legacy foams, i.e. foams already in stock at producers' or users' sites, should be disposed of safely. In the following, first these two main options are discussed and compared. Then, the specific conditions of the restrictions are discussed across both options, including potential sector- or application-specific conditions, transition periods, allowed residual PFAS concentrations in foams and the application of specific Risk Management Measures (RMMs). Comparison of the RMOs Effectiveness Both scenarios will eventually lead to an elimination of the use and therefore the emissions of PFAScontaining fire-fighting foams. Therefore, they can both be considered effective in addressing the identified concern. The reduction of emissions would be achieved more quickly in Scenario 2 and therefore Scenario 2 would also achieve a higher reduction of cumulative PFAS contamination. The shelf life of PFAS-based foams is reported to be typically between 10 and 20 years (to a maximum of 30 years)181, so in Scenario 1 some (decreasing) emissions of PFAS-based foam could continue for a long period after the entry into force of the restriction. Based on the annual sales and average lifetime of fire-fighting foams, it is estimated that the stocks of PFAS-based fire-fighting foams in existing systems may be between 210,000 and 435,000 tonnes (see Section 8.1). However, it is uncertain what share of foams in existing systems would be used (and hence to some extent emitted) and what share would be replaced at the end of their shelf life or replaced voluntarily (and hence disposed of safely). It should be noted that in Scenario 2, there are potential risks of emissions from the incineration of legacy foams, but further research is needed to identify and quantify the emissions produced from the incineration of PFAS. Practicality and monitorability In principle, both options appear practical and monitorable, as there are already other regulations in place controlling the placing on the market and use of fire-fighting foams. However, as Scenario 2 covers the use in addition to the placing on the market (which is also covered under Scenario 1), it is subject to more complex 181 Proposal for a restriction: Perfluorohexane sulfonic acid (PFHxS), its salts and PFHxS-related substances https://echa.europa.eu/documents/10162/a22da803-0749-81d8-bc6d-ef551fc24e19 June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 189 Wood Environment & Infrastructure Solutions UK Limited requirements in terms of implementation, enforcement, management and monitoring, compared to Scenario 1. One stakeholder pointed out the following practicality issue for Scenario 1. When large amounts of foam are used for an incident, foam tanks need to be quickly refilled to allow continued operation, sometimes even during the same incident. However, it is not recommended to mix different foams in the same system (because this could affect performance and the new foam would be contaminated with PFAS from the old foam), so refilling during an incident would not be feasible if PFAS-foam was used in existing systems. This could potentially lead to end-users building up stocks of PFAS-based foams before the restrictions comes into place, or it could potentially lead to users not replacing foams in existing systems to save costs causing problems during a large incident when a refill during the incident would be needed. Socio-economic impacts The socio-economic implications of both scenarios are discussed in more detail in Section 8 (Section 8.3 in particular summarises the overall impacts and the differences between the two scenarios). However, a briefer summary of key points is provided here to support the conclusions of this section. Both scenarios require purchasing of alternative foams which is estimated to incur additional costs (compared to the baseline) of around 27m per year in the EU. In Scenario 2, these costs would be incurred immediately when the restriction comes into force (or before), whereas in Scenario 1 the costs increase gradually and only reach 27m per year once all stocks are depleted. This would be partly off-set by savings, e.g. from lower disposal cost of fluorine-free foams when they reach their expiry date. However, Scenario 2 would also require existing stocks of PFAS-based foams (estimated 210,000-435,000 tonnes) to be written off (considering depreciation since their purchase), and new stocks would have to be purchased, subject to replacement costs (minus the value of existing stocks already depreciated) estimated at around 1.0 billion (range -60 million182 to 8.3 billion). In Scenario 2, additional costs would also be incurred for the disposal of the existing stocks of PFAS-based foams. Total EU costs (one-off) are estimated at up to 320 million (range up to 60m-4.8bn) depending on the method used and the share of foams that would have reached expiry date without use (whose disposal is merely brought forward by the restriction, but costs are not additional to the baseline). There is a trade-off between the disposal costs and the mitigation of potential environmental risks from disposal (as discussed above). Additional transport, storage and labour costs have not been quantified. There are other potential economic costs for transitioning that are difficult to quantify, of which cleaning/replacement of equipment before switching the foam are likely the most important. These costs could be significant (e.g. cleaning could potentially be in the order of 1 billion, depending on the residual concentration limit and number of installations affected). They are not likely to vary significantly across the two options but could be more spread over time under Scenario 1. Alternatives are generally considered to be technically feasible in most applications. Further testing is required to confirm the technical feasibility of alternatives for specific applications, particularly large atmospheric storage tanks. The speed of fire suppression may be slower and application of foams may be less flexible and less easy to use (e.g. different foams may be needed for different flammable liquids), in some cases. In Scenario 1 some of these risks would be mitigated for as long as stocks of PFAS-based foams in existing systems are being used for the cases in question. There are potentially significant benefits in terms of reduced clean-up / remediation costs. As a very high level estimate for illustration, the potential order of magnitude of avoided remediation could be hundreds of millions or Euros (assuming tens of sites requiring remediation at tens of millions of Euro per site) to billions of Euros (assuming hundreds of sites requiring remediation at tens of millions of Euro per site). More 182 I.e. a potential saving of 60 million, if fluorine-free alternatives are less expensive than the PFAS-based foams they replace (possible in some cases but unlikely on average) and no additional volumes are required. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 190 Wood Environment & Infrastructure Solutions UK Limited information on the total number of sites, real-world use of PFAS per site as well as implementation and effectiveness of best practices in terms of containment and immediate clean-up would be required to assess to which extent remediation is likely to be required in the future as a result of current use of PFAS-based firefighting foams (and could therefore be avoided because of the restriction). Any such benefits would be higher in Scenario 2, given the quicker elimination of PFAS emissions and higher reductions of accumulated PFAS contamination. Treatment of fire-water run-off and short-term clean-up after the use of fire-fighting foams is largely driven by other components of the fire-water run-off, rather than the foam used. At least in some cases, run-off treatment costs could be around 0.7 per litre (range ca 0-11) or up to tens of millions of Euro per incident cheaper when fluorine-free foams are used, but data on the total amount of fire-water run-off treated was lacking to quantify an EU total. In cases where fire-water run-off is not contained and further clean-up is possible, clean-up costs may also be lower for fluorine-free foams due to their lower persistence. No specific data was available to quantify this saving, but for illustration the potential order of magnitude of savings be could be several million Euros (assuming several tens of incidents per year using PFAS-based foams where clean-up is required and which could be avoided if fluorine-free foams were used). Again, any such benefits would be higher in Scenario 2, given the quicker elimination of PFAS emissions and higher reductions of accumulated PFAS contamination. It is considered unlikely that either scenario will cause any significant macroeconomic impacts (e.g. employment, trade). Conclusion The key consideration in judging and comparing the appropriateness of the two RMOs is the balance between their effectiveness (i.e. the reduction of PFAS emissions) and their socio-economic impacts (primarily the costs of transitioning to fluorine-free foams and potentially fire-safety risks from using alternatives, offset partly by benefits of reduced clean-up / remediation). As the environmental/health benefits of reduced PFAS emissions (and indeed some of the socio-economic impacts) could not be quantified, it is not possible to use cost-benefit analysis to directly assess if the proposed intervention is proportionate. ECHA's approach to the "Evaluation of restriction reports and applications for authorisation for PBT and vPvB substances in SEAC"183 uses the cost per unit (e.g. kilogram) of emission reduced. Based on the quantifiable socioeconomic impacts, as a central estimate, it was calculated that the cost effectiveness could be around 850 (Scenario 1) to 1,700 (Scenario 2) per kg of annual reduction of PFAS emissions. However, this could range from savings in the 10s per kg to costs around 10,000 per kg.184 Therefore, the approach adopted in the following is to identify the uses/applications and conditions (transition periods, concentration thresholds, other risk management measures) that would achieve relatively high levels of effectiveness (i.e. reductions of PFAS emissions) with relatively small adverse socio-economic impacts. Specific conditions for different uses The various user sectors and applications of fire-fighting foams vary significantly in terms of the potential for a restriction to reduce PFAS emissions to the environment (`PFAS risk reduction potential'), the feasibility of transitioning to fluorine-free alternatives (`substitution potential') and the resulting potential socio-economic 183 https://echa.europa.eu/documents/10162/13580/evaluation_pbt_vpvb_substances_seac_en.pdf/af4a7207-f7ad-4ef3ac68-685f70ab2db3 184 The wide variance of the range is primarily due to the significant uncertainty associated with the quantification of some costs and benefits. For instance, a saving could be achieved if the benefits in terms of reduced costs for clean-up and fire-water-run-off treatment are at the higher end of their estimated ranges and the costs in terms of disposal of stocks, cleaning of equipment, replacement of foam stocks are at the lower end of their estimated ranges, and vice-versa for the highest possible emission reduction costs per kg. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 191 Wood Environment & Infrastructure Solutions UK Limited impacts of that transition. Therefore, it may be appropriate for regulatory management to set different conditions for the different sectors and applications, in order to balance the effectiveness of the measure with considerations around feasibility of alternatives and socio-economic impacts. Table 9.3 summarises and compares substitution potential, socio-economic impacts and PFAS risk reduction potential across the main identified user sectors. Testing and training (across all sectors) are included separately because they vary significantly from application in actual fire incidents. The rows for user sectors refer to the use in actual fire incidents. Value judgements ("low", "high" etc.) are relative, based on a comparison between the different sectors and applications. A higher substitution potential, lower socioeconomic impacts and a higher risk profile would suggest that stricter conditions can be imposed on the use/application in question, and vice versa. Conclusions are drawn below the table. Table 9.3 Comparison of substitution potential, socio-economic impacts and PFAS risk reduction potential of different user sectors and applications Use / application Chemical / petrochemical Marine Applications Military Civil Aviation Municipal Fire Services Substitution potential Potential socio-economic impacts PFAS risk reduction potential Low for some applications, medium/high for others: Sector includes many different and complex scenarios. Alternatives have successfully been implemented for some applications but may not be readily available for others. In particular, additional testing required to confirm feasibility of alternatives for large atmospheric storage tanks. High: By far the largest user (59% of annual sales), so transition is large scale. Highest potential fire-safety risks from using alternatives, although relatively low risk of danger to human life. High: By far the largest user (59% of annual sales), average potential for retention of run-off and clean-up after incidents. High: Feasible alternatives considered to be available and have successfully been implemented by many users. Medium: Average user (12% of annual sales), average potential for fire-safety risks from using alternatives. Very high: Average user (12% of annual sales), likely lowest potential for retention of run-off and clean-up after incidents. Medium: Feasible alternatives considered to be available but not many have been certified or implemented by users yet. Medium/High: Relatively small user (6% of annual sales), so relatively small scale of transition. Average potential for fire-safety risks from using alternatives, which could result in a relatively high potential of danger to human life. Medium: Relatively small user (6% of annual sales), average potential for retention of run-off and clean-up after incidents. High: Feasible alternatives considered to be available and have successfully been implemented by many users. Medium/High: Relatively small user (9% of annual sales), so relatively small scale of transition. Average potential for fire-safety risks from using alternatives, but any risks would result in a relatively high potential of danger to human life. Medium: Relatively small user (9% of annual sales), average potential for retention of run-off and clean-up after incidents. High: Feasible alternatives considered to be available and have successfully been implemented by many users. Low: Average user (12% of annual sales), so average scale of transition. Low potential for fire-safety risks from using alternatives. High: Average user (12% of annual sales), likely lower potential for retention of run-off and clean-up after incidents because not restricted to specific industrial sites. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 192 Wood Environment & Infrastructure Solutions UK Limited Use / application Ready to use applications Testing Training Substitution potential Potential socio-economic impacts High: Feasible alternatives considered to be available. They have not yet been implemented by many users but ready to use applications rarely deal with large flammable liquid fires, so there is very little need for high performance foams. Low/Medium: Relatively small user in terms of quantities (1% of annual sales according to Eurofeu data, several % based on estimated number of all fire-extinguishers) but potentially large number of devices affected (including millions of fire extinguishers). Very low potential for fire-safety risks from using alternatives. Very high: Feasible alternatives considered to be available and have successfully been implemented by many users. No need for high performance foams. Very low: Likely very small share of use, not the most expensive high performance foams required. Very low risk of damages resulting from performance of alternatives. Very high: Feasible alternatives considered to be available and have successfully been implemented by many users. Little need for high performance foams. Low: Likely very large share of use, but likely not the most expensive high performance foams required. Low risk of damages resulting from performance of alternatives. PFAS risk reduction potential Medium/High: Relatively small user, likely lower potential for retention of run-off and clean-up after incidents because not restricted to specific industrial sites. Low: Likely very small share of use, relatively high potential for retention. Low/Medium: Likely very large share of use, but relatively high potential for retention. The comparison in the table suggests that training and testing should be the highest priority for a quick transition to fluorine-free foams, because the use of alternatives is well established and already recommended as industry best practice. Training accounts for the majority of fire-fighting foam use (although likely not for the majority of emissions) and the potential for adverse socio-economic impacts is very low for training and testing. Chemical / petrochemical are the largest user sector meaning that the costs of transitioning but also the current risk of PFAS emissions are higher. However, derogations with a longer transition period may be needed for specific applications (notably large tank fires) where the substitution potential is currently low (further testing is required to determine the technical feasibility of alternatives) and potential fire-safety risks from using alternatives are high. In these specific cases the socio-economic implications could outweigh the potential benefits in terms of PFAS emissions until more suitable alternatives have been developed and tested. Note that further testing on the feasibility of alternatives is planned by LASTFIRE185 between April and July 2020 (although this may well be postponed due to the COVID-19 pandemic). A quick transition in marine applications should be a high priority due to its low potential for retention of run-off and clean-up after incidents, and established alternatives. Municipal fire services and ready to use applications should also be priorities for a quick transition because alternatives are well-established and these sectors may involve fire incidents outside of specific industrial sites where there is a risk that retention of run-off and clean-up after incidents are more difficult. Alternatives are less well established in the military sector, but they are considered to be feasible by stakeholders and the applications are similar to those of other similar sectors (with similar activities such as aerospace), where substitution has taken place. Transition is probably possible but requires extra care 185 A project by the oil and petrochemical industries to assess fire hazards of Large Atmospheric Storage Tanks (see www.lastfire.co.uk). June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 193 Wood Environment & Infrastructure Solutions UK Limited because if the use of alternative caused any fire-safety risks, the potential damages could be significant and could include danger to human life. Also in civil aviation there is the concern that if the use of alternative caused any fire-safety risks, the potential damages could be significant and would likely include danger to human life. However, alternatives are considered feasible and have successfully been implemented by many users (e.g. the airports of Dubai, Dortmund, Stuttgart, London Heathrow, Manchester, Copenhagen, Australia and Auckland), so this is considered unlikely and a relatively quick transition should be sought, as has been achieved elsewhere. Transition periods recommended for the various sectors are further discussed in the following section. Transition periods Several users have provided input on manageable transition periods: One stakeholder claimed that a transition time of 10 years would be needed for the switch in the O&G / petrochemicals sector. Another stakeholder from the same sector cited 5-10 years, in order to minimise and spread the costs to change foam and re-build, or re-place fire extinguishing systems or equipment, but they would like to keep PFAS stocks in case of a big fire incident. As reported in the case study in Section 7.6, Equinor took around 8 years to transition to fluorine-free foams; An industrial end user under consideration of discussions with some representatives from aviation industry groups and municipal users has developed a detailed draft proposed timeline covering a range of tasks required for a full transition to fluorine-free foams (across all sectors). The full timeline is provided in Appendix 4, but key milestones suggested are (years from formal start of transition and introduction of legislation): No more PFAS foam use in training: Immediately; No more PFAS foam use in systems testing: 4 years; No more PFAS foams used for small incidents: 4 years; and Completion of transition: 10 years. The additional 6 years from the previous steps is largely driven by further replacement and disposal of stocks of legacy foam186, as well as the need for further development of fluorine-free foams by manufacturers. A stakeholder from the aerospace and defence sector suggested the system change to enable use of non-PFAS foam could be introduced at time of major refit, which typically occurs every 6 -12 years. On the other hand, the US Fiscal Year 2020 National Defense Authorization Act (NDAA) requires a phase-out of PFAS-containing firefighting foam in the US military (except on ships) by October 2024, i.e. within 4 years; Several stakeholders across different sectors stated at the workshop or in response to the written consultation that 3-6 years may be sufficient; One stakeholder suggested different transition periods for different uses. They explained municipal fire brigades should be able to transition quicker than operators of fixed installations for example. They argued that the use of fluorine free foam for tank fire fighting needs further testing and therefore more time; and The PFHxA proposed restriction foresees the following transition periods: Concentrated firefighting foam mixtures placed on the market until 18 months after the entry into force of the restrictions can be used in the production of other firefighting foam mixtures until 5 years after 186 Note that this does not necessarily imply that no more PFAS based foams are purchased during that period. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 194 Wood Environment & Infrastructure Solutions UK Limited the entry into force, except for use of fire-fighting foam for training and (if not 100% contained) testing. There is also an exception proposed for concentrated fire-fighting foam mixtures for certain defence applications until a successful transition to alternatives can be achieved, and for concentrated fire-fighting foam mixtures for cases of class B fires in storage tanks with a surface area above 500 m2 until 12 years after the entry into force.187 In conclusion, different transition periods have been considered appropriate for different uses. Successful transition to fluorine-free foams for training and testing has been reported by stakeholders across sectors and is already recommended as industry best practice. Therefore, a transition period may not be required for training and testing. In terms of the use for real fire incidents, oil and gas / petrochemicals are the only sector where users have suggested a longer transition period of up to 10 years is required, to conduct further testing of the feasibility of alternatives for large atmospheric storage tanks (LAST), among other things. This is broadly consistent with the reported duration of the transition by Norwegian oil and gas company Equinor (see case study 2 in Section 7.6), which took about 8 years from development and testing to full operation of fluorine-free alternatives. Oil and gas / petrochemicals is the largest user sector, so in order to ensure effectiveness of the regulation in reducing PFAS-emissions, the transition period should be limited to the most sensitive applications within this sector, particularly large incidents and LAST. For small incidents as well as all other sectors (e.g. marine applications, military, civil aviation, municipal fire services, ready to use applications), shorter transition periods between 3-6 years have been suggested and are expected to minimise socio-economic implications of the restriction. Concentration thresholds There are two main considerations to choose appropriate thresholds for remaining PFAS-contamination in fire-fighting foams: The costs of cleaning and replacement of equipment which are strongly dependent on the concentration threshold chosen, and detection limits. Costs of cleaning and achievable/detectable concentrations are discussed in more detail in Section 10.2 (subsection a. Cleaning of equipment), but key messages are summarised below. The following thresholds were considered feasible by consulted stakeholders (all have been converted to ppb): Regulation in Queensland (Australia) allows up to 10,000 ppb for PFOA/PFHxS and 50,000 ppb for PFOA and PFOA related precursors and higher homologues. One stakeholder recommended these to be adopted in the EU as well; One stakeholder that has transitioned to fluorine-free foams (in the petrochemicals sector) reported that they had aimed for and achieved a level of 0.001% (10,000 ppb); One stakeholder reported experience with a relatively simple cleaning process (emptied tank, flushed two times with warm water) which can lead to very low remaining PFAS contamination (both when tested immediately and after a few years), but cautions a threshold below 100 ppb would be unrealistic; Two stakeholders suggested 1 ppb as the lowest achievable concentration in most cases. One of them linked this to a 32-stage legacy foam decontamination process costing 12,300 per appliance. In one-third of appliances this process can yield concentrations even lower (below 0.07ppb); and In terms of the lowest detectable concentrations, one stakeholder suggested laboratories are reported to be able to analyse down to a level of 30-150 ppb. This is contradicted by other stakeholders that cite lower concentrations having been achieved and tested (see above). In the REACH restriction on PFOA, a concentration limit of 25 ppb of PFOA including its salts or 1,000 187 Note that these transition periods and exemptions may change when (and if) the proposal is taken forward. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 195 Wood Environment & Infrastructure Solutions UK Limited ppb of one or a combination of PFOA-related substances was adopted, based on the capabilities of analytical methods according to the RAC's opinion on the restriction dossier. In conclusion, there was a wide divergence in opinion on appropriate concentration thresholds ranging from 1ppb to 50,000ppb. The available information suggests that 100 ppb can be achieved with a relatively simple cleaning process (cost likely low but not quantified) while 1 ppb is achievable with more complex and costly processes (in the order of 12,300 per appliance according to one estimate). Given this is based on a very small number of estimates, it appears advisable to seek further input on the costs of achieving a specific concentration in any consultation as part of a potential future restriction proposal. Furthermore, a balance would need to be struck between the amount of PFAS emissions remaining if a given threshold is adopted, versus the costs of cleaning imposed in order to achieve that threshold. For example, if the concentration of PFAS in fluids in use is currently perhaps 0.5% (5 million ppb), a threshold of 100 ppb would represent a reduction in concentration (and hence emissions) of 99.998%, while a threshold of 50,000 ppb would represent a reduction in concentration and emissions of 99.0%. Other risk management targeted at reducing release Industry best practice guidance (e.g. from the Fire Fighting Foam Coalition188) and regulations or guidelines in some EU Member States (e.g. England and Wales189, Bavaria190) already recommend or impose a range of measures to reduce the risk to the environment from the use of fire-fighting foams (see Section 9.4). These cover for instance containment, treatment, and proper disposal of foams and fire water run-off. However, it is not clear to what extent these practices are being implemented or what their relative effectiveness is. Stakeholder input to the consultation has also highlighted the importance of such measures to reduce emissions of PFAS-based foams, with recommendations made to legally impose retention systems, proof of proper disposal of any contaminated water/liquid, and use of appropriate PPE and cleaning procedures for after-use treatment. At the workshop, a stakeholder also suggested supporting the transition with mandatory fire management plans for every site, which would include a description of the procedure and reasons for the procurement of the specific fire-fighting foams, their storage, use, recovery, containment and treatment. They also proposed setting up centrally managed stocks at specific, well-contained sites in large industrial areas that could be made available to potential users in case of emergencies, in order to control and restrict the use of PFASbased foams to only the necessary applications during the transition period. This suggestion could help reduce the risk to the environment while allowing a potentially longer period to transition to alternatives, particularly for large industrial sites. In conclusion, it is advisable to further investigate a potential obligation to apply best practice emission reduction measures during and after the use of PFAS-based fire-fighting foam, particularly during the transition periods when PFAS-based foams continue to be used in certain applications and if the use of existing foams is not restricted (scenario 1). 9.7 Conclusions on the most appropriate (combination of) regulatory management options Section 9.5 discussed the need for further regulatory management of the concerns associated with the use of PFAS in fire-fighting foams, based on the following: 188 https://www.fffc.org/ 189Environmental Protection Handbook for the Fire and Rescue Service, https://www.ukfrs.com/sites/default/files/201709/Environment%20Agency%20and%20DCLG%20environmental%20handbook.pdf 190 https://www.oecd.org/chemicalsafety/portal-perfluorinated-chemicals/countryinformation/germany.htm June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 196 Wood Environment & Infrastructure Solutions UK Limited Significant hazards have been shown at least for some PFAS, including some short-chain PFAS (not precluding any ongoing work or conclusions by the PFAS working group which were not available for this report); Many PFAS are highly mobile, highly persistent, and have the potential to accumulate within the environment and living organisms; The continued use of PFAS-based fire-fighting foams and resulting releases to the environment; and A lack of existing regulation, and of implementation or proven effectiveness of other risk management measures to address the release of PFAS from the use of PFAS-based fire-fighting foams. It was agreed in discussions with the steering group to focus on assessing potential designs of a restriction, rather than comparing a restriction with alternative types of measures. However, a restriction appears to be an appropriate option because: Alternatives are considered feasible for most applications (all except large atmospheric storage tanks), so that PFAS emissions can be eliminated by using fluorine-free products; and Other risk management measures that could reduce release of PFAS to the environment are available and are to some extent already being applied; however, these appear unlikely to eliminate the emissions of PFAS from the use of fire-fighting foams as effectively. It appears advisable to address the concern at EU-level, because there is no indication that Member State measures will be forthcoming, and any potential discrepancies in national-level management could have implications for the degree to which the environment is protected and for the functioning of the internal market for fire-fighting foam products. Furthermore, due to their high mobility and persistence as well as their ubiquity (at least of some PFAS), it appears very likely that PFAS emissions could lead to cross-border pollution. Section 9.6 assessed the potential conditions of a restriction, in terms of whether it would ban only the placing on the market of PFAS-based fire-fighting foams, or both the placing on the market and the use of those foams. Potential variations across different user sectors, transition periods, concentration thresholds, and potential combination with other risk management measures are also relevant. Two main options have been considered: A ban on the placing on the market would allow continued use of existing stocks of PFASbased fire-fighting foams, which have been estimated at between 210,000 and 435,000 tonnes. PFAS emissions related to their use could continue, and this may last for some 10-30 years after the entry into force of the restriction, based on the shelf-life of fire-fighting foams. When stocks are depleted, users would need to buy alternative foams incurring additional costs (compared to the baseline) of around 27m per year in the EU due to potentially higher volumes of alternative foams needed to achieve the desired performance. Before that, installations would need to be cleaned or replaced at potentially significant one-off cost (cleaning could potentially be in the order of up to 1 billion). This would be at least partly off-set by savings, e.g. from lower disposal cost of fire-water run-off (total difficult to quantify) and fluorine-free foams when they reach their expiry date (potentially 100,000s to millions per year), and from reduced clean-up (potentially up to 10s of millions) / remediation costs (potentially up to billions over a long time span). However, more information on the total number of sites, realworld use of PFAS per site as well as implementation and effectiveness of best practices in terms of containment and immediate clean-up would be required to assess the extent to which remediation and clean-up could be avoided by using fluorine-free fire-fighting foams. More details on uncertainties, ranges and other potential impacts are presented in Section 8.3; and June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 197 Wood Environment & Infrastructure Solutions UK Limited A ban on the placing on the market and the use of PFAS-based fire-fighting foams would immediately stop the emissions from the use of PFAS-based fire-fighting foams. This increased effectiveness needs to be weighed against the additional socio-economic implications. The existing stocks of PFAS-based fire-fighting foams would need to be disposed of (incineration costs estimated at 320 million) and new stocks would need be purchased (subject to replacement costs minus the value of existing stocks already depreciated estimated at around 1 billion). Furthermore, roll-out by suppliers and training/familiarisation would need to be done in a much more compressed timescale, but any potential savings from using alternatives (as discussed above) would also be incurred more quickly. It should be noted that these estimates are associated with significant uncertainties and ranges have been estimated. There are other potential economic costs and benefits that could not be quantified. Adjusting the potential restriction to minimise this is discussed further below. Although alternatives are generally considered to be technically feasible in most applications (further testing is required for large atmospheric storage tanks), there are also potential implications of the performance of alternatives in some cases, including slower fire suppression, and foams being less flexible and less easy to use. These have not been quantified. It should be noted that there was divergence in the stakeholder input about technical feasibility of alternatives. A few stakeholders have voiced concerns over the potentially reduced fire safety, at least in specific applications, and the associated risk of additional health, safety and economic (fire damage) impacts. However our analysis has concluded that they are not the most likely outcome and that large atmospheric storage tanks are the main application for which there is still further testing required. In order to maximise effectiveness while minimising potential adverse socio-economic impacts of a restriction, it appears appropriate to vary the specific conditions (particularly transition periods) by application and user sectors, because of their significant divergence in terms of the likelihood of emissions and implications of switching to alternative foams: Training and testing should be the highest priority for a quick transition to fluorine-free foams, because the use of alternatives is well established and already recommended as industry best practice. Training accounts for the majority of fire-fighting foam use (although likely not for the majority of PFAS emissions) and the potential for adverse socio-economic impacts is very low for training and testing; Chemicals / petrochemicals is the largest user sector meaning that the costs of transitioning but also the current risk of PFAS emissions are higher in total (although not necessarily higher per company, per turnover, etc.). However, derogations with a longer transition period may be needed for specific applications (notably large tank fires) where further testing is required to determine the technical feasibility of alternatives and potential fire-safety risks from using alternatives are high. Users have suggested a longer transition period of up to 10 years is required. This is the largest user sector, so in order to ensure effectiveness of the regulation in reducing PFAS-emissions, it seems appropriate that any longer transition period should be limited to the most sensitive applications within this sector, particularly large incidents and large atmospheric storage tanks. Further consideration of this would be needed in the (public) consultation on any restriction proposal; For small incidents as well as all other sectors, shorter transition periods between 3-6 years have been suggested and are expected to minimise socio-economic implications of a restriction: Of these, in particular marine applications, municipal fire services and ready to use applications should be priorities for a quick transition. In marine applications the potential for retention of run-off and clean-up after incidents is particularly low, and alternatives are established. For municipal and ready to use applications, alternatives are well-established June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 198 Wood Environment & Infrastructure Solutions UK Limited and these sectors may involve fire incidents outside of specific industrial sites where there is a risk that retention of run-off and clean-up after incidents are more difficult; In civil aviation a relatively quick transition could be sought as well, because alternatives are considered feasible and have successfully been implemented by many users. However the potential for retention of run-off and clean-up is relatively high, while there is the concern that, if the use of alternatives caused any increased fire-safety risks, the potential damages could be significant and would likely include danger to human life; and Alternatives are less well established in the military sector, but they are considered by stakeholders to be feasible. Transition is probably possible but requires extra care because, if the use of alternatives caused any increased fire-safety risks, the potential damages could be significant and could include danger to human life. A relatively long transition period may be needed to allow for sufficient time for alternative products to gain the necessary certifications. Regarding concentration thresholds, a balance would need to be struck between the amount of PFAS emissions remaining if a given threshold is adopted, versus the costs of cleaning imposed in order to achieve that threshold. Stakeholder input suggests that 100 ppb can be achieved with a relatively simple cleaning process (cost likely low but not quantified). Lower thresholds are achievable with more complex and costly processes. For instance, achieving 1 ppb could cost around 12,300 per appliance according to one estimate, which could imply EU total costs in the order of 1 billion. However, setting a lower concentration threshold would lead to a relatively small additional reduction in PFAS emissions, compared to the overall reduction achieved by the restriction. The average concentration of PFAS in PFAS-based fire-fighting foams is some 23%, mixed with water before application it is in the order of 0.5% (or 5 million ppb). This means a reduction from 5 million ppb to 100 ppb would cover 99.998% of the initial emissions. A further reduction to 1 ppb would cover 99.99998% of the initial emissions (an additional 0.00198%). Lastly, it is advisable to further investigate a potential obligation to apply best practice emission reduction measures during and after the use of PFAS-based fire-fighting foam. These cover for instance containment, treatment, and proper disposal of foams and fire water run-off. Particularly during the transition periods when PFAS-based foams continue to be used in certain applications, and if the use of existing foams is not restricted, these measures could provide relatively effective reduction of PFAS-emissions at relatively low cost. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 A1 Wood Environment & Infrastructure Solutions UK Limited Appendix 1 Consultation questionnaire The following questionnaire was sent directly via email to ~40 targeted stakeholders. The list of stakeholders was discussed with and approved by ECHA and the Commission prior to the launch of the consultation. The list of stakeholders aimed to target the full range of relevant sectors and backgrounds (see Section 2.1). In a number of cases, stakeholders forwarded the consultation document to other stakeholders. In the scoping interview stage, it was agreed with the main European trade association for foam producers (EUROFEU), that they would provide a joint response for the manufacturers of foams. However, we also accepted submissions from individual producers. A stakeholder contact log was maintained using an Excel file to keep a record of which stakeholders had received the consultation. A consultation period of ~6 weeks was allowed, for the completion of the stakeholder questionnaire. A brief extension to this time limit was permitted for a number of stakeholders, to maximise the number of responses received. The responses to the consultation questionnaire were collated into an Excel table, to allow relative ease of comparison between the different inputs, and easily identify any key trends or discrepancies between the responses for each individual question/section of the survey. Questionnaire: Consultation on polyfluoroalkyl and perfluoroalkyl substances (PFAS) in firefighting foams and on their alternatives Introduction to this consultation Wood Environment and Infrastructure Solutions UK Limited (`Wood') has been commissioned by the European Commission, DG Environment (`DG ENV') and by the European Chemicals Agency (`ECHA') to conduct two inter-connected projects to provide an assessment on polyfluoroalkyl and perfluoroalkyl substances (PFASs) in firefighting foams, covering: "The use of PFAS and fluorine-free alternatives in fire-fighting foams" (the `DG ENV study'); and "Assessment of alternatives to PFAS-containing fire-fighting foams and the socioeconomic impacts of substitution" (the `ECHA study'). Wood is working in partnership with Ramboll on the DG ENV study and with COWI on the ECHA study, both acting as subcontractors to Wood. The overall aim of these projects is to assess the use of PFAS and alternatives (including fluorine-free substances) in firefighting foams, including the identity and functionality of the substances used; volumes of firefighting foams on the market; the availability and technical and economic feasibility of alternatives; the releases to different environmental compartments; the environmental and health impacts; and remediation costs when the fire-fighting foams are released. The ultimate goal is to identify the most appropriate instrument for possible regulatory risk management activities, either towards new foams products June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 A2 Wood Environment & Infrastructure Solutions UK Limited and/or those already used in existing systems, to address the concerns resulting from the use of PFAS in fire-fighting foams and assess the potential socio-economic impact of these activities. Why have we have contacted you? This survey is a key step in the data gathering process of these projects. It is essential for us to collect the relevant data and opinions, covering the full range of stakeholders involved in the production and use of firefighting foams, including manufacturers and users of foams across different sectors (e.g. aviation, oil and gas, chemicals), as well as remediation specialists, academia, national authorities and NGOs. This questionnaire is addressed to you as a key stakeholder. We hope that you are able to complete as much as possible of the questionnaire using data already available or in the case of industry associations, based on a rapid survey of your member companies, given the available timescales. Your response will help to ensure that the possible options for, and implications of, potential regulatory risk management measures for your sector or field of expertise are taken into account as the European Commission and ECHA consider this issue. Confidentiality We are aware that some of the information you may want to provide could be commercially sensitive and confidential. If any of the information provided is to be viewed as confidential, please clearly mark this as such and we will agree any further steps with you, including how to report any information derived from your confidential input to the European Commission or ECHA. We will not disclose any information marked as confidential without your permission to the Commission, ECHA or any third party. We will make anonymous all information relevant to specific companies and/or facilities within our reporting and will not pass on the information that you provide to any other party without your express permission. Any information you provide will solely be used for the purpose of this study and provision of a report to the European Commission or ECHA. We will also present uncertainty ranges in reported data in order to avoid disclosing market-sensitive information. This questionnaire Please complete all of the questions that you are able to. The survey questions are split into separate sections covering: Background information on you and your organisation; Chemical identity, functionality of PFAS in firefighting foams; Alternatives to PFAS in firefighting foams; Foam use and environmental emissions; Implications of potential regulatory action; and Additional information - including suggestions for other resources and stakeholders to consult. Where you are not able to answer questions in one or more of the sections - due to lack of data or because it is not relevant to your organisation - there is no need to provide a response. Where answers are uncertain, an estimate is more useful than no information at all. Where annual data is provided, please state the year. Please return you completed questionnaire to us by 28 June 2019. Please be aware that if responses are received after this date, then the information may not be included in our analysis. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03  Wood Environment & Infrastructure Solutions UK Limited wood. Project timeline Upon closing the consultation in June 2019, we intend to use the information collected from this stage to inform the following stages of the project: A stakeholder workshop to be held in Helsinki on 24 September 2019. This will be used to discuss and validate the initial findings of the project(s) and gather additional evidence; and A final report to be delivered to ECHA and the European Commission in February 2020. Contact details Should you have any questions or require any further information, please do not hesitate to contact the project team: Ian Keyte (Consultation Coordinator), 1868, @woodplc.com Julius KreiBig (Project Manager, DG ENV study), 1671, woodplc.conn Liz Nicol (Project Manager, ECHA study), 7354, M@woodplc.corn June 2020 Doc Ref. 41288 WOD )O( XX RP OP 0009_A_P03 A4 Wood Environment & Infrastructure Solutions UK Limited Part 1: Background information Your details Name: Organisation: Job title: Telephone number: E-mail address: Type of organisation: Manufacturer User/Industry NGO Academic Member State Competent Authority / Agency Remediation Other If Other, please specify: If `user/ industry', which sector applies to you: Oil refineries/storage Chemicals Petrochemicals Airports Other (please specify): June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 A5 Wood Environment & Infrastructure Solutions UK Limited Summary of activities of your organisation: June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 A6 Wood Environment & Infrastructure Solutions UK Limited Part 2: Chemical identity, functionality of PFAS in firefighting foams This section aims to identify which PFAS are currently being used in which fire-fighting foam products, the function these PFAS impart on the foams and the volumes of these products that are currently on the market and used in the EU, 2.1. Identity of firefighting foam products in use Please provide details of the firefighting foam products currently used in your sector(s) that intentionally use PFAS, or where PFAS are known to be present as impurities. Please indicate the sector(s) in which these foams are used, and the typical application method used. If within their sector(s) of use, multiple different foam products are used, indicate the type and size of fire that specific product can be used for. Please also provide an indication of whether the product is produced in the EU, and if not, where it is imported from, and in what quantities. If the product is currently on the market in the EU (i.e. it is being sold), please note the geographic scale to which your response refers (e.g. national, EU, global markets), and if no longer sold, please indicate if the foam product is still used in existing firefighting systems. # Product name Sector(s) applicable Type of use Application method Produced in the EU? Currently on the market in the EU? e.g. trade name, brand e.g. airport, oil and gas, chemicals e.g. the type and size of fire; training only? e.g. fixed/mobile, Compressed Air Foam, etc. Y/N (If N, please note the country imported from) Y/N (If Y, at national, EU, global scale? If N, is the product still used in existing systems?) 1 2 3 4 5 (add additional rows if required) June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 A7 Wood Environment & Infrastructure Solutions UK Limited 2.2. Identity of PFAS used in firefighting foams For each of the products described in Section 2.1, please provide details of the PFAS intentionally used, and where PFAS or other harmful chemicals are known to be present as impurities. # PFAS used Estimated PFAS content (w/w) Known impurities e.g. the chemical or common/ abbreviated name and CAS# e.g. the PFAS contained and the % composition by weight, if known 1 2 3 4 5 e.g. PFAS and other chemical impurities present; estimated % composition (w/w) 2.3. Volume of PFAS-containing firefighting foam concentrates For each of the products described in Section 2.1, please provide an estimate of the total quantities of foam concentrates manufactured/imported and sold, the approximate revenue or unit price derived from their sale, and total quantities currently present in existing systems. We are particularly interested in EU-level estimates, if these are available. Please specify if the information provided is at company, sector, national or European level, depending on your role/organisation. Please provide any available information on past trends or expected future changes in production and sales, and the drivers of these trends. Please specify the timescales covered by these trends. Ideally this should be limited to the previous 10 years. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 A8 Wood Environment & Infrastructure Solutions UK Limited # Volume manufactured in the EU / imported to the EU e.g. annual production, import Volume sold in the EU e.g. annual sales 1 Revenue from product sales (or if not known, average unit price) e.g. Annual company turnover from product; unit price of products Volume present in existing systems in the EU e.g. quantity previously installed and not yet used/disposed of and therefore currently present in existing systems Trends in production/sales of product e.g. trend over the previous 10 years and any expected future trends Main drivers for changes e.g. costs, regulations, other market factors 2 3 4 5 (add additional rows if required) 2.4 Functionality of different components (e.g. film-forming, surfactants, solvents) For each of the firefighting foam products described in Section 2.1, please describe the specific technical function that the PFAS provide to the foam, which specific applications/uses this function enables, and why PFAS have not been fully replaced by alternatives in this application. # Function of PFAS in the foam e.g. film-forming, surfactants, solvents, others 1 Specific applications/uses this function enables e.g. effective control of 10m+ tank fires Why have foam products containing PFAS not been fully replaced by alternatives in this application? e.g. consideration of costs, compliance with safety standards 2 3 4 5 (add additional rows if required) June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 A9 Wood Environment & Infrastructure Solutions UK Limited Part 3: Alternatives to PFAS in firefighting foams This section aims to identify the chemical substances/products being used in specific fire-fighting foams in place of PFAS, volumes on the market, and the implications of using these alternatives. 3.1 Alternative firefighting foam products For firefighting foam concentrates containing PFAS, are any alternative PFAS-free firefighting foam products (including fluorine-free products) available that could potentially perform their functions and/or enable the same applications? Please provide details of these products and, where applicable, which products described in Section 2.1 these are designed to replace in the table below. Please specify if the alternative foam is a direct `drop in' replacement or if this can only partially substitute the PFAS foam, and under which conditions # Product name Sector(s) applicable e.g. trade name, brand e.g. airport, oil and gas, chemicals A Type of use Application method e.g. the type and size of fire; training only? e.g. fixed/mobile, Compressed Air Foam, etc. Is this product a substitute for the foams detailed in Section 2.1 (please refer to the number(s) of the product(s) listed under Section 2.1. applicable)?* e.g. is this a direct drop-in replacement or used in combination with other products; under which conditions? (Note that the differences in technical performance will be discussed in Section 3.5) B C D E (add additional rows if required) 3.2 Chemical identity of alternatives For the alternative firefighting foam concentrates products described in Section 3.1. Please provide details of the main chemical constituents, both those used intentionally in the formulation, and those potentially present as impurities. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 A10 Wood Environment & Infrastructure Solutions UK Limited # Key chemical composition e.g. chemical constituents and their proportions w/w A B C D E (add additional rows if required) PFAS present as impurities? e.g. approx. % concentration w/w 3.3 Availability of alternatives Please provide details on the availability of the alternative foams described in Section 3.1 and 3.2. Please indicate if these products are produced in the EU (or the country imported from), and if these are currently available on the market and in use. For products that are being developed/not yet available, please provide an indication of the amount of time expected for these to reach the market in the necessary quantities to replace the PFAS-containing foams. # Produced in the EU? Y/N, (if N, please note the country imported from) A Currently on the market in the EU? Y/N, (e.g. at national, EU, global scale?) Reasons why product is not currently on the market e.g. still in R+D phase, awaiting approvals, phased out due to environmental concerns Estimated timescale for product reaching the market. e.g. approx. number of months/years if known B C D E (add additional rows if required) June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 A11 Wood Environment & Infrastructure Solutions UK Limited 3.4 Volume of alternative firefighting foam concentrates For each of the products described in Section 3.1, please provide an estimate of the total quantities of foams manufactured/imported and sold, and the approximate revenue or unit price derived from their sales. We are particularly interested in EU-level estimates, if these are available. Please specify if this information is at company, sector, national or European level, depending on your role/organisation. # Volume manufactured in Volume sold in the EU the EU / imported to the EU e.g. annual production, import e.g. annual sales A Revenue from product sales (or if not known, average unit price) e.g. Annual company turnover from product; unit price of product Trends in production/sales of product Main drivers for changes e.g. trend over the previous 10 years and any expected future trends e.g. costs, regulations, other market factors B C D E (add additional rows if required) 3.5 Technical feasibility of alternatives Where alternative foams are being developed or are marketed, please provide details any technical implications of using those alternatives, compared with `traditional' PFAS-containing foams they were designed to replace. Technical implications of alternatives For the alternative products described in Section 3.1, please provide an indication of any technical implications associated with using these alternatives relative to the PFAs-containing foams. For example, do they impart the desired functionality and comply with the required performance criteria/standards; are there differences in required volumes of use or application methods? Please provide an indication of whether the alternative can only partially replace the PFAS-containing foam, and the reasons why. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 A12 Wood Environment & Infrastructure Solutions UK Limited # Application/use compared to PFAS- Please refer containing foams (add the to products corresponding the foam detailed in in Section Section 2.1) 3.1 Can the alternative replace the use of the PFAS foam entirely, and if not, how does it differ? Specify if the alternative foam can only partially substitute the PFAS foam. A B C D E (add additional rows if required) Compliance with performance standards Which standards are the foams in compliance? Differences in volumes required between different foams to achieve comparable/ acceptable functionality e.g. per application or total volume used per year Other implications (e.g. different application method, equipment needed) Please specify Comment on feasibility of the foams for different uses and applications Please provide an indication, in your opinion, of whether the alternative foam products are technically feasible of replacing PFAS-containing foams, and why. Please also highlight any specific applications or uses where these alternatives ARE, or are NOT considered feasible alternatives. # (please refer to products in Section 3.1) Overall, do you consider the alternative as technically feasible for this specific application/use? e.g. Y/N, please explain A B C D E (add additional rows if required) Uses/applications where alternatives ARE considered technically feasible e.g. types or scale of fire or use in particular situations or equipment Uses/applications where alternatives are NOT considered technically feasible e.g. types or scale of fire or use in particular situations or equipment June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 A13 Wood Environment & Infrastructure Solutions UK Limited Critical uses/applications Are there critical uses/applications of fire-fighting foams where PFAS CANNOT be adequately replaced by ANY alternatives? If yes, please substantiate your statement. 3.6 Economic feasibility of alternatives Based on the available information, what are the financial/economic implications of using those potential alternatives? For example, where detailed testing results of fire extinguishing systems are available, please provide details of these and indicate if/where this is confidential information. For the alternative foams detailed in Section 3.1, please complete the tables below on the potential costs; savings; and other financial implications. Costs # (please refer to products in Section 3.1) A Unit price of alternative product e.g. or unit price differences between PFAS-based foams and `alternatives' Required amounts/loadings of alternative foams e.g. required to achieve comparable/ acceptable functionality Frequency of foam replacement e.g. due to expiration date Costs of new equipment required e.g., capital cost of purchase and installation, operational cost compared to previous equipment B C D E June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 A14 Wood Environment & Infrastructure Solutions UK Limited Savings # (please refer to products in Section 3.1) A B C D E Savings from the use of the alternative foam e.g. avoided clean-up and/or remediation costs Other financial aspects # (please refer to products in Section 3.1) A Other financial aspects B C D E (add additional rows if required) June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 A15 Wood Environment & Infrastructure Solutions UK Limited Part 4: Foam use and environmental emissions This section is aimed at identifying the quantities of fire-fighting foam products used, disposed of and potentially released to the environment. 4.1 Firefighting foam use If you are a user of firefighting foams, for the foam products identified in Sections 2.1 and 3.1, please provide information (quantitative if possible) on the volumes of foam purchased and used per year (including both products based on PFAS and fluorine-free alternatives). If available, please provide any information on the volumes used in each instance of foam use. PFAS-containing firefighting foams # Amount of foam purchased per year kg/year 1 2 3 4 5 (add additional rows if required) Volume of foams per instance of use kg. Please specify if concentrate or wateradded solution Typical frequency of use minutes, hours etc Additional detail on this sector/use describe typical application practices PFAS-free alternatives # Amount of foam purchased per year kg/year A B C D E (add additional rows if required) June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 Volume of foams per instance of use kg. Please specify if concentrate or water-added solution Typical frequency of use minutes, hours etc. Additional detail on this sector/use describe typical application practices A16 Wood Environment & Infrastructure Solutions UK Limited 4.2 Firefighting foam collection and prevention of release to the environment Please provide information on any measures, both in terms of legislation and best practice actions, put in place to prevent release of firefighting foam discharges to the environment. If available, please indicate if the level of implementation of these measures has been monitored or assessed. Is there national-level legislation in your Member State governing the containment/prevention of release of firefighting foam/ firewater runoff to the environment? Y/N If Y, please provide details e.g. what the legislation controls, how it is implemented and enforced. Is there best-practice guidance available to users on how to best contain/prevent release of firewater and foam discharge to the environment? Y/N If Y, please provide details e.g. who published the guidance, what does this cover? What level of implementation for these best practice measures is currently achieved? e.g. number/proportion of installations with action plans in place for minimising discharges, with specialised equipment in place, etc If possible, please provide information (quantitative if possible) on the quantities or proportions of foams sent for different disposal practices. Please complete the following tables for PFAS-containing foams and alternative foams. PFAS-containing firefighting foams # Volume/% collected (Please specify if you refer to concentrate or water-added solution) For incineration For other disposal/ treatment Volume/% not collected (i.e. potentially released to the environment) Please specify if you refer to concentrate or water-added solution Other disposal options used Additional detail on this disposal e.g. reason, conditions such as temperature and incineration time 1 2 3 June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 A17 Wood Environment & Infrastructure Solutions UK Limited 4 5 (add additional rows if required) PFAS-free alternatives # Volume/% collected (Please specify if you refer to concentrate or Volume/% not collected (i.e. water-added solution) potentially released to the environment) For incineration For other disposal/ treatment Please specify if you refer to concentrate or water-added solution Other disposal options used Additional detail on this disposal e.g. reason, conditions such as temperature and incineration time A B C D E (add additional rows if required) 4.3 Disposal of foams For the foams and uses described under 2.1 and 3.1, if applicable, please provide information (quantitative or qualitative) on the disposal practices used (e.g. incineration or waste water treatment practices). Please indicate the type and conditions of the processes used and the associated costs, either per unit weight of foam disposed, or total operations costs if available. Please provide any available information on the environmental emissions, particularly the chemical identity and concentration of any fluorinated substances released. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 A18 Wood Environment & Infrastructure Solutions UK Limited Is there sufficient capacity available to dispose of waste firefighting foams in your facility/country? # see Sections 2.1 and 3.1 Type of disposal e.g. hazardous waste incineration; municipal waste incineration Conditions used e.g. temperature; time Estimated costs e.g. cost per kg of foam; total operating costs per year Environmental emissions e.g. type and concentration of fluorinated substances Sufficient capacity available for disposal? e.g. Y/N ; please explain (add additional rows if required) 4.4 Environmental releases For the foams and uses described under 2.1 and 3.1, please provide information (quantitative or qualitative) of the expected or actual environmental discharges of PFAS and/or fluorine-free chemicals used in firefighting foams to the environment. Please include any known information on the volumes of release, the particular circumstances or activities leading to release: Product # see Sections 2.1 and 3.1 Discharge to terrestrial environment e.g. typical share of product used, total quantity Discharge to surface water e.g. typical share of product used, total quantity Discharge to ground water e.g. typical share of product used, total quantity Additional detail on this discharge e.g. description of the circumstances of the release or any other explanations of the data provided June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 A19 Wood Environment & Infrastructure Solutions UK Limited Part 5: Potential restrictions on PFAS in firefighting foams 5.1 Impacts of a potential restriction Are there any other key impacts (other than already mentioned under economic feasibility of alternatives) in the event of a restriction on PFAS-containing firefighting foams for your sector that you would like to point out? Such impacts could include those associated with the performance of the sector using firefighting foams (e.g. increased safety risk at airports), impacts on manufacturers of firefighting foams (e.g. impacts on employment), the impacts on trade and competitiveness, and those associated with the improved protection of human health and the environment through reduced exposure to PFAS. Please provide details, along with any supporting quantitative and/or qualitative estimates if possible, on the following aspects: Potential impact of different transition periods for phasing out PFAS in firefighting foams? (e.g. in relation with the ability to use the PFAS foams already in stock and the expiry date of foams in stock). Potential impact of different threshold concentrations of PFAS (i.e. impurity levels) in firefighting foams once the potential future regulation is in place? (e.g. in relation with the cost to clean up the installation to comply with the PFAS impurity threshold) Potential impact of restrictions on new PFAS-containing firefighting foam products entering the market only vs restrictions on both new PFAS-containing foam products and those already in use in existing systems? June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 A20 Wood Environment & Infrastructure Solutions UK Limited Part 6: Additional information 6.1 Other information If there is any other information you would like us to take into account, please provide details here: If you wish to submit documents directly, please provide these as an email attachment accompanying this completed questionnaire. Please clearly label any attachments as `non-confidential' (preferred) or `confidential' to ensure we handle any information provided appropriately. 6.2 Suggestions for additional resources to consult Please provide the details or links to any other useful resources/literature that provide information on any of the key aspects of the project covered in this survey Reference Link Details (add additional rows if required) Thank you very much for completing this questionnaire. We appreciate you taking the time to help with this project. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 B1 Wood Environment & Infrastructure Solutions UK Limited Appendix 2 Workshop report June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 European Chemicals Agency (ECHA) The use of PFAS and fluorine-free alternatives in fire-fighting foams Stakeholder workshop report Tuesday 24 September 2019 at ECHA, Helsinki. Specific contract ECHA/2018/561 This report has been prepared by Amec Foster Wheeler Environment & Infrastructure GmbH which is now part of John Wood Group plc (known as Wood) and is hereinafter referenced by our brand name "Wood"- October 2019 0 Wood Environment & Infrastructure Solutions UK Limited Draft - see disclaimer wood. Report for Denis Mottet Scientific officer Risk Management Unit II European Chemicals Agency PO Box 400 / Annankatu 18 00121 HELSINKI, Finland Main contributors Liz Nicol (Wood) Julius KreiBig (Wood) David Tyrer (Wood) Marlies Warming (COWI) Issued by Liz Nicol Approved by David Tyrer Wood Floor 23 25 Canada Square Canary Wharf London E14 5LB United Kingdom Tel 1610 Doc Ref. 41433-WOD-XX-XX-RP-OP-0011_53_P01 H:\Projects\41433 PPChem PFASs and fluorine -free alternatives\C Client Related\Reports\Workshop report Draft report disclaimer This report has been prepared in a working draft form and has not been finalised or formally reviewed. As such it should be taken as an indication only of the material and conclusions that will form the final report. Any calculations or findings presented here may be changed or altered and should not be taken to reflect Wood's opinions or conclusions. Copyright and non-disclosure notice The contents and layout of this report are subject to copyright owned by Wood ( Wood Environment & Infrastructure Solutions UK Limited 2019) save to the extent that copyright has been legally assigned by us to another party or is used by Wood under licence. To the extent that we own the copyright in this report, it may not be copied or used without our prior written agreement for any purpose other than the purpose indicated in this report. The methodology (if any) contained in this report is provided to you in confidence and must not be disclosed or copied to third parties without the prior written agreement of Wood. Disclosure of that information may constitute an actionable breach of confidence or may otherwise prejudice our commercial interests. Any third party who obtains access to this report by any means will, in any event, be subject to the Third-Party Disclaimer set out below. Third party disclaimer Any disclosure of this report to a third party is subject to this disclaimer. The report was prepared by Wood at the instruction of, and for use by, our client named on the front of the report. It does not in any way constitute advice to any third party who is able to access it by any means. Wood excludes to the fullest extent lawfully permitted all liability whatsoever for any loss or damage howsoever arising from reliance on the contents of this report. We do not however exclude our liability (if any) for personal injury or death resulting from our negligence, for fraud or any other matter in relation to which we cannot legally exclude liability. Management systems This document has been produced by Wood Environment & Infrastructure Solutions UK Limited in full compliance with the management systems, which have been certified to ISO 9001, ISO 14001 and OHSAS 18001 by LRQA. Document revisions No. Details 1 Draft workshop report Date 16/10/2019 16 October 2019 Doc Ref. 41433-WOD-XX-XX-RP-OP-0011_53_PO1 3 Wood Environment & Infrastructure Solutions UK Limited Draft - see disclaimer Introduction On Tuesday 24th September 2019 the European Chemicals Agency (ECHA) hosted a workshop in Helsinki to discuss the use of Per-and polyfluoroalkyl substance (PFAS) -based fire-fighting foams as well as fluorine-free alternatives. This workshop formed part of a study being undertaken jointly by the European Commission, DG Environment (`DG ENV') and ECHA examining the use of PFAS and their alternatives in fire-fighting foams and identifying the most appropriate instrument for possible regulatory risk management activities. The purpose of the workshop was to present, validate and seek feedback on the preliminary project findings, gather views on possible risk management options and explore the feasibility of replacing PFAS-based foams with fluorine-free alternatives. A series of breakout groups on key topic areas focused on specific questions designed to inform possible future regulatory activities. 1.1 Workshop context Wood has been contracted by DG ENV and ECHA to provide services on two concurrent contracts: "The use of PFASs and fluorine-free alternatives in fire-fighting foams" (the `DG ENV study') ; and "Assessment of alternatives to PFAS-based fire-fighting foams and the socio-economic impacts of substitution" (the `ECHA study'). Wood is working in partnership with Ramboll on the DG ENV study and with COWI on the ECHA study, acting as subcontractors to Wood in both cases. As a whole, the project aims to provide an assessment on the use of PFAS and their alternatives in firefighting foams and to identify the most appropriate instrument for possible regulatory risk management activities. Addressing both concerns resulting from the continued use of PFAS in fire-fighting foams and assessing potential socio-economic impacts of potential regulatory activities. For both studies to be effective in considering possible future regulatory risk management activities, engagement with a wide range of stakeholders is paramount. A questionnaire has already been issued to a large number of stakeholders however this workshop was held to engage further with additional stakeholders on this topic to gather views and opinions on the use of PFAS-based firefighting foams and fluorine-free alternatives. 1.2 This report The main body of this report (Section 2 onwards) documents the discussions that took place during the workshop on the 24th September and the full order of events in the form of meeting minutes. The workshop hosted 30-40 participants from all interested sectors over a single day at ECHA - participants included representatives from foam manufactures, users, Member States' Competent Authorities, Government bodies and trade associations. 16 October 2019 Doc Ref. 41433-WOD-XX-XX-RP-OP-0011_S3_P01 4 Wood Environment & Infrastructure Solutions UK Limited Draft - see disclaimer The appendices of this report contain additional information on the list of participants involved in the workshop (Appendix A) and the presentation slides from both the Wood project team (Appendix B) and the invited speakers (Appendix C). Welcome and introduction to the workshop by ECHA and DG ENV Denis Mottet (DM), the project manager and scientific officer from ECHA opened the workshop, welcomed participants and introduced the personnel facilitating the workshop. DM informed the attendees that ECHA and DG ENV are working together on the issue of fire-fighting foams and hence a joint workshop was being held to engage stakeholders further on the issue of PFAS use in fire-fighting foams. Valentina Bertato (VB), a Policy Officer within Directorate B2 of DG ENV, introduced the policy context to the study and why the European Commission and ECHA are working together to look at the use of PFAS and non-fluorinated alternatives in fire-fighting foams. Introduction by project team David Tyrer (DT) from the Wood project team introduced the agenda of the workshop and provided further context for the project including the progress made to date and the purpose of the workshop in seeking further input from stakeholders. DT noted that the two studies are being run in close collaboration but comprise different tasks - the ECHA study looks at alternatives and socio-economic analysis. These are components that will feed into the Commission study, which develops a pre-RMOA (regulatory management option analysis) and pre-Annex XV dossier. DT further pointed participants towards the pre-workshop report issued by Wood and stated that it reflected the outcomes of literature review, discussions with and survey responses from stakeholders. DT emphasised that the key objective of the workshop was to present, validate and seek feedback on the project findings so far and to gather views on possible risk management options; the functionality/feasibility of alternatives; environmental emissions of PFAS and alternatives; and remediation costs following foam use. Initial Study Results Julius Kreissig (JK) and Liz Nicol (LN) from the Wood project team presented the initial study results from the Commission study and the ECHA study respectively. The following topics were covered - further details of the findings for each of these topics can be found in the pre-workshop report: 1. Substance identification of PFAS-based foams and alternatives 2. Market analysis of PFAS-based foams and alternatives 3. Estimates of substance emission from foams 4. Analysis of fluorine-free alternatives All slides presented by the project team are included in Appendix B. 16 October 2019 Doc Ref. 41433-WOD-XX-XX-RP-OP-0011_S3_P01 5 Wood Environment & Infrastructure Solutions UK Limited Draft - see disclaimer Plenary discussion on study findings to date The plenary session was opened by DT. Several stakeholders asked questions and commented on the preliminary results with some stakeholders indicating to be in possession of further relevant information or documentation. Their feedback is summarised in meeting minute format below. 5.1 Substance identification and Market analysis of PFAS-based foams and alternatives A stakeholder from ECHA asked for further explanation on the process that the Commission will go through with regard to their `PFAS strategy'. The Commission representative responded clarifying that the new Commissioner will ultimately make the decision on what will happen regarding a strategy or action plan for PFAS. Presently they are investigating concerns over PFAS substances under all the regulatory directives. A participant raised a question for the Wood team on the volume of `unknown' substances presented in the results table of the market analysis section. These unknown substances comprised a substantial proportion of the total volumes of PFAS identified as being on the market in the EU and therefore, do the project team know what substances these are and why are they unknown? A member of the Wood project team responded stating that data has been collected from a number of manufacturers and they did not disclose the specific substance names/CAS numbers in this instance (presumably due to commercial sensitivity). ECHA noted in response to this that they should be able to look up the registration documents for these substances and find out exactly what they are. A stakeholder from the oil and gas sector stated that it is often difficult to obtain information on the compounds in fire-fighting foams from the manufacturer but they (Concawe) have data available from monitoring that they may be able to share with Wood. One stakeholder from a national authority highlighted that according to the market analysis the municipal fire sector would be a large user sector. Their opinion was that municipal brigades should not be using PFASbased foams at all. A member of the Wood project team confirmed that consultation responses have suggested that these volumes are sold to and used in this sector at present. Another stakeholder from a national authority asked to what extent the contractors (Wood) have looked at registration data under REACH. A member of the Wood project team clarified that ECHA have looked at identifying substances using registration data for use in fire-fighting foams but not the tonnages. This may be data that can be added in the future. A representative from the Commission noted that the commercial sensitivity around specific substances in foams may not hinder a restriction, as the Commission can be broad in the scope of the restriction to capture all the PFAS substances that are used. A participant from a national authority suggested that 0.5-45% is a large range for the concentrations of PFAS in the foams. They considered this unexpectedly high and asked for a reason for the large range? A member of the Wood project team confirmed this reflects data received from stakeholders. According to some input received, concentration of PFAS are sometimes increased for a more effective foam. The same participant from a national authority mentioned that they know more about uses of foams in the automotive industry - they may be able to provide some data for this sector. A company representative commented that the market analysis data on use in fire extinguishers appears small in comparison to other uses. They are aware that this is a large sector of use. A member of the Wood 16 October 2019 Doc Ref. 41433-WOD-XX-XX-RP-OP-0011_S3_P01 6 Wood Environment & Infrastructure Solutions UK Limited Draft - see disclaimer project team responded noting that the information came from manufacturing industry but the tonnage alone is not the only criteria that determines the focus of any potential regulation Another company representative asked if the foam manufacturers have provided specific information on which PFAS substances they are using? Do they test what PFAS substances are in products? A member of the Wood project team responded saying we do not have any information from manufacturers specifically, but sometimes they do not fully know what is in their products. 5.2 Estimates of substance emission from foams A participant from a national authority asked where oil and gas exploration and production sectors were covered in the data presented for the Task 3 emission model? A member of the Wood project team that responded this is likely to be in petroleum refineries sector split but this can be clarified in the final report. Another participant from a national authority mentioned that their experiences from offshore training suggests there are high releases during training. Most foam will be discharged to the sea so 97% capture could be too high. They may be able to provide more data on emissions from offshore application of foams. A company representative suggested that capture during live incidents should be higher than the zero currently assumed. Especially during storage tank fires where foam is inserted into the tank, 100% of runoff is captured. Hence this capture percentage really depends on the application. One stakeholder representing an NGO suggested 97% of capture during training may be too high based on his experience in petrochemicals. Even when 100% of the runoff is captured and sent to hazardous waste treatment, if the treatment operators are not told what it contains then it is not treated as PFAS but instead just a hydrocarbon. This can be an issue. Some places have big containment ponds for runoff just in case large fire incidents occur. Additionally, foam is not treated specifically in sewage treatment works (STWs) and does not degrade. Emission estimates work will need to consider whether the treatment processes really `treat' the substances, or if they pass through the works. A different NGO representative noted that emissions depend on scale of release/foam usage. If large volumes are used, the containment may overflow and lead to environmental emissions which could have been avoided using smaller volumes of more efficient foams. They mentioned a case from a burning chemical factory in Melbourne as an example. A participant from a national authority asked whether environmental monitoring data will be used to validate emission estimates from the model. A member of the Wood project team responded saying that monitoring data can be used as a sense check (for the model), but requires caution about distinguishing between different (background) sources of PFAS. The national authority stakeholder stated that they have done some monitoring at airports in Norway and they do not have any PFAS manufacture and therefore low background concentrations in Norway. The Wood project team agreed that this sort of monitoring data will be essential in checking the estimates from the model. Another participant from a national authority mentioned a report with monitoring data on live incident emissions and contamination of equipment after switching from PFAS-based foams. The agency found discharge of PFAS from tanks that were not fully emptied before foam switching. A company representative remarked that there should be a distinction between municipal and specialised waste water treatment plants and asked whether there will there be a consideration of different treatment types in the model. Furthermore, the 50% removal needs to be further explained and that much is not likely to degrade. A member of the Wood project team responded saying that the model may build in different treatment type scenarios and associated percentage removal. They noted the Wood team were aware that the 50% removal assumed is too high and the term `transformation' may be more appropriate than degradation. 16 October 2019 Doc Ref. 41433-WOD-XX-XX-RP-OP-0011_S3_P01 7 Wood Environment & Infrastructure Solutions UK Limited Draft - see disclaimer One stakeholder representing an NGO commented that the data of 300 tonnes of PFAS in 14,000 tonnes of foams suggests an average concentration of 2.5% of PFAS in fire-fighting foam concentrates, which they consider to be very accurate. The stakeholder indicated that the use of legacy products and subsequent contamination are driving the environmental concentrations of PFAS. Capture and treatment will be very important going forward and more efforts will likely be necessary in the future. A participant from a national authority asked whether the data for incineration is from a literature review or just an assumption at this stage? The stakeholder indicated that it may be unlikely to result in 99% destruction of PFAS and this may be too high. A member of the Wood project team answered that there is some degree of expert judgement in the current values and percentages are likely to be reviewed going forward. A representative from the Commission commented that sewage sludge is being applied to land so we need to consider this as a pathway. Just because long chain PFAS end up in the sludge does not mean that they do not end up in the environment. 5.3 Alternatives A stakeholder from an association mentioned that airports may have fewer alternatives available to them because they test against specific PFAS-standards for aviation, that are different to other uses. One stakeholder from the defence sector noted that only some foam concentrates are sent for specific testing against ICAO or EN standards. Producers only test for specific markets so approvals are not always indicative of applicability to different fire types. They asked whether Wood have had any information on the technical differences of equipment required for alternative foams? A representative from the Wood project team responded saying that only limited information is available so far on the different technical aspects of using the alternatives. A participant from a national authority stated that the ICAO class B test is not sufficient, because it only tests for one single endpoint point but there are many different applications (designed 30 years ago with PFAS foams in mind). Bundeswehr, for example, has tried to move to siloxane-based alternatives, which was sufficient to pass the ICAO class B tests, but did not work for gasoline fires at all. Certificates may therefore need to be revised. A second participant from a national authority noted that 40 O&G installations in Norway have transitioned to fluorine-free foams. All alternatives used are EN approved. They encountered some obstacles on the way - freeze protection and viscosity issues - both of which have been resolved. Norway reports a 95% drop in PFAS emissions in 5 years following this switch to fluorine-free foams. One stakeholder representing an NGO reinforced the need to question whether the tests are relevant for real life applications. Tests are sometimes designed for AFFF and cannot be met by alternatives but that does not reflect their fire-fighting efficiency. The stakeholder suggested that part of the transition should be looking at test protocols as to whether they meet the necessary use criteria including whether they perform in the same way. Military specification (MILSPEC) is a classic example of where the test criteria are based on PFAS-based foams. A participant from a national authority indicated that the same certification tests apply for all airports in Europe. Some airports have successfully transitioned indicating that it may be possible for others. Remediation costs for PFAS are significant and this should be an incentive to switch. A stakeholder from an association stated that some airports voiced concerns over efficacy and changes of equipment. They suggested that Heathrow airport have also had problems associated with their transition. A stakeholder representing an NGO commented that training facility contamination is from legacy foam use. There is a consensus in industry (aviation) to use alternatives in training. Many of the identified foams are EN 16 October 2019 Doc Ref. 41433-WOD-XX-XX-RP-OP-0011_S3_P01 8 Wood Environment & Infrastructure Solutions UK Limited Draft - see disclaimer certified but that does not necessarily simulate reality of the fire-fighting systems. Other tests are more realistic. Emissions in marine applications have been reduced significantly by changing training/testing measures and that could be the main contributor in reducing emissions of PFAS going forward. A representative from the Commission indicated that Heathrow said one advantage of alternatives is that they can use the same foam for training and real incidents. The Norwegian experience will also be important for judging feasibility of alternatives in the O&G sector. One stakeholder from the defence sector asked if the study had identified any risks of alternative substances? A member of the Wood project team responded that it had not yet, but this will be investigated during the second part of the project. A stakeholder representing an NGO brought up a fire incident at Heathrow where the fire could not be extinguished after multiple foam attacks for approximately 14 hours. They also mentioned an incident in Dubai in 2016 as an example and that outdoor temperatures can influence the performance of foams. The participant indicated that more information was available on read-across from heptane to gasoline fires, as these differ and may require different foams. A participant from a national authority asked who the leaders in using fluorine free alternatives are? They suggested that this was likely to be municipal brigades and airports. A company representative mentioned that Copenhagen brigades use fluorine-free foams and these are ICAO approved, but with different ratings than PFAS-based foams. A stakeholder representing an NGO (via Webex) stated that ambient temperatures are less important than engine cooling temperatures. Vapour cloud fire is often crucial. Forty degrees as a testing criteria is not a feasible parameter as it requires highly specialised and very large testing facilities, making the development, process and conducting of testing even more challenging. DT closed the morning plenary session Invited speakers DT introduced the invited speakers from each of the different organisations (full presentations can be found in Appendix C). Questions raised after the presentations are detailed below. 6.1 Thomas Leonhardt from Eurofeu A participant from a national authority asked whether the AFFF reference in the presentation referred to C6 or PFOS-based foams? The speaker replied that the alternatives are compared to C6 foams. Another participant from a national authority stated that the fire-safety risk could be increased from use of fluorine-free foams but do we know by how much? Is it possible to make crude calculation to establish what the risk of using alternatives is (how many fires per year, how many people may die etc.) to compare with environmental/health risks? They mentioned that perhaps society has to accept a higher risk. The speaker replied to say that the level of risk is not comparable and does not translate to real world scenarios to compare the risk for different products. The speaker further noted that foam replacement needs to be comprehensive and we have to look at application technique, hardware and training status of fire-fighters. A representative from the Commission commented that the concentration range presented is much lower than preliminary results of the market analysis suggested. The speaker clarified that 16 October 2019 Doc Ref. 41433-WOD-XX-XX-RP-OP-0011_S3_P01 9 Wood Environment & Infrastructure Solutions UK Limited Draft - see disclaimer his concentration figures refer to a premix of a 3% foam-concentrate so the concentration is lower (only 0.5%) than for the concentrate itself. A stakeholder representing an NGO asked if there are design standards for fire system design? The speaker stated that these have been developed around AFFF foams and are not necessarily sufficient for fluorine-free foams, as they are testing different properties of the products. Another stakeholder representing an NGO highlighted that there are committees looking at the specification standards as they know that there are problems and fluorine-free foams will need to be addressed differently. 6.2 Veli-Matti Sskilahti - Head of Rescue and Fire Fighting section, Finavia Corporation A participant from a national authority reiterated that Norway has replaced their foams with fluorine-free foams in airports so the situation/environment is surely similar. The stakeholder emphasised that there should be the possibility to exchange information on this issue and learn what the Norwegian experiences are. Another participant from a national authority again referred to the O&G exploration in Barents Sea and explained that they had problems with viscosity due to sea salt but these have been solved and PFAS-based foams have been replaced. A stakeholder representing an NGO noted that low viscosity fluorine-free foams are coming on the market and the LASTFIRE consortium are testing some of them now. 6.3 Eric Paillier - Total HSE and Fire Safety Coordinator Following the presentation, a representative from the Commission asked for an estimate of the time it would take to transition to alternatives? The speaker responded stating that 5-10 years may be appropriate, but they would like to keep PFAS stocks in case of a big fire incident. A representative from the Commission also asked the speaker why foams have been found to contain fluorine? The speaker stated that they have found traces of fluorine in "fluorine-free" foams in internal tests, so this is still an issue, but they do not know whether this is contamination pre/post manufacture. Another participant from a company further responded stating that there can be trace contaminants far below any functional level in fluorine-free foams unless manufacturers use a completely separate production facility than where PFAS foams are produced. One participant from a national authority mentioned that if there still is fluorine in fluorine-free foams then if you are training with the same equipment you are still contaminating the environment with PFAS. The speaker indicated that the O&G sector cannot burn large quantities of (liquid fuel) products for training purposes so they only conduct small scale training (4/5 m2) fires inside the site and large-scale testing is done at official testing sites. From these tests however, they can see that fluorine-free foams are effective. A company representative raised the point that when switching from PFAS-based foams to alternatives it is an entire system change that is required and not just a foam change. The speaker agreed and they know that when the company change they will have to review their entire system. 16 October 2019 Doc Ref. 41433-WOD-XX-XX-RP-OP-0011_S3_P01 10 Wood Environment & Infrastructure Solutions UK Limited Draft - see disclaimer 6.4 Niall Ramsden - Project Coordinator of LASTFIRE A stakeholder from an association noted that most people will likely agree that ca. 99% of liquid fires can be managed with fluorine-free alternatives, and only some specific applications (e.g. large atmospheric storage tanks) remain where transition will be feasible soon. The stakeholder stated that we need to be clear about what are we disagreeing and agreeing on as critical uses across the sector. A stakeholder representing an NGO responded to the previous comment, stating that there are large areas where the feasibility of transition is still uncertain (e.g. sprinklers in industrial applications) and there is a long process to prove effectiveness until it can be fully ensured. Breakout session on remaining data gaps The format and focus of the breakout session was then described by DT, indicating that there would be four different breakout groups after lunch. Participants were asked to attend three discussion topics spending ~30 minutes in each, before rotating. The following groups were proposed with ~10 participants allocated to each for the first session: Different Risk Management Options (RMOs) Essential uses and availability of alternatives Remediation costs and technologies Current/ future market trends in PFAS-based and fluorine free foams 7.1 Breakout group 1 - Different Risk Management Options The session was facilitated by Julius Kreissig from the project team. The group focused on the potential issues related to different risk management options based on the following questions: Different Risk Management Options (RMOs) What are the potential impacts of: different transition periods for phasing out PFAS in firefighting foams? different threshold concentrations of PFAS (i.e. impurity levels) in firefighting foams once the potential future regulation is in place? (e.g. what are the cost to clean up the installation associated with specific PFAS impurity thresholds) restrictions on either new PFAS-containing firefighting foam products entering the market only vs restrictions on both new PFAS-containing foam products and those already in use in existing systems? Additional considerations: Are there specific technical and economic feasibility considerations for conditions on the minimisation of releases of PFAS in the environment for "essential uses" where PFAS foams would be still needed? Capacity available, conditions required, efficiency of, human health/environmental safety and costs of disposal of existing PFAS foams (e.g. via incineration). 16 October 2019 Doc Ref. 41433-WOD-XX-XX-RP-OP-0011_S3_P01 11 Wood Environment & Infrastructure Solutions UK Limited Draft - see disclaimer The following points were raised during the discussion and are grouped in relation to each of the questions posed in the breakout group. What are the potential impacts of different transition periods for phasing out PFAS in firefighting foams? Answers and comments from stakeholders: General comments: There was a general consensus that for the majority of uses a phase out is of PFAS-based fire-fighting foams is possible, but many stakeholders noted that the required transition periods would vary by use. The idea of different transition periods for new and existing foams was also raised. A stakeholder representing an NGO suggested a transition period would usefully provide a specific target to progress the development of alternatives. They noted that in Queensland every user was required to developt and follow a 5 year transition plan (to avoid use until the last day of the transition period and then a hasty, problematic transition). A company representative noted that municipal fire-fighters fight class A and small class B fires, for which PFAS-based foams are not critical, but still cautioned implementing too short transition periods. A stakeholder from an association added that he expects for municipal fire-fighting, small spills and small fuel fires 2-3 years would be appropriate, not to rush the transition, allow sufficient spread over time for disposal and for equipment changes which are needed in some cases. Another company representative reported of their experience of transitioning to fluorine-free foams in airports in Germany which suggests transition can be made very quickly when putting the right equipment in place, but notes that this might not apply to the use for storage tanks. Other stakeholders noted that the lifetime of foams is about 20 years and while that may be too long given the concerns about persistence of PFAS, 2-3 years is a too short transition period. One company representative suggested that 10 years would be needed for a complete restriction to allow for the rebuilding of equipment and appropriate training of fire-fighters. They added that the experience from the phase-out of PFOS has shown that also disposal capacities can pose a challenge for a quicker transition. What are the potential impacts of different threshold concentrations of PFAS (i.e. impurity levels) in firefighting foams once the potential future regulation is in place? Answers and comments from stakeholders: Some stakeholders have shared their experience with cleaning equipment during their transition to fluorine-free foams: A stakeholder from an association reported a relatively simple cleaning process (emptied tank, flushed two times with warm water) revealed very low remaining PFAS contamination (both when tested immediately and after a few years), but cautions below 100ppb would be unrealistic. They noted some of their experienced were published and that the University of Bonn holds the data which could be used for a meta-analysis of concentration levels. A company representative mentioned there is a large difference in the clean-up effort between shorter (easier) and longer (harder) chain PFAS. They also recommended to consider what is detectable in measurements for setting a threshold concentration (for instance, precursors are more difficult to measure in the fire-fighting foam matrix than for example PFOS). 16 October 2019 Doc Ref. 41433-WOD-XX-XX-RP-OP-0011_S3_P01 12 Wood Environment & Infrastructure Solutions UK Limited Draft - see disclaimer Another company representative mentioned guidance on best practice for washing equipment from Bavaria, which recommends not to mix fire-fighting foam concentrates in the same equipment. Hence equipment always needs to be cleaned to switch products. A participant from a national authority noted he holds potentially useful information from the cleaning of Dutch tunnel systems from PFOS. They also reported that Melbourne had to develop a 32 step washing programme to clean their equipment. A company representative mentioned noted that threshold concentration are not only relevant in the context of cleaning equipment, but also because the production of strictly fluorinefree is virtually impossible, due to omnipresent PFAS contamination (e.g. in the water used for production). Therefore a regulatory definition of "fluorine-free" would be useful to provide long-term security about the threshold of PFAS contamination in the produced foams. Another company representative reports their fluorine-free products are tested by the University of Bonn to not exceed 1ppb. A few stakeholders referred to previous regulatory initiatives as a potential guide to define threshold concentrations. The PFOA restriction proposal included a discussion about threshold concentrations. Regulation in Queensland allows concentrations of 10/million for PFOS/PFHxS and 50/million for PFOA. What are the potential impacts of restrictions on either new PFAS-containing firefighting foam products entering the market only vs restrictions on both new PFAS-containing foam products and those already in use in existing systems? Answers and comments from stakeholders: Several stakeholders stated their preference to keep using stocks of PFAS-based foams due to concerns about the effectiveness of alternatives currently available for specific critical uses. For instance, one company representative noted that as a user for storage tank fires or large bund releases where they need full foam capacity, they would want their PFAS-based foam stock available. Several different companies using different foams may be involved in fighting the same tank fire (mutual aid agreements with neighbouring companies), and it is currently unclear if using fluorine-free foam on top of PFAS-based foam is effective. Other stakeholders argued that a restriction only covering PFAS in new foams would be problematic because many users would either stockpile PFAS-based foams before the restriction comes in place, or have problems switching to fluorine-free foams during or shortly after an incident. A participant from a national authority noted that in the framework of the Stockholm Convention there was a detailed discussion about the definition of stocks in existing systems (e.g. stocks are only considered "existing" if they are physically in a system), which can have significant implications in terms of the amount of foams to be phased out. Are there specific technical and economic feasibility considerations for conditions on the minimisation of releases of PFAS in the environment for "essential uses" where PFAS foams would be still needed? Answers and comments from stakeholders: Several stakeholders encouraged the use of risk management focusing at the reduction of release, both for potential critical uses as well as during a transition period. Some of the measures proposed were reducing the release of PFAS during storage of foams, as well as containment of foams in action. 16 October 2019 Doc Ref. 41433-WOD-XX-XX-RP-OP-0011_S3_P01 13 Wood Environment & Infrastructure Solutions UK Limited Draft - see disclaimer A stakeholder representing an NGO recommended the increased use of containment, but warned that it will never be feasible for all cases, not 100% reliable, and can be very expensive. They also highlighted that the definition of critical uses should consider that in most industrial uses, the risk resulting from the fire concerns mainly the asset value and disruption to operations, rather than health and safety concerns. As a result, fighting these fires is not as time critical compared to other uses. Therefore, the stakeholder proposed as an alternative interim solution for industrial uses to restrict PFAS-based foams to a small number of central, strategically located and well-managed stockpiles to be sent in case of emergencies. A company representative explained that fire water recovery systems are already obligatory regardless of foam used, based on reasonable worst case assumptions, in some Member States (e.g. Germany). Capacity available, conditions required, efficiency of, human health/environmental safety and costs of disposal of existing PFAS foams (e.g. via incineration). Answers and comments from stakeholders: This question received relatively little attention during the breakout sessions. A participant from a national authority argued that disposal capacity for foams is not too relevant for a potential restriction, because if foams are not disposed of then their continued use would also potentially require a similar remediation capacity. 7.2 Breakout group 2 - Essential uses and availability of alternatives The session was facilitated by Marlies Warming (COWI) from the project team. The following questions were presented: Essential uses and availability of alternatives Do the alternatives impart the desired functionality and comply with the required performance criteria/standards? If not, what functionality is inadequate? Are there critical uses/applications of fire-fighting foams where PFAS CANNOT be adequately replaced by ANY alternatives? Are some sectors more advanced on substitution than others and why is that the case? Are there differences in required volumes of use or application methods between PFAS-based and fluorine-free foams? Do volumes differ depending on specific applications/conditions? What are the financial/economic implications of using fluorine-free alternatives (e.g. unit price, frequency of foam replacement, cost of new equipment)? Do costs differ depending on specific applications/uses? Are there any other alternatives (including technologies) still under development/testing phase, not already (widely) available on the market? The following points were raised during the discussion and are grouped in relation to each of the questions posed in the breakout group. 16 October 2019 Doc Ref. 41433-WOD-XX-XX-RP-OP-0011_S3_P01 14 Wood Environment & Infrastructure Solutions UK Limited Draft - see disclaimer Do the alternatives impart the desired functionality and comply with the required performance criteria/standards? If not, what functionality is inadequate? AND Are there critical uses/applications of fire-fighting foams where PFAS CANNOT be adequately replaced by ANY alternatives? Are some sectors more advanced on substitution than others and why is that the case? Answers and comments from stakeholders: There was largely a consensus across discussion groups that substitution of PFAS foams with fluorine-free alternatives was possible, but that time was needed for the shift. There are experiences from the transition from C8 to C6 technology, but the participants argued that transition to fluorine-free alternatives is fundamentally different and requires more time. A shift requires not only a new foam, but adaption of the whole system (technology and technique). Ready drop-ins are not available, apart from experiences at off-shore facilities in Norway. Alternatives need to be tested and validated for use in different applications. Currently, testing procedures face the following limitations: Appropriate test criteria reflecting real life situations have to be developed Only few testing facilities are present in Europe and very often they are by their building permit limited to testing of fires with a single/very few fuels. Furthermore, there is a lack of facilities for large-scale testing and a lack of design standards. LASTFIRE is working on testing protocols for the use at tank storage sites. In the US (UL, NFPA, US military) also a lot of work is done in developing new tests, according to one stakeholder. Still, there is a long way to go. A company representative mentioned explains that their customers, e.g. a large German airport, developed their own test before deciding to switch to fluorine-free alternatives. Test procedures and results are confidential and not shared with other airports. The largest challenges are in the petrochemical sector, at tank storage sites, specialty chemicals and fires with water-miscible fuels. Participants noted there were possibly significant challenges for aviation. Substitution should be straight forward in municipal firefighting. One stakeholder from the O&G sector claimed that a transition time of 10 years would be needed for the switch in the petrochemicals sector. Several stakeholders also stated that 4-6 years may be sufficient. Are there differences in required volumes of use or application methods between PFAS-based and fluorine-free foams? Do volumes differ depending on specific applications/conditions? Answers and comments from stakeholders: Not possible to make general statements about volumes. In some situations, larger volumes of fluorine-free alternatives may be required compared to PFAS foams, in some situations the volumes will be the same. Volume is just one out of many parameters in successful firefighting, and certainly not the most important one. Not possible to make general statements about application methods. The preferred option is not to change application method when substituting PFAS with fluorine-free alternatives. However, there may be fluorine-free alternatives that require more gentle application (e.g. applying the foam against a wall for sliding down onto burning fuel surface instead of directly on the surface) 16 October 2019 Doc Ref. 41433-WOD-XX-XX-RP-OP-0011_S3_P01 15 Wood Environment & Infrastructure Solutions UK Limited Draft - see disclaimer The switch to fluorine-free alternatives may be easier in fixed systems such as sprinklers. A switch requires new proportioning systems - which is the cost driver in substitution What are the financial/economic implications of using fluorine-free alternatives (e.g. unit price, frequency of foam replacement, cost of new equipment)? Do costs differ depending on specific applications/uses? Answers and comments from stakeholders: Shelf-life was discussed. Participants noted it was not possible to make general statements. Shelf-life of fluorine-free alternatives can be as good as for PFAS foams. One end user mentioned they got a 10 yr warranty on their fluorine-free product, meaning they would obtain free replacement, if the product degraded before. Degradation in fluorine-free alternatives may be more critical compared to fluorinated foams, because fluorinated foams may still be somehow efficient even though one component has degraded because there may be several active components. In fluorine-free alternatives, the hydrocarbon surfactant may be the only active component, meaning performance is zero when this component is degraded. A company representative reported a practical solution - they bought new firefighting trucks with an extra compartment, so the trucks can both carry fluorine-free alternatives and PFAS foams. This would require investment of an additional 35,000 per truck. Are there any other alternatives (including technologies) still under development/testing phase, not already (widely) available on the market? AND Shortlist of alternative fluorine-free products that are most widely used in the EU - Which are the most commonly used and viable? Answers and comments from stakeholders: Some products are mentioned by specific product names (recommended concentrations, e.g. Re-Healing Foam RF3x3 FP ATC) others only by brand name, e.g. Respondol (Respondol is available as Respondol ATF 3-3% and Respondol ATF 3-6%). Wood need to distinguish what naming convention we are using when referring to products There are overall 2 categories of fluorine-free products in the shortlist. 1) Only products with designations including two numbers such as 3x3, 3-6 or 1/3 are newer alternative synthetic foams which can potentially substitute PFAS foams and are worth to be analysed further, including AR (alcohol-resistant) variants. 2) Other products with designations with single numbers such as F-6, F6 or 1% are older synthetic foams, which are on the market and are used, but do not have the properties which make them possible replacements for PFAS foams. The list is a moving target. As transition is ongoing, new products are developed. Next year's trade fair at Hannover will possibly present another 20 new fluorine-free products. None of the stakeholders said something about that some products are not used/ some more used than others. Fluorine-free siloxane products are viewed as regrettable substitutions by several national authority stakeholders. 7.3 Breakout group 3 - Remediation costs and technologies The session was facilitated by Liz Nicol from the project team. The following questions were presented and discussed: 16 October 2019 Doc Ref. 41433-WOD-XX-XX-RP-OP-0011_S3_P01 16 Wood Environment & Infrastructure Solutions UK Limited Draft - see disclaimer Remediation costs and technologies Which technologies are most commonly/likely applied for the remediation of soil and water contaminated by PFAS or alternative fire-fighting foams? What are the differences in remediation practices between PFAS-containing foams and fluorine free foams and between fire training exercises and true emergency responses? Are there cases where remediation is not necessary, not technically feasible or not economically viable? What approaches are used to manage regular run-off and storm-water run-off and what restrictions exist on discharge concentrations/volumes and treatment prior to discharge? Which additives, degradation-products or by-products of fire-fighting foams need to be considered, for both PFAS foams and alternatives? What are the current regulatory drivers to engage in remediation (e.g. permits for training activities and discharge, Water Framework Directive EQS for PFOS)? The following points were raised during the discussion and are grouped in relation to each of the questions posed in the breakout group. Which technologies are most commonly/likely applied for the remediation of soil and water contaminated by PFAS or alternative fire-fighting foams? Answers and comments from stakeholders: The general consensus between stakeholders was that remediation costs are highly sitespecific and risk-based. Remediation technologies applied will depend on whether the site has a legacy contamination from previous foam use or whether contamination is `new' from a recent live fire event. Legacy remediation is very difficult to address. One stakeholder noted that technologies have primarily been designed to remediate PFOS and the short chain PFAS substances are more mobile and remediation may therefore be more costly. No cost estimates were however given. Remediation technologies were discussed and a number of stakeholder mentioned the use of GAC, RO, ozonation and ion exchange resins (sometimes applied as polishing step) as the most commonly applied. One stakeholder noted that when estimating costs, both CAPEX and OPEX should be considered as GAC, for example, needs to be maintained and replaced every few years. A comment was made by one stakeholder that for any treatment process to work efficiently it needs to be optimised. They also added that once optimised, it can be possible to clean water to meet drinking water standards. Norway have transitioned away from PFAS-based foams in all airports and have compiled cost data on remediating drinking water and soil. A stakeholder gave an estimate of 1-30 million euros per airport for remediation. Overall, all stakeholders agreed that there were a lack of options for remediation of soil and the incineration capacity within the EU is likely insufficient (as the soil is classed as hazardous waste). Wastewater treatment was considered cheaper than incineration. One stakeholder from the O&G sector reported costs for incineration are in the region of 400-600,000 euros and the 16 October 2019 Doc Ref. 41433-WOD-XX-XX-RP-OP-0011_S3_P01 17 Wood Environment & Infrastructure Solutions UK Limited Draft - see disclaimer OPEX for GAC is estimates to be 50-160,000 euros. The same stakeholder mentioned that work is being done under the NICOLE network in the EU to examine costs of PFAS remediation. A new soil remediation technique was mentioned by one company representative and that a paper had just been released on the degradation of PFAS using anaerobic bacteria in soil, from Princeton university. The paper reported 60% of the PFAS was degraded by the bacteria in bench scale testing. Ozonation as a form of remediation technology was also mentioned by one stakeholder. There have been two case studies of its use in Australia and treatment of fire water was successful down to 0.002 ug/l of PFOS (using TOP assay). Overall, all stakeholders agreed that the technologies to deal with remediation are generally expensive so containment of fire-fighting wastewater and treatment before it reaches soil and groundwater is key. What are the differences in remediation practices between PFAS-containing foams and fluorine free foams and between fire training exercises and true emergency responses? Answers and comments from stakeholders: For big fire incidents, the area will need to be cleaned up after a live incident anyway for example during aeroplane crashes. One stakeholder suggested that the remediation practices would be largely the same but would mostly include remediation of firewater/runoff for emergency responses. General agreement by all stakeholders that clean up should happen as soon as possible after the incident if using PFAS-based foams but that remediation is not always necessary after the use of fluorine-free foams. Industry would like guidance on what to use and where. One stakeholder mentioned this is currently lacking and makes choosing the appropriate treatment challenging. Are there cases where remediation is not necessary, not technically feasible or not economically viable? Answers and comments from stakeholders: Strong agreement from all stakeholders that remediation is necessary in all cases. One stakeholder mentioned that for hydrocarbon fires there will always be remediation due to the contaminants present as a result of the fire material as well as the foam runoff. One stakeholder from the O&G sector suggested that the only instance where remediation would be very challenging is where fire-fighting foams have been used on live incidents close to waterbodies (on O&G platforms for example). Extracting the foam/firewater that has been directly discharged to water/sea is practically impossible. An example was given by one stakeholder where this recently happened in Denmark when there was a harbour fire and all runoff went directly to the sea. The issue of remaining stocks of PFAS-base foams was raised by one national authority stakeholder, questioning how we dispose of these in the event of a restriction especially if incineration capacity is limited in the EU. What approaches are used to manage regular run-off and storm-water run-off and what restrictions exist on discharge concentrations/volumes and treatment prior to discharge? Answers and comments from stakeholders: 16 October 2019 Doc Ref. 41433-WOD-XX-XX-RP-OP-0011_S3_P01 18 Wood Environment & Infrastructure Solutions UK Limited Draft - see disclaimer One stakeholder from an association noted the lack of awareness amongst firefighters with regard to the capture and treatment of runoff. Many are not aware of the implications of runoff escaping into the environment so there is a need for education training in this area. Effects of the foam runoff on the water treatment works were also mentioned by one member. The treatment of fluorine free foams was said to cause an emulsion in the treatment works that effects the efficacy of (subsequent) substance removal. An example was given by one national authority participant for a permit being granted in Copenhagen where 5,000 litres of firewater runoff (from fluorine-free foams) can be discharged direct to sewer, after a fuel separator step. Which additives, degradation-products or by-products of fire-fighting foams need to be considered, for both PFAS foams and alternatives? Answers and comments from stakeholders: Discussion on this topic emphasised that PFAS from firefighting foams in only a single component of a complex mixture that forms the fire runoff water. If there was to be consideration of regulating fire runoff water then one stakeholder commented that the toxicity of the runoff water in general should be taken into account. One stakeholder raised concerns over the use of silicone-based alternatives and questioned their appropriateness as their breakdown products could pose a risk to the environment. The RISE institute in Sweden was mentioned by one stakeholder, who referred to a report published in 2001 on the components of fire runoff and possible biodegradation of firewater runoff substances. What are the current regulatory drivers to engage in remediation (e.g. permits for training activities and discharge, Water Framework Directive EQS for PFOS)? Answers and comments from stakeholders: The majority of stakeholders agreed that the primary drivers for remediation were contamination of surface waters (WFD EQS) but also drinking water contamination. One stakeholder indicated that the receptor will drive the remediation technique applied. If drinking water is being compromised then soil remediation is crucial. 7.4 Breakout group 4 - Current/ future market trends in PFAS-based and fluorine-free foams The session was facilitated by DT from the project team. The following questions were presented: Current/ future market trends in PFAS-based and fluorine-free foams Are the estimates of the tonnages of PFAS-based and fluorine-free fire-fighting foams placed on the EU market and used in different sectors (still) accurate? Are any further shifts in the market expected (e.g. increasing share of specific types of foams, changes in prices for certain foams, changes in use patterns)? If so, what? How can the current data gaps (revenues from sales, which PFAS and alternative substances are used the most in fire-fighting foam) be addressed? 16 October 2019 Doc Ref. 41433-WOD-XX-XX-RP-OP-0011_S3_P01 19 Wood Environment & Infrastructure Solutions UK Limited Draft - see disclaimer The following points were raised during the discussion and are grouped in relation to each of the questions posed in the breakout session. Are the estimates of the tonnages of PFAS-based and fluorine-free fire-fighting foams placed on the EU market and used in different sectors (still) accurate? Answers and comments from stakeholders: Obtaining market data was recognised as sensitive, given its commercial nature. The data is based on a 3-year average (so we assume from 2017-2019 inclusive). Comparing overall volume data from a similar survey undertaken in 2018 (N.B this data has not been provided) - also based on a 3-year average - indicates that there has been a shift in the overall EU market, with the majority now using fluorine free foams. This was not the case in 2018. Whilst participants did not have market data, the import of foams into the EU is judged to be small and this reflects regulatory differences. However, the export market is judged to be much larger and quite significant. Stakeholders mentioned that when interpreting tonnage data, it is important to note that in this case, production is not use. Foams are retained in inventory. Are any further shifts in the market expected (e.g. increasing share of specific types of foams, changes in prices for certain foams, changes in use patterns)? If so, what? Answers and comments from stakeholders: Stakeholders commented that there is quite a high national containment of sales (i.e. a strong link between national producers and purchasers). Anecdotally, this was thought to reflect language barriers amongst - for example fire fighters. Whilst some participants noted that the precise shelf life of fluorine-free foams are not certain, given the lack of long-term use, several others indicated there was no difference in shelf life between foams. Both last - under appropriate storage conditions - for between 20 to 25 years. However, one participant indicated there may be some drop off in performance in fluorine free alternatives, which could be mounted/addressed with regular sampling tests every 2/3 years. These are inexpensive (sample testing with 5 litre samples costs c. 1k). Another issue affecting take up may be a relative loss of flexibility with alternative foams. PFAS based foam can be used across several types of fire, for fluorine free, specific types of foam are required for different types of fire. It comes down to specific products and testing with these are necessary. One participant commented that with testing demand increasing, there is a shortage of appropriate testing sites. Others had noticed a strong change in sentiment about fluorinefree foams from the US and globally, with for example, military purchases having changed their specifications. One industry participant noted that an issue preventing faster transition is the absence of specific standards for fluorine-free foams, that downstream users cannot use some foams as there are not specific standards which are designed for them. How can the current data gaps (revenues from sales, which PFAS and alternative substances are used the most in fire-fighting foam) be addressed? Answers and comments from stakeholders: 16 October 2019 Doc Ref. 41433-WOD-XX-XX-RP-OP-0011_S3_P01 20 Wood Environment & Infrastructure Solutions UK Limited Draft - see disclaimer Participants felt that the municipal firefighting application/sector had experienced a comparatively easy transition to fluorine free foams. This was not fully reflected in the data presented during the morning session - which indicated quite large PFAS based volumes were still being used. This surprised some participates (but it must be noted this was 3-year average data as noted above). Others suggested this may reflect lack of awareness. However further participants noted that in Sweden, Norway and Germany, they were largely fluorine free in this application. Participants queried whether "general industry" was covered in the data presented in the morning session. A participant from the military sector indicated that whilst testing and evaluation of fluorine free foams had been undertaken, they were, in his view, adopting a `wait and see' approach. Feedback from one participant in the airports sector indicated the same. In interpreting the volumes of PFAS containing and fluorine free foams in the petrochemical applications/sectors, the storage of quite high volumes was important for the most serious fires, likely more so than other sectors which may be reflected in the data presented in the morning session (i.e. they still held larger volumes of "older" PFAS foams). Participants reiterated the need for a long term plan for PFAS foam replacement. Participants judged there was no major differences in the unit price between PFAS and alternative foam types and that differences in unit costs is not likely to be an issue. A larger concern from this participant was the administrative burden and time required for substitution -e.g. regulatory compliance, training. Another participant noted that certain alternative foams may need faster application rates - in order to put out the fire in acceptable time periods. This would imply both greater volumes and costs, along with changes to the application system/nozzles to ensure it could deliver the required application rates. NFPA are doing testing now in order to issue guidelines. It is understood they have done some 150 tests, focusing on application rates and times to put out fires. They are expected to issue a revised design standard. Some end users (e.g. a large chemical company was mentioned) are carrying out their own tests on different type of fuel fires (e.g. Kerosene, Alcohol, ketones). Certain oil platforms have switched to fluorine-free foams, in this use the application rate is high, existing systems were able to cope with requirements for faster application rates. No further information was obtained on revenues. Reporting from break-out groups The rapporteurs for the BOGs reported back to the plenary (based on the notes above) and participants were invited to add further comments as appropriate. No additional comments were made by participants, so DT closed the session and moved to the final session. 16 October 2019 Doc Ref. 41433-WOD-XX-XX-RP-OP-0011_S3_P01 21 Wood Environment & Infrastructure Solutions UK Limited Draft - see disclaimer Closing remarks VB thanked the workshop participants for the good discussion throughout the day and noted that this was the first time a workshop had been held to discuss a potential RMOA. The experience was positive so this approach may be repeated for further projects. Participants were invited to provide further data and/or comments on the pre-workshop report and will receive a full set of workshop documents from the day at a later date. VB outlined the proposed timelines for a possible restriction for PFAS in foams (at least two years before draft regulations proposed) and stressed that the legislation may come eventually so transition to fluorinefree alternatives should be considered by all sectors. For any exemptions, more precise information will be needed to justify `critical use' exemptions and interested parties should be proactive in suppling this information. DM raised the issue of remaining data gaps for the project, including lack of data on hazards of alternatives and figures on transition/cleaning costs and disposal. Another participant from ECHA asked participants to provide information on transitional period and concentration threshold of a possible restriction so these can be considered in the final restriction dossier. DT formally closed the workshop 16 October 2019 Doc Ref. 41433-WOD-XX-XX-RP-OP-0011_S3_P01 A1 Wood Environment & Infrastructure Solutions UK Limited Appendix A Participants register Angelika Baumbusch Valentina Bertato Birgitta Beuthe Carlo Boledi Javier Castro Ingunn Correll Myhre Peter Hannebaum Sami Heikkila Olivier Houlbert Jenny Ivarsson Kalle Kivela Jeroen Konijnenberg Julius Kreiig Felix Kuemmerlen Stylianos Lekatos Thomas Leonhardt Jan Meinster Denis Mottet Liz Nicol John Olav Ottesen Eric Paillier Eike Peltzer Stephen Pepper Juan Pineros Niall Ramsden Veli-Matti Sskilahti Simone Schalles Tim Schulte-Frankenfeld Timo Seppl Vasileios Stefanioros David Tyrer Maria Uhl Jaakko Valtonen Marlies Warming Mike Willson Toke Winther 16 October 2019 Doc Ref. 41433-WOD-XX-XX-RP-OP-0011_S3_P01 B1 Wood Environment & Infrastructure Solutions UK Limited Appendix B Workshop presentation slides 16 October 2019 Doc Ref. 41433-WOD-XX-XX-RP-OP-0011_S3_P01 Welcome! Workshop Agenda Session Registration Plenary Overview (study purpose/ approach/ scope) and headline results Q and A discussion Coffee break Invited speakers Introduction to breakout session Buffet lunch Breakout sessions Coffee break Group feedback and discussion session Plenary and close 1 Timings 08:30-09:00 09:00- 09:30 09:30 - 10:15 10:15 - 11:00 11:00- 11:20 11:20 - 12:20 12:20 - 12:35 12:35-13:15 13:15-15:15 30 mins discussion per group. 15:15-15:35 15:35 - 17:00 17:00-17:30 Plenary 09:00 - 09:30 2 An introduction to the workshop (administrative aspects; house rules; the agenda for the day) ECHA 3 Policy context around the PFAS in fire-fighting foams study DG Environment 4 Study on PFAS and alternatives in firefighting-foams: the policy context 24 September 2019 Valentina Bertato European Commission, DG Environment Council conclusions, June 2019 The Council of the European Union: UNDERLINES the increasing health and environmental concerns posed by highly persistent chemicals; NOTES in specific the growing evidence for adverse effects caused by exposure to highly fluorinated compounds (PFAS), the evidence for wide spread occurrence of PFAS in water, soil, articles and waste and the threat this may cause to our drinking water supplies; CALLS on the Commission to develop an action plan to eliminate all non-essential uses of PFAS 6 At EU level New Commission: zero-pollution ambition. Wideranging approach looking at air and water quality, hazardous chemicals, emissions, pesticides and endocrine disruptors. Member States: asking the Commission for a PFAS strategy - to look at PFAS as a group; - use different regulatory instruments Drinking water directive: Commission proposal for a limit for all PFAS 7 Concerns of PFAS Long-chain PFAS (PFOA, PFOS, C9-C14 PFCAs and their salts): included in the Candidate List/restricted e.g. because of: - Extreme persistence - Bioaccumulation - Toxicity for reproduction Short-chain PFAS: High contamination potential of food, surface & ground water and drinking water sources - Mobility in the environmental compartments - No efficient techniques available for removal from sewage, drinking water and contaminated sites due to low adsorption potential; - Accumulation in (edible) plants; bioaccumulation potential; protein binding potential - Found in humans and in the environment despite of limited volumes - Long-range transport potential - wide geographical scale PFASs also result from degradation of precursors (side-chain fluorinated polymers and fluorotelomers) 8 REACH activities on PFAS PFOS, PFOA, C9-C14 PFCAs, PFHxS: all restricted or in the restriction process. GenX: recently identified as a Substance of Very High Concern - Persistence, mobility, potential for long-range transport, observed adverse effects, low adsorption potential and high water solubility rendering the substance fully bioavailable for uptake via (drinking) water. Together, these elements lead to a very high potential for irreversible effects. Restriction intention for PFHxA 9 International activities on PFAS Stockholm Convention COP agreed to list PFOA in Annex A Derogations more stringent than REACH restriction: will be taken over by the POP Regulation Encouraging Parties not to replace fire-fighting foam that contains PFOA with short-chain PFASs due to their persistency and mobility, potential negative environmental, human health and socioeconomic impacts PFHxS under discussion 10 Actions at EU level COM + ECHA: study to look at the use of all PFAS and non-fluorinated alternatives in fire-fighting foams - Hazard and emissions of all PFASs and alternatives - Costs of contamination of soil and water - SEA and AoA: identify specific, critical uses where fluorine-based FFF are needed - Potential basis for a restriction request to ECHA Will be followed by a study targeting use in textiles and leather 11 Are PFASs always needed? Provide unique performance in many applications BUT They are substances of concern Their use should be limited to the applications where they are essential - they provide vital functions - currently there are no available alternatives For the other applications, safer alternatives should be used Challenge for fire-fighting foams uses: identify if there are uses where PFASs are essential 12 Disclaimer All views expressed are purely personal and should not be considered as representative of the European Commission's official position. Neither the European Commission nor any person acting on behalf of the Commission is responsible for the use which might be made of the information provided. 13 Agenda Recap Session Registration Plenary Overview (study purpose/ approach/ scope) and headline results Q and A discussion Coffee break Invited speakers Introduction to breakout session Buffet lunch Breakout sessions Coffee break Group feedback and discussion session Plenary and close 15 Timings 08:30-09:00 09:00- 09:30 09:30 - 10:15 10:15 - 11:00 11:00- 11:20 11:20 - 12:20 12:20 - 12:35 12:35-13:15 13:15-15:15 30 mins discussion per group. 15:15-15:35 15:35 - 17:00 17:00-17:30 Overview 17 Overview (study purpose/ approach/ scope) and headline results of PFAS in fire-fighting foams study 09:30-10:15 14 Preliminary results for study on PFAS in fire-fighting foams Presenters: David Tyrer, Miriam Schpel, Julius Kreiig, Liz Nicol woodplc.com Aims Study: - Basis for a decision on the appropriate regulatory measures to control the risks associated with PFAS Purpose of this workshop: - Present, validate and seek feedback on the project findings so far - Gather views on Possible risk management options Functionality/feasibility of alternatives Preliminary estimates of environmental emissions Remediation costs following foam use Future trends in use of PFAS-based foams and alternatives 18 Tasks DG ENV study Substance identification Market analysis Emissions and hazards Remediation costs Pre-RMOA Pre-Annex XV dossier 19 ECHA study Analysis of alternatives Socio-economic Analysis Supporting both studies Consultation Workshop Methodology Review of literature, regulatory documents and monitoring data Written questionnaire sent to ~60 organisations 27+ responses received Scoping and follow-up interviews with key stakeholders Further engagement through stakeholder workshop 20 Substance identification of PFAS-based foams and alternatives 21 Main findings - Substance identification Aim: - Identify PFAS in fire-fighting foams - Identify constituents of the fluorine-free alternatives - Identify any non-PFAS fluorinated alternatives Sets the scene for the whole study: - What substances underpin the concern to be assessed? - What are the alternatives? 22 Main findings - Substance identification Results indicate that there are NO substances that are fluorinated but not PFAS (not poly- or per-). Overview of PFAS in AFFF - 63 substances were "fully" identified ( fully = name, chemical structure & CAS/EC) - Limited information on the respective salts 23 Main findings - Substance identification 22 "common" PFAS PFCAs (perfluorocarboxylic acids): C4-C18 PFSAs (perfluoroalkane sulfonic acids): C2-C11 12 derivates of PFAS (=additional functionality at the headgroup) - e.g. PFOSaAM (sulfonamido amine ) and PFHpSA (sulphonamide) Structure of PFOSaAM 7 "other" PFAS, e.g. a perfluorinated ketone (Dodecafluoro-2-methylpentan-3-one ) Structure of Dodecafluoro- 2-methylpentan-3-one 24 Main findings - Substance identification Fluorotelomers (non-fluorinated carbon spacer between functional headgroup and perfluorinated chain) Structure of 6:2 FTS - High variety in spacer length, perfluorinated chain, and functional groups identified Spacer lengths: xx:2, xx:1:2, xx:3 Perfluorinated chain: C4-C12 Functional groups: Sulfonic acid (S) , Alkylbetaine, Betaine (B), Carboxylic acid (CA), Hydroxy (OH), Thioamido sulfonates (TAoS), Unsaturated carboxylic acid (UCA), Sulfonamido betaines (SaB), Sulfonamide amine (SaAm), Thio hydroxy ammonium (THN+) 25 Main findings - Substance identification Overview of non-fluorinated alternatives, showing 4 groups (number of substances): Non-fluorinated alternatives Hydrocarbons (24) Detergents (33) Proteins (3) Siloxanes (3) 26 Main findings - Substance identification Hydrocarbons & Detergents: a variety of hydrocarbons and detergents were identified, that are used in AFFF (solely & combined). - 24 Hydrocarbons: Fatty acids Gums Sugars Alcohols Polyethylene glycols (PEGs) Alkanes - 33 Detergents: Structure of sodium octyl sulphate Alkylbetaines Alkylsulfates Alkylamines Others Structure of sodium octyl sulphate 27 Main findings - Substance identification Proteins & Siloxanes: available information is limited. In the case of the siloxanes, the usage of these substances in firefighting foams is mostly still under development. - Siloxanes: 1 "fully" identified substance () Sugar-based siloxanes (under development) Structure of Siloxanes and Silicones, 3-hydroxypropyl Me, ethers with polyethylene glycol mono-Me ether - Proteins: hydrolysed protein silk-based protein hydrolysate horn and hoof-based proteins 28 Main findings - Substance identification In summary, a large number of diverse PFAS substances were identified that are used in firefighting foams. This could be an indication of extensive and ongoing replacement chemistry The sheer amount of identified substances highlights the need for prioritisation of the identified substances and products, especially for subsequent tasks. 29 A presentation by Wood. Market analysis of PFAS-based and fluorine-free foams 30 Main findings - Market analysis Aims: - Estimate tonnages and values of fire-fighting foams manufactured and placed on the market in the EU - Different functions provided and the type of fires for which they are used - Expected market developments 31 Main findings - Market analysis Tonnages Market data in the literature mostly outdated and focused on PFOS or "PFOA-related compounds" - results depend heavily on consultation >335 tonnes of 8 specific and 3 unknown (confidential) fluoro-compounds used to manufacture fire-fighting foams in EU (see table next slide, 2018 data) Volumes expected to have shifted towards fluorine-free New data has been received since the pre-workshop report has been issued 32 A presentation by Wood. Main findings - Market analysis Fluoro-compound 1-Propanaminium,N-(carboxymethyl)-N,N-dimethyl-3-[[(3,3,4,4,5,5,6,6,7,7,8,8,8tridecafluorooctyl)sulfonyl]amino]-,inner salt 1-Propanaminium, 3-amino-N-(carboxymethyl)-N,N-dimethyl-N-[[(gamma-omega-perfluoro-C6C16-alkyl)thio]acetyl] derives., inner salts 2-methyl-2 - [(1-oxo-3 - [(3,3,4,4,5,5,6,6,7,7,8,8,8-tridecafluorooctyl) thio] propyl) amino] -1propanesulfonic acid, sodium salt 2-hydroxy-N,N,N-trimethyl-3-[(3,3,4,4,5,5,6,6,7,7,8,8,8-tridecafluorooctyl)thio]-1-Propanaminium, chloride (1:1) 2-Propenamide, telomer with 4-[(3,3,4,4,5,5,6,6,7,7,8,8,8-tridecafluorooctyl)thio]-1-butanethiol ) 2-Propenoic acid, telomer with 2-propenamide and 4-[(3,3,4,4,5,5,6,6,7,7,8,8,8tridecafluorooctyl)thio]-1-butanethiol, sodium salt 2-Propenamide, telomer with 3,3,4,4,5,5,6,6,7,7,8,8,8-tridecafluoro-1-octanethiol unknown C-6 fluorinated substances unknown unknown 1-Propanaminium,N-(carboxymethyl)-N,N-dimethyl-3-[[(3,3,4,4,5,5,6,6,7,7,8,8,8tridecafluorooctyl)sulfonyl]amino]-, inner salt and 6:2 FTS CAS number 34455-29-3 80475-32-7 62880-93-7 88992-45-4 unknown unknown 76830-12-1 unknown unknown unknown 34455-29-3 and 27619-97-2 Tonnes per year 21.1 17.2 0.5 0.2 0.2 0.3 0.9 17.1 138.6 138.6 unknown* 33 A presentation by Wood. *) used to produce 550,000 litres of foam concentrate Main findings - Market analysis Newly collected data (to be validated/extrapolated): - Tonnes of foam sales in the EU (rounded to closest 100t) Fluorine-free foam offerings 1a 2a share into airports share into chemical/petrochemical industry 3a 4a 5a Fluorine-containing foam 1b offerings 2b share into municipal fire brigades share into ready for use products share into marine applications share into airports share into chemical/petrochemical industry 3b share into municipal fire brigades 4b share into ready for use products 5b share into marine applications Split by revenue: - Fluorine-containing foams: 76% - Fluorine-free foams: 24% 34 A presentation by Wood. 700 1,000 3,900 100 2,300 800 7,800 1,500 200 2,100 Main findings - Market analysis Values No data on revenues from sales Prices range widely for both fluorine-free and PFAS-based foams - Performance needs to be considered to compare prices of different products 35 A presentation by Wood. Main findings - Market analysis Functions and types of fires PFAS and alternatives act as surfactants, i.e. to form a film over the burning surface Particularly relevant feature for fire involving flammable liquids (Class B fires) Used for spills, accidents, fuel/alcohol fires, tests and trainings Main sectors of use: - Majority in the chemicals/petrochemicals sectors - Significant share in marine applications, airports, municipal fire-fighting - Relatively small volumes: the waste sector, fire-extinguishers, railway tunnels 36 A presentation by Wood. Main findings - Market analysis Next steps Main data gaps: - Breakdown of use/sales by user sectors - Revenues from sales - Additional information for prioritisation: Which are the most commonly used PFAS and alternative substances in firefighting foams? Workshop breakout group 4: - Discuss validity of the results provided - Expected market developments (Are any further shifts in the market expected?) - Discuss data gaps and how they can be addressed 37 A presentation by Wood. Analysis of feasibility and availability of fluorinefree alternatives 38 Analysis of alternatives The purpose of this task is to assess the feasibility and availability of alternatives to PFAS containing fire-fighting foams. Analysis of alternatives The AoA will focus on alternative substances or techniques that could fulfil the required function including: Technical feasibility (performance and efficacy) Economic feasibility (cost) Availability of fluorine-free alternatives This task has identified potential alternatives to PFAS-containing foams using literature screening, stakeholder consultation and the results of the Commission study. But what are the implications of switching? Main findings - Analysis of alternatives Alternative products cover use across all sectors. Both emergency response and training foams are available. The European Standards of EN 1568 Part 1-4 test for extinguishment and burnback performance on liquid fuel fires. For all liquid fuel types, tested fluorine-free foams are available. Percentage of alternative products that can be used for each sector 17% 10% 10% 2% 6% 4% 51% aviation forest and nature multiple oil and gas domestic marine Not suitable for fuels 40 Analysis of alternatives Preliminary results - Consultation responses The specific chemical identity of foam products is not always available/divulged No information on amount of alternatives imported from outside the EU In terms of differences in volumes needed between alternatives and PFAS-based foams, most responses suggest there is no difference between `traditional' and `alternative' foams Users indicated the trend in their demand for foams has remained stable over the past 10 years. 41 A presentation by Wood. Analysis of alternatives Preliminary results - `in-use' alternatives Shortlist of alternative fluorine-free products that are most widely used in the EU Which are the most commonly used and viable? We would welcome your feedback Product Sthamex F-15 Sthamex F-6 Moussol FF 3x6 bungsschaummittel-N Expandol LT Forexpan Respondol Bluefoam 3x3 Bluefoam 1x3 Bluefoam 3x6 Bluefoam 6x6 Re-Healing Foam RF-H+ Re-Healing TF Re-Healing Foam RF3x3 FP ATC Re-Healing Foam RF 3x6 FP ATC Re-Healing Foam RF1 1% Re-Healing Foam RF1-S 1% Re-Healing Foam RF3 3% Re-Healing Foam RF3x6 ATC Re-Healing Foam RF-MB Re-Healing Foam RF6 6% ECOPOL BIO FOR BIO FOAM BIO T3 and BIO T6 EE-3 Newtonian Training foam Unipol ARC 3x3 Environ FREEFOR SF 42 A presentation by Wood. Manufacturer/Supplier Dr. Sthamer Angus fire Orchidee Solberg Bio-ex Auxquimia Fomtec 3F Company Analysis of alternatives Next steps Main data gaps Information not readily available in the public domain for alternatives under R&D Limited data received on the costs of replacing equipment associated with switching to alternative foams. Similarly, limited quantitative data was provided on the potential savings associated with switching to alternatives. Workshop breakout group 2 discussion: - Critical uses/applications where PFAS foams CANNOT be replaced - Financial/economic and technical (volume) implications of using fluorine-free alternatives - Other alternatives (including technologies) under development 43 A presentation by Wood. Estimating emissions of PFAS-based foams and alternatives 44 Main findings - Emissions Scope: - Estimate emissions of PFAS / alternatives to the environment (by compartment) and possible uptake by humans Task in early stages: No results available yet but key preliminary assumptions to be verified/refined (1/2) Industry sectors Military Market split as % 29% Annual usage rates (against stockpiles held) 7% Proportion used for training and testing 93% Proportion used for live incidents 7% Civil Aviation 16% 12% 93% 7% Municipal fire services 14% 7% 7% 93% Petroleum refineries 20% 12% 93% 7% Petrochemical 21% 7% 93% 7% manufacturing 45 Main findings - Emissions Preliminary assumptions to be verified/refined (2/2) Life-cycle stage and processes Assumptions Formulation of fire-fighting foam concentrates Emissions to: air 2.5% of surfactant used; wastewater 2% of surfactant used; and land 0.01% of surfactant used. Storage of concentrates prior to Emissions related to leaks and spillages: 1% of stockpiles held in use storage annually. Efficacy of capture and storage Efficacy assumed to be 97% - i.e. 97% of all foam used is captured and devices during testing / training retained for destruction. 3% is lost to wastewater systems. Efficacy of capture and storage devices during live incidents Efficacy assumed to be 0%. I.e. during live incidents 100% will be lost to environment. Assumed to be 50% land and 50% surface water. Efficacy of waste incineration for Assumed efficacy of incineration processes 99%. destruction of surfactants Efficacy of waste water treatment processes PFAS-based foams: Wastewater treatment processes will be 50% effective (i.e. 50% remains undegraded and is released to surface water / sewage sludge). Non-fluorinated foams: 80% effective 46 Remediation costs of foam use 47 Main findings - Remediation costs Scope: - Develop remediation case studies for most likely use scenarios to identify most likely remediation techniques and their costs Task in early stages: No results available yet but key questions identified (for discussion in breakout group 3): - Current clean-up practices: Clean-up procedures after a fire training exercise vs true emergency response Differences between using PFAS-containing foams and fluorine free foams Additives, degradation-products or by-products to be considered Cases where remediation is not necessary or not feasible - Run-off: Approaches to manage regular run-off and storm-water run-off Discharge: restrictions on concentrations/volumes and treatment prior to discharge - Historic release: Technologies used to manage (historic) release to soil and groundwater Source area treatment vs. end-of-pipe technology - Regulatory drivers: What are the current regulatory drivers to engage in remediation Permits for training activities and discharge Impact of Water Framework Directive EQS for PFOS 48 Thanks for listening! 49 Questions Please raise questions on a topic by topic basis 1. Substance identification of PFAS-based foams and alternatives 2. Market analysis of PFAS-based foams and alternatives 3. Analysis of fluorine-free alternatives 4. Estimates of substance emission from foams 5. Remediation costs 51 A presentation by Wood. Agenda Recap Session Registration Plenary Overview (study purpose/ approach/ scope) and headline results Q and A discussion Coffee break Invited speakers Introduction to breakout session Buffet lunch Breakout sessions Coffee break Group feedback and discussion session Plenary and close 53 Timings 08:30-09:00 09:00- 09:30 09:30 - 10:15 10:15 - 11:00 11:00- 11:20 11:20 - 12:20 12:20 - 12:35 12:35-13:15 13:15-15:15 30 mins discussion per group. 15:15-15:35 15:35 - 17:00 17:00-17:30 Q&A discussion session 10:15 - 11:00 50 Time for coffee! 11:00-11:20 52 Invited speakers 11:20- 12:20 54 Invited speakers We will now hear about experiences of key sectors 11:20-11:35 Eurofeu (presenter TBC) 11:35-11:50 Veli-Matti Sskilahti - Finavia 11:50-12:05 Eric Paillier - Total HSE and Fire Safety Coordinator 12:05-12:20 Niall Ramsden - Project Coordinator of LASTFIRE (15 min slot including questions after each presentation) 55 A presentation by Wood. Agenda Recap Session Registration Plenary Overview (study purpose/ approach/ scope) and headline results Q and A discussion Coffee break Invited speakers Introduction to breakout session Buffet lunch Breakout sessions Coffee break Group feedback and discussion session Plenary and close 56 Timings 08:30-09:00 09:00- 09:30 09:30 - 10:15 10:15 - 11:00 11:00- 11:20 11:20 - 12:20 12:20 - 12:35 12:35-13:15 13:15-15:15 30 mins discussion per group. 15:15-15:35 15:35 - 17:00 17:00-17:30 Introduction to the breakout session (after lunch) 12:20- 12:35 57 Context At this stage of the project we have collated information from the literature and stakeholder questionnaires For the next stage of analysis we require further input from stakeholders on the remaining data gaps Key topics will be discussed after lunch during a series of breakout groups where we would like you to share your experiences/insights and any key case study examples. 58 A presentation by Wood. Format There will be four breakout groups in the session after lunch and participants will have the opportunity to move between three chosen topic areas of interest. Participants will then report back from the breakout groups in the late afternoon For each group, there will be a facilitator/ rapporteur who will lead and report back on the discussions during the final plenary session. The facilitators/ rapporteurs will be from the Wood project team. 59 A presentation by Wood. Format Series of breakout groups are as follows: - Proposed RMOs - Alternatives - Remediation of PFAS - Current/future trends in PFAS-based foam use 60 A presentation by Wood. Groups RMOA- K323 room Ingunn Kalle Denis Johanna Eike Simone Tim Peter Remediation -Guido Sacconi room Angelika Birgitta Jenny Felix Stephen Timo Vasileios Toke 61 A presentation by Wood. Alternatives -Margot Valentina Olivier Jeroen Jan Juan Niall Veli-Matti Jaakko Mike Wallstrm plenary room Market trends - K324 room Carlo Javier Stylianos John Olav Eric David Maria Thomas Please remember your breakout groups for this afternoon Time for lunch! 12:35-13:15 62 Agenda Session Registration Plenary Overview (study purpose/ approach/ scope) and headline results Q and A discussion Coffee break Invited speakers Introduction to breakout session Buffet lunch Breakout sessions Coffee break Group feedback and discussion session Plenary and close 63 Timings 08:30-09:00 09:00- 09:30 09:30 - 10:15 10:15 - 11:00 11:00- 11:20 11:20 - 12:20 12:20 - 12:35 12:35-13:15 13:15-15:15 30 mins discussion per group. 15:15-15:35 15:35 - 17:00 17:00-17:30 Breakout sessions 13:15- 15:15 64 Groups RMOA- K323 room Ingunn Kalle Denis Johanna Eike Simone Tim Peter Remediation -Guido Sacconi room Angelika Birgitta Jenny Felix Stephen Timo Vasileios Toke 65 A presentation by Wood. Alternatives -Margot Valentina Olivier Jeroen Jan Juan Niall Veli-Matti Jaakko Mike Wallstrm plenary room Market trends - K324 room Carlo Javier Stylianos John Olav Eric David Maria Thomas Format Facilitators will assist each group to guide the discussion and take notes Your first breakout group has been pre-allocated Next two groups can be your choice We will let you know after 30 mins are up and you can move to your next group 66 A presentation by Wood. Different Risk Management Options (RMOs) What are the potential impacts of: - different transition periods for phasing out PFAS in firefighting foams? - different threshold concentrations of PFAS (i.e. impurity levels) in firefighting foams once the potential future regulation is in place? (e.g. what are the cost to clean up the installation associated with specific PFAS impurity thresholds) - restrictions on either new PFAS firefighting foam products entering the market only vs restrictions on both new PFAS-containing foam products and those already in use in existing systems? Additional considerations: Are there any specific technical or economic considerations that need to be considered to minimize releases of PFAS for "essential uses" where PFAS foams would still be needed? Capacity available, conditions required, efficiency of, human health/environmental safety and costs of disposal of existing PFAS foams (e.g. via incineration). 67 A presentation by Wood. Essential uses and availability of alternatives Do the alternatives impart the desired functionality and comply with the required performance criteria/standards? If not, what functionality is inadequate? Are there critical uses/applications of fire-fighting foams where PFAS CANNOT be adequately replaced by ANY alternatives? Are some sectors more advanced on substitution than others and why is that the case? Are there differences in required volumes of use or application methods between PFAS-based and fluorine-free foams? Do volumes differ depending on specific applications/conditions? What are the financial/economic implications of using fluorine-free alternatives (e.g. unit price, frequency of foam replacement, cost of new equipment)? Do costs differ depending on specific applications/uses? Are there any other alternatives (including technologies) still under development/testing phase, not already (widely) available on the market? 68 A presentation by Wood. Essential uses and availability of alternatives Shortlist of alternative fluorine-free products that are most widely used in the EU Which are the most commonly used and viable? 69 A presentation by Wood. Product Sthamex F-15 Sthamex F-6 Moussol FF 3x6 bungsschaummittel-N Expandol LT Forexpan Respondol Bluefoam 3x3 Bluefoam 1x3 Bluefoam 3x6 Bluefoam 6x6 Re-Healing Foam RF-H+ Re-Healing TF Re-Healing Foam RF3x3 FP ATC Re-Healing Foam RF 3x6 FP ATC Re-Healing Foam RF1 1% Re-Healing Foam RF1-S 1% Re-Healing Foam RF3 3% Re-Healing Foam RF3x6 ATC Re-Healing Foam RF-MB Re-Healing Foam RF6 6% ECOPOL BIO FOR BIO FOAM BIO T3 and BIO T6 EE-3 Newtonian Training foam Unipol ARC 3x3 Environ FREEFOR SF Manufacturer/Supplier Dr. Sthamer Angus fire Orchidee Solberg Bio-ex Auxquimia Fomtec 3F Company Current/ future market trends in PFAS-based and fluorine-free foams Are the estimates of the tonnages of PFAS-based and fluorine-free fire-fighting foams placed on the EU market and used in different sectors (still) accurate? Are any further shifts in the market expected (e.g. increasing share of specific types of foams, changes in prices for certain foams, changes in use patterns)? If so, what? How can the current data gaps (revenues from sales, which PFAS and alternative substances are used the most in fire-fighting foam) be addressed? 71 A presentation by Wood. Remediation costs and technologies Which technologies are most commonly/likely applied for the remediation of soil and water contaminated by PFAS or alternative fire-fighting foams? What are the differences in remediation practices between PFAScontaining foams and fluorine free foams and between fire training exercises and true emergency responses? Are there cases where remediation is not necessary, not technically feasible or not economically viable? What approaches are used to manage regular run-off and stormwater run-off and what restrictions exist on discharge concentrations/volumes and treatment prior to discharge? Which additives, degradation-products or by-products of fire-fighting foams need to be considered, for both PFAS foams and alternatives ? What are the current regulatory drivers to engage in remediation (e.g. permits for training activities and discharge, Water Framework Directive EQS for PFOS)? 70 A presentation by Wood. Time for coffee! 15:15-15:35 72 Group feedback and discussion session 15:35 - 17:00 73 Group 1. RMOs Main points of discussion General trends Potential impacts of future risk management options - Transitional periods - Threshold concentrations - New vs On the market 74 A presentation by Wood. Group 2. Alternatives Main points of discussion General trends - Are there essential uses where PFAS cannot be replaced? - Technical and financial/economic implications of using fluorine-free alternatives - Alternatives still under development/testing phase - Are some use sectors more advanced in terms of replacing PFAS-based foams? 75 A presentation by Wood. Group 3. Remediation Main points of discussion General trends - Which technologies are most commonly/likely applied for the remediation of PFAS or alternative fire-fighting foams? - Are there cases where remediation is not necessary, not technically feasible or not economically viable? - Which additives, degradation-products or by-products of fire-fighting foams also need to be considered for remediation? 76 A presentation by Wood. Group 4. Market trends Main points of discussion General trends - What are the main differences in the use patterns between PFAS-based and fluorine-free fire-fighting foams? - What level of substitution is currently happening and what have the experiences been? - Are any further shifts in the market expected? 77 A presentation by Wood. Plenary and close 17:00 - 17:30 78 Remaining information gaps Market value and tonnages used of PFAS-based and fluorine-free foams Which alternatives are currently in use in the EU and are there 'essential uses' where PFAS- based foams cannot be replaced Are there any other alternatives still under development/testing phase, not available on the market? How do the costs of switching to fluorine-free alternatives compare to PFAS-based foams (foam, equipment, cleanup) Next steps - project Commence final tasks on -- Remediation costs of using PFAS-based foams -- Socio-economic analysis of substitution Summarise all information in the form of a Risk management option analysis (pre-RMOA) and Pre-Annex XV restriction dossier Project will complete summer 2020 Next steps - workshop Workshop meeting notes will be circulated along with -- Participant list -- Presentations from the day -- Feedback forms If you have any further questions or comments after today, please contact -- Julius @woodplc.com or Liz woodplc.com for project related enquiries preuntaWn Thank you! Have a safe trip home wood. x.odpkxom C1 Wood Environment & Infrastructure Solutions UK Limited Appendix C Invited speaker presentation slides 16 October 2019 Doc Ref. 41433-WOD-XX-XX-RP-OP-0011_S3_P01 EUROFEU Helsinki 2019 Dr. Thomas Leonhardt Member of the Board Chairman Section Firefighting Agents FFA Agenda About EUROFEU What is EUROFEU The organization Our mission Anatomy of Foam Concentrates Surfactants in Firefighting Foams Fluorosurfactants in Firefighting Foams Fluorine Free Foams (F3) Firefighting Foams - The Future The EUROFEU Position Dr. Thomas Leonhardt, September 25th. 2019 2 FFA What are we EUROFEU is a non-for-profit organization, founded in 1969 in Frankfurt am Main. EUROFEU is the umbrella organization of the European fire protection industry representing both national trade associations of the EU-Members as well as individual companies active in the field of fire protection in Europe. EUROFEU's member associations and -companies constitute the relevant European market for active fire protection products EUROFEU has been the European representative for active fire protection for many decades and still is. EUROFEU holds, grows and delivers expert knowledge and long term experience in the field of active fire protection. Dr. Thomas Leonhardt, September 25th. 2019 3 FFA The Organization Member structure institutional members (national trade associations) from Belgium, France, Germany, Italy, Spain and Switzerland Company members Dr. Thomas Leonhardt, September 25th. 2019 4 FFA Our Network EUROFEU liaises with different European and International Organisations of which the most important are: Accredited stakeholder to ECHA Observer to OSPAR Observer to UN Stockholm-, Basel- and Rotterdam-Convention Liaison with ISO Liaison with CEN and CENELEC Liaison with Insurance Europe Liaison with Eurosprinkler Dr. Thomas Leonhardt, September 25th. 2019 5 FFA What is our mission EUROFEU seeks to improve the quality of products and services in active fire protection, to develop and improve standards, support their application, develop the market and improve safety of use of products to improve the overall fire safety level in Europe. EUROFEU holds expert knowledge: members have direct access to proven experts in their field in any subject of active fire protection EUROFEU develops expert knowledge: EUROFEU supports studies, links with other groups and organisations and collects input from other areas to promote and develop its expertise in active fire protection and related areas EUROFEU provides expert knowledge: EUROFEU delegates experts to and liaises with standardization committees, supports the market and its members with position papers, acts as a knowledge base, supports legislators and authorities with inside expert knowledge on all aspects of fire protection Dr. Thomas Leonhardt, September 25th. 2019 6 FFA Firefighting Foams Foam is a technology to make water lighter, wetter and more effective: Foams are very light weight hence can float on almost any liquid's surface enable extinguishment and coverage of liquid fuels Foam contains surfactants enabling water to wet or stick to water repellent surfaces (e.g. soot covered surfaces) Foam contains only 0,1 to 10% vol. of water reduces collateral damage caused by fire waters dramatically Foam has a very low density hence is capable to fill large voids (High expansion foams in ware houses or aircraft hangars) Dr. Thomas Leonhardt, September 25th. 2019 Picture by Vladislav96kv - Own work, CC BY-SA 4.0, https://commons.wikimedia.org/w/index.php?curi d=63967895 7 FFA Anatomy of Foam Concentrates Foaming Agents (surfactants, proteins): reduce the surface tension of aqueous solutions and ultimately make the bubbles Solvents (water, glycols): help keeping all ingredients in solution (balancing effect) Functional additives (anti-freezes, preservatives, performance boosters, polymers ...): help establish/enhance additional technical features or properties Dr. Thomas Leonhardt, September 25th. 2019 8 FFA Surfactant Action Head: Water attracting AND Fat-repelling Tail: Water repelling AND Fatattracting Dr. Thomas Leonhardt, September 25th. 2019 Surfactants self-arrange to molecular layers/films at the interface between water and non-miscible matter: Surfactant in water: Head down into the water and the tail up into the air. ...and in fuel: now fat-loving tail down into the fuel, head up into the air 9 FFA Surfactant Action Surfactant molecules form membranes at the interface between water and non- water miscible matter (grease, dirt, air or gasses) allowing to disperse it into the water sphere. This makes water repellent surfaces such as (e.g. soot covered ones) wettable - hence accessible to fire fighting agents Dr. Thomas Leonhardt, September 25th. 2019 Water droplet 10 FFA Emuslification - Flipside of wetting If the non water-miscible matter is a liquid (e.g. fuels) dispersing it uses up surfactant molecules which are no more available for foam bubbles the foam collapses. Dr. Thomas Leonhardt, September 25th. 2019 And it mixes micro-droplets of fuel into the firefighting foam making it "flammable". 11 FFA Surfactants Carbon Hydrate Surfactant Head: Water attracting AND Fat-repelling Tail: Water repelling AND Fat-attracting A "little" difference - key to performance Fluoro Surfactant Head: Water attracting AND Fat-repelling Tail: Water repelling AND Fat- repelling Dr. Thomas Leonhardt, September 25th. 2019 12 FFA Fluoro-Surfactants Fluorosurfactants make the foam bubble fuel repellent! Drastically reduces fuel pick-up Improves vapor resistance of the foam blanket Universal, non-selective effect on all fuels Dr. Thomas Leonhardt, September 25th. 2019 < 0,05% FS needed: Concentrate contains ~0,5-5%w/w, solution for use contains 0,5-6% concentrate 13 FFA Fluorine Free Foams F3's seem to require a much closer look prior to and during use: F3s seem to be much more sensible to changing conditions such as fuel type, water quality, temperature, pressure, hardware and others. F3s also seem to respond more drastically to any change of those conditions: even slightly adverse conditions do not just reduce performance but could cause a steep drop of it F3s are not very forgiving for errors in application or dosage Conformity Testing according to international standards bases upon the principle of extrapolating test results to analogue real world situations - this principle does not work the same way across the board hence standards need to be adopted - standard test results need to be looked at more critical. Dr. Thomas Leonhardt, September 25th. 2019 14 FFA Firefighting Foams - The Future In order to maintain the current level of fire safety we suggest a concerted action of all stakeholders: Legislators: Maintain access to AFFF foams for high risk areas such as: sites operating with a complex mix of liquid fuels (chemical or petrochemical sites) Large fuel storage plants Special risk scenarios (adjacent other facilities or housing areas, etc., some airfields, military, ). until fluorine free alternatives are available for all applications Restrict the use of AFFF (based upon justification, presence of sufficient firewater retention and -disposal, ...) Users: Eliminate use of AFFF in areas where no benefit derives from it (municipal FBs, sites with limited or no class B-risk or few class B fuels only, etc.) In case of emergency always start operation using F3, pull in AFFF on demand only Establish measures to review and improve the fire protection concept regularly to reduce use of AFFF Support research for new/alternative concepts, techniques or products Manufacturers: Continue and intensify search for alternatives to Fluorosurfactants in foam agents Support testing of F3s for their suitability for different fuels Review standards for applicability on F3s Support users with testing Dr. Thomas Leonhardt, September 25th. 2019 15 FFA The EUROFEU Position EUROFEU does not generally oppose the restriction of Fluorocompounds in firefighting agents. EUROFEU does not promote the continuous use of Fluorocompounds in firefighting media. We do believe that access to AFFF should be granted for high risk areas (e.g. chemical- /petrochemical industry, airports, fuel depots) until combined measures allow for use of Fluorine Free Foams (F3) without sacrificing the level of fire safety. Whenever AFFF are used users should justify the use and establish measures to mitigate the risk of an uncontrolled release of AFFF into the environment. We believe that F3s are already very suitable for a growing number of applications such as municipal fire fighting, training, some testing and as foam agents in first responding fire trucks. We believe that continuous efforts to further improve the performance of F3s will lead to F3s with a performance equal to AFFF Dr. Thomas Leonhardt, September 25th. 2019 16 FFA ...you made it! ... anything you want to ask ? 17 Fire Fighting Foams at Airports ECHA 24.9.2019 Finavia Airport Rescue and Fire Fighting (ARFF) 21 AIRPORTS 300 Fire Fighters Helsinki professional FF Network airports multi skill FF 3 23.9.2019 CTIF sharing information to airports 4 23.9.2019 Aircraft accident Amount of kerosene JET A-1, Airbus 350 140.000 liters Response time 3 minutes in airports - knock out fire fast, conditions able to exit the plane - Moscow accident 5 of May - Water does not work in aircraft accidents 5 23.9.2019 Extinguish agents Level ICAO B or C foam Amount of foam in fire vehicles and storage, EASA regulation AFFF foams Using all over the world Performance against fire - filming feature is very good Viscosity to mixing systems and using in cold temperature - it works Principle in accidents used foam - all will be collected Powder is extra but foam is main extinguisher What is the future, what kind of foams is reasonable buy just now? 6 23.9.2019 Training challenges Trainings have done with water many years - environmental reasons Younger FF have not used or even seen foam - Isolate and cool the fuselage - Extinguish the spill/pool fire - Try to find good simulations 7 23.9.2019 You el Thank you! @finavia.fi 8 23.9.2019 FINAVIA for smooth travelling FLUORINATED FOAM - TOTAL'S VISION ECHA working Group - Helsinki - 24th of September 2019 Eric PAILLIER TOTAL IN BRIEF ECHA WORKSHOP - Helsinki - 24th of September 2019 2 MEETING A GROWING DEMAND Becoming the responsible energy major means meeting the growing demand for energy and our customers' expectations. To achieve this, our activities span the entire value chain, from exploration & production, through to transformation and distribution. EXPLORE & PRODUCE 1 Oil & Gas 2 Solar & Wind power 3 Biomass TRANSFORM & DEVELOP TRANSPORT & MARKET 4 Refining & Petrochemicals 5 Polymers 6 Speciality chemicals 7 Trading & Shipping 8 Marketing & Services 9 Gas & Power Marketing 1 1 2 3 5 6 4 8 7 8 1 9 8 ECHA WORKSHOP - Helsinki - 24th of September 2019 3 OUR STRENGTHS Our integrated business model Our presence across the entire value chain, from production to distribution. Our employees More than 100,000 people, representing 150 nationalities and 500 mtiers. A diversity which is decisive for our competitiveness and attractiveness. Our global footprint Active in more than 130 countries. Nearly 800 production sites in the world. ECHA WORKSHOP - Helsinki - 24th of September 2019 4 KEY FIGURES $ 13,6 bn adjusted net income in 2018 10 GW of low-carbon electricity generation capacity by 2023 2 The world no. liquefied natural gas operator $ 1.5 - 2 bn invested in low-carbon electricity and renewables each year 2.8 millon barrels of oil equivalent/day of production in 2018 6 major integrated refining & petrochemical complexes No. 4 lubricant retailer in the world A global top10 refiner and petrochemical manufacturer 143 millon tons of crude & refined oil shipped by sea 8 More than million customers 14,000 served in our service stations each day More than 4,000 researchers $ 1 bn spent on R & D in 2018 ECHA WORKSHOP - Helsinki - 24th of September 2019 5 TYPES OF FIRE IN O&G ECHA WORKSHOP - Helsinki - 24th of September 2019 6 Foam concentrate can be used in our industry for HC "Liquid" fires (onshore in bunds, in tanks , offshore) with large surfaces HC Liquids blanketing (to avoid vapor clouds) LPG spills blankets Water soluble fuels In different application modes : Gentle (pourers) Forceful (powerful monitors up to 40 000 l/min) At the level of the product From distance/height ECHA WORKSHOP - Helsinki - 24th of September 2019 7 And for use outside retention (with direct access to environment) On road/train transportation spills or fire On Vessels for spills / fires (when at berths) On berths and piers in case of pipeline leak/fire For products from Crude to LPG and Bio HCs And for offshore assets Protection of Helidecks Defense of small airport created for project purposes (<ICAO 4) ECHA WORKSHOP - Helsinki - 24th of September 2019 8 OUR CONSTRAINTS ON FOAM CHOICE ECHA WORKSHOP - Helsinki - 24th of September 2019 9  An EN regulation (EN13565) that gives a prime to the use of premium foams Q = Qth Fc Fo Fh Q: minimum application rate, in lit/min.m2 Qth: nominal application rate 4.0 lit/min.m2 Fc: correction factor for the class of the foam concentrate according to EN 1568 Fo: correction factor for the kind of object Fh: correction factor for nozzle distance in outdoor deluge systems France gives lower application rate for bund fires for foam classified list I according GESIP protocol (validated by French Civil Protection and LASTFIRE test work) ECHA WORKSHOP - Helsinki - 24th of September 2019 10  Some design specifications associated to travel distance These distance are conservative (LASTFIRE has shown much greater lengths are possible with correct equipment/foam combination) And we cannot multiply on one site the types of concentrates that we use ECHA WORKSHOP - Helsinki - 24th of September 2019 11 WHERE ARE WE / WHAT LACKS FOR TRANSITION TO FFF ECHA WORKSHOP - Helsinki - 24th of September 2019 12  A lot of problematics on liquid hydrocarbons have been raised and were subject to testing but some are still to be validated through testing Topic Extinguishment capability - tank Extinguishment capability - bund Travel distance Proportioning issues Performance based foam choice Blanketing capabilities Cleaning issues Reduced application rate program Small test scale validation LASTFIRE (*) (**) NFPA GESIP TOTAL (*) gentle application (foam pourer) (**) direct application with a monitor ECHA WORKSHOP - Helsinki - 24th of September 2019 Done Program to be done 13 CONCLUSION ECHA WORKSHOP - Helsinki - 24th of September 2019 14  FFF Technology hasn't proved that it will meet the performances of existing Fluorinated Foams But sufficiently to enable training with them (efficiency proven on small scale fires) and for some spill and tank related scenarios The viscosity of FFF is different and would lead to installations re engineering works (costs not evaluated) Concentration products below 3% aren't under the scope of testing but are key for an industry using a lot of mobiles capacities ECHA WORKSHOP - Helsinki - 24th of September 2019 15 We have to transition as we cannot continue to use product that remain in the middle And to avoid extra costs, we would like to transition according the replacement program of our stocks, not on a law based deadline But are Fluorine Free foam the solution till they contain Fluorine (under actual detection level)? So lacking information have to be investigated and as it costs a lot , through international JIP's like LASTFIRE ECHA WORKSHOP - Helsinki - 24th of September 2019 16 LASTFIRE Developing best practice guidance in storage tank Fire Hazard Management www.lastfire.org.uk The Organisation A consortium of international oil companies developing best industry practice in storage tank Fire Hazard Management through operational feedback, networking, incident analysis and research Full members Current Members Associates Project Coordinator www.lastfire.org.uk Foam - The current "Big Issue" LASTFIRE Response LASIFIRES Large Atmospheric Storage Tank Fires Foam the current big issue LASTFIRE Response? Position Paper* Assurance guidance* Procurement specification* Performance and Environmental Contact @Iastfire.org Research work LASTFIRE Assurance Process Foam Assurance Protocol Ten elements to address different areas Key and sub questions Guidance on documentary/physical proof Extensive practical guidance Member feedback/buy in Red, Amber, Green ranking Self audit or Third Party Not just applicable to tanks www.lastfire.org.uk Element 1 Assessment of Needs Element 2 Foam Concentrate Procurement Specification & Procedures Element 3 Site Foam Storage and Stock Management Element 4 Site Foam Concentrate Assurance Element 5 System specification and design Element 6 - Testing of Foam Application Equipment and Systems Element 7 - Environmental FireFighting Foam Management Assurance Element 8 - Site Logistics for Foam Application Element 9 - Training and Exercising for Foam Application Element 10 - Scenario Specific Emergency Response Plans Foam Assurance: The LASTFIRE Process Demonstrate responsible approach Formal assessment Needed during transition and afterwards!! Research Work Overall objective: To provide a firm basis for future cost effective, long term, sustainable policies regarding the selection and use of fire fighting foam based on rational, relevant and independent, end user driven test programmes. www.lastfire.org.uk Research Work Overall objective: To provide a firm basis for future cost effective, long term, sustainable policies regarding the selection and use of fire fighting foam based on rational, relevant and independent, end user driven test programmes. www.lastfire.org.uk Research Work - Rational Progression more than 200 tests Subsurface tests Small scale Simulated tank fire Critical application rates Spill fire Critical application rates Phases have included Different foams Different nozzles Different application methods Different rates Different fuels (including crude) Larger scale Different preburns "Real life" Application Fresh/Salt water NFPA rates Longer flow "Real life" Application NFPA rates Self expanding foam www.lastfire.org.uk Vapour suppression Hybrid Medium Expansion Research Work www.lastfire.org.uk Monitor application - Real World conditions Research Work CAF application Compressor fed - continuous flow Similar to standard monitor www.lastfire.org.uk LASITIRE Large Atmospheric Storage Tank Fires Larger Scale 1 FF "Long flow tests" Dallas 2018 . lastfire.org www.lastfire.org.uk LASTFIRE Large Atmospheric Storage Tank Fires Overall Achievements/Conclusions - Carried out over 200 tests - Validated extrapolation of test data from small scale LASTFIRE testing to Important large scale not to draw - No direct drop-in -- performance plus suitability for system generic - Cannot be generic! conclusions! - Combination of foam/foam properties/application rate/application technique is critical - (Currently not reflected in standards) - Other techniques give the potential for more efficient extinguishing of large tank/bund fires Dlastfire.org www.lastfire.org.uk LASIFIRE Large Atmospheric Storage Tank Fires Overall Achievements/Conclusions - Proved that Fluorine Free foams can provide equivalent performance to C6 foams and provide appropriate performance for hydrocarbons: Important - When used with NFPA application rates for following applications: - Tank fires "15m+ diameter (No reason to doubt >25m+) - Conventional pourer standard application rates - Aspirating monitor not to draw generic conclusions! - "Non aspirating" monitor with appropriate foam characteristics - Tank fires - 60m+ diameter (No reason to doubt >80m +) or bund fires - Foam pourer We can - When used at lower rates than NFPA using CAF application: overcome - Tank fires "15m+ diameter (No reason to doubt >25m+) performance - Monitor application issues but ... - Tank fires "80m+ diameter (No reason to doubt >100m +) or bund fires. ,iastfire.org - Foam pourer www.lastfire.org.uk LASITIRFt''\k4o lommoo Large Atmospheric Storage Tank Fires 2019 What is Missing? -- Performance Issues - Polar Solvent tests - Big monitor application -- longer distances - Other foams/combinations of foam/application methods - Life safety situations -- tactics - Optimising properties Working with other groups - Eurofeu etc! NFPA -- Concentrating on UL GESIP Etank Fire DFW Important to coordinate! Eurofeu German Firefighters etc Iastfire.org www.lastfire.org.uk LASTFIRE' Large Atmospheric Storage Tank Fires 2019 What is Missing? -- Other Issues - Clean out - Methodology - What is acceptable level? - Remediation - What is in new foams ? - What is acceptable? - Separate production? - Meanwhile -- better Procurement to Disposal Management - LASTFIRE Assurance - We want long term sustainable solutions!! Dlastfire.org www.lastfire.org.uk We have achieved a lot We are getting there but more work to do! A closer look at the optimum combination of equipment, foam concentrate, rate and technique! An opportunity, not a crisis! C1 Wood Environment & Infrastructure Solutions UK Limited Appendix 3 Overview of PFAS physical properties and why they contribute to hazards FAS is a term used to cover approximately 4,700 specific chemical species191. Longer chain ( C8) PFAS compounds have been used within industry as surfactants specifically because of their potent water and oil repellence at low concentrations (Buck, 2011). Prior to 2000 the use of PFAS within fire-fighting foams in Europe utilised the salts of C8 PFAS compounds such as PFOS and PFOA, particularly the ammonium salt of PFOA (APFO) (CAS 3825-26-1)192. As of the late 1990s growing concerns around longer chain PFAS compounds highlighted that they were highly mobile in the aquatic and terrestrial environment, highly persistent, and had the capability to bioaccumulate up food chains193. Many longer chain PFAS species also had toxic effects identified. The ECHA SVHC nomination dossier for PFOA (2013) indicated that PFOA (from the ammonium salt) is readily absorbed by the body and can pass to the foetus (by blood) and child (by mother's milk), and concentrates in the blood, liver and kidneys with toxic effects. The nomination also notes that the RAC identified sufficient scientific evidence to conclude that PFOA could also be a reproductive toxin for the unborn child. Concerns over the mobility and persistence of longer chain PFAS substances, along with potential health effects led to an industry initiative in the early to mid-2000s to switch to shorter chain ( C6) PFAS alternatives (UNECE, 2004). For fire-fighting foams this includes the salts of C6 or lower based PFAS substances194. However, concerns have continued that shorter chain PFAS substance are also mobile (if not more mobile) than C8 substances and are highly persistent albeit with potentially lower bioaccumulation195. Table A3.1 provides as an example of the mobility of PFAS compounds with different carbon chain lengths (based on log Koc) as an indicator that shorter chain PFAS are likely to be highly mobile. Kjolholt (2015)196 indicates that WWTPs are likely to be ineffective against short-chain PFAS, just as they are also ineffective against longer chain PFAS compounds. 191 OECD, 2018, PFAS database, toward a new comprehensive global database of per and polyfluoroalkyl substances. 192 Stockholm Convention risk management evaluation dossier for PFOA, its salts and related compounds UNEP/POPs/POPRC.14/6/Add.2 193 UNECE, 2004, PFOS dossier for purpose of nominating PFOS to the LRTAP Protocol and Stockholm Convention. 194 Tyco fire protection, 2016, `Transition if the firefighting foam industry from C8 to C6 fluorochemistry'. 195 Cousins et al, 2018, `short-chain perfluoroalkyl acids: environmental concerns and regulatory strategy under REACH', Environmental science Europe vol 30. 196 Kjoltholt et al, 2015, `short chain polyfluoroalkyl substances (PFAS) a literature review of information on human health effects and environmental fate and effect of short chain PFAS', Danish Ministry for Environment. June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 C2 Wood Environment & Infrastructure Solutions UK Limited Table A3.1 Overview of PFAS substances mobility using log Koc Carbon chain length Species PFCAs 11 Perfluoroundecanoate (PFUnDA) 10 Perfluorodecanoate (PFDA) 9 Perfluorononanoate (PFNA) 8 Perfluorooctanoate(PFOA) 8 Perfluorooctane sulfonate (PFOS) 6 Perfluoroheptane sulfonate (PFHxS) 6.1 Perfluorohexanoate (PFHxA) 4 Perfluorobutane sulfonate (PFBS) 4 Perfluorobutanoate (PFBA) Fluorotelomers 8 8:2 Fluorotelomer alcohol (8:2 FTOH) 6 6:2 Fluorotelomer alcohol (6:2 FTOH) 4 4:2 Fluorotelomer alcohol (4:2 FTOH) *reference ITRCP PFAS factsheet. https://pfas-1.itrcweb.org/ CAS number Log KOC 2058-94-8 3.3 to 3.56 335-76-2 // 3830-45-3 // 3108-42-7 2.76 to 2.96 375-95-1 2.36 to 3.69 335-67-1 1.89 to 2.63 1763-23-1 2.4 to 3.7 355-46-4 2.4 to 3.1 307-24-4 1.3 375-73-5 // 59933-66-3 1.2 to 1.79 375-22-4 1.9 678-39-7 4.13 647-42-7 2.43 2043-47-2 0.93 June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 D1 Wood Environment & Infrastructure Solutions UK Limited Appendix 4 Detailed foam transition timescales (from industry) The following table has been provided as stakeholder input by an industrial end user and is reproduced in this report with kind permission from that stakeholder. Note that the table reflects the views of that stakeholder. Conclusions of the authors of this study are presented in the main body of the report. Key Research/Testing Modification to Standards, legislation etc Development of Guidance/data gathering Site Specific Tasks Other Milestones Task Formal Start of Transition and Introduction of Legislation Manufacturer development of FF products Validation of performance based small scale acceptance testing tanks Validation of performance based small scale acceptance testing aviation Validation of performance based small scale acceptance testing general purpose use (municipal brigades) Notes t-4 t-3 t-2 t-1 T Assumed start date. If delayed, then subsequent phases would be delayed also Ongoing/continuous Already done by LASTFIRE for tanks, using conventional application methods Some work done by aviation authorities but needs greater full acceptance. Effectively already completed as EN 1568 performance based t+1 t+2 t+3 t+4 t+5 t+6 t+7 t+8 t+9 t+10 June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 D2 Wood Environment & Infrastructure Solutions UK Limited Task Notes t-4 t-3 t-2 t-1 T Establishment of formulations and effects of different foam types Acceptability criteria for PFAS, etc PERF work in progress for oil industry, but relevant to all sectors By regulator Full environmental effects data for new concentrates and acceptability criteria Regulator needs to be precise on requirements so that foams can be tested before introduction of legislation Small Scale Testing and selected large scale testing with a range of fuels including water soluble. LASTFIRE is about to embark on this sort of programme working with German Industrial Firefighters et al. Large scale testing of proven foam concentrates and monitor application to deep seated (deep fuel) fires Approvals Listings Modification of standards and system design/acceptance criteria Stop using PFAS foams in training Planning this with GESIP and others Critical in some areas globally and in some industries LASTFIRE working with NFPA and EN EN strictly already in place as EN 13565 refers back to EN 1568 performance criteria NFPA requires further work No more PFAS foams used in training Stop using PFAS foams in system testing or, if PFAS is still in place ensure total containment and appropriate treatment Every effort should be made to minimise the need for discharging PFAS based foams in system testing, even when full containment is available No more PFAS foams used in system testing t+1 t+2 t+3 t+4 t+5 t+6 t+7 t+8 t+9 t+10 June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 D3 Wood Environment & Infrastructure Solutions UK Limited Task Notes t-4 t-3 t-2 t-1 T Review and revision of site ERPs including containment issues Suggest this should be a requirement early on in transition to minimise current usage Replacement of stocks with FF Development of company/site long term plan for transition We suggest this should be a regulatory requirement on a site specific basis Development of site programme/instructions to control stocks and use of PFAS foams, risk assessments, control/mitigation measures, containment and collection, disposal etc. Completion of Site Specific Transition Plans Should include milestones and reporting Development and acceptance of alternative technology options using Fluorine Free Foam with appropriate testing Development of guidance on proven and accepted methods of cleaning foam tanks and equipment Development of guidance on appropriate disposal routes Management of change evaluation and programme to ensure compatibility and effectiveness of every foam system Transition to Fluorine Free for first strike application to small incidents LASTFIRE ongoing programmes with CAF, Sef Expanding Foam, Hybrid Medium Expansion, etc. Companies are already beginning to evaluate this recognising the current situation No more PFAS foams used for small incidents Full corrosion and materials compatibility data of new concentrates See LASTFIRE Typical procurement specification t+1 t+2 t+3 t+4 t+5 t+6 t+7 t+8 t+9 t+10 June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 D4 Wood Environment & Infrastructure Solutions UK Limited Task Testing of compatibility of applying different foams to an incident simultaneously Compatibility of concentrates data Agreement of accepted disposal routes Fire testing with site specific fuels and equipment Roll out of site management of change programme/instructions Disposal of existing concentrates Possible development and management of interim strategic stock holdings Completion of Transition Notes t-4 t-3 t-2 t-1 T Not good practice to mix concentrates anyway, but perhaps useful for commercial reasons Although no formal plans, an option to still have current foams available if there are concerns might be for industry to develop strategic, well managed and controlled stock for major incidents. This would have to include plans for containment and immediate clean up if the stock was to be used. t+1 t+2 t+3 t+4 t+5 t+6 t+7 t+8 t+9 t+10 June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 E1 Wood Environment & Infrastructure Solutions UK Limited Appendix 5 List of international standards for fire-fighting foam performance International Fire-fighting Foam Standards Underwriters Laboratory International Civil Aviation Organization EN 1568 UL162 ICAO Level A ICAO Level B ICAO Level C Part 1 Part 2 Part 3 Part 4 Description UL 162 is an Internationally recognised test method carried out by the UL (Underwriters Laboratory), an independent not-for-profit organisation. In the UK, the CAA (Civil Aviation Authority) requires a foam concentrate for use in Civilian Airports to be tested using potable (fresh) water to ICAO Level A, B or C. European Standard that critically tests a foam for both extinguishment and burnback in sea and potable (fresh) water Sector(s) applicable Type(s) of fire / fuel Type(s) of foam Area applicable Offshore platforms Heptane fire, or polar solvent All 50 sq. feet Onshore Civilian Airports Heptane fire Onshore Civilian Airports Heptane fire All All 2.8m2 4.5m Onshore Civilian Airports Heptane fire All 7.32m All All Heptane fire Heptane fire Medium expansion foam for use on waterimmiscible liquids High expansion foam for use on waterimmiscible liquids 4.52 m2 4.52 m2 All All Heptane fire Acetone fire Low expansion foam for use on waterimmiscible liquids Low expansion foam for use on watermiscible liquids 4.52 m2 1.72 m2 June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 E2 Wood Environment & Infrastructure Solutions UK Limited International Fire-fighting Foam Standards Underwriters Laboratory International Civil Aviation Organization EN 1568 UL162 ICAO Level A ICAO Level B ICAO Level C Part 1 Part 2 Part 3 Part 4 Application conditions Application Rate (L/min/m2) Discharge Rate (L/min) and duration Extinguring time (with flickers) Extinguishing time (full) Pre-burn time Burnback test (and waiting time) Using a freeze protected foam with potable (fresh) and sea water 1.63 Foam concentrate for use in Civilian Airports to be tested using potable (fresh) water 4.1 Foam concentrate for use in Civilian Airports to be tested using potable (fresh) water 2.5 Foam concentrate for use in Civilian Airports to be tested using potable (fresh) water 1.75 2.52L/min/m 18.6 (180 s) <180 seconds 60 seconds Yes (20% in 300 seconds); 540 seconds 11.4 (120 seconds) 11.4 (120 seconds) 11.4 (120 seconds) <60 seconds <60 seconds <60 seconds <120 seconds 60 seconds Yes, 2 minutes <120 seconds 60 seconds Yes, 2 minutes <120 seconds 60 seconds Yes, 2 minutes 60 seconds 2.52L/min/m 2.52L/min/m 6.6L/min/m 60 seconds 60 seconds 120 seconds June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 E3 Wood Environment & Infrastructure Solutions UK Limited International Fire-fighting Foam Standards Underwriters Laboratory International Civil Aviation Organization EN 1568 20% Re-ignition Time (mins) Nozzle type Nozzle pressure (Kpa) Degradation considered Pass/Fail test? UL162 Hose nozzles, monitors Not specified No Yes June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 ICAO Level A ICAO Level B ICAO Level C Part 1 Part 2 Part 3 Part 4 >5 "Uni 86" Foam Nozzle" 700 No >5 "Uni 86" Foam Nozzle" 700 No >5 "Uni 86" Foam Nozzle" 700 No "Uni 86" Foam Nozzle" "Uni 86" Foam Nozzle" "Uni 86" Foam Nozzle" "Uni 86" Foam Nozzle" No No No Not a pass or Not a pass or Concentrates Concentrates fail standard fail standard are allocated are allocated grades of grades of performance, performance, ie Grade 1-4 ie Grade 1-2 for for extinguishing extinguishing performance performance and Grades and Grades A- A-D for C for burnback burnback resistance. 1A resistance. is the highest 1A is the achievable highest grade achievable grade E4 Wood Environment & Infrastructure Solutions UK Limited International Fire-fighting Foam Standards Underwriters Laboratory International Civil Aviation Organization Frequency of monitoring/ conformity testing Sea water or powder compatibility UL162 3 months Sea water ICAO Level A ICAO Level B ICAO Level C N/A N/A N/A Part 1 No test protocol provided No test protocol provided No test protocol provided EN 1568 Part 2 Part 3 Part 4 June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 E5 Wood Environment & Infrastructure Solutions UK Limited International Maritime Organization CAP 437 Military Specification (US) National Fire Protection Agency (NFPA) ISO - 7203 Description Sector(s) applicable Type(s) of fire / fuel Type(s) of foam IMO MSC.1/Circ.1 312 IMO MSC Circ.670 These standards ensure that foam used at sea is fit for purpose and takes into consideration performance with sea water induction and temperature conditioning (accelerated ageing). Maritime Maritime CAP 437 For UK offshore helidecks, the standard adopted by the Civil Aviation Authority (CAA) is CAP 437 - Standards for Offshore Helicopter Landing Areas, Chapter 5, paragraph 2.6. Offshore Helidecks (UK) MIL-F-24385 NFPA 11 MIL-F-24385 is a US Military Test Specification that critically tests AFFFs for both extinguishment and burnback in sea and potable (fresh) water. Military Heptane fire, Unleaded petrol NFPA 11 is an internationally recognised US Standard for Low-, Medium-, and HighExpansion Fire Fighting Foam. 7203-1 7203-2 7203-3 7203-4 Area applicable Application conditions Application Rate 2.52 2.52 (L/min/m2) Discharge Rate (L/min) and duration 11.4 (300 sec +/- 2) 11.4 (300 sec +/- 2) Tested in sea water and freeze protected Using foam with potable and sea water. 1.65 or 2.91 7.57 (90 seconds) June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 E6 Wood Environment & Infrastructure Solutions UK Limited International Maritime Organization Extinguishing time (with flickers) Extinguishing time (full) Pre-burn time Burnback test (and waiting time) 20% Re-ignition Time (mins) Nozzle type IMO MSC.1/Circ.1 312 IMO MSC Circ.670 Depends on class Depends on class "Uni 86" Foam Nozzle" "Uni 86" Foam Nozzle" Nozzle pressure (Kpa) Degradation considered Pass/Fail test? Frequency of monitoring/ conformity testing Sea water or powder compatibility 630 +/- 30 Sea water (if compatible) 630 +/- 30 Sea water (if compatible) June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 CAP 437 CAP 437 Military Specification (US) National Fire Protection Agency (NFPA) ISO - 7203 MIL-F-24385 NFPA 11 7203-1 7203-2 7203-3 7203-4 Depends on pan; <30; <50 10 seconds Yes (25% in 360 seconds); 60s 680 Yes- requires a result of 50% or greater for a BOD/ COD ratio Sea water, powder "Uni 86" Foam Nozzle" "Uni 86" Foam Nozzle" "Uni 86" Foam Nozzle" "Uni 86" Foam Nozzle" F1 Wood Environment & Infrastructure Solutions UK Limited Appendix 6 List of alternative fire-fighting foam products available on the EU market, as identified in consultation responses Product ECOPOL BIO FOR BIO FOAM BIO T3 BIO T6 RE-HEALINGTM RF3, 3% Low Viscosity Foam Concentrate PROFOAM 806G Sthamex F-15 Sthamex F-6 Testschaum V Manufacturer/Supplier Bio-ex Bio-ex Bio-ex Bio-ex Bio-ex Solberg Gepro Group Dr. Sthamer Dr. Sthamer Dr. Sthamer Freedol SF Freedol Freefor SF Hyfex SF Freedex SF Respondol ATF 3-3 Respondol ATF 3-6 High Combat A Jetfoam 1% Jetfoam 3% Jetfoam 6% Syndura Expandol LT 3F 3F 3F 3F 3F Angus fire Angus fire Angus Fire Angus fire Angus fire Angus fire Angus fire Angus fire June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 F2 Wood Environment & Infrastructure Solutions UK Limited Product Expandol Forexpan Trainol-3 Trainol-6 TF 3 TF 6 TF 90 Unipol FF 3/6 TF 136 EE-3 SF-60 L H-930 RFC-105 CAFOAM Unipol FF 1 Class A Plus Extreme DeltaFire Schaumgeist Sthamex F-6 Sthamex F-15 Sthamex F-20 Sthamex F-25 Sthamex-class A Moussol FF 3x6 Fettex bungsschaummittel-N bungsschaummittel-U Sthamex - K iFoam Manufacturer/Supplier Angus fire Angus fire Angus fire Angus fire Angus fire Angus fire Angus fire Auxquimia Auxquimia Auxquimia Auxquimia Auxquimia Auxquimia Auxquimia Auxquimia Chemguard Chemguard DeltaFire Dr. Sthamer Dr. Sthamer Dr. Sthamer Dr. Sthamer Dr. Sthamer Dr. Sthamer Dr. Sthamer Dr. Sthamer Dr. Sthamer Dr. Sthamer Dr. Sthamer Febbex June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 F3 Wood Environment & Infrastructure Solutions UK Limited Product Greenagent Technology Enviro 3x3 Plus Enviro 3x3 ultra Enviro 3 % ICAO Enviro 3x6 Plus Enviro 6x6 Plus Enviro USP KV-Lite PF KV-Lite HEF KV-Lite HAZMAT Foam KV-Lite Class-K Foam Ecopol Ecopol 3x6 Ecopol 6 Ecopol F3HC Bio T3 Bio T6 Bio for C Bio for N Bio for S Bio Foam 5 Bio Foam 15 Responder Class A Knockdown High Expander Training Foam Bluefoam 3x3 Bluefoam 1x3 Manufacturer/Supplier Fireade Firechem Foamtech AntiFire Fomtec Fomtec Fomtec Fomtec Fomtec Fomtec KVFires KVFires KVFires KVFires Leader/ BioEx Leader/ BioEx Leader/ BioEx Leader/ BioEx Leader/ BioEx Leader/ BioEx Leader/ BioEx Leader/ BioEx Leader/ BioEx Leader/ BioEx Leader/ BioEx NationalFoam NationalFoam NationalFoam NationalFoam Orchidee Orchidee June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 F4 Wood Environment & Infrastructure Solutions UK Limited Product Manufacturer/Supplier Bluefoam 3x6 Orchidee Bluefoam 6x6 Orchidee Orchidex ME 1% F-ECO Orchidee Orchidex ME 3% F-ECO Orchidee Orchidex ME 3% HP Orchidee Orchidex ME 3% F-10 Orchidee Orchidex ME 3% ECO Orchidee Orchidex ME 6% F-ECO Orchidee Orchidex Training Foam Orchidee Orchidex A Orchidee Orchidee XF 3000 Orchidee Re-Healing Foam RF-H+ Solberg Re-Healing Foam RF1 1% Solberg Re-Healing Foam RF1-S 1% Solberg Re-Healing Foam RF3 3% Solberg Re-Healing Foam RF6 6%1 1 Solberg Re-Healing Foam RF3x3 FP ATC Solberg Re-Healing Foam RF3x6 ATC Solberg Re-Healing Foam RF 3x6 FP ATC Solberg Re-Healing Foam RF-MB Solberg Re-Healing Foam RF6 6% 2 Solberg Re-Healing TF Solberg Aberdeen Foam 1% F3 OilTechnics Aberdeen Foam 3% F3 OilTechnics Aberdeen Foam 3x3% AR-F3 OilTechnics Aberdeen Foam 1% Class A OilTechnics Aberdeen Foam 1% Training Foam OilTechnics Aberdeen Foam 3% Training Foam OilTechnics Silvara 1 vsFocum June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 F5 Wood Environment & Infrastructure Solutions UK Limited Product Silvara ZFK Silvara APC 3x3% Silvara APC 3x6% Manufacturer/Supplier vsFocum vsFocum vsFocum June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 G1 Wood Environment & Infrastructure Solutions UK Limited Appendix 7 "Pre-Annex XV Dossier" June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03 ECHA EUROPEAN CHEMICALS AGENCY PRE-ANNEX XV RESTRICTION REPORT PROPOSAL FOR A RESTRICTION (DRAFT) SUBSTANCE NAME(S): Polyfluoroalkyl and perfluoroalkyl substances (PFAS) in firefighting foams CONTACT DETAILS OF THE DOSSIER SUBMITTER: Not applicable. This document has been prepared by contractors working for the European Commission (contract No 07.0203/2018/791749/ENV.B.2). It is intended for review by the Commission and should be read in conjunction with the final report for the study. The document should not be taken to reflect the opinions or conclusions of the contractors or of the European Commission. VERSION NUMBER: 3.0 DATE: 05 June 2020 Annankatu 18, P.O. Box 400, FI-00121 Helsinki, Finland I Tel. I Fax +358 9 68618210 I echa.europa.eu PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS TABLE OF CONTENTS Report...................................................................................................................... 8 1. The problem identified............................................................................................ 8 1.1. Hazard, exposure/emissions and risk..................................................................... 8 1.1.1. Identity of the substance(s), and physical and chemical properties ................... 8 1.1.1.1. Overview .......................................................................................... 8 1.1.1.2. Long chain PFAS .............................................................................. 12 1.1.1.3. Short chain PFAS ............................................................................. 12 1.1.1.4. Derivates of perfluoroalkyl sulfonic PFAS (also PASF-based substances) . 13 1.1.1.5. Fluorotelomers ................................................................................ 14 1.1.1.6. Other PFAS substances..................................................................... 15 1.1.1.7. Chemical definitions of the identified substances which could be used for a possible future restriction ............................................................................. 15 1.1.2. Justification for grouping ............................................................................18 1.1.3. Classification and labelling..........................................................................18 1.1.4. Hazard assessment ...................................................................................19 1.1.5. Exposure assessment ................................................................................20 1.1.6. Risk characterisation..................................................................................22 1.2. Justification for an EU wide restriction measure .....................................................22 1.3. Baseline............................................................................................................24 1.3.1. Overview..................................................................................................24 1.3.2. Definition of the baseline scenario for the assessment of economic impacts ......24 1.3.3. Overview of current regulatory measures .....................................................25 1.3.3.1. Stockholm Convention ..................................................................... 25 1.3.3.2. EU Regulation ................................................................................. 26 1.3.3.3. Other international controls .............................................................. 27 1.3.4. Industry Measures.....................................................................................29 1.3.4.1. Substitution and phase-out ............................................................... 29 1.3.4.2. Containment and control .................................................................. 30 2. Impact assessment ...............................................................................................31 2.1. Introduction ......................................................................................................31 2.2. Risk Management Options ...................................................................................31 i PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS 2.3. Restriction scenario(s) ........................................................................................32 2.4. Economic impacts ..............................................................................................35 2.5. Human health and environmental impacts.............................................................36 2.6. Other impacts, practicability and monitorability .....................................................37 2.7. Proportionality (including comparison of options) ...................................................37 2.7.1. Comparison of different users .....................................................................38 2.7.2. Transition periods......................................................................................39 2.7.3. Concentration thresholds............................................................................40 2.7.4. Other risk management targeted at reducing release .....................................40 3. Assumptions, uncertainties and sensitivities .............................................................41 4. Conclusion ...........................................................................................................41 Annex A: Manufacture and uses .................................................................................45 A.1. Manufacture, import and export...........................................................................45 A.2. Uses.................................................................................................................45 A.3. Uses advised against by the registrants ................................................................56 Annex B: Information on hazard and risk.....................................................................57 B.1. Identity of the substance(s) and physical and chemical properties ...........................57 B.2. Manufacture and uses (summary) ........................................................................85 B.3. Classification and labelling ..................................................................................86 B.4. Environmental fate properties .............................................................................87 B.5. Human health hazard assessment ........................................................................88 B.6. Human health hazard assessment of physicochemical properties .............................92 B.7. Environmental hazard assessment .......................................................................93 B.8. PBT and vPvB assessment...................................................................................93 B.9. Exposure assessment .........................................................................................93 B.10. Risk characterisation ...................................................................................... 113 Annex C: Justification for action on a Union-wide basis ............................................... 114 Annex D: Baseline .................................................................................................. 115 Annex E: Impact Assessment ................................................................................... 116 ii PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS E.1. Risk Management Options ................................................................................. 116 E.2. Alternatives..................................................................................................... 116 E.3. Restriction scenario(s) ...................................................................................... 145 E.4. Economic impacts ............................................................................................ 145 E.5. Risk reduction capacity ..................................................................................... 172 E.6. Other impacts, practicability and monitorability ................................................... 177 E.7. Practicality and monitorability............................................................................ 177 E.8. Proportionality (comparison of options)............................................................... 177 E.9.1. Comparison of Restriction Options ................................................................... 180 E.9.2. Comparison of costs and benefits .................................................................... 180 Annex F: Assumptions, uncertainties and sensitivities ................................................. 188 Annex G: Stakeholder information ............................................................................ 190 TABLE OF TABLES Table 1.1 Table 1.2 Table 1.3 Table 1.4 Table A.1 Table B.1 Table B.2 Table B.3 Table B.4 Table B.5 Table B.6 Overview of the PFAS classification, generalised chemical structures, and minimal number of C-atoms of substances that were identified as being used in AFFF 16 Comparison of the substance identification as in the PFOA restriction and a proposal made for the PFAS-substances in AFFF. 17 Overview of ratios for emissions by different environmental compartment for all life-cycle stages combined. 21 Overview or ratios for emissions by different life-cycle stages 21 Tonnage of fluorosurfactants purchased for the production of fire-fighting foams by manufacturers participating in the 2018 Eurofeu survey 46 Identified hydrocarbons (identified by CAS) incl. CAS/EC identifier, the substance name, chemical group and the supplier and/or product name 60 Identified detergents (identified by CAS) incl. CAS/EC identifier, the substance name, chemical group and the supplier and/or product name 63 Siloxanes (identified by CAS) incl. CAS/EC identifier, the substance name, chemical group and the supplier and/or product name 68 PFSAs (identified by CAS) with C6 incl. CAS/EC identifier, the designation, the acronym and the supplier and/or product name 70 PFCAs (identified by CAS) with C7 incl. CAS/EC identifier, the designation, the acronym and the supplier and/or product name 71 PFSAs (identified by CAS) with <C6 incl. CAS/EC identifier, the designation, the acronym and the supplier and/or product name 72 iii PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Table B.7 Table B.8 Table B.9 Table B.10 Table B.11 Table B.1 Table B.1 Table B.1 Table B.2 Table B.3 Table B.4 Table B.5 Table B.6 Table B.7 Table B.8 Table E.1 Table E.2 Table E.3 Table E.4 Table E.5 Table E.6 Table E.7 Table E.1 Table E.2 Table E.3 Table E.4 Table E.5 Table E.6 PFCAs (identified by CAS) with <C7 incl. CAS/EC identifier, the designation, the acronym and the supplier and/or product name 73 Identified derivates of perfluoroalkyl sulfonic PFAS (also PASF-based substances) 75 Fluorotelomer (identified by CAS) substances incl. CAS/EC identifier, the designation, the acronym and the supplier and/or product name 78 Other per- or polyfluorinated substances (identified by CAS) incl. CAS/EC identifier, the designation, the acronym and the supplier and/or product name 83 Summary of key preliminary market analysis results 86 Overview of PFAS substances mobility using log Koc 87 Overview on substances used in fluorine-free fire-fighting foams and one substance used in a fluorinated foam. Shown are the product, CAS/EC, PNECs, and the used reference. The respective lowest PNECs are highlighted in bold. 89 Industry splits and usage rates based on data from Eurofeu and Brooke et al (2004)* 97 Summary of factors applied to data 99 Final selection of substances (substances highlighted in blue selected) - see also footnotes at end of table. 102 PFAS based substances for selection 106 Overview of ratios for emissions by different environmental compartment for all life-cycle stages combined. 107 Overview or ratios for emissions by different life-cycle stages 107 log Koc values for a set of solvents, POPs and PFAS based substances as indicative guide to partitioning against Koc values. 109 log Koc values for non-fluorinated substances included within this assessment 109 Shortlist of fluorine-free alternative products for assessment 118 Assessment of Respondol ATF 3-6% 120 Assessment of Re-Healing Foam RF3x6 ATC 122 Assessment of Re-Healing Foam RF1 1% 124 Assessment of Moussol FF 3x6 (F-15) 125 Assessment of FOAMOUSSE 3% F-15 127 Assessment of Ecopol Premium 128 Estimated costs for the replacement of fire extinguishers in the whole of the EU 147 Effectiveness of alternatives - summary 149 Use patterns of alternatives - summary 152 Annual foam costs - input assumptions 154 Scenarios, gross and net foam costs -annual cycle replacement costs for total EU market (M denotes millions) 154 Quantitative data - economic costs 155 iv PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Table E.7 Table E.8 Table E.9 Table E.10 Table E.11 Table E.12 Table E.13 Table E.14 Table E.15 Table E.16 Table E.17 Table E.1 Quantitative data - economic costs 155 Overview of key impacts of alternatives 159 Typical cost per site of remediation of PFAS contamination resulting from the use of fire-fighting foams 160 Availability of alternatives - summary 164 "Top down" assessment - annual demand and supply of PFAS and Fluorine free FFF 165 Processing time based on existing incinerator capacity processing 25l per hour. 170 Processing time based on existing incinerator capacity processing one tonne per hour. 170 Estimated costs of disposal 171 Estimate of total PFAS emissions from fire-fighting foams 173 Estimate of total quantifiable cost of a potential restriction on PFAS in fire- fighting foams 174 Estimate of cost-effectiveness of the reduction of PFAS emissions from fire- fighting foams 176 Summary of socio-economic considerations for the main expected impacts of potential regulatory management options 181 TABLE OF FIGURES Figure 1.1 Hierarchical clustering of the identified short-, long-chain and substituted PFAs substances 10 Figure 1.2 Hierarchical clustering of identified fluorotelomers 11 Figure 1.3 Split of PFAS-based fire-fighting foams by sector 20 Figure 2.1 Map summarising potential effects of a restriction on the placing on the market of PFAS-based fire-fighting foams 33 Figure 2.2 Map summarising potential effects of a restriction on the use of PFAS-based fire-fighting foams 34 Figure A.1 Split of PFAS-based fire-fighting foams by sector 48 Figure A.2 Yearly use of fluorine-free firefighting foams by sector. 54 Figure B.1 Chemical structure of sodium octyl sulphate 62 Figure B.2 Sugar-based siloxane as described by Hetzer et al. 68 Figure B.3 Hierarchical clustering of the identified short-, long-chain and substituted PFAs substances 77 Figure B.4 Hierarchical clustering of identified fluorotelomers 82 Figure B.5 Chemical structure of Dodecafluoro-2-methylpentan-3-one, a fluorinated ketone 83 v PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Summary This `pre-Annex XV' dossier discusses a potential restriction on the use of PFAS in firefighting foams. Significant concerns have been demonstrated at least for some PFAS, including some short-chain PFAS. However, the hazards of PFAS themselves were not a primary focus of this study, given ongoing work by the PFAS working group1. Many PFAS are highly mobile, highly persistent, have the potential to accumulate within the environment and living organisms, and to cause cross-border pollution. There is a lack of existing regulation, and of implementation or proven effectiveness of other risk management measures to address the release of PFAS from the use of PFAS-based firefighting foams. National regulation does not appear to be forthcoming and discrepancies across Member States could affect the functioning of the internal market. It is therefore concluded that a restriction on the placing on the market (and potentially the use) of PFAS-containing fire-fighting foams at EU-level appears to be an appropriate option. In order to maximise effectiveness while minimising potential adverse socio-economic impacts of such a restriction, it appears appropriate to vary the specific conditions (particularly transition periods) by application and user sector, because of their differences in terms of the likelihood of emissions and implications of switching to alternative foams. It is concluded that training and testing should be the highest priority for a quick transition to fluorine-free foams. Users have suggested a longer transition period of up to 10 years is required and derogations with a longer transition period may be needed for specific applications (notably large atmospheric storage tank fires) where further testing is required to determine the technical feasibility of alternatives and potential fire-safety risks from using alternatives may be higher (and are still under investigation). This use (particularly the chemicals/petrochemicals sector) is the largest user sector, so in order to ensure effectiveness of a restriction in reducing PFASemissions, it seems appropriate that any longer transition period should be limited to the most sensitive applications within this sector, particularly large incidents and large atmospheric storage tanks. For small incidents2 as well as all other sectors, shorter transition periods between 3-6 years have been suggested and are expected to minimise socio-economic implications of a restriction. Regarding thresholds for the remaining concentration of PFAS in equipment that previously used PFAS-based fire-fighting foams, a balance would need to be struck between the amount of PFAS emissions remaining if a given threshold is adopted, versus the costs of cleaning that would be required in order to achieve that threshold. Stakeholder input suggests that 100 ppb can be achieved with a relatively simple cleaning process (cost likely low but not quantified); such a limit would remove the vast majority of emissions. Lower thresholds are achievable with more complex and costly processes. For instance, achieving 1 ppb could cost around 12,300 per appliance according to one estimate, which could imply EU total costs in the order of 1 billion. However, setting a lower concentration threshold would lead to a relatively small 1 A working group under ECHA's stewardship to assess the hazards associated with PFAS substances, including persistence, mobility, bioaccumulation and toxicity. 2 Note that the distinction between small and large incidents is based on stakeholder feedback and would need to be more precisely defined, for instance in any consultation as part of a potential future restriction proposal. PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS additional reduction in PFAS emissions, compared to the overall reduction achieved by the restriction. Lastly, it is advisable to further investigate a potential obligation to apply best practice emission reduction measures during and after the use of PFAS-based fire-fighting foam, as a condition of any restriction. These could cover, for instance, containment, treatment, and proper disposal of foams and fire water run-off. These measures could provide relatively effective reduction of PFAS-emissions at relatively low cost particularly during the transition periods when PFAS-based foams continue to be used in certain applications and if the use of existing foams is not restricted. 7 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Report Note that this document has been prepared based on two contracts undertaken by Wood, COWI and Ramboll for the European Commission and ECHA to examine the potential impacts of a restriction on the use of PFAS in firefighting foams. The outputs are presented in the format of an Annex XV dossier for restriction under REACH. However, this `pre-Annex-XV' dossier has been prepared in order to facilitate drafting of a possible future restriction proposal. It does not imply that the Commission or ECHA have yet concluded on what the most appropriate risk management option for PFAS is. The main body of this report presents a summary of the results of the two studies mentioned above. The more detailed gathering and analysis of information that these results are based on, is presented in the Annexes, following the Annex XV dossier format. 1. The problem identified 1.1. Hazard, exposure/emissions and risk 1.1.1. Identity of the substance(s), and physical and chemical properties 1.1.1.1. Overview Polyfluoroalkyl and perfluoroalkyl substances (PFAS) is a broad term used to cover approximately 4 700 specific chemical species. Longer chain (C8) PFAS compounds have been used within industry as surfactants specifically because of their potent water and oil repellence at low concentrations (Buck, 20113). The main function of PFAS contained in fire-fighting foam is to act as a surfactant, that is to form a film over the surface of a burning liquid in order to prevent flammable gases from being released from it as well as reigniting. They are therefore used in fires involving flammable liquid (Class B fires4) within a range of sectors. Tonnages of foam used by sector are discussed in the next sub-section below. PFAS-based fire-fighting foams are used for fires in many different applications involving flammable liquids, and are used in equipment such as small fire extinguishers up that for to large tank fires. They can be applied with both mobile and semi-stationary equipment and are also used in training and testing of equipment. 3 Buck, R. C., Franklin, J. , Berger, U. , Conder, J. M., Cousins, I. T., de Voogt, P. , Jensen, A. A., Kannan, K. , Mabury, S. A. and van Leeuwen, S. P. (2011), Perfluoroalkyl and polyfluoroalkyl substances in the environment: Terminology, classification, and origins. Integr Environ Assess Manag, 7: 513-541. doi:10.1002/ieam.258 4 The European Standard Classification of Fires distinguishes between the following fires: Class A - fires involving combustible solid materials (e.g. wood, paper or textiles); Class B - fires involving flammable liquids (e.g. petrol, diesel or oils); Class C - fires involving gases; Class D - fires involving metals; Class K - fires involving live electrical apparatus; Class F - fires involving cooking oils. 8 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS A large number of highly diverse PFAS substances have been identified in the context of use in fire-fighting foams. The following grouping is possible: Unsubstituted long chain PFAS (see Section 1.1.1.2 and Annex B 1.1.1 and B 1.1.2) Unsubstituted short chain PFAS (see Section 1.1.1.3 and Annex B 1.1.3 and B 1.1.4) Substituted short and long chain PFAS (see Section 1.1.1.4 and Annex B 1.1.5) Fluorotelomers (see Section 1.1.1.5 and Annex B 1.1.6) Others (See Section 1.1.1.6 and Annex B 1.1.7) Summary overviews of the long- and short-chain PFASs identified and of the fluorotelomer substances identified are provided in the figures below. The figures below provide a hierarchical clustering of the substances that have been identified as being used in fire-fighting foams, including short-, long-chain and substituted PFAs substances (Figure 1.1) and also fluorotelomers (Figure 1.2). 9 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Figure 1.1 Hierarchical clustering of the identified short-, long-chain and substituted PFAs substances 10 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Figure 1.2 Hierarchical clustering of identified fluorotelomers 11 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS 1.1.1.2. Long chain PFAS The group of long chain PFAS consists of both perfluorosulfonic acids (PFSAs) with C6 (chemically defined as CnF2n+1-SO3H)5 and perfluorocarboxylic acids (PFCAs) with C86 (chemically defined as CnF2n+1-COOH). The group of long chain PFAS (defined by OECD as perfluorosulfonic acids (PFSAs) with C6 and perfluorocarboxylic acids (PFCAs) with C8) encompasses the following substances: PFSAs with C6 (see a full overview of these substaces in Annex B 1.1.1) Perfluorohexane sulfonic acid (PFHxS) (C6) Perfluoroheptane sulfonic acid (PFHpS) (C7) Perfluorooctane sulfonic acid (PFOS) (C8) Perfluorononane sulfonic acid (PFNS) (C9) Perfluorodecane sulfonic acid (PFDS) (C10) Perfluoroundecan sulfonic acid (PFUnDS) (C11) PFCAs with C8 (see a full overview of these substaces in Annex B 1.1.2) Perfluorooctanoic acid (PFOA) (C8) Perfluorononanoic acid (PFNA) (C9) Perfluorodecanoic acid (PFDA) (C10) Perfluoroundecanoic acid (PFUnDA) (C11) Perfluorododecanoic acid (PFDoDA) (C12) Perfluorotridecanoic acid (PFTrDA) (C13) Perfluorotetradecanoic acid (PFTeDA) (C14) Perfluorostearic acid (PFOcDA) (C18) 1.1.1.3. Short chain PFAS Short chain PFAS identified include sulfonic acids and carboxylic acids: PFSAs with C2-C5 (see Annex B 1.1.3) Perfluoroethane sulfonic acid (PFEtS) (C2) Perfluoropropane sulfonic acid (PFPrS) (C3) Perfluorobutanesulfonic acid (PFBS) (C4) 5 The PFSAs and PFCAs identified as used in FFFs are covered by the general classification of per- and polyfluoroalkyl substances (PFASs) by the OECD. 6 C8 covers in this case perflouralkylcarbons as well as the single carbon belonging to the acid group. 12 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Perfluoropentane sulfonic acid (PFPeS) (C5) PFCAs with C4-C6 (see Annex B 1.1.4) Perfluoro-n-butanoic acid (PFBA) (C4) Perfluoropentanoic acid (PFPeA) (C5) Perfluorohexanoic acid (PFHxA) (C6) Perfluoroheptanoic acid (PFHpA) (C7) 1.1.1.4. Derivates of perfluoroalkyl sulfonic PFAS (also PASF-based substances) All the named substances above are characterised by a perfluorinated alkaline carbon chain that is connected to a sulfonic- or carboxylic acid head group. In other PFAS substances, this head group is also equipped with additional chemical groups. These other substances form the group derivates of perfluoroalkyl sulfonic PFAS, also called perfluroalkane sulfonyl fluoride substances (PASF), as their synthesis is based on perfluroalkane sulfonyl fluoride. This can be for example an amide (sometimes methylated or ethylated). The chemical formulae of this group can be summarised as: Perfluoroalkane sulfonyl fluoride (PASF) = CnF2n+1SO2F PASF-based derivates = CnF2n+1SO2-R, where R = NH, NHCH2CH2OH, etc. However, in most cases, these substances were not found when the actual foam was tested but rather when environmental samples were tested. In addition, some of the substances are also known to be environmental transformation products. Other substances are raw materials for surfactant and surface protection products (EtFOSE and N-MeFOSe) (Buck et al. 2011). In this sub group, the following substances were found: Perfluoroalkyl sulfonamido amines (PFOSaAm); C7-FASA - Perfluoroheptane sulfonamidoethanol (PFHpSA); C8-PFSiA (PFOSI); N-Ethyl perfluorooctane sulfonamidoacetic acid (EtFOSAA); N-Methyl perfluorooctane sulfonamidoacetic acid (EtFOSE); N-Methylperfluorobutanesulfonamide (FBSA); Perfluorooctane sulfonamide (FOSA); Perfluorooctane sulfonamido acetic acid (FOSAA); Perfluorooctane sulfonamidoethanol (FOSE); N-methyl perfluorooctanesulfonamidoacetic acid (N-MeFOSA); N-Methyl perfluorooctane sulfonamidoethanol (N-MeFOSE); Perfluoroalkyl sulfonamido amines (PFBSaAm); N-[3-(Dimethyloxidoamino)propyl] -3,3,4,4,5,5,6,6,7,7,8,8,8-Tridecafluor-1- octanesulfonamid; and Carboxymethyl)dimethyl [3- (gamma-omega-perfluor-1-C6-14- Alkansulfonamid)propyl)ammonium. 13 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS A full overview of the substituted short and long chain PFAS identified is provided in Annex B 1.1.5. 1.1.1.5. Fluorotelomers Fluorotelomers are defined by having an additional non-fluorinated spacer between the perfluorinated alkyl chain and the charged head group (denotated as number of perfluorinated carbons: number of non-fluorinated carbons). The most known homologues of this subgroup are those that have a two carbon atom spacer (defined as CnF2n+1-C2H4-R)7. Fluorotelomers cover a wide range of positively/negatively charged head groups or combinations of those. Most of the fully identified substances, exhibit the xx:2 structure, where two non-fluorinated carbon atoms are inserted between the perfluorinated carbon chain and the head group. However, in the case of fluorotelomer betaines also xx:1:2 and xx:3 are found. In the latter case, three non-fluorinated carbon atoms are inserted between the perfluorinated carbon chain and the head group. In the case of the xx:1:2 substances, an additional fluorinated carbon is inserted between the perfluorinated alkyl chain and the non-fluorinated spacer. Based on the manufacturing dates that are cited in the respective publications, it can be assumed that the use of fluorotelomers in fire-fighting foams began later than the use of traditional PFAS substances without a non-fluorinated spacer. The following head groups have been identified: Alkylbetaine (AB); Betaine (B); Carboxylic acid (CA); Hydroxy (OH); Thioamido sulfonates (TAoS); Unsaturated carboxylic acid (UCA); Sulfonamido betaines (SaB); Sulfonamide amine (SaAm); and Thio hydroxy ammonium (THN+). A full overview of the fluorotelomer substances identified is provided in Annex B 1.1.6. 7 This corresponds with the general classification of per- and polyfluoroalkyl substances (PFASs) by the OECD, however flurotelomers used in FFFs have also been identified with a spacer of three non fluorinated carbon atoms (for example 7:3 FTB), as well as fluorotelomers with a non-fluorinated and an additional single-fluorinated carbon. 14 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS 1.1.1.6. Other PFAS substances In some cases, perfluorinated substances that do not belong to any of the named groups (long-/short-chain PFAS, fluorotelomers, and derivates of perfluoroalkyl sulfonic PFAS) have been identified (`others'). The identified substances grouped under the term "others" show diverse chemical structures. A full overview of the chemical substances attributed to `other' is provided in Annex B 1.1.7. The only feature that is common to all of them is a perfluorinated substructure. The substances include: Ammonium 2,2,3 trifluor-3-(1,1,2,2,3,3-hexafluoro-3-trifluormethoxypropoxy), propionate Dodecafluoro-2-methylpentan-3-one Poly(1,1,2,2-tetrafluoro-1,2-ethanediyl), -fluoro--2-[3-((carboxylatomethyl) dimethylammonio)propylaminosulfonyl]ethyl Thiols, C8-20, gamma-omega-perfluoro, telomers with acrylamide Sodium p-perfluorous nonenoxybenzene sulfonate Bis(trifluorovinyl)ether However, in analogy to the perfluorinated ethers like ADONA (CnF2n+1-O- CmF2m+1), the substance Dodecafluoro-2-methylpentan-3-one (a ketone) could be defined by CnF2n+1CO-CmF2m+1. 1.1.1.7. Chemical definitions of the identified substances which could be used for a possible future restriction Any regulatory action on chemical substances/substance groups relies on a precise chemical identification. In the following the identified PFAS-substances have been checked to confirm whether they are covered by the general classification of per- and polyfluoroalkyl substances (PFASs) by the OECD, which itself is based on the commonly agreed terminology for nomenclature of PFASs (Buck et al. 2011). In the case of the PFCAs, chemically defined as CnF2n+1-COOH, the substances identified in this task, AFFF-related PFAS-substances, would be covered. This is also true for the sulfonic homologues (PFSA, defined as CnF2n+1-SO3H). Fluorotelomers-based substances are chemically defined by having a non-perfluorinated spacer between the perfluorintated carbon chain and a polar head group. The most known homologues of this subgroup are those that have a two carbon atom spacer (defined as CnF2n+1-C2H4-R). This definition is also given in the OECD report ("Working towards a global emission inventory of PFASs: focus on PFCAS - status quo and the way forward"). In this task, multiple substances belonging to this group were identified, varying in the perfluorinated chain length. However, homologues with a spacer of three non fluorinated carbon atoms (for example 7:3 FTB) were also identifed, thus the definition would need to be enlarged to CnF2n+1CmHm+1-R, so that substance with a variable chain length could be included. In addition fluorotelomers with a non-fluorinated and an additional single-fluorinated carbon were 15 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS identified (for example 7:1:2 FTB). In order to include such substances, the chemical definition for these homologues would need to be (CnF2n+1-CHF-CmHm+1-R). The derivates of PFSA substances are chemically defined by having an additional chemical moiety connected to the sulfonic headgroup (CnF2n+1-SO2-R). All of the identified substances identified in this task would be covered by this definition. The identified substances grouped under the term "others" show diverse chemical structures. The only feature that is common to all of them is a perfluorinated substructure. However, in analogy to the perfluorinated ethers like ADONA (CnF2n+1-OCmF2m+1), the substance Dodecafluoro-2-methylpentan-3-one (a ketone) could be defined by CnF2n+1-CO- CmF2m+1. The following table summarises the named PFAS classifications, the generalised chemical structures, and the minimal number of carbon atoms of AFFF-related PFAS substances. It is observable, that the common sub unit is a perfluorinated ethyl-group (-C2F4- or C2F5)8. Based on that, the definition that would be needed to be to cover the all relevant AFFF-related PFAS substances would be based on these particular -C2F4- or C2F5-sub groups. Table 1.1 Overview of the PFAS classification, generalised chemical structures, and minimal number of C-atoms of substances that were identified as being used in AFFF PFAS classification (Buck et al. 2011) PFCAs PFSAs I PFSAs II Fluorotelomer-based substances I Fluorotelomer-based substances II Fluorotelomer-based substances III Perfluoroalkyl ether-based substances Perfluoroalkyl ether-based substances Generalised chemical structure CnF2n+1-COOH CnF2n+1-SO3H CnF2n+1-SO2-R CnF2n+1-C2H4-R CnF2n+1-CmHm+1-R CnF2n+1-CHF-CmHm+1-R CnF2n+1-O- CmF2m+1 CnF2n+1-CO- CmF2m+1 Minimal number of Catoms as identified in AFFF 4 2 4 4 4 4 2 2 8 -C2F4- if incorporated in the chemical structure of the PFAS substance or -C2F5 when attached terminaly to the structure. 16 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS In the following, a proposal for the definition in the form of substance identity, that could be used for a potential restriction, is made. For this, in the following table, the definition of PFOA as stated in the restriction (Entry 68 to Annex XVII to REACH) and a draft version of the possible definition for the restriction on PFAS-substances found in AFFF is shown. In addition, the definition in the "Information Document accompanying the "Call for evidence supporting an analysis of restriction options for the PFAS group of substances (fluorinated substance(s))" as published in the context of the RMOA has been used. Table 1.2 Comparison of the substance identification as in the PFOA restriction and a proposal made for the PFAS-substances in AFFF. Perfluorooctanoic acid (PFOA) CAS No. 335-67-1 EC No. 206-397-9 and its salts. Any related substance (including its salts and polymers) having a linear or branched perfluoroheptyl group with the formula C7F15- directly attached to another carbon atom, as one of the structural elements. Any related substance (including its salts and polymers) having a linear or branched perfluorooctyl group with the formula C8F17- as one of the structural elements. The following substances are excluded from this designation: Per- and polyfluoroalkyl substances (PFAS) CAS No. various EC No. various Any substance having at least two perfluorinated carbons with the formula CnF(2n+1)- (n2) directly attached to any chemical group, as one of the structural elements. [This is a provisional definition that would need to be tested in terms of its implications as part of the consultation on any future restriction proposal, and taking into account the conclusions of the PFAS working group.] - C8F17-X, where X = F, Cl, Br. - C8F17-C(=O)OH, C8F17-C(=O)O-X or C8F17-CF2-X (where X = any group, including salts). In the following, the proposed definition is discussed in the context of whether it is comprehensive enough to avoid any existing or new PFAS being used in fire-fighting foams. For this the publicly available ECHA database has been checked using its advanced search feature based on structural elements. Based on the proposed definition, any PFAS substance that contains -CnF2n+1 (n2) or CnFn+1 (n2) as one of the structural elements would be covered. Substances with only one -CF3 moiety would not be covered; however in this project no PFAS-substance with only a single-CF3 moiety has been identified. In addtion, this group is used, for example, in certain drugs and pigments. A fluorine to chlorine replacement is for example found in F-53B (6:2 chlorinated polyfluorinated ether sulfonate), a novel mist suppressant used as a replacement in metal plating (mainly in China see Du et al., 2016) . However, based on the entire structure this substance would also be covered by the definition proposed above. 17 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS 1-Chloro-1,2,2,2-tetrafluoroethane (HCFC-124 , CAS No 2837-89-0) is a substance used in refrigerants as replacements for "older" chlorofluorocarbons. HCFC-124 is also used in gaseous fire suppression systems as a replacement for bromochlorocarbons. This particular substance would be not covered by the definition; however its potential usage in AFFF is questionable as it is gaseous. A search for this sub structure (-CClF3 or (Cl)C(F)(F)F) gave nine hits. A search for bromine (Br)C(F)(F)F) resulted in three hits. The limited amount of hits, does, in a first approximation, show how many substances would not be covered by a possible restriction as elaborated above. However, the data is limited to the information publicly available in the ECHA database. Also a replacement of fluorine atoms by hydrogen is observed in some substances (fluorotelomers). However, the fluorotelomers in this project would all be covered. An addtitional search in ECHA based on the -CHF-CF39 substructure gave 15 hits. Taken together, the proposed definition is very broad and should prevent existing or new PFAS being used in fire-fighting foams. However, when flourine is replaced by, for example, chlorine, bromine or hydrogen, the resulting substances would not be covered. It should be noted that this definition has been developed specifically in the context of fire fighting foams. This does not imply that it would be an appropriate definition for any other possible restriction on PFAS in other uses. 1.1.2. Justification for grouping However, high level comments on the rationale for grouping of PFAS substances is provided here. Due to the large number of PFAS chemicals (in general, but also specifically those used in fire-fighting foams), a substance-by-substance risk assessment and management approach is not adequate to efficiently prevent risks to the environment and human health from a single PFAS or mixtures of them. While the specific hazards of individual PFAS can vary, they are subject to some important common concerns. Notably, all PFAS either are, or degrade to, persistent chemicals that accumulate in humans, animals and the environment, and have been shown to be ubiquitous in the environment and human bodies. Taking precautionary risk management actions for groups of chemicals and promoting the use of chemicals that are `safe-and-circular-by-design' could help to limit future pollution10 while avoiding so-called regrettable substitution. 1.1.3. Classification and labelling Note that the scope of this study was to base information on hazards on results from the PFAS working group, which have not been available for this report. Therefore, a review of the classification and labelling has not been undertaken. The outputs of that work should be taken into account when drawing up any formal Annex XV restriction proposal. 9 SMILES (C(F)C(F)(F)F) 10 See for instance: https://www.eea.europa.eu/themes/human/chemicals/emerging-chemicalrisks-in-europe 18 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS 1.1.4. Hazard assessment A PFAS working group exists under ECHA's stewardship to assess the hazards associated with PFAS substances, including persistence, mobility, bioaccumulation and toxicity. To avoid conflicting with the work of the PFAS working group an in-depth assessment of the hazards for PFAS substances (as a family of chemicals used for fire-fighting foams) has not been completed under the current study. Therefore, based on the wealth of research that has already been developed, high level comments on the hazards associated with PFAS substances are provided here, in order to provide context on the need for action at the EU level. Further discussion on the hazards of the non-fluorinated alternatives is provided in Annex B, Section B.5. PFAS is a broad term used to cover approximately 4,700 specific chemical species11 which have a wide range of uses. These uses are principally based around the carbonfluorine bond which is particularly strong and offers physical properties that include high water and oil repellence12. The same properties mean that many PFAS substances are also highly mobile (within the natural environment) and highly persistent (see Appendix 3 of the underlying study13). This can create issues where PFAS substances emitted to the environment reach and contaminate important resources such as groundwater. There is evidence to suggest that exposure to PFAS can lead to adverse health effects in humans (by eating or drinking food or water contaminated by PFAS). In particular the US EPA14 highlight studies that indicate the longer chain (C8 PFAS) species PFOS and PFOA can cause reproductive and developmental, liver and kidney, and immunological effects on laboratory animals. Furthermore, both chemicals have caused tumours in animal studies. Their use is already restricted in the EU and elsewhere. Some short-chain PFAS (PFHxS, PFBS, HFPO-DA) have also been listed as SVHCs, based on there being an equivalent level of concern to the named groups of chemicals under the authorisation provisions under REACH (carcinogens, mutagens and reprotoxicants (CMRs) and persistent, bioaccumulative and toxic/very persistent and very bioaccumulative (PBTs/vPvBs) chemicals). The Nordic Council of Ministers15 commented that the annual health-impacts within an EEA exposure study (from all uses of PFAS, not only fire-fighting foams) was estimated at 52-84 billion. This gives an indication of the scale of the issue and magnitude of the potential impacts from the environmental build-up of PFAS. The same study describes 11 OECD, 2018, PFAS database, toward a new comprehensive global database of per and polyfluoroalkyl substances. 12 Buck et al, 2011, `Perfluoroalkyl and polyfluoroalkyl substances in the environment: Terminology, classification and origins', Integrated environmental assessment and management vol 7 issue 4. 13 Wood, Ramboll, COWI: "The use of PFAS and fluorine-free alternatives in fire-fighting foams - Final report". Report for the European Commission DG Environment and European Chemicals Agency (ECHA) under specific contracts No 07.0203/2018/791749/ENV.B.2 and ECHA/2018/561. 14 US EPA, 2019, `Basic information on PFAS', https://www.epa.gov/pfas/basic-information-pfas 15 Nordic Council of Ministers, 2019, `The Cost of Inaction - A socioeconomic analysis of environmental and health impacts linked to exposure to PFAS', http://norden.divaportal.org/smash/get/diva2:1295959/FULLTEXT01.pdf 19 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS remediation costs associated with contamination from PFAS at European sites ranging from several hundred thousand up to 40 million with one high-cost example for the Dusseldorf Airport, Germany estimating a total remediation cost of up to 100 million. Based on the physical properties of PFAS (particularly mobility and persistence) along with identified health effects for some PFAS, PFAS represent a challenging environmental and human health hazard issue. 1.1.5. Exposure assessment Based on an extrapolation of data provided by Eurofeu (see Annex A for more details) it is estimated that some 20,000 tonnes of PFAS-based fire-fighting foams are sold in the EU per year. Of these, about 12,000 tonnes are estimated to be employed in fixed systems and 8,000 in mobile systems16. The split by sector is detailed in Figure 1.3 below. This shows that chemical/petrochemical is by far the largest user sector (59%), but municipal fire brigades, marine applications, airports and military applications also account for significant volumes. Ready-for-use products only account for a very small share of PFAS-based foams according to this data. The majority of this category are fire extinguishers, although not all foam fire extinguishers use ready-for-use foams (according to personal communications with Eurofeu). The annual tonnage of PFAS-based fire-fighting foam used in all extinguishers in the EU has been estimated at 360-675 tonnes (not counting the water that foam concentrates are mixed with in the extinguishers before/during use). Figure 1.3 Split of PFAS-based fire-fighting foams by sector Ai rports 9% Mi l i tary 6% Ready for use products 1% Ma ri ne a pplications 12% Muni cipal fire bri ga des 13% Chemi cal/ p e tro ch emical 59% Source: Data provided to the authors by Eurofeu. 16 All these figures have been extrapolated from the original values provided by Eurofeu, which covered approximately 70% of the market. The number of companies that provided a response on whether the foams are used in fixed or mobile systems is lower than those that provided a response for the sectoral overview, therefore in the original data the total tonnage of the former is lower than the latter. To fill this gap, the tonnages for both fixed and mobile systems have been inflated so that their total matches the total in the sectoral split. 20 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS The use of these PFAS-based foams accounts for an annual consumption of around 480560 tonnes of fluorosurfactants per year in the EU, based on data provided by Eurofeu. Using a source-flow model and various assumptions that are outlined in Annex B, Section B.9., emission estimates have been developed to provide an illustrative assessment to help better understand the material flow and key emission compartments of fire-fighting foams. The source-flow model has been used to produce emission estimates for 10 unique nonfluorinated substances (hydrocarbons and detergents); as well as two PFAS-based substances. Table 1.3 and Table 1.4 provide summary overviews (as percentage ratios) of the key emission compartments and life-cycle stages for emissions. The initial overview presented in Table 1.3 highlights that fresh surface water and soil are the key receiving environmental compartments. Furthermore, Table 1.4 highlights that, for nonfluorinated substances, live incidents are the major point of release, while for PFAS the waste phase is the key life-cycle stage for emissions, primarily from losses associated with releases at WWTPs. Table 1.3 Overview of ratios for emissions by different environmental compartment for all life-cycle stages combined. Substance group Non-fluorinated alternatives (range) Non-fluorinated alternatives (mean average) 1-Propanaminium,N-(carboxymethyl)-N,N-dimethyl3-[[(3,3,4,4,5,5,6,6,7,7,8,8,8tridecafluorooctyl)sulfonyl]amino]-,inner salt 1-Propanaminium, 3-amino-N-(carboxymethyl)-N,Ndimethyl-N-[[(gamma-omega-perfluoro-C6-C16alkyl)thio]acetyl] derives., inner salts *includes releases from WWTPs after treatment. Air 9 - 18% 14% 9% Fresh surface water* 33 -37% 35% 51% Marine waters 10 - 15% 13% 8% Soil 30 - 45% 38% 32% 9% 30% 8% 53% Table 1.4 Overview or ratios for emissions by different life-cycle stages Substance Group Non-fluorinated alternatives (range) Non-fluorinated alternatives (mean average) PFAS based substances (mean average) Formulation 9 - 18% 14% 9% Storage and Training 12 - 18% 15% 9% Live 40 - 62% 52% 30% Waste 1% - 35% 19% 52% Regarding the emissions by environmental compartment, it should be noted that while the non-fluorinated fire-fighting foams make up approximately one third of the market, the volumes of alternative surfactants can be greater than their PFAS counterparts due to greater concentrations within the product itself, potentially leading to higher emissions of 21 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS the non-fluorinated alternatives. However, it is important to recognise that emission alone is not an indicator of impact, and the degradation rates, potential for bioaccumulation, and harmful effects also need to be considered (as discussed in the previous section 1.1.4 and in more detail in Annex B.5). Regarding the emissions by life cycle stage, it should be noted that the major use of firefighting foams is for training purposes. During training exercises, aside from marine applications, it is assumed that the efficacy of bunding17 and/or other control measures is relatively good. This means much of the fire-fighting concentrate within runoff is contained and sent for final destruction primarily within waste water treatment plants (WWTPs) on-site or off-site. For the non-fluorinated alternatives, the effectiveness of WWTPs is relatively good, minimising the emission which is split between surface water and soil. Because WWTPs are more effective in irreversibly destroying the named nonfluorinated substances, their use in training where run-off can be contained and treated leads to relatively low releases to the environment. This increases the relative importance of live incidents - where there is a direct release without treatment. For the PFAS-based substances, WWTPs is expected to be ineffective at treating PFAS, meaning direct release to surface water / soil depending on the partition coefficient. Waste is thus the most important life-cycle stage for the PFAS substances. 1.1.6. Risk characterisation A risk characterisation has not been undertaken, pending results from the PFAS working group on the hazards and risks of PFAS. 1.2. Justification for an EU wide restriction measure Section 1.1.4 has illustrated that (without precluding any ongoing work or conclusions by the PFAS working group) there are concerns associated with PFAS. Some PFAS have been shown to cause reproductive and developmental, liver and kidney, and immunological effects as well as tumours in animal studies (note that the scope of this study was to base information on hazards on results from the PFAS working group, which have not been available for this report). Many PFAS are highly mobile, highly persistent, and have the potential to accumulate within the environment and living organisms. The assessed non-fluorinated alternatives' persistence is considerably lower than PFAS. Section 1.1.5 has shown that, while in some user sectors PFAS-based foams have been increasingly replaced by fluorine-free alternatives and industry best practice guidance recommends not using PFAS-based foams in training and testing, some 20,000 tonnes of PFAS-based fire-fighting foams are still used annually in the EU in applications involving flammable liquid fires (Class B fires), including testing and training18. This use leads to releases to the environment, with fresh surface water and soil being the key receiving 17 The use of retaining walls to contain fire-water run-off. 18 See Section B.9.3.2 for a discussion of how much of the total could be used for testing and training. 22 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS environmental compartments. For non-fluorinated substances, live incidents are the major point of release, while for PFAS the waste phase is the key life-cycle stage for emissions, primarily from losses associated with releases at WWTPs. Some PFAS were shown to be ubiquitous contaminants, for instance in arctic wildlife19. The use of certain PFAS substances has been regulated in the past. This has led to the replacement of the regulated (e.g. long-chain) PFAS with fluorine-free alternatives in some cases, but also other PFAS substances (e.g. short-chain PFAS), as illustrated by the fact that the majority of fire-fighting foams used are still PFAS-based. Concerns have continued that shorter chain PFAS substances are also mobile (if not more mobile) than C8 substances and are highly persistent, albeit with potentially lower bioaccumulation20. Some (PFHxS, PFBS, HFPODA) have also been listed as SVHCs, based on there being an equivalent concern to the named groups of chemicals under the authorisation provisions under REACH (carcinogens, mutagens and reprotoxicants (CMRs) and persistent, bioaccumulative and toxic/very persistent and very bioaccumulative (PBTs/vPvBs) chemicals). National regulations exist that require the containment of fire-water run-off, but the consultation suggested that containment is rarely 100% effective and there are concerns about the efficacy of removal of PFAS from collected fire-water in WWTP. Industry best practice measures aim to minimise the use and release of PFAS-based foams (e.g. ceasing its use in training and testing, as has happened in many locations already) but the consultation suggested that these are not being fully implemented (e.g. the use of PFAS-based foams in training has been reported). Stakeholder input did not allow to conclude on their relative effectiveness. In conclusion, it has been demonstrated that the use of PFAS in fire-fighting foams is associated with a significant environmental concern that does not seem to be adequately addressed by the current measures in place (current measures are discussed in more detail in Section 1.3). Even if additional measures were introduced at Member State level (and the consultation has not raised anything suggesting that they will be), there is potential for discrepancies in the definitions and scope of any national restrictions (e.g. definition of substances covered, uses covered, concentration thresholds, transition periods). This has implications not only for the degree to which the environment is protected, but also in terms of ensuring the functioning of the internal market. Different restrictions in different Member States could make it very challenging to market firefighting foam products saleable in all Member States. Moreover, due to their high mobility and persistence as well as their proven ubiquity (at least of some PFAS), it appears very likely that PFAS emissions lead to cross-border pollution. Therefore, potential further regulatory management on EU-level is likely required. 19 See for instance Muir, D. et al. (2019): Levels and trends of poly-and perfluoroalkyl substances in the Arctic environment-An update. Emerging Contaminants, 5, 240-271. 20 Cousins et al, 2018, `short-chain perfluoroalkyl acids: environmental concerns and regulatory strategy under REACH', Environmental science Europe vol 30. Annex 3 23 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS 1.3. Baseline 1.3.1. Overview The baseline presented here comprises an overview of the current use of PFAS-based fire-fighting foams based on the market analysis (used in particular as baseline economic activity for the assessment of economic impacts) and an overview of the current regulatory and voluntary industry measures to control the risk of this use. Resulting baseline exposure have already been presented in Section 1.1.5 and are not repeated here. 1.3.2. Definition of the baseline scenario for the assessment of economic impacts The baseline scenario describes the situation in the absence of any further regulatory management options (RMOs). It reflects the current market situation, but also any anticipated changes in the absence of the proposed RMOs. It was used to compare restriction scenarios (defined in the next sub-section), to ensure that the SEA evaluates the impacts of the RMOs being assessed. More details are provided in the market analysis (see Annex A), but the key points are below. It is estimated that currently some 14,000-20,000 tonnes (likely closer to the upper end of the range) of PFAS-based fire-fighting foams are sold per year in the EU and used in various sectors including chemicals/petrochemicals, municipal fire-fighting, marine, airports, military, railways and fire extinguishers. Their use is particularly important and widespread where there is a risk of Class B fires, i.e. where flammable liquids are present. They are used for fire-fighting, but in some cases also for training and testing of equipment. Some 9,000 tonnes per year of fluorine-free foams are already used in most of the same applications, although the split by sector varies from that of PFAS-based foams. Several stakeholders, including manufacturers of fire-fighting foams, have indicated that the use of fluorine-free foams has been increasing, particularly in applications where PFAS-based foams can be very easily replaced (e.g. training). This trend is expected to continue in the future to some extent (even in the absence of any restriction on PFAS-based foams). Some stakeholders also noted that containment of fire-water run-off, particularly from training, has been increasing and that this has likely reduced emissions of PFAS significantly. In addition, there are significant existing stocks of PFAS containing foams which have been already purchased. These may need to be disposed of and replaced. The total quantum of these stocks is uncertain, but are estimated as follows: o Annual sales of PFAS-based foams are estimated at between 14,00020,000 tonnes per year. o Current annual sales of fluorine-free foams are estimated at 7,000-9,000 tonnes per year. Historically, this demand would have been served by PFAS containing foams, hence the total annual sales of PFAS-based foams could have been some 21,000-29,000 tonnes. 24 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS o The shelf life of PFAS-based foams is reported to be typically between 10 and 20 years (and up to a maximum of 30 years)21. Given that foams may be used before the end of their shelf life, the actual lifetime of foams could be shorter. BiPRO 2010 suggests that the average lifespan of fire-fighting foams is 15 years, which appears consistent with the above information22. o Given that between 14,000 and 29,000 tonnes of PFAS-based foam have historically been replaced per year, and assuming an average lifespan of foams of 15 years, indicates that the existing European stocks of PFASbased foam may be between 210,000 and 435,000 tonnes23. These volumes of stock are used in the SEA calculations. 1.3.3. Overview of current regulatory measures 1.3.3.1. Stockholm Convention The Stockholm Convention on Persistent Organic Pollutants (POPs) includes restrictions on the production and use of a number of specific PFAS, at international level, including some provision for exemptions for the production and use of these compounds for use in firefighting foams. PFOS, its salts and PFOSF are listed under Annex B of the Stockholm Convention, which restricts production and use to specified acceptable purposes and specific exemptions. Upon its initial listing in 2009, an acceptable purpose was put in place for PFOS used in firefighting foams. At the POPRC meeting in 2018, the committee recommended, based on the findings of an assessment of alternatives to PFOS24 , that the acceptable purposes for the production and use of PFOS, its salts and PFOSF for fire-fighting foam be amended to a specific exemption for the use of fire-fighting foam for liquid fuel vapour suppression and liquid fuel fires (Class B fires) already in installed systems, including both mobile and fixed systems, and with the same conditions put in place for PFOA (see below). This exemption was agreed accordingly at the Ninth Meeting of the Conference of the Parties (COP) to the Stockholm Convention in 2019. At the 14th meeting of the POPRC in September 2018 the POPRC recommended listing PFOA, its salts and PFOA-related compounds in Annex A to the Convention with specific exemptions. One exemption specified was for use of firefighting foams containing PFOA already installed in systems including both mobile and fixed systems with specific conditions. Parties to the Convention can register for this exemption if they: i) ensure that FFFs that contain or may contain PFOA shall not be exported or imported except for the purpose of environmentally sound disposal; ii) do not use FFFs that contain or may contain PFOA for training or testing (unless all releases are contained) purposes; iii) by 21 Proposal for a restriction: Perfluorohexane sulfonic acid (PFHxS), its salts and PFHxS-related substances https://echa.europa.eu/documents/10162/a22da803-0749-81d8-bc6d-ef551fc24e19 22 BiPRO, 2010, Study on waste related issues of newly listed POPs and candidate POPs 23 A lifespan of 15 years means that each year, 1/15 of the stocks are replaced. So, if between 14,000 to 29,000 tonnes are replaced per year, then the stock is 15 times that tonnage. Multiplying annual replacement tonnages with 15 yields the above estimates. 24 UNEP/POPS/POPRC.14/INF/8 : http://chm.pops.int/TheConvention/POPsReviewCommittee/Meetings/POPRC14/Overview/tabid/7398/Default.as px 25 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS the end of 2022 if possible, but no later than 2025, restrict uses of FFFs that contain or may contain PFOA, to sites where all releases can be contained; iv) ensure all fire water, waste water, run-off, foam and other wastes are managed. This was also agreed accordingly at the 9th COP in 2019. At its fifteenth meeting, the POPRC adopted the risk management evaluation on perfluorohexane sulfonic acid (PFHxS), its salts and PFHxS-related compounds and recommended to the Conference of the Parties that it consider listing the chemicals in Annex A to the Convention without specific exemptions. The listing will not be officially adopted until the next COP meeting in May 2021, and would be officially added to the Annexes of the Convention in 2022. 1.3.3.2. EU Regulation The European Union has implemented the POPs Regulation (EC 2019/1021)25 which acts to implement the provisions of the Stockholm Convention across the EU Member States. PFOS was originally included in the restricted substances list of REACH. However, since its addition to the Stockholm Convention in 2009, it has been regulated under the POPs Regulation. PFOS, its salts and PFOSF are listed under Annex I of the POPs Regulation, specifying the following exemptions for unintentional trace contaminants (UTC)26: Substances or preparations (<10 mg/kg) Semi-finished products or articles, or parts (<0.1 % by weight) An exemption is also foreseen for the use as a mist suppressant for non-decorative hard chromium plating. PFOA has been identified under REACH as a SVHC since 2013 and it is restricted under entry 68 of Annex XVII. However, the restriction includes an exemption for PFOA used in concentrated fire-fighting foam mixtures placed on the market before 4 July 2020 and those used in the production of other fire-fighting foam mixtures. There is also an exemption for use in fire-fighting foam mixtures produced before 4 July 2020 and used for training purposes, provided that emissions to the environment are minimised and effluents are collected and safely disposed of. The POPs Regulation is expected to be amended in summer 2020 to include PFOA in Annex I following the listing under the Stockholm Convention (see above). The derogations for fire-fighting foams proposed under the POPs Regulation are more limited compared to the REACH restriction, as the listing under the Stockholm Convention allows no derogation for use in training; it only allows use of foams in installed systems, only until 2022 (or 2025 at the latest), and only with containment requirements. 25 https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32019R1021&from=EN 26 There is an exemption for the use in hard chromium plating, although that is not relevant for fire-fighting foams. 26 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS PFHxS, has, since June 2017, also been listed as an SVHC under REACH and there is an ongoing restriction proposal27 (at the time of writing at the stage of public consultation on the SEAC draft opinion). It is expected that PFHxS will ultimately also be regulated at EU-level under the POPs Regulation, when its listing to the Stockholm Convention is finalised (see above). In December 2019, a proposal28 for a restriction under REACH on PFHxA was published. The proposal includes certain transition periods and derogations for uses in fire-fighting foams. It is proposed that concentrated fire-fighting foam mixtures placed on the market until 18 months after the entry into force of the restriction could still be used in the production of other firefighting foam mixtures until 5 years after the entry into force, except for use of fire-fighting foam for training and (if not 100% contained) testing. There is also an exception for concentrated fire-fighting foam mixtures for certain defence applications until a successful transition to alternatives can be achieved, and for concentrated fire-fighting foam mixtures for cases of class B fires in storage tanks with a surface area above 500 m2 until 12 years after the entry into force. 1.3.3.3. Other international controls In 2016, The Swedish Chemicals Agency (KEMI) published its strategy for reducing the use of PFASs29 beyond solely the implementation of EU legislation. This included specific measures to tackle PFAS in firefighting foams, including a proposal for national regulations covering, for example: legal requirement for the collection and destruction of fluorine-based fire-fighting foam imposing reporting requirements review of exemptions - with the aim of reducing the number of exemptions as much as possible In some non-EU countries, there are also regulations in place, specifically targeting PFAS in firefighting foams. For example, in Norway30, there are regulations in place that focus on the following: The monitoring and screening of PFAS in the environment in general The monitoring and clean-up of PFAS polluted soil caused by airport fire drills A requirement for airports to monitor levels of PFAS at their fire drill sites and propose measures to reduce pollution A requirement for airports to screen and report levels of PFAS in their soil, and must propose measures to reduce pollution 27 https://echa.europa.eu/registry-of-restriction-intentions/-/dislist/details/0b0236e1827f87da 28 https://echa.europa.eu/registry-of-restriction-intentions/-/dislist/details/0b0236e18323a25d 29 https://www.kemi.se/global/rapporter/2016/report-11-16-strategy-for-reducing-the-use-of-higly-fluorinatedsubstances-pfas.pdf 30 https://www.oecd.org/chemicalsafety/portal-perfluorinated-chemicals/countryinformation/norway.htm 27 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS In the USA, at federal level, the US EPA has developed and launched a PFAS Action Plan31 to evaluate whether and how to regulate PFAS compounds under various federal environmental programmes (including TSCA). The primary focus of this plan is to reduce environmental and public health concerns when PFAS are released into the environment (e.g., through setting safe drinking water limits and remediation criteria). While the plan specifically references the use of firefighting foams as a key source of PFAS contamination and exposure, it does not set limits or actions specifically at national level for use of PFAS in foams. In December 2019, the Fiscal Year 2020 National Defense Authorization Act (NDAA) was released, which phases out the US Department of Defense's use of PFAS-containing firefighting foam by October 2024 (with an exception for shipboard use) and immediately prohibits the uncontrolled release of fluorinated aqueous film-forming foam (AFFF) and the use of AFFF in training exercises at military installations32. It should be noted that individual States also implement their own measures, and there is a wide variety of approaches, measures, and timescales adopted. As an example of some of the States with the strictest approaches: Washington bans the sale and the use for training purposes of PFAS-based firefighting foams from 1 July 2020 (except for oil refineries, chemical plants and uses required by federal law such as aircraft rescue)33. In California, a bill was proposed to the Senate (but not yet passed at the time of writing) to ban, from the beginning of 2022, the placing on the market of firefighting foams with intentionally added PFAS, except for uses required by federal law. It also requires manufacturers to recall products affected by the ban by that date, practically banning the use as well34. In Australia, the biggest source of concentrated emissions of PFAS is from historical use of PFAS-containing fire-fighting foams, particularly at fire-fighting training grounds. The Industrial Chemicals (Notification and Assessment) Act (ICNA Act), requires industry to provide toxicity data for new substances (including PFASs) or products containing new PFASs being introduced into Australia. Based on the level of toxicity and environmental persistence, the National Industrial Chemicals Notification and Assessment Scheme (NICNAS) recommends restrictions on how these substances can and cannot be used35. 31 https://www.epa.gov/sites/production/files/201902/documents/pfas_action_plan_021319_508compliant_1.pdf 32 https://armedservices.house.gov/_cache/files/f/5/f50b2a93-79aa-42a0-a1aad1c490011bae/3552B8ED0CB74FB28CC88F434EFB306A.fy20-ndaa-conference-summary-final.pdf 33 http://lawfilesext.leg.wa.gov/biennium/2017-18/Pdf/Bills/Senate%20Passed%20Legislature/6413S.PL.pdf?q=20200413062702 34 https://leginfo.legislature.ca.gov/faces/billCompareClient.xhtml?bill_id=201920200SB1044&showamends=false 35 https://www.oecd.org/chemicalsafety/portal-perfluorinated-chemicals/countryinformation/australia.htm 28 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS 1.3.4. Industry Measures 1.3.4.1. Substitution and phase-out As noted in several documents under the Stockholm Convention, for over a decade, a number of alternatives to the use of C8-based fluorosurfactants (containing PFAS) in firefighting foams have been developed and are now widely available. These include shorterchain (C6) fluoro-surfactants, as well as fluorine-free fire-fighting foams; and other developing fire-fighting foam technologies that avoid the use of fluorine. The use of C8-based AFFF has been largely phased out in favour of these alternatives. For example, it is reported that the volume of AFFF-containing PFOS used in the USA declined from around 21 million litres in 2004 to less than 9 million litres in 201136. The POPRC officially recognises that a transition to the use of short-chain per- and polyfluoroalkyl substances (PFAS) for dispersive applications such as fire-fighting foam is not a suitable option from an environmental and human health point of view and that some time may be needed for a transition to alternatives without PFAS (POPRC-14/3). In the USA, in 2006, the US EPA launched the PFOA Stewardship Program following concerns raised about the impact of PFOA and long-chain PFASs on human health and the environment, including concerns about their persistence and presence in the environment37. The programme involved eight major companies38 committing to reducing PFOA from facility emissions and product content by 95 percent no later than 2010, and to work toward eliminating PFOA from emissions and product content no later than 2015. All participating companies state in the most recent progress reports, that they met the PFOA Stewardship Program goals39. In Australia, it has been reported that the Department of Defence commenced phasing out its use of PFOS and PFOA-containing fire-fighting foams and switched to `Ansulite', which only contains trace elements of PFOS/PFOA and is only used in emergency situations or in controlled environments to test equipment. Furthermore, PFAS use is also limited by Air Services Australia, a government-owned corporation that provides air traffic control management, which has transitioned away from fluorinated firefighting foam to non-fluorinated firefighting foam including the destruction of remaining stockpiles40. 36 FFFC (2011) Estimated Inventory Of PFOS-based Aqueous Film Forming Foam (AFFF). 2011 update to the 2004 report entitled "Estimated Quantities of Aqueous Film Forming Foam (AFFF) In the United States". Prepared for the Fire Fighting Foam Coalition, Inc. 37 https://www.epa.gov/assessing-and-managing-chemicals-under-tsca/fact-sheet-20102015-pfoastewardship-program 38 Arkema, Asahi, BASF, Clariant, Daikin, 3M/Dyneon, DuPont, Solvay Solexis 39 https://www.epa.gov/assessing-and-managing-chemicals-under-tsca/20102015-pfoa-stewardship-program2014-annual-progress 40 https://www.oecd.org/chemicalsafety/portal-perfluorinated-chemicals/countryinformation/australia.htm 29 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS 1.3.4.2. Containment and control In Germany41, it is reported that the regulatory authorities and fire-fighting associations have compiled a leaflet on PFAS in fire-fighting, which has reportedly resulted in an increased awareness of the risks associated with certain PFASs by industry, NGOs and the public. In Norway42 it is reported that fluorine-containing fire-fighting foam has been substituted with fluorine-free alternatives in most civil airports and fluorine-containing foam is no longer in use at fire-fighting training sites with the Norwegian military forces. Furthermore, it is reported that PFAS are being gradually substituted with fluorine freealternatives in the offshore sector, and the volumes of fluorine-containing foam used in this sector are decreasing. One respondent to the consultation questionnaire conducted for this project reported that the Swedish Petroleum and Biofuels Institute has previously (2011) provided guidance on how to plan and implement the prevention of spillage and secondary containment embankments, methods for emergency response, and for the assessment and preventing product tanks to lift off inside water filled bunds/embankments. It was estimated that ~80 % of the member companies were in compliance with this guidance. The trade association, the Fire Fighting Foam Coalition (FFFC) has published a best practice guidance document for the safe use of firefighting foams for Class B fires43, with the aim to "foster use of foam in an environmentally responsible manner so as to minimize risk from its use". The guidance covers the following aspects of Class B firefighting foam use: Foam Selection - specifying situations where the use of Class B foams is, and is not, recommended, e.g. limiting the use of Class B foams to situations that present `a significant flammable liquid hazard'. Eliminating Foam Discharge - noting that this is not always possible in emergency situations, but emphasising the possibility to achieve this in training and the testing of foam systems and equipment. Training - providing guidance on the formulation of training foams, the design, construction and operation of training facilities. Foam System Testing - including guidance on acceptance tests, conducted pursuant to installation of the system; and maintenance tests (i.e. of firefighting vehicles). Containing Foam Discharge - guidance to prevent discharge to the environment, both for manual and fixed systems. 41 https://www.oecd.org/chemicalsafety/portal-perfluorinated-chemicals/countryinformation/germany.htm 42 https://www.oecd.org/chemicalsafety/portal-perfluorinated-chemicals/countryinformation/norway.htm 43 Covering aqueous film-forming foam (AFFF), alcohol resistant aqueous filmforming foam (AR-AFFF), filmforming fluoroprotein foam (FFFP), alcohol resistant film-forming fluoroprotein foam (AR-FFFP), and fluoroprotein foam (FP, FPAR). 30 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Firewater and foam concentrate disposal - with an emphasis on incineration but also covering coagulation, flocculation, electro-flocculation, reverse osmosis, and adsorption on granular activated carbon (GAC). Similarly, the Fire Protection Association Australia has published a guidance document on the selection and use of firefighting foams44. This covers, for example, Factors impacting on selection and use - including firefighting performance, environmental impact, system and equipment compatibility Environmental and firefighting performance indicators Fluorinated and fluorine-free firefighting foams Environmental best practice - including training and system testing and commissioning, fire water effluent, remediation of contaminated soil and water, cleaning/change out of existing foams The consultation did not yield information on the extent to which these best practice measures outlined by the likes of the FFFC and FPAA are being implemented, or their effectiveness. 2. Impact assessment 2.1. Introduction This impact assessment is based primarily on a socio-economic analysis and preregulatory management option analysis (pre-RMOA) on a potential restriction (ban) on the placing on the market (and the use) of PFAS-based fire-fighting foams in the EU. No specific temporal scope has been defined and the impacts relating to the manufacture, use and waste stage of fire-fighting foams, as well as resulting contamination. The scope and focus of the analysis was discussed and agreed with the steering group of the underlying study45 during regular project meetings. 2.2. Risk Management Options Two main regulatory management options (RMOs) have been assesed: 1) Restriction (ban) on the placing on the market of PFAS-based fire-fighting foams (hereafter referred to as Scenario 1). The use of legacy foams, i.e. foams already in stock at producers' or users' sites, is still permitted. 2) Restriction (ban) on the placing on the market and the use of PFAS-based firefighting foams (hereafter referred to as Scenario 2). The legacy foams, i.e. foams already in stock at producers' or users' sites, should be disposed of safely. 44 FPA Australia (2017) 45 Wood, Ramboll, COWI: "The use of PFAS and fluorine-free alternatives in fire-fighting foams Final report". Report for the European Commission DG Environment and European Chemicals Agency (ECHA) under specific contracts No 07.0203/2018/791749/ENV.B.2 and ECHA/2018/561. 31 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS 2.3. Restriction scenario(s) The two figures below summarise the main effects (i.e. anticipated responses from the supply chains along with associated impacts) resulting from the two restriction scenarios. These are identified based on literature review, the targeted stakeholder consultation, and discussions with the steering group. The large text in the solid green boxes summarises each effect in a brief headline, the smaller hollow boxes provide some additional commentary. The numbered boxes at the end of each chain represent the ultimate impacts to be assessed. These ultimate impacts are discussed one by one in Annex E, Section E.4. 32 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Figure 2.1 Map summarising potential effects of a restriction on the placing on the market of PFAS-based fire-fighting foams Restriction on placing on the market Cleaning of a equipment Costs and remaining contamination Use of alternatives As stocks are depleted b Other options e.g. eliminating the need for firefighting foams if possible Technical performance Implications of performance of alternatives, equipment changes Economic e feasibility Price differences, cost for new products Emissions Comparative emissions of PFAS and alternatives h Availability Supply /demand balance i Other impacts E.g. trade, employment c Fire safety Economic/HSE impacts of any reduced effectiveness d Use patterns To achieve comparable / acceptable performance Environmental / f health impacts Relative impacts: PFAS vs alternatives Remediation and g cleanup Relative costs: PFAS vs alternatives PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Figure 2.2 Map summarising potential effects of a restriction on the use of PFAS-based fire-fighting foams Restriction on the use Disposal of legacy foams Including 'safe' treatment, e.g. incineration Cleaning of equipment (as discussed above) Use of alternatives (as discussed above) Environmental / j health impacts E.g. emissions from disposal Technical feasibility k / availability Capacity shortages of disposal facilities (e.g. incinerators) Economic feasibility l Cost of disposal 34 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS 2.4. Economic impacts Both scenarios require purchasing of alternative foams which is estimated to incur additional costs (compared to the baseline) of around 27m per year in the EU. In Scenario 2, these costs would be incurred immediately when the restriction comes into force (or before), whereas in Scenario 1 the costs increase gradually and only reach 27m per year once all stocks are depleted. This would be partly off-set by savings, e.g. from lower disposal cost of fluorine-free foams when they reach their expiry date. However, Scenario 2 would also require existing stocks of PFAS-based foams (estimated 210,000-435,000 tonnes) to be written off (considering depreciation since their purchase), and new stocks would have to be purchased, subject to replacement costs (minus the value of existing stocks already depreciated) estimated at around 1.0 billion (range -60 million46 to 8.3 billion). In Scenario 2, additional costs would also be incurred for the disposal of the existing stocks of PFAS-based foams. Total EU costs (one-off) are estimated at up to 320 million (range up to 60m-4.8bn) depending on the method used and the share of foams that would have reached expiry date without use (whose disposal is merely brought forward by the restriction, but costs are not additional to the baseline). There is a trade-off between the disposal costs and the mitigation of potential environmental risks from disposal (as discussed above). Additional transport, storage and labour costs have not been quantified. There are other potential economic costs for transitioning that are difficult to quantify, of which cleaning/replacement of equipment before switching the foam are likely the most important. These costs could be significant (e.g. cleaning could potentially be in the order of 1 billion, depending on the residual concentration limit and number of installations affected). They are not likely to vary significantly across the two options but could be more spread over time under Scenario 1. Alternatives are generally considered to be technically feasible in most applications (see Annex E.2). Further testing is required to confirm the technical feasibility of alternatives for specific applications, particularly large atmospheric storage tanks. The speed of fire suppression may be slower and application of foams may be less flexible and less easy to use (e.g. different foams may be needed for different flammable liquids), in some cases. This may have further economic impacts that have not been quantified. In Scenario 1 some of these risks would be mitigated for as long as stocks of PFAS-based foams in existing systems are being used for the cases in question. There are potentially significant benefits in terms of reduced clean-up / remediation costs. As a very high level estimate for illustration, the potential order of magnitude of avoided remediation could be hundreds of millions or Euros (assuming tens of sites requiring remediation at tens of millions of Euro per site) to billions of Euros (assuming hundreds of sites requiring remediation at tens of millions of Euro per site). More information on the total number of sites, real-world use of PFAS per site as well as implementation and effectiveness of best practices in terms of containment and immediate clean-up would be required to assess to which extent remediation is likely to be required in the future as a 46 I.e. a potential saving of 60 million, if fluorine-free alternatives are less expensive than the PFASbased foams they replace (possible in some cases but unlikely on average) and no additional volumes are required. 35 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS result of current use of PFAS-based fire-fighting foams (and could therefore be avoided because of the restriction). Any such benefits would be higher in Scenario 2, given the quicker elimination of PFAS emissions and higher reductions of accumulated PFAS contamination. Treatment of fire-water run-off and short-term clean-up after the use of fire-fighting foams is largely driven by other components of the fire-water run-off, rather than the foam used. At least in some cases, run-off treatment costs could be around 0.7 per litre (range ca 011) or up to tens of millions of Euro per incident cheaper when fluorine-free foams are used, but data on the total amount of fire-water run-off treated was lacking to quantify an EU total (see Annex E.4.1.g. for a more detailed discussion). In cases where fire-water runoff is not contained and further clean-up is possible, clean-up costs may also be lower for fluorine-free foams due to their lower persistance. No specific data was available to quantify this saving, but for illustration the potential order of magnitude of savings be could be several million Euros (assuming several tens of incidents per year using PFAS-based foams where clean-up is required and which could be avoided if fluorine-free foams were used). Again, any such benefits would be higher in Scenario 2, given the quicker elimination of PFAS emissions and higher reductions of accumulated PFAS contamination. It is considered unlikely that either scenario will cause any significant macroeconomic impacts (e.g. employment, trade). 2.5. Human health and environmental impacts Both scenarios will eventually lead to an elimination of the use and therefore the emissions of PFAS-containing fire-fighting foams. Therefore, they can both be considered effective in addressing the identified concern and eliminating any further human health and environmental impacts of PFAS exposure related to the use of fire-fighting foams (noting that impacts of exposure related to legacy emissions may continue for a long time, considering the persistence of PFAS). The reduction of emissions would be achieved more quickly in Scenario 2 and therefore Scenario 2 would also achieve a higher reduction of accumulative PFAS contamination. The shelf life of PFAS-based foams is reported to be typically between 10 and 20 years (to a maximum of 30 years)47, so in Scenario 1 some (decreasing) emissions of PFAS-based foam could continue for a long period after the entry into force of the restriction. Based on the annual sales and average lifetime of fire-fighting foams, it is estimated that the stocks of PFAS-based fire-fighting foams in existing systems may be between 210,000 and 435,000 tonnes (see Annex A). However, it is uncertain what share of foams in existing systems would be used (and hence to some extent emitted) and what share would be replaced at the end of their shelf life or replaced voluntarily (and hence disposed of safely). It should be noted that in Scenario 2, there are potential risks of emissions from the incineration of legacy foams, but further research is needed to identify and quantify the emissions produced from the incineration of PFAS. 47 Proposal for a restriction: Perfluorohexane sulfonic acid (PFHxS), its salts and PFHxS-related substances https://echa.europa.eu/documents/10162/a22da803-0749-81d8-bc6d-ef551fc24e19 36 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS As mentioned above, the analysis of alternatives (see Annex E.2) has concluded that alternatives are generally considered to be technically feasible in most applications. Further testing is required to confirm the technical feasibility of alternatives for specific applications, particularly large atmospheric storage tanks. The speed of fire suppression may be slower and application of foams may be less flexible and less easy to use (e.g. different foams may be needed for different flammable liquids), in some cases. If not properly managed, these risks could have human health impacts that have not been quantified. In Scenario 1 some of these risks would be mitigated for as long as stocks of PFAS in existing systems are being used for the cases in question. 2.6. Other impacts, practicability and monitorability In principle, both options appear practical and monitorable, as there are already other regulations in place controlling the placing on the market and use of fire-fighting foams. However, as Scenario 2 covers the use in addition to the placing on the market (which is also covered under Scenario 1), it is subject to more complex requirements in terms of implementation, enforcement, management and monitoring, compared to Scenario 1. One stakeholder pointed out the following practicality issue for Scenario 1. When large amounts of foam are used for an incident, foam tanks need to be quickly refilled to allow continued operation, sometimes even during the same incident. However, it is not recommended to mix different foams in the same system (because this could affect performance and the new foam would be contaminated with PFAS from the old foam), so refilling during an incident would not be feasible if PFAS-foam was used in existing systems. This could potentially lead to end-users building up stocks of PFAS-based foams before the restrictions comes into place, or it could potentially lead to users not replacing foams in existing systems to save costs causing problems during a large incident when a refill during the incident would be needed. 2.7. Proportionality (including comparison of options) The key consideration in judging and comparing the appropriateness of the two RMOs is the balance between their effectiveness (i.e. the reduction of PFAS emissions) and their socioeconomic impacts (primarily the costs of transitioning to fluorine-free foams and potentially fire-safety risks from using alternatives, off-set partly by benefits of reduced clean-up / remediation). As the environmental/health benefits of reduced PFAS emissions (and indeed some of the socio-economic impacts) could not be quantified, it is not possible to use costbenefit analysis to directly assess if the proposed intervention is proportionate. ECHA's approach to the "Evaluation of restriction reports and applications for authorisation for PBT and vPvB substances in SEAC"48 uses the cost per unit (e.g. kilogram) of emission reduced. Based on the quantifiable socio-economic impacts, as a central estimate, it was calculated that the cost effectiveness could be around 850 (Scenario 1) to 1,700 (Scenario 2) per kg of annual reduction of PFAS emissions. However, this could range from savings in the 10s 48 https://echa.europa.eu/documents/10162/13580/evaluation_pbt_vpvb_substances_seac_en.pdf/af4a7207-f7ad4ef3-ac68-685f70ab2db3 37 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS per kg to costs around 10,000 per kg49. The full calculations are presented in Annex E, Section E.5. Therefore, the approach adopted in the following is to identify the uses/applications and conditions (transition periods, concentration thresholds, other risk management measures) that would achieve relatively high levels of effectiveness (i.e. reductions of PFAS emissions) with relatively small adverse socio-economic impacts. 2.7.1. Comparison of different users The various user sectors and applications of fire-fighting foams vary significantly in terms of the potential for a restriction to reduce PFAS emissions to the environment (`PFAS risk reduction potential'), the feasibility of transitioning to fluorine-free alternatives (`substitution potential') and the resulting potential socio-economic impacts of that transition. Therefore, it may be appropriate for regulatory management to set different conditions for the different sectors and applications, in order to balance the effectiveness of the measure with considerations around feasibility of alternatives and socio-economic impacts. A table summarising and comparing substitution potential, socio-economic impacts and risk profile across the main identified user sectors is provided in Annex E.8.1. The comparison in the table suggests that training and testing should be the highest priority for a quick transition to fluorine-free foams, because the use of alternatives is well established and already recommended as industry best practice. Training accounts for the majority of fire-fighting foam use (although likely not for the majority of emissions) and the potential for adverse socio-economic impacts is very low for training and testing. Chemical / petrochemical are the largest user sector meaning that the costs of transitioning but also the current risk of PFAS emissions are higher. However, derogations with a longer transition period may be needed for specific applications (notably large tank fires) where further testing is required to determine the technical feasibility of alternatives and potential fire-safety risks from using alternatives are high. In these specific cases the socio-economic implications could outweigh the potential benefits in terms of PFAS emissions until more suitable alternatives have been developed and tested. Note that further testing on the feasibility of alternatives is planned by LASTFIRE50 between April and July 2020 (although this may well be postponed due to the COVID-19 pandemic). A quick transition in marine applications should be a high priority due to its low potential for retention of run-off and clean-up after incidents, and established alternatives (e.g. two of 49 The wide variance of the range is primarily due to the significant uncertainty associated with the quantification of some costs and benefits. For instance, a saving could be achieved if the benefits in terms of reduced costs for remediation, clean-up and fire-water-run-off treatment are at the higher end of their estimated ranges and the costs in terms of disposal of stocks, cleaning of equipment, replacement of foam stocks are at the lower end of their estimated ranges, and vice-versa for the highest possible emission reduction costs per kg. 50 A project by the oil and petrochemical industries to assess fire hazards of Large Atmospheric Storage Tanks (see www.lastfire.co.uk). 38 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS the alternatives shortlisted in the analysis of alternatives were reported to be used in the marine sector). Municipal fire services and ready to use applications should also be priorities for a quick transition because alternatives are well-established and these sectors may involve fire incidents outside of specific industrial sites where there is a risk that retention of run-off and clean-up after incidents are more difficult. Alternatives are less well established in the military sector, but they are considered by stakeholders to be feasible, have been adopted by the Danish and Norwegian armed forces51, and the applications are similar to those of other similar sectors (with similar activities such as aerospace), where substitution has taken place. Transition is probably possible but requires extra care because if the use of alternative caused any fire-safety risks, the potential damages could be significant and could include danger to human life. Also in civil aviation there is the concern that if the use of alternative caused any fire-safety risks, the potential damages could be significant and would likely include danger to human life. However, alternatives are considered feasible and have successfully been implemented by many users (e.g. the airports of Dubai, Dortmund, Stuttgart, London Heathrow, Manchester, Copenhagen, Australia and Auckland), so this is considered unlikely and a relatively quick transition should be sought, as has been achieved elsewhere. 2.7.2. Transition periods Based on input from a range of stakeholders (see Annex E.8.2), different transition periods have been considered appropriate for different uses. Successful transition to fluorine-free foams for training and testing has been reported by stakeholders across sectors and is already recommended as industry best practice. Therefore, a transition period may not be required for training and testing. In terms of the use for real fire incidents, oil and gas / petrochemicals are the only sector where users have suggested a longer transition period of up to 10 years is required, to conduct further testing of the feasibility of alternatives for large atmospheric storage tanks (LAST), among other things. This is broadly consistent with the reported duration of the transition by Norwegian oil and gas company Equinor (see case study 2 in Annex E, Section E.2.), which took about 8 years from development and testing to full operation of fluorine-free alternatives. Oil and gas / petrochemicals is the largest user sector, so in order to ensure effectiveness of the regulation in reducing PFAS-emissions, the transition period should be limited to the most sensitive applications within this sector, particularly large incidents and LAST. For small incidents as well as all other sectors (e.g. Marine Applications, Military, Civil Aviation, Municipal Fire Services, Ready to use applications), shorter transition periods between 3-6 years have been suggested and are expected to minimise socio-economic implications of the restriction. 51 According to the IPEN publication on "Fluorine-free firefighting foams (3F) viable alternatives to fluorinated aqueous film-forming foams (AFFF)". 39 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS 2.7.3. Concentration thresholds There are two main considerations to choose appropriate thresholds for remaining PFAScontamination in fire-fighting foams: The costs of cleaning and replacement of equipment which are strongly dependent on the concentration threshold chosen, and detection limits. Costs of cleaning and achievable/detectable concentrations are discussed in more detail in Annex E (Section E.4, sub-section a. Cleaning of equipment), but key messages are summarised below. There was a wide divergence in opinion on appropriate concentration thresholds ranging from 1 ppb to 50,000 ppb (stakeholder input is provided in Annex E.8.3). The available information suggests that 100 ppb can be achieved with a relatively simple cleaning process (cost likely low but not quantified) while 1 ppb is achievable with more complex and costly processes (in the order of 12,300 per appliance according to one estimate). Given this is based on a very small number of estimates, it appears advisable to seek further input on the costs of achieving a specific concentration in any consultation as part of a potential future restriction proposal. Furthermore, a balance would need to be struck between the amount of PFAS emissions remaining if a given threshold is adopted, versus the costs of cleaning imposed in order to achieve that threshold. For example, if the concentration of PFAS in fluids in use is currently perhaps 0.5% (5 million ppb), a threshold of 100 ppb would represent a reduction in concentration (and hence emissions) of 99.998%, while a threshold of 50,000 ppb would represent a reduction in concentration and emissions of 99.0%. 2.7.4. Other risk management targeted at reducing release Industry best practice guidance (e.g. from the Fire Fighting Foam Coalition52) and regulations or guidelines in some EU Member States (e.g. England and Wales53, Bavaria54) already recommend or impose a range of measures to reduce the risk to the environment from the use of fire-fighting foams (see Section 1.3). These cover for instance containment, treatment, and proper disposal of foams and fire water run-off. However, it is not clear to what extent these practices are being implemented or what their relative effectiveness is. Stakeholder input to the consultation has also highlighted the importance of such measures to reduce emissions of PFAS-based foams, with recommendations made to legally impose retention systems, proof of proper disposal of any contaminated water/liquid, and use of appropriate PPE and cleaning procedures for after-use treatment. At the workshop, a stakeholder also suggested supporting the transition with mandatory fire management plans for every site, which would include a description of the procedure and reasons for the procurement of the specific fire-fighting foams, their storage, use, recovery, 52 https://www.fffc.org/ 53Environmental Protection Handbook for the Fire and Rescue Service, https://www.ukfrs.com/sites/default/files/201709/Environment%20Agency%20and%20DCLG%20environmental%20handbook.pdf 54 https://www.oecd.org/chemicalsafety/portal-perfluorinated-chemicals/countryinformation/germany.htm 40 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS containment and treatment. They also proposed setting up centrally managed stocks at specific, well-contained sites in large industrial areas that could be made available to potential users in case of emergencies, in order to control and restrict the use of PFASbased foams to only the necessary applications during the transition period. This suggestion could help reduce the risk to the environment while allowing a potentially longer period to transition to alternatives, particularly for large industrial sites. In conclusion, it is advisable to further investigate a potential obligation to apply best practice emission reduction measures during and after the use of PFAS-based fire-fighting foam, particularly during the transition periods when PFAS-based foams continue to be used in certain applications and if the use of existing foams is not restricted (Scenario 1). 3. Assumptions, uncertainties and sensitivities See Annex F. 4. Conclusion Section 1.1.1.7 discussed the need for further regulatory management of the concerns associated with the use of PFAS in fire-fighting foams, based on the following: Significant hazards have been shown at least for some PFAS, including some short-chain PFAS (not precluding any ongoing work or conclusions by the PFAS working group which were not available for this report). Many PFAS are highly mobile, highly persistent, and have the potential to accumulate within the environment and living organisms. The continued use of PFAS-based fire-fighting foams and resulting releases to the environment. A lack of existing regulation, and of implementation or proven effectiveness of other risk management measures to address the release of PFAS from the use of PFAS-based fire-fighting foams. It was agreed in discussions with the steering group to focus on assessing potential designs of a restriction, rather than comparing a restriction with alternative types of measures. However, a restriction appears to be an appropriate option because: Alternatives are considered feasible for most applications (all except large atmospheric storage tanks), so that PFAS emissions can be eliminated by using fluorine-free products; Other risk management measures that could reduce release of PFAS to the environment are available and are to some extent already being applied; however, these appear unlikely to eliminate the emissions of PFAS from the use of fire-fighting foams as effectively. It appears advisable to address the concern at EU-level, because there is no indication that Member State measures will be forthcoming, and any potential discrepancies in nationallevel management could have implications for the degree to which the environment is protected and for the functioning of the internal market for fire-fighting foam products. Furthermore, due to their high mobility and persistence as well as their ubiquity (at least of some PFAS), it appears very likely that PFAS emissions could lead to cross-border pollution. 41 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Section 2 assessed the potential conditions of a restriction, in terms of whether it would ban only the placing on the market of PFAS-based fire-fighting foams, or both the placing on the market and the use of those foams. Potential variations across different user sectors, transition periods, concentration thresholds, and potential combination with other risk management measures are also relevant. Two main options have been considered: A ban on the placing on the market would allow continued use of existing stocks of PFAS-based fire-fighting foams, which have been estimated at between 210,000 and 435,000 tonnes. PFAS emissions related to their use could continue, and this may last for some 10-30 years after the entry into force of the restriction, based on the shelf-life of fire-fighting foams. When stocks are depleted, users would need to buy alternative foams incurring additional costs (compared to the baseline) of around 27m per year in the EU due to potentially higher volumes of alternative foams needed to achieve the desired performance. Before that, installations would need to be cleaned or replaced at potentially significant one-off cost (cleaning could potentially be in the order of up to 1 billion). This would be at least partly off-set by savings, e.g. from lower disposal cost of fire-water run-off (total difficult to quantify) and fluorine-free foams when they reach their expiry date (potentially 100,000s to millions per year), and from reduced clean-up (potentially up to 10s of millions) / remediation costs (potentially up to billions over a long time span). However, more information on the total number of sites, real-world use of PFAS per site as well as implementation and effectiveness of best practices in terms of containment and immediate clean-up would be required to assess the extent to which remediation and clean-up could be avoided by using fluorine-free firefighting foams. More details on uncertainties, ranges and other potential impacts are presented in Annex F. A ban on the placing on the market and the use of PFAS-based fire-fighting foams would immediately stop the emissions from the use of PFAS-based firefighting foams. This increased effectiveness needs to be weighed against the additional socio-economic implications. The existing stocks of PFAS-based firefighting foams would need to be disposed of (incineration costs estimated at 320 million) and new stocks would need be purchased (subject to replacement costs minus the value of existing stocks already depreciated estimated at around 1 billion). Furthermore, roll-out by suppliers and training/familiarisation would need to be done in a much more compressed timescale, but any potential savings from using alternatives (as discussed above) would also be incurred more quickly. It should be noted that these estimates are associated with significant uncertainties and ranges have been estimated. There are other potential economic costs and benefits that could not be quantified. Adjusting the potential restriction to minimise this is discussed further below. Although alternatives are generally considered to be technically feasible in most applications (further testing is required for large atmospheric storage tanks), there are also potential implications of the performance of alternatives in some cases, including slower fire suppression, and foams being less flexible and less easy to use. These have not been quantified. It should be noted that there was divergence in the stakeholder input about technical feasibility of alternatives. A few stakeholders have voiced concerns over the potentially reduced fire safety, at least in specific applications, and the associated risk of additional health, safety and economic (fire damage) impacts. However our analysis has concluded that they are not the most likely outcome and that large atmospheric storage tanks are the main application for which there is still further testing required. In order to maximise effectiveness while minimising potential adverse socio-economic impacts of a restriction, it appears appropriate to vary the specific conditions (particularly 42 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS transition periods) by application and user sectors, because of their significant divergence in terms of the likelihood of emissions and implications of switching to alternative foams: Training and testing should be the highest priority for a quick transition to fluorine-free foams, because the use of alternatives is well established and already recommended as industry best practice. Training accounts for the majority of fire-fighting foam use (although likely not for the majority of PFAS emissions) and the potential for adverse socio-economic impacts is very low for training and testing. Chemicals / petrochemicals is the largest user sector meaning that the costs of transitioning but also the current risk of PFAS emissions are higher in total (although not necessarily higher per company, per turnover, etc.). However, derogations with a longer transition period may be needed for specific applications (notably large tank fires) where further testing is required to determine the technical feasibility of alternatives and potential fire-safety risks from using alternatives are high. Users have suggested a longer transition period of up to 10 years is required. This is the largest user sector, so in order to ensure effectiveness of the regulation in reducing PFAS-emissions, it seems appropriate that any longer transition period should be limited to the most sensitive applications within this sector, particularly large incidents and large atmospheric storage tanks. Further consideration of this would be needed in the (public) consultation on any restriction proposal. For small incidents as well as all other sectors, shorter transition periods between 3-6 years have been suggested and are expected to minimise socioeconomic implications of a restriction. Of these, in particular marine applications, municipal fire services and ready to use applications should be priorities for a quick transition. In marine applications the potential for retention of run-off and clean-up after incidents is particularly low, and alternatives are established. For municipal and ready to use applications, alternatives are well-established and these sectors may involve fire incidents outside of specific industrial sites where there is a risk that retention of run-off and clean-up after incidents are more difficult. In civil aviation a relatively quick transition could be sought as well, because alternatives are considered feasible and have successfully been implemented by many users55. However the potential for retention of run-off and clean-up is relatively high, while there is the concern that, if the use of alternatives caused any increased fire-safety risks, the potential damages could be significant and would likely include danger to human life. Alternatives are less well established in the military sector, but they are considered by stakeholders to be feasible. Transition is probably possible but requires extra care because, if the use of alternatives caused any increased firesafety risks, the potential damages could be significant and could include danger to human life. A relatively long transition period may be needed to allow for sufficient time for alternative products to gain the necessary certifications. Regarding concentration thresholds, a balance would need to be struck between the amount of PFAS emissions remaining if a given threshold is adopted, versus the costs of cleaning imposed in order to achieve that threshold. Stakeholder input suggests that 100 55 No data on the exact number or market share was not available, but a list of examples that are mentioned in the literature/by stakeholders is provided in Section 2.7.1 above. 43 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS ppb can be achieved with a relatively simple cleaning process (cost likely low but not quantified). Lower thresholds are achievable with more complex and costly processes. For instance, achieving 1 ppb could cost around 12,300 per appliance according to one estimate, which could imply EU total costs in the order of 1 billion. However, setting a lower concentration threshold would lead to a relatively small additional reduction in PFAS emissions, compared to the overall reduction achieved by the restriction. The average concentration of PFAS in PFAS-based fire-fighting foams is some 2-3%, mixed with water before application it is in the order of 0.5% (or 5 million ppb). This means a reduction from 5 million ppb to 100 ppb would cover 99.998% of the initial emissions. A further reduction to 1 ppb would cover 99.99998% of the initial emissions (an additional 0.00198%). Lastly, it is advisable to further investigate a potential obligation to apply best practice emission reduction measures during and after the use of PFAS-based fire-fighting foam. These cover for instance containment, treatment, and proper disposal of foams and fire water run-off. Particularly during the transition periods when PFAS-based foams continue to be used in certain applications, and if the use of existing foams is not restricted, these measures could provide relatively effective reduction of PFAS-emissions at relatively low cost. 44 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Annex A: Manufacture and uses A.1. Manufacture, import and export This study has focused on the use of PFAS in fire-fighting foams. The available data on the use of PFAS in fire-fighting foams and the sales and uses of these foams in the EU are described in detail in the following section. In personal communication, Eurofeu indicated that the manufacture of PFAS-based fire-fighting foams in the EU is similar to the sales. Hence, the quantity of PFAS-based fire-fighting foams manufactured in the EU is expected to be in a similar order of magnitude as the sales presented below (14,000-20,000 tonnes per year), while import and export are expected to be relatively small. A.2. Uses A.2.1. Introduction The main aim of this Section is to estimate the tonnages of fluorine-based and fluorine-free fire-fighting foams manufactured and placed on the market in the EU. The different functions (e.g. film-forming, surfactants, solvents) provided by different components of firefighting foams and the type of fires for which their use is recommended is also discussed. In addition, an overview of market data (and functions provided) for fluorine-free alternatives is also given, to support the analysis of alternatives and socio-economic impacts. A.2.2. Tonnages of fluorosurfactants used in fire-fighting foams production According to data provided by Eurofeu, five foam manufacturers representing approximately 60-70% of the EU market purchase approximately 335 tonnes of fluorosurfactants per annum in the EU (data collected in 2018). These data include 7 specific known fluorocompounds and 3 unknown fluoro-compounds (see Table A.1). They are used to produce fire-fighting foam concentrates or liquid ready-for-use agents (pre-fill for fixed firefighting systems and/or portable extinguishers). According to the same Eurofeu data, the concentration of the fluoro-compound in the fire-fighting foam concentrates range between 0.1% and 45% (no average value was given). It should be noted that the identity of the substances with the largest tonnages was not specified in these data as the data were confidential. Based on the approximate share of the market reflected in these data, it is estimated that the total tonnage of fluorosurfactants used in fire-fighting foams in the EU is approximately 480-560 tonnes per year56. This is consistent with the total tonnage of PFAS-based fire-fighting foams estimated further below, and an average concentration of fluorosurfactants in the foams of around 2-3% (as suggested by various stakeholder responses to the consultation). 56 According to Eurofeu, the data is expected to cover 60-70% of the EU market. The total market has been estimated by dividing 335 tonnes by 70% (lower end of range) and by 60% (upper end of range), respectively. 45 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Table A.1 Tonnage of fluorosurfactants purchased for the production of fire-fighting foams by manufacturers participating in the 2018 Eurofeu survey Fluoro-compound CAS number Tonnes per year Share of the total market 1-Propanaminium,N- 34455-29-3 21.1 6% (carboxymethyl)-N,N-dimethyl-3- [[(3,3,4,4,5,5,6,6,7,7,8,8,8- tridecafluorooctyl)sulfonyl]amino]- ,inner salt 1-Propanaminium, 3-amino-N- 80475-32-7 17.2 5% (carboxymethyl)-N,N-dimethyl-N- [[(gamma-omega-perfluoro-C6-C16- alkyl)thio]acetyl] derives., inner salts 2-methyl-2 - [(1-oxo-3 [(3,3,4,4,5,5,6,6,7,7,8,8,8tridecafluorooctyl) thio] propyl) amino] -1-propanesulfonic acid, sodium salt 62880-93-7 0.5 <1% 2-hydroxy-N,N,N-trimethyl-3[(3,3,4,4,5,5,6,6,7,7,8,8,8tridecafluorooctyl)thio]-1Propanaminium, chloride (1:1) 88992-45-4 0.2 <1% 2-Propenamide, telomer with 4- unknown 0.2 [(3,3,4,4,5,5,6,6,7,7,8,8,8- tridecafluorooctyl)thio]-1- butanethiol ) <1% 2-Propenoic acid, telomer with 2- unknown 0.3 propenamide and 4- [(3,3,4,4,5,5,6,6,7,7,8,8,8- tridecafluorooctyl)thio]-1- butanethiol, sodium salt <1% 2-Propenamide, telomer with 3,3,4,4,5,5,6,6,7,7,8,8,8tridecafluoro-1-octanethiol 76830-12-1 0.9 <1% unknown C-6 fluorinated substances unknown 17.1 5% unknown 1 unknown 138.6 41% unknown 2 unknown 138.6 41% Total (2018 Eurofeu survey) 335 Total EU market (extrapolated) 480-560 [1] Source: Wood 2019 based on data provided to the authors by Eurofeu. Notes: Substances marked as unknown have not been revealed by the individual manufacturers to preserve commercially sensitive information. [1] According to Eurofeu, the data is expected to cover 60-70% of the EU market. The total market has been estimated by dividing 335 tonnes by 70% (lower end of range) and by 60% (upper end of range), respectively. Results were rounded to two significant figures. 46 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS A.2.3. PFAS-based fire-fighting foams A.2.3.1. Sales of fire-fighting foams by user sector Eurofeu also provided figures on the yearly sales of PFAS-based fire-fighting foams to various user sectors in Europe, based on a 3-year average (2016-2018). Six Eurofeu member companies57 have provided data. In total, they sell 13,669 tonnes of PFAS-based fire-fighting foams per year. Of these, an estimated 8,200 are employed in fixed systems and 5,500 in mobile systems58. The split by sector is detailed in Figure A.1 below. This shows that chemical/petrochemical is by far the largest user sector (59%), but municipal fire brigades, marine applications, airports and military applications also account for significant volumes59. Ready-for-use products only account for a very small share of PFASbased foams according to this data. The majority of this category are fire extinguishers although not all foam fire extinguishers use ready-for-use foams, according to personal communications with Eurofeu). However, some stakeholders have suggested that the number of fire extinguishers using PFAS-based foams could be significant. An estimate is provided in the following sub-section. 57 Dr. STHAMER Hamburg, Auxquimia (Perimeter Solutions), Solberg Scandinavia, Dafo Fomtec, Orchidee, Johnson Controls (aka Tyco) 58 The number of companies that provided a response on whether the foams are used in fixed or mobile systems is lower than those that provided a response for the sectoral overview, therefore in the original data the total tonnage of the former is lower than the latter. To fill this gap, the tonnages for both fixed and mobile systems have been inflated so that their total matches the total in the sectoral split. The original values were 5.010 tonnes for fixed systems and 3,350 tonnes for mobile systems (total 8,360 tonnes). 59 According to personal communication with Eurofeu, there is some uncertainty in the data available to foam manufacturers about the precise distinction between user sectors. This is because although certain products may be marketed primarily for a specific user sector, it is not always known to whom the products are ultimately sold through traders and vending companies, and what they ultimately use it for (particularly for large users active across several sectors). Generally "chemical/petrochemical" is expected to include offshore oil and gas platforms (in addition to refineries and other facilities storing, processing or transporting flammable liquids), while "marine applications" refers to the shipping industry. However, due to the above uncertainty some of the tonnage for marine applications may also reflect use in offshore oil and gas platforms. 47 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Figure A.1 Split of PFAS-based fire-fighting foams by sector Ai rports 9% Mi l i tary 6% Ready for use products 1% Ma ri ne a pplications 12% Muni cipal fire bri ga des 13% Chemi cal/ p e tro ch emical 59% Source: Wood 2019 based on data provided to the authors by Eurofeu. Eurofeu estimate that the data they provided based on an internal survey covers roughly 70% of the EU market. It is therefore estimated that the total annual EU use of PFAS-based fire-fighting foams could be in the order of 20 thousand tonnes60. A.2.3.2. Additional estimate of use in fire extinguishers Three different sources for the number of fire extinguishers using PFAS-based fire-fighting foam in in the EU were identified: 1. Eurofeu provided the European Commission with a position paper which estimates that there are approximately 76 million fire extinguishers in the EU, approximately 15 million of which use PFAS-based fire-fighting agents. 2. Through individual communication with TSF (a German consultancy specialised in firefighting services), it has been estimated61 that, in the whole of the EU, between 60 Calculated as 13,669 tonnes divided by 70% and rounded to the closest thousand tonne. 61 The values have been extrapolated from data from bvfa - Bundesverband Technischer Brandschutz e. V. (German Federal Association of Technical Fire Protection) for fire extinguisher sold in Germany in 2016 as follows. Tonnages of major additional fire extinguisher manufacturers that are not part of bvfa have been added to the bvfa data by TSF. This yields the estimate that approximately 2,2 million fire extinguishers are sold every year in Germany, with an average lifetime of 20-25 years, which suggests that roughly 50 million units are currently present in Germany. Dividing this figure by the German population (82 million), a value of 0.6 fire extinguishers per capita is obtained. This value is then multiplied by the population of each country to estimate the number of fire extinguishers in each of them (population Netherlands: 17 m, population France: 67 m, population Belgium: 11,5 m, population United Kingdom: 60 m, population Ireland: 5 m, population Austria: 9 m, population Switzerland: 8,5 m, population rest of Europe: 500 m). Finally, the value obtained is multiplied by the share of PFAS foam-based fire extinguishers on the total of fire extinguishers in each country as estimated by TSF (Germany: 35%, Netherlands: 55%, France: 55%, Belgium: 45%, United Kingdom: 25%, Ireland: 25%, Austria: 45%, Switzerland: 45%, rest of Europe: 10%). This yields the following number of fire extinguishers using PFASbased foam per country: Germany: 17 million units; Netherlands: 6 million units; France: 22 million units; 48 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS about 60 million and 90 million fire extinguishers using PFAS-based foam currently exist, but note that this is a high-level estimate based on extrapolation from German data and expert judgement, so the Eurofeu estimate is likely more accurate. 3. The REACH restriction proposal for PFHxA62 states based on personal communication with one stakeholder and on data from the German Federal Association for Technical Fire Safety (bvfa), that in Germany roughly 600 000 hand held fire extinguishers containing AFFF are placed on the market per year, so it is possible that in Germany 6 - 12 million and EU-wide 40 - 80 million extinguishers are in use (i.e. in circulation in total rather than on an annual basis). Given the same underlying data source (bvfa) was used and similar results were obtained, it is likely that this is in fact the same estimation as source number 2 above, with slightly different assumptions. Based on the figures above, the following estimates the total tonnage of PFAS-based firefighting foam in fire-extinguishers in circulation, as well as the annual tonnage placed on the market. The Eurofeu position paper quotes 6-9 litres as the typical size of a fire extinguisher. According to TSF (based on bvfa data), the size can range between 2 and 9 litres. Multiplication of 6-9 litres with the estimated 15 million fire extinguishers yields a range of 90-135 million litres (wider range: 30-810 million litres using 2-9 litres and 60-90 million fire extinguishers) of PFAS-based fire-fighting agents used in fire extinguishers. This would be equivalent to about 90,000-135,000 tonnes (wider range 30,000-810,000 tonnes)63 of PFAS-based fire-fighting agents currently present in fire extinguishers in the EU, or ca 3,600-6,750 tonnes (wider range 1,200-35,000 tonnes) of PFAS-based fire-fighting agents sold in fire extinguishers in the EU annually64. According to personal communication with Eurofeu, the PFAS-based fire-fighting agents in fire extinguishers are either foam concentrate already mixed with water, or a capsule of foam concentrate that is mixed with water when the extinguisher is triggered. That means that only a small share of the fire-fighting agent in the extinguisher is PFAS-based foam concentrate, and the concentration of PFAS in the fire-fighting agent is much lower (2-5g per 6-9 litre extinguisher, or 0.02-0.08%, according to the Eurofeu position paper) than for the foam concentrates discussed above. To make the 3,600-6,750 tonnes per year of PFAS-based fire-fighting agents in fire extinguishers comparable to sales of PFAS-based foam concentrates by sector (presented in the previous subsection), they need to be converted: Conservatively assuming that foam concentrates account for 10% of the fire-fighting agent for fire extinguishers would imply some 360-675 tonnes of PFAS-based foam concentrates are used annually in fire extinguishers in the EU2865. Belgium: 3 million units; United Kingdom: 10 million units; Ireland: 1 million units; Austria: 2 million units; Switzerland: 2 million units; Rest of Europe: 30 million units. 62 https://echa.europa.eu/registry-of-restriction-intentions/-/dislist/details/0b0236e18323a25d 63 Assuming a density of approximately 1kg/l. 64 Calculated by dividing the total tonnage present by the average lifetime of 20-25 years, as indicated by TSF. 65 Calculated as: 3,600 tonnes of PFAS-based fire-fighting agents * 10% = 360 tonnes of PFAS-based foam concentrate. Similarly for the higher end of the range 6,750 tonnes * 10% = 675 tonnes. 49 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Lastly, to sense check this result, it is compared to the tonnage of ready-for-use products estimated in the previous sub-section: Based on Eurofeu data, it was estimated that the total annual EU use of PFASbased fire-fighting foams in the EU is at least 14,000 tonnes but it could be up to around 20,000 tonnes. Figure A.1 (also based on Eurofeu data) puts the share of ready-for-use products at 1%, so the annual tonnage of ready-for-use products is around 140-200 tonnes66. This is somewhat lower than the estimated 360-675 tonnes of PFAS-based foam concentrates used in fire extinguishers. However, the data appear to be consistent because Eurofeu specified that not all foam fire extinguishers are included in the category "ready-for-use foams". Even if the share of ready-for-use products was higher than suggested by Eurofeu (Figure A.1), the total tonnage across all sectors would not be significantly affected by the addition of a few hundred tonnes of ready-to-use products, as it was only estimated at an accuracy in the order of magnitude of thousands of tonnes in this report. A.2.3.3.Other information on tonnages from the consultation The following additional information on tonnages was provided in the consultation: Additional fire-fighting foam manufacturers (not covered by Eurofeu's internal survey) provided figures for three different products they manufacture where the PFAS Carboxymethyldimethyl-3-[[(3,3,4,4,5,5,6,6,7,7,8,8,8tridecafluorooctyl)sulphonyl]amino]propylammonium hydroxide (CAS number 34455-29-3) and 6:2 FTS are used (i.e. all three products use both substances combined). The three products are employed in different sectors: o The first is used by the respondents' customers in airport and marine applications. Of this foam, 700,000 litres are manufactured/imported and 200,000 litres are sold in the EU every year. o The second is used in oil and gas, marine, chemistry and municipal fire fighters applications. 450,000 litres of this product are manufactured/imported in the EU and 250,000 litres are sold every year in the EU. o The third product is used in the oil and gas and marine sectors. 250,000 litres of this foam are manufactured/imported and 100,000 litres are sold every year in the EU. o These volumes are additional to the Eurofeu data presented above. The three foams in sum account for 550,000 litres of annual sales in the EU. Assuming a density of approximately 1kg/l, this would be equivalent to about 550 tonnes of foam that can be added to the Eurofeu total (but would already be included in the EU total extrapolated from Eurofeu data). Hover, given the exact sector split is not known, they have not been added to the sector breakdown. One respondent operating in the field of industrial safety, in particular dedicated to technical support and training, stated that they manufacture 5,000 litres per year of a foam containing a C6 fluorine compound, which is used only for 66 Calculated by multiplying the total tonnage of fire-fighting foams (14,000-20,000 tonnes) with the share of ready for use products (1%). 50 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS training purposes. As above, this is additional to the Eurofeu data, but has not directly been added because the tonnage or density is not known, One respondent operating in the oil and gas sector provided figures for four firefighting foams they purchase; two of these contain poly(1,1,2,2-tetrafluoro-1,2ethanediyl),alpha fluoro-omega-2-(3((caboxylatomethyl)dimetylammonoi)propylaminosulfonyl)ethyl, whereas the other two contain different PFAS that have not been specified: o The two products containing poly(1,1,2,2-tetrafluoro-1,2-ethanediyl),alpha fluoro-omega-2-(3((caboxylatomethyl)dimetylammonoi)propylaminosulfonyl)ethyl are used in the offshore oilrig and refinery sectors for spills67, accidents and function tests in process plant fires and trainings. They purchase less than 5 tonnes per year of each of these foams and employ less than 5 tonnes in each instance of use. o The third product is used in the offshore oil and refinery sectors in cases of spills, accidents and function tests in alcohol fires. Similarly to the previous, less than 5 tonnes are bought every year and less than 5 tonnes are employed in each instance of use. o A volume between 30 tonnes and 70 tonnes of a fourth product is purchased every year by the respondent, but no other details have been provided regarding the use of this foam. One respondent operating in industrial safety for the oil refineries, chemicals and petrochemicals sectors provided figures for one foam based on the C6 fluorine compound, which is used for training exercises on large hydrocarbon fires. They purchase 5 tonnes per year of this product and typically employ it 100 days a year. Another respondent operating in the oil refineries, chemicals and petrochemicals sectors provided figures for one product they purchase, which can be used for almost all class B fires. They purchase between 20 and 60 tonnes per year of this foam and in 75% of cases, fires are extinguished with less than 400 litres of foam concentrate. Respondents quoted prices for PFAS-based fire-fighting foams in the range from 2 to 30 per litre for concentrates. For those PFAS based fire-fighting foams for which data on tonnage and price is available, the weighted average price is around 3 per litre, but note that these products reflect only a small share of the total market, so this estimate is uncertain. Some consultation responses suggest that generally speaking, foams providing a higher performance often contain a higher concentration of PFAS which is associated with a higher cost. 67 AFFF are in some cases also used as prevention in spills that have not (yet) caught fire. See for instance: https://www.nrl.navy.mil/accomplishments/materials/aqueous-film-foam 51 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS A.2.3.4. Number of sites using fire-fighting foams No specific data on the number of sites using fire-fighting foams (PFAS-based or fluorinefree) was available. However, in order to estimate the order of magnitude of user sites, the total number of sites in some of the of the main user sectors can be considered: Chemicals/petrochemicals: There are over 10,000 establishments covered under the EU's Seveso III Directive68. One of the main accident scenarios linked to most Seveso-regulated substances is related to fires. Many other facilities with flammable fuels and chemicals below the Seveso Directive thresholds will also require firefighting equipment. Marine applications: Over 1,200 commercial seaports operate in the EU69 and Europe's maritime traffic is responsible for some 15,000 seagoing vessels70. Airports: There are 401 commercial airports in the EU-2871, many of which will have multiple fire-fighting foam storage/use equipment. Municipal fire brigades: There are over 50,000 public fire brigades in the EU, excluding those covering airports and private brigades covering industrial risks72. Military: In the European Economic Area, there are about 239 military airbases. Based on the above, there are likely to be several tens or potentially hundreds of thousands of facilities using (or at least possessing) fire-fighting foams. In addition, there are likely many other sites possessing fire-extinguishers using fire-fighting foams. A.2.3.5. Conclusions of the market analysis for PFAS-based fire-fighting foams In conclusion, based on information provided by Eurofeu and additional manufacturers, it has been estimated that at least 14,000 tonnes, but probably around 20,000 tonnes of PFAS-based fire-fighting foams are sold in the EU annually. The main application is the chemical and petrochemical industry, which employs 59% of these foams. This is followed by municipal fire brigades, marine applications, airports and the military. The foams are used in fire incidents, spills, tests and training exercises. There are likely several tens or potentially hundreds of thousands of facilities using (or at least possessing) fire-fighting foams, not counting those only using fire-extinguishers.Prices for PFAS based fire-fighting foams range from 2 to 30 per litre for concentrates, with the average estimated at around 3 per litre (subject to significant uncertainty). 68 Analysis and summary of Member States' reports on the implementation of Directive 96/82/EC on the control of major accident hazards involving dangerous substances, Final report, https://op.europa.eu/en/publication-detail//publication/26c9aa63-523e-11e7-a5ca-01aa75ed71a1. 69 European Commission (2013): Europe's Seaports 2030: Challenges Ahead. Available at : https://ec.europa.eu/commission/presscorner/detail/en/MEMO_13_448. 70 In early 2019, the total world fleet stood at 95,402 ships. Europe accounted for 16% of container port traffic (as a proxy for the share of global vessels relevant to Europe). Source: UNCTAD Review of Maritime Transport 2019. Available at https://unctad.org/en/PublicationsLibrary/rmt2019_en.pdf. 71 Eurostat: Number of commercial airports (with more than 15,000 passenger units per year) [avia_if_arp], Data for 2017. 72 FEU statistics, https://www.f-e-u.org/career2.php 52 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS A.2.3.6. Functions provided in the foams and types of fires the foams are used for According to the consultation, the PFAS-based fire-fighting foams find application in a broad range of sectors, such as aviation, marine, oil and gas, offshore oil, refineries, chemicals and railways73. The main function of the PFAS contained in the foam is to act as a surfactant, i.e. to form a film over the burning liquid surface in order to prevent flammable gases from being released from it. This is a particularly relevant feature that enables applications in industrial fires for example tank fires, where large quantities of flammable liquid are stored. They are used for training purposes and in a variety of fire incidents, from small fires to the abovementioned large tank fires, and can be applied both with mobile and semi-stationary equipment. A.2.4. Fluorine-free alternatives A.2.4.1. Sales of fire-fighting foams by user sector Consultation with Eurofeu provided figures on the yearly consumption of fluorine-free firefighting foams in various sectors in Europe, based on a 3-year average (2016-2018), highlighting a total use of 6,553 tonnes per year. Of these 6,553 tonnes, 2,134 are utilised in fixed systems and 4,418 in mobile systems74. The split by sector is detailed in Figure A.2 below. Notably, it varies considerably from that of PFAS-based foams, with a much larger share used by municipal fire brigades but a much smaller share in the chemical/petrochemical sectors. 73 A respondent responsible for railway maintenance stated that PFAS-based foams are used in railways; the use of fire-fighting foams is particularly relevant for fire-protection in railway tunnels. The reason is that railways can carry various chemicals and other dangerous goods and, if they catch fire in tunnels, it is particularly critical and fires can be much more difficult to extinguish. 74 The number of companies that provided a response on whether the foams are used in fixed or mobile systems is lower than those that provided a response for the sectoral overview, therefore in the original data the total tonnage of the former is lower than the latter. To fill this gap, the tonnages for both fixed and mobile systems have been inflated so that their total matches the total in the sectoral split. The original values are 1,259 tonnes for fixed systems and 2,605 tonnes for mobile systems (total 3,864 tonnes). 53 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Figure A.2 Yearly use of fluorine-free firefighting foams by sector. Ai rports 8% Mi l i tary 2% Ready for use products 1% Ma ri ne a pplications 16% Muni cipal fire bri ga des 44% Chemi cal/ p e tro ch emical 29% Source: Data provided to the authors by Eurofeu. Notes: The majority of the `ready for use products' are fire extinguishers. However, not all foam fire extinguishers use ready-for-use foams. Eurofeu estimate that the data they provided based on an internal survey covers roughly 70% of the EU market. It is therefore estimated that the total EU use of fluorine-free firefighting foams could be in the order of 9 million tonnes75. A.2.4.2. Other information on tonnages from the consultation The following information on tonnages was provided in the consultation. Information on which chemical group of alternatives (based on the grouping established in the substance identification, see Section B.1.) is also listed. Additional fire-fighting foam manufacturers (not covered by Eurofeu's internal survey) stated that they manufacture/import a total of 1,250,000 litres and sell 380,000 litres of PFAS-free foams (based on hydrocarbon surfactants) per year in the EU. Assuming a density of approximately 1 kg/l, this would be equivalent to about 380 tonnes of foam that can be added to the Eurofeu total (but would already be included in the EU total extrapolated from Eurofeu data). Hover, given the exact sector split is not known, they have not been added to the sector breakdown. One respondent operating in fire protection for oil refineries/storage, chemicals, petrochemicals and municipalities provided figures for three types of fluorinefree foams (chemical groups of alternatives unknown) used for different purposes: o The first is used by the respondent for exercise and testing of fixed systems (i.e. not for fire-fighting), about 12-20 times per year at 300-10,000 kg per use. They purchase 15,000-30,000 kg of this foam per year. 75 Calculated as 13,669 tonnes divided by 70% and rounded to the closest million tonnes. 54 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS o The second is used by the respondent for testing of proportioning systems (i.e. not for fire-fighting), typically 4-6 times per year, with 1,000-6,000 kg used in each instance. They purchase 10,000 kg of this product per year. o The third was due to start testing in autumn 2019, therefore they did not yet have any experience on real fires with this foam. It is expected that this product will be used about 50 times per year, with 1-400 kg used in each instance. One respondent operating in the field of industrial safety, particularly dedicated to technical support and training, provided figures for two different fluorine-free foams, both used for training purposes: o The first (a product shown to contain detergents according to the substance identification task) is used by the respondent for hydrocarbon fires in the oil and gas sector, with a typical frequency of 150 days per year. They purchase 4,000 kg of this product per year. o The second (chemical group of alternatives unknown) is used by the respondent for alcohol fires, about 30 days a year. They purchase 1,000 kg of this foam per year. One respondent providing training in the safety sector gave figures for one type of fluorine-free foam (a product shown to contain detergents according to the substance identification task). This is used only for training purposes on fires of different sizes and in various sectors, such as airports, oil and gas and marine. They purchase 1,200 kg of this product a year and typically use it around 4 hours per week, depending on the training activity. One respondent active in the airport sector provided figures for one fluorine-free foam (a product shown to contain hydrocarbon surfactants and detergents according to the substance identification task), which is used for all aircraft applications and training activities. They purchase 3,600 litres of this foam a year. Approximately 300 litres are used each month, with a typical use of 15 minutes per month. Another respondent working in the airport sector stated that they purchase 5,000 litres per year of a fluorine-free foam (chemical group of alternatives unknown), which is used only for training and system testing. Additional respondents have stated they use fluorine-free foams based on hydrocarbon surfactants and detergents in aviation, offshore oil installations and onshore terminals and refineries, without specifying quantities. Respondents quoted prices for fluorine-free foams ranging from 0.7 to 10 per litre. For those fluorine-free fire-fighting foams for which data on tonnage and price is available, the weighted average price is around 3 per litre, but note that these products reflect only a small share of the total market, so this estimate is uncertain. Although the range is lower and the average is similar to prices of PFAS-based foams (see above), some respondents suggested that fluorine-free foams are around 50% more expensive than comparable foams containing fluorine. However, fluorine-free foams are still predicted to have a growing presence on the market, due to increasing regulations/controls on fire-fighting training and testing. 55 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS A.2.4.3. Conclusions of the market analysis for fluorine-free alternatives Based on information provided by Eurofeu and additional manufacturers, it has been estimated that at least some 7,000 tonnes, but probably around 9,000 tonnes of fluorinefree firefighting foams are sold in the EU annually. A breakdown by chemical group of alternatives (based on the grouping established in the substance identification) is not available, but consultation responses suggest that the main alternatives used are based on hydrocarbon surfactants and detergents. The split by sector of use varies considerably from that of PFAS-based foams, with a much larger share used by municipal fire brigades but a much smaller share in the chemical/petrochemical sectors. Prices for fluorine-free foams range from 0.7 to 10 per litre, with the average estimated around 3 per litre (subject to significant uncertainty). A.2.4.4. Functions provided in the foams and types of fires the foams are used for The fluorine-free fire-fighting foams considered in this analysis are specifically those that can potentially be used as alternatives to the PFAS-based foams. As such, they are potentially used in the same applications. The consultation responses specifically indicated that fluorine-free alternatives are currently used for training, process fires, alcohol fires and fuel fires, as well as for testing proportioning systems and are applied both with fixed and mobile equipment. When it comes to the application of the products, no significant differences between fluorine-based and non-fluorine foams have been highlighted from a market perspective, but this is analysed in more detail in the analysis of alternatives (see Section E.2.). The substance identification (Section B.1) identified the following groups of substances that PFAS-free fire-fighting foams are based on: hydrocarbons, siloxanes, protein foams, detergents. All of these groups largely mimic the function of fluoro-surfactants in the PFASbased fire-fighting foams, for instance hydrocarbon foams use hydrocarbon surfactants76, siloxanes are also primarily used in fire-fighting foams to function as surfactants77 and detergents are by definition surfactants. A.3. Uses advised against by the registrants The analysis in this pre-Annex-XV dossier is based on substances that have been identified as being used in fire-fighting foams. No review of registration dossiers for all of the potentially relevant PFAS substances has been undertaken in terms of identifying any specific uses that are advised against by the registrants. 76 See for example: https://www.fomtec.com/fluorine-free/category38.html or https://www.chemguard.com/about-us/documentslibrary/documents/Martin2009ReebokEcoguardpresentation2010-10-11.pdf. 77 See for example: https://www.nfpa.org/-/media/Files/News-and-Research/Resources/ResearchFoundation/Symposia/2016-SUPDET/2016-Papers/SUPDET2016Hetzer.ashx?la=en. 56 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Annex B: Information on hazard and risk B.1. Identity of the substance(s) and physical and chemical properties The objective of this section is to identify the PFAS (including long and short chain, their salts and precursors, intentionally used or as impurities) present in fire-fighting foams, the constituents of the fluorine-free fire-fighting foams and any non-PFAS fluorinated alternatives (if they exist). In the following, the approach is briefly described (this Section). Then, results are discussed in Section B.1, in separate sub-sections first for alternatives to PFAS in fire-fighting foam that are fluorinated (but not based on PFAS), then for completely fluorine-free alternatives, and lastly for PFAS used in fire-fighting foams. The substance identification was based on desktop research covering: Literature research based on: o Scientific peer reviewed literature (pubmed, google scholar); o Reports or other publications by national and regional environmental agencies; and o Reports or other publications by NGOs. Information gathered in the framework of regulations: o REACH (for example RMOAs, Annex XV restriction reports, RAC & SEAC documents of PFAS substances); o Stockholm convention (for example risk management evaluation, AoA reports, technical paper on the identification and assessment of alternatives); and o Basel convention(technical guidelines). Safety Data Sheets ((M)SDS) and any other information of known producers/associations; Environmental and human (bio-)monitoring data and case studies; and Expert knowledge (international experts). In general, all the above-named documents were screened by using the following search terms: fire, foam, fluor and/or alternative. More specifically, in case the documents covered the analysis of alternatives (e.g. documents by REACH, Stockholm and NGOs) the documents were screened using the search terms fire and foam. This strategy was also undertaken in the screening of more general reports, for example those reports that cover PFAS in general. These kinds of reports were mostly published by environmental agencies. In cases where analytical measurements were reported (case studies, (bio-) monitoring and scientific publications) it was made sure, that an unambiguous assignment to the usage of firefighting foam could be made. Only in cases where this was possible, the respective data was extracted. A different strategy was elaborated for (M)SDS, in this case only the term "fluor" was used. More detail about the specific search terms applied and the specific documents screened is provided alongside the results in the following sub-sections. A matrix was created to collect all potentially relevant information from the literature review, but the identified information is summarised in the following. 57 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS B.1.1. Name and other identifiers of the substance(s) B.1.1.1. Substance identification non-PFAS fluorinated alternatives Due to concerns about their toxicity and regulatory pressure, long chain PFAS (such as C8, see definition later in this section) have been widely replaced by (perceived safer) alternative substances starting from the early 2000s. These alternatives include short-chain substances like C6 fluorotelomer based fluorosurfactants78, but also non-fluorinated substances. The knowledge of the chemical identity of these substances is currently very limited. As reflected in the Terms of Reference of this project, it is clear that a variety of PFAS and fluorine free-substances are used in fire-fighting foams, but it is not certain if there are any non-PFAS but fluorinated substances that have been or are still being used in fire-fighting foams. The distinction between PFAS and non-PFAS fluorinated substances is the following: PFAS are a fully (per) or partly (poly) fluorinated carbon chain that "contain one or more C atoms on which all the hydrogen atoms are substituted (present in the non-fluorinated analogues from which they are notionally derived) by F atoms, in such a manner that they contain the perfluoroalkyl moiety (CnF2n+1-)." (OECD 2018). Non-PFAS fluorinated substances do not exhibit this particular feature of having "one or more C atoms on which all the H- are substituted by F-atoms". An example for this substance group are silicon dioxide molecules which are perfluorinated. These substances might be used in textiles as an alternative to PFAS79. Based on the length of the fluorinated carbon chain, short and long chain PFASs can be distinguished. Long chains refers to: Perfluorocarboxylic acids (PFCAs) with carbon chain lengths C8 and higher, including perfluorooctanoic acid (PFOA); Perfluoroalkane sulfonic acids (PFSAs) with carbon chain lengths C6 and higher, including perfluorohexane sulfonic acid (PFHxS) and perfluorooctane sulfonate (PFOS); and Precursors of these substances that may be produced or present in products. To identify any potential non-PFAS fluorinated substances used in fire-fighting foams, a literature research in pubmed and google scholar was undertaken, using the following search terms: (("substance" OR "chemical" OR "compound")) AND ("fire fighting foam" OR fire-fighting "fire fighting") As of April 2019, the pubmed search returned 53 hits. However, the relevant hits covered only poly- and perfluorinated compounds. The same result has been found using google scholar. SDS/supplier information, monitoring data, EPAs, NGOs, case studies and legislation were also screened for information on non-PFAS fluorinated substances (simultaneously with the screenings for information on the substance identity of PFAS- and fluorine free-chemicals, discussed below). No non-PFAS fluorinated substances could be identified. 78 Fluorosurfactants are synthetic organofluorine compounds with multiple fluorine atoms. They can be fluorocarbonbased or polyfluorinated (Lehmler, 2005). 79 https://greensciencepolicy.org/wp-content/uploads/2015/04/Presentation-Stefan-PosnerPFAS-April-2015.pdf 58 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS In conclusion, the analysis suggests that fluorinated non-PFAS alternatives in the area of firefighting foams do not exist. This was confirmed in personal communication by Zhanyun Wang (ETH Zrich), an international expert on PFAS chemicals. It was also discussed and not disputed at the project workshop. B.1.1.2. Substance identification - FFF (fluorine-free foams) Because of regulatory pressure and consumer preferences for fluorine-free replacements, a lot of producers of PFAS-containing foams have introduced fluorine-free alternatives. Most of the foams are advertised as intended for use on class B hydrocarbon fuel fires such as oil, diesel and aviation fuels as well as class A fires such as wood, paper, textiles etc. As explained above, various information sources have been reviewed in order to identify any relevant alternative to PFAS in fire-fighting foams. Many of these sources did not provide chemical names or/and CAS/EC numbers. In a lot of sources (e.g. from NGOs, ECHA and Stockholm Convention documents), only very general hints on replacement substances or substance groups have been identified. This includes the naming of the following substance groups: 1. Hydrocarbons; 2. Detergents; 3. Siloxanes; and 4. Protein foams. However, more specific information on substances in FFF was identified in SDS and/or supplier information, some reports published by national authorities, and some peer-reviewed publications. Most relevant information was identified in SDS. As an additional source patents were considered using the google patent search. The results were in most cases the same as for the SDS. A report by the Swedish chemicals agency (KEMI) compiles available knowledge about firefighting foams that were available on the Swedish market in 2014, with respect to chemical content, use, handling and disposal80. Scientific peer-reviewed publications by Hetzer et al. highlighted various sugar-based siloxanes (Hetzer, R. et al. ; Hetzer, R. et al. 2014; Hetzer, R. H. und Kmmerlen 2016; Hetzer, R. H. et al. 2015). However, to our knowledge no CASnumbers are available for these chemical compounds. In the following, the identified substances are presented in more detail. In general, AFFF concentrates are themselves mostly water, with other components such as surfactants, solvents and stabilisers. The lowering of surface tension to allow formation of foam and hence a blanket over the source of fuel, may be accomplished by use of both fluorocarbon and hydrocarbon surfactants. In this context, some of the substances identified in this task are not believed to be direct PFAS- replacements in terms of being a surface active agent81. In the following, only those substances which were identified by their chemical structure as replacements (R) for PFAS are discussed. It is also possible that some of the identified substances may need to be combined with other substances (for example a hydrocarbon in combination with a detergent) in order to fulfil their capacity as a PFAS-replacement. However, it should be noted that their suitability as alternatives to PFAS-based fire-fighting foams is discussed in more detail in the analysis of alternatives (Section E.2.). 80 https://www.kemi.se/global/pm/2015/pm-6-15.pdf 81 Those substances are for example antimicrobial agents that are needed for the biological stability of the foam. 59 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS For a better overview, the substances were grouped in the following substance groups: hydrocarbons, siloxanes, protein foams and detergents based on expert judgement. Hydrocarbons In terms of hydrocarbons, a variety of different substances/substance groups were found. This includes for example various fatty acids, xanthan gums, sugars, alcohols, PEGs and alkanes. These substances are found in a variety of different products from different manufacturers. In the following table more information on this is given. This includes the CAS/EC identifier, the substance name, the chemical group, the supplier and respective product name. The chemical group was assigned based on the authors' knowledge and presented and not disputed at the stakeholder workshop". Table B.1 Identified hydrocarbons (identified by CAS) incl. CAS/EC identifier, the substance name, chemical group and the supplier and/or product name CAS EC Substance name 500-3446 939-5232 112-53-8 15762794-6 Alcohols, C10-16, ethoxylated, sulfates, triethanolammonium salts Alcohols, C8-10, ethoxylated, sulfates, sodium salts 203-9820 1-Dodecanol 112-72-1 204-0003 Tetradecanol 16090127-9 6776219-0 6776241-8 6813139-5 266-9290 500-4649 Alcohols, C9-11, ethoxylated, sulphates, ammonium salts 500-1721 Alcohols, C10-16, ethoxylated, sulfates, ammonium salts 272-4906 tetradecan-1-ol 500-1957 Alcohols, C12-15, ethoxylated 6770105-7 Fatty acids, C8-18 and C18-unsatd. Chemical group Alcohols Supplier and Product Name N/A (identified via ECHA's dissemination website) Alcohols Alcohols Alcohols Alcohols Alcohols N/A (identified via ECHA's dissemination website) Respondol ATF 3-6%: Angus Fire (Angus International: Angus Fire, National Foam and Eau et Feu.) LS xMax: Dafo Fomtec AB STHAMEX 2% F6 Multi-purpose detergent foam: Dr Sthamer STHAMEX-SV/HT 1% F-5 #9142: Dr Sthamer Respondol ATF 3-6%: Angus Fire (Angus International: Angus Fire, National Foam and Eau et Feu.) LS xMax: Dafo Fomtec AB STHAMEX 2% F6 Multi-purpose detergent foam: Dr Sthamer STHAMEX-SV/HT 1% F-5 #9142: Dr Sthamer OneSeven of Germany GmbH. OneSeven Foam Concentrate Class A Kempartner AB: Meteor Allround Ma-13 Alcohols Alcohols Fatty Acid/oil Angus Fire: Expandol (aka Expandol 1-3), Expandol LT (aka Expanol 1-3LT) Verde Environmental Inc (Micro Blaze): MicroBlaze Out N/A (identified via ECHA's dissemination website) 60 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS CAS 1113866-2 9000-300 9005-258 12096203-0 2532268-3 2725280-8 3261248-9 7366522-2 9613061-9 308-7660 439-0706 EC Substance name Chemical group Supplier and Product Name 234-3942 Xanthan gum Gum Auxquimia: Phos-Chek 36 Fluorine Free (aka UNIPOL-FF 3/6); Phos-Chek Training Foam 140 Dr Sthamer: Moussol-FF 3/6 FireRein: Eco-Gel Kempartner AB: Unifoam Bio Yellow Verde Environmental Inc (Micro Blaze) : MicroBlaze Out 232-5368 Cyamopsis gum; Cyanopsis tetragonoloba Gum FireRein: Eco-Gel 232-6796 Starch Hydrocarbo n Solberg: US20080196908 601-7486 Canola Oil Oil Eco-Gel; FireRein 500-0382 Poly(oxy-1,2ethanediyl),-hydro-hydroxy- Ethane-1,2-diol, ethoxylated Polyethylen e glycol Dafo Fomtec AB: Fomtec AFFF 1% F, Fomtec AFFF 3% S, Fomtec AFFF 3% 608-0689 ALLYLOXY(POLYETHYLEN E OXIDE), METHYL ETHER (9-12 EO) Polyethylen e glycol 1% AFFF Denko 3% AFFF Denko 6% AFFF Denko Alcohol AFFF 3% - 6% Single or Double Strength Denko 608-7600 Poly(oxy-1,2-ethanediyl), -sulfo--(dodecyloxy)-, ammonium salt (1:1) P Polyethylen e glycol Orchidee Fire: Orchidex BlueFoam 3x3 616-0067 Poly(oxy- 1,2ethanediyl), .alpha.sulfo-.omega.-hydroxyC6-10-alkyl ethers, sodium salts Polyethylen e glycol Dr Sthamer: STHAMEX 2% F6 Multi-purpose detergent foam, STHAMEX 3% F6 Multipurpose detergent foam, STHAMEX K 1% F15 #9143,STHAMEX-SV/HT 1% F-5 #9142, TRAINING FOAM-N 1% F-0 #9141 619-1949 Poly(oxy-1,2-ethanediyl), -sulfo--hydroxy-, C911-alkyl ethers, sodium salts Polyethylen e glycol Dafo Brand AB: ARC Milj Dafo Fomtec AB: Fomtec AFFF 1% A, Fomtec AFFF 1% F, Fomtec AFFF 1% Plus, Fomtec AFFF 1% Ultra LT, Fomtec AFFF 3%, Fomtec AFFF 3%ICAO, Fomtec AFFF 3% S, , Fomtec Askum 9828367-1 undecyl glucoside Sugar N/A (identified via ECHA's dissemination website) 439-0706 (2R,3R,4S,5S)-2,3,4,5tetrahydroxyhexanal (2R,3S,4R,5R)-2,3,4,5,6pentahydroxyhexanal (2S,3S,4S,5R)-2,3,4,5tetrahydroxy-6oxohexanoic acid acetic acid calcium dihydride hydrate magnesium dihydride potassium hydride sodium hydride Sugar N/A (identified via ECHA's dissemination website) 11061547-9 600-9758 Alkylpolyglycoside C1016 Sugar Orchidee Fire: Orchidex BlueFoam 3x3 61 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS CAS 5454925-6 6851573-1 N/a EC Substance name 259-2181 (3R,4S,5S,6R)-2(decyloxy)-6(hydroxymethyl)oxane3,4,5-triol 500-2201 Alkyl polyglucoside 917-3414 AAlkyl polyglucoside Chemical group Sugar Supplier and Product Name Unifoam Bio Yellow Sugar Sugar Dafo Brand AB: ARC Milj Dafo Fomtec AB: Enviro 3x3 Plus, Enviro 3x3 Ultra, Enviro 3x6 Plus, Environ 6x6 Plus, LS aMax, MB -20, Trainer E-lite, Fomtec AFFF 1% A, Fomtec AFFF 1% F, Fomtec AFFF 1% Plus, Fomtec AFFF 1% Ultra LT, Fomtec AFFF 3% ICAO, Fomtec AFFF 3% S, Fomtec AFFF 3% OneSeven of Germany GmbH: OneSeven Foam Concentrate Class B-AFFF vs FOCUM: Silvara APC 3x6 Solberg: US20080196908 Detergents Chemically, detergents belong to the group of hydrocarbons, however in the context of this project this substance group is considered separately. This group is characterised by their amphiphilic nature, being partly hydrophilic (polar) and partly hydrophobic (non-polar). The polar headgroup is needed to ensure their action on surfaces/interfaces (formation of micelles, lowering of the surface tension of water). The substances identified in this group, cover various alkanes that differ in the carbonic chain length (e.g. decyl, lauryl) and the head group (e.g. betaine, sulphates, amido betaines, triethanolamines). A betaine is a quaternary ammonium compound having three methyl groups. This pattern is to some extent similar to those of the poly- and perfluorinated substances, in which an F-atom replaces the H-atom. In Figure B.1 sodium octyl sulphate is shown, this substance has been identified in at least ten individual products from several suppliers as an alternative to PFAS substances. The polar head group is highlighted in red and the non-polar alkaline chain is highlighted in blue. It should be noted, that also PFAS-containing AFFF may also contain some of these detergents (for example STHAMEX -AFFF 3%). Figure B.1 Chemical structure of sodium octyl sulphate 62 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Table B.2 Identified detergents (identified by CAS) incl. CAS/EC identifier, the substance name, chemical group and the supplier and/or product name CAS 308062-28-4 68155-09-9 70592-80-2 269-087-2 1469983-49-0 147170-44-3 61789-40-0 EC 608-528-9 / 931292-6 268-938-5 274-687-2 68187-32-6 939-455-3 604-575-4 / 931333-8 931-296-8 Substance name Chemical group Amines, C12-14 (even numbered) alkyldimethyl, Noxides Alkylamine Amides, coco, N-(3(dimethylamino)prop yl), N-oxides Alkylamine Amines, C10-16alkyldimethyl, Noxides Alkylamine l-Glutamic acid, Ncoco acyl derivs., monosodium salts Alkylamine 1-Propanaminium, N-(3-aminopropyl)2-hydroxy-N,Ndimethyl-3-sulfo-, N(C8-18(even numbered) acyl) derivs., hydroxides, inner salts Alkylbetaine 1-Propanaminium, 3-amino-N(carboxymethyl)N,N-dimethyl-, N(C8-18(even numbered) and C18 unsaturated acyl) derivs., hydroxides, inner salts Alkylbetaine 1-Propanaminium, 3-amino-N(carboxymethyl)N,N-dimethyl-, N(C12-18(even numbered) acyl) derivs., hydroxides, inner salts Alkylbetaine Supplier and Product Name Dafo Fomtec AB: Enviro 3% ICAO, Enviro USP Dr Sthamer: vaPUREx LV 1% F10 #7141 Angus Fire: Syndura (6% fluorine free foam) Angus Fire: Syndura (6% fluorine free foam) Dafo Fomtec AB: Enviro 3x3 Plus, Enviro 3x3 Ultra, Enviro 3x6 Plus, Environ 6x6 Plus, LS aMax, Silvara APC 1 Dr Sthamer: MOUSSOL-FF 3/6 F-15 #7941 OneSeven of Germany GmbH: OneSeven Foam Concentrate Class A Solberg: Solberg Patent US20080196908 64265-45-8 264-761-2 68139-30-0 13150-00-0 268-761-3 236-091-0 N-(2-hydroxyethyl)N-[2-[(1oxooctyl)amino]ethyl ]--alanine Alkylbetaine Cocamidopropyl hydroxysultaine Alkylbetaine Sodium 2-[2-[2(dodecyloxy)ethoxy] ethoxy]ethyl sulphate Alkylsulfate vs FOCUM: Silvara APC 1, Silvara APC 3x3, Silvara APC 3x6, Silvara ZFK (0.5%) Solberg: US20080196908 Kempartner AB : Unifoam Bio Yellow 63 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS CAS 139-96-8 142-31-4 EC 205-388-7 205-535-5 Substance name Chemical group 2-[bis(2hydroxyethyl)amino] ethanol; dodecyl hydrogen sulfate Alkylsulfate Sodium octyl sulphate Alkylsulfate Supplier and Product Name Dr Sthamer: Sthamex SVM Dr Sthamer: Moussol-FF 3/6 Kempartner AB: Unifoam S Kempartner AB: Unifoam OneSeven of Germany GmbH: OneSeven Foam Concentrate Class BAFFF vs FOCUM: Silvara 1 (1%) vs FOCUM: Silvara APC 1 vs FOCUM: Silvara APC 3x3 vs FOCUM: Silvara ZFK (0.5%) Angus Fire (Angus International: Angus Fire, National Foam and Eau et Feu.) : Syndura (6% fluorine free foam) Chemguard: 3% AFFF Foam Concentrate (C303) Chemguard: 3% Low Temp AFFF (C3LT) Dafo Brand AB: AFFF 3-6 % Fire Services Plus: FireAde Fire Services Plus: FireAde AR AFFF OneSeven of Germany GmbH: OneSeven Foam Concentrate Class BAFFF OneSeven of Germany GmbH: OneSeven Foam Concentrate Class BAFFF-AR Solberg : Solberg Patent US20080196908 Dr Sthamer: TRAINING FOAM-N 1% F-0 #9141 vs FOCUM: Silvara ZFK (0.5%) 64 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS CAS 142-87-0 EC 205-568-5 143-00-0 205-577-4 151-21-3 2235-54-3 25882-44-4 205-788-1 218-793-9 247-310-4 273-257-1 287-809-4 68955-19-1 85586-07-8 Substance name Chemical group Sodium decyl sulfate Alkylsulfate Dodecyl hydrogen sulfate;2-(2hydroxyethylamino)e thanol Alkylsulfate Sodium dodecyl sulphate Alkylsulfate Ammonium alkyl ether sulphate Alkylsulfate disodium;4-[2(dodecanoylamino)et hoxy]-4-oxo-3sulfonatobutanoate Alkylsulfate Sulfuric acid, monoC12-18-alkyl esters, sodium salts Alkylsulfate Sulfuric acid, monoC12-14-alkyl esters, sodium salts Alkylsulfate Supplier and Product Name Chemguard: 3% AFFF Foam Concentrate (C303) Chemguard: 3% Low Temp AFFF (C3LT) Chemguard: 6% AFFF Foam Concentrate (C603) Chemguard: 6% Low Temp AFFF (C6LT) Dafo Brand AB: AFFF 3-6 % Dafo Fomtec AB: LS xMax Dafo Fomtec AB: MB -20 Solberg : Solberg Patent US20080196908 Dr Sthamer: TRAINING FOAM-N 1% F-0 #9141 vs FOCUM: Silvara 1 (1%) Solberg : Solberg Patent US20080196908 Solberg: US20080196908 Fire Services Plus: FireAde; FireAde AR AFFF Kempartner AB: Unifoam, Unifoam S Angus Fire (Angus International: Angus Fire, National Foam and Eau et Feu.) : Expandol (aka Expandol 1-3), Expandol LT (aka Expanol 1-3LT) N/A (identified via ECHA's dissemination website) N/A (identified via ECHA's dissemination website) 65 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS CAS 3088-31-1 577-11-7 68081-96-9 68439-57-6 68877-55-4 68877-55-4 68891-38-3 85338-42-7 EC 221-416-0 209-406-4 268-364-5 931-534-0, 270407-8 272-563-2 272-563-2 500-234-8 286-718-7, 939332-4 Substance name Chemical group Sodium 2-(2dodecyloxyethoxy)et hyl sulphate Alkylsulfate 1,4-bis(2ethylhexoxy)-1,4dioxobutane Sulfuric acid, monoC10-16-alkyl esters, ammonium salts Alkylsulfate Alkylsulfate Sulfonic acids, C1416-alkane hydroxy and C14-16-alkene, sodium salts Alkylsulfate Sodium 3-[2-(2heptyl-4,5-dihydro1H-imidazol-1yl)ethoxy] propionate Alkylsulfate Sodium 3-[2-(2heptyl-4,5-dihydro1H-imidazol-1yl)ethoxy] propionate Alkylsulfate Sodium laureth sulfate Alkylsulfate Sulfuric acid, monoC8-10 (even numbered)-alkyl esters, sodium salts Alkylsulfate Supplier and Product Name Buckeye Fire Equipment Company: Buckeye High Expansion Foam (BFC-HX) (aka Hi-Ex 2.2) Dr Sthamer: STHAMEX K 1% F15 #9143 Orchidee Fire: Orchidex BlueFoam 3x3 Verde Environmental Inc (Micro Blaze): Micro-Blaze Out Dafo Fomtec AB: Enviro 3x3 Plus, Enviro 3x6 Plus, Environ 6x6 Plus Dr Sthamer: STHAMEX 3% F6 Multi-purpose detergent foam, STHAMEX K 1% F15 #9143 vaPUREx LV 1% F-10 #7141 OneSeven of Germany GmbH: OneSeven Foam Concentrate Class BAFFF, OneSeven Foam Concentrate Class B-AFFF-AR OneSeven of Germany GmbH: OneSeven Foam Concentrate Class BAFFF, OneSeven Foam Concentrate Class B-AFFF-AR Angus Fire: Expandol (aka Expandol 1-3), Expandol LT (aka Expanol 1-3LT), Respondol ATF 3-6% Dafo Fomtec AB: Enviro 3% ICAO, Enviro USP, LS xMax, Trainer E-lite Angus Fire: Respondol ATF 3-6% Dafo Fomtec AB: Enviro 3x3 Ultra, LS aMax 66 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS CAS 85665-45-8 90583-18-9 90583-25-8 N/a N/a 4292-10-8 EC 939-262-4 939-265-0, 292216-9 292-224-2 919-131-8 944-611-9 224-292-6 Substance name Chemical group Sulfuric acid, monoC8-14 (even numbered)-alkyl esters, compds. with triethanolamine Alkylsulfate Sulfuric acid, C12-14 (even numbered)alkyl-esters, compds. with triethanolamine Alkylsulfate Sulfuric acid, monoC6-12-alkyl esters, sodium salts Alkylsulfate Fatty alcohol polyglycol ether sulfate, sodium salt Alkylsulfate Reaction mass of Cisodecyl and Cisoundecyl sulphonatosuccinate Alkylsulfate (carboxymethyl)dim ethyl-3-[(1oxododecyl)amino]pr opylammonium hydroxide Detergent Supplier and Product Name Dr Sthamer: MOUSSOL-FF 3/6 F-15 #7941, MOUSSOL-FF 3/6 F-5 #7942, STHAMEX 2% F6 Multi-purpose detergent foam, STHAMEX-SV/HT 1% F-5 #9142, TRAINING FOAM-N 1% F-0 #9141 Dafo Fomtec AB: Enviro 3% ICAO, Enviro USP OneSeven of Germany GmbH: OneSeven Foam Concentrate Class A vs FOCUM: Silvara APC 3x6 Unifoam Bio Yellow BASF: Emulphor FAS 30 Respondol ATF 3-6% vs FOCUM: Silvara 1 (1%), Silvara ZFK (0.5%) Siloxanes A limited number of siloxanes were identified in this task, this might be because the usage of this substance group is still in the phase of development. This is further explained in the following. Only one substance belonging to siloxanes could be identified by CAS number. This substance is a mixture of siloxanes and silicones (CAS 117272-76-1). It was found in products by Denko, namely: 1% AFFF; 3% AFFF; 6% AFFF; Alcohol AFFF 3% - 6% Single or Double Strength. Judging by the name, it could be that these substances were used in combination with fluorinated substances. However, for the sake of completeness the substance is named although it is not used as a PFAS-replacement. This information is shown in the table below, where also the chemical structure is shown. 67 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Table B.3 Siloxanes (identified by CAS) incl. CAS/EC identifier, the substance name, chemical group and the supplier and/or product name CAS EC Substance name 11727276-1 601-468-4 Siloxanes and Silicones, 3hydroxypropyl Me, ethers with polyethylene glycol mono-Me ether Chemical group Siloxanes Supplier & Product Name Chemical structure 1% AFFF Denko 3% AFFF Denko 6% AFFF Denko Alcohol AFFF 3% 6% Single or Double Strength Denko In addition, publications by Hetzer et al. presented various sugar-based siloxanes for which CAS-numbers are not available. For a better understanding, in Figure B.2 a sugar-based siloxane, as presented by Hetzer et al., is shown. It is important to note that these substances are used without further addition of PFAS substances. The most recent publication by these researchers states that siloxane-based firefighting foam concentrate shows an extinguishing performance which significantly surpasses the commercial PFAS-free foams (whereby the actual product is not named) and nearly meets the performance of the PFAS-containing AFFF in fire suppression tests based on the NATO standard fuel F-34 (class B fire). However, no commercial product containing these substances was identified in this task. Regarding their persistency, some siloxanes are known SVHC, having identified PBT and/or vPvB properties (cyclic D4, D5, D6) and others (linear) are currently undergoing PBTassessment (e.g. octamethyltrisiloxane). In this context, the publications highlight that the formation of the desired product and its purity were verified after the filtration process. No more information is available at this time. Figure B.2 Sugar-based siloxane as described by Hetzer et al. For more information on these substances please refer to the individual publications (Hetzer, R. et al. ; Hetzer, R. et al. 2014; Hetzer, R. H. und Kmmerlen 2016; Hetzer, R. H. et al. 2015). Proteins Regarding protein-based foams also only one substance with a CAS number could be identified. This belongs to silk-based protein hydrolysate (CAS 306-235-8). However, the associated product/foam manufacturer was not identified. Some SDS mention proteins from horn and hoof (National Foam) or hydrolysed protein (Gepro Group PROFOAM 806G). In these cases, no CAS number was given. The sources mentioning horn and hoof-based proteins also recommended that these should not be used because of the risk of epizootic diseases. 68 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS B.1.1.3. Substance identification - PFAS Generally, most information on PFAS in fire-fighting foams was found in the scientific literature. This is partially due to the fact that SDS and supplier information only indicate general terms like "fluorinated surfactant" without naming a CAS number and/or referring to propriety information. Environmental agencies mostly also cite scientific literature, so this information overlaps with substances already identified in the review of scientific literature. This is also true for information from legislation (REACH, Stockholm, Basel Convention). When searched in pubmed and google scholar, the following search terms were used: ("fluorochemical*" OR "per- and polyfluoroalkyl" OR "perfluoroalkyl" OR "polyfluoralkyl" OR "fluorinated" OR "PFAS") AND ("fire fighting" OR "airport" OR "fire") As of April 2019, this search yielded 86 hits. Those publications were mostly highly relevant, and the substance details were extracted into excel sheets relevant for the next working steps. An additional source of information is case studies and monitoring activities. However, these are considered to be of less importance because mostly only a very limited variety of PFAS substances was covered. Additionally, when environmental/human samples are considered, for fluorinated foams, also environmental and biological degradation processes need to be considered. For example, it is known that perfluorosulfonamides, undergo abiotic degradation as well as in vivo and in vitro biotransformation (DanEPA 2015). With regards to the substances identified in the scientific literature, for a large share it was not possible to find a CAS/EC number. Sixty-three substances were identified by CAS/EC number, while around 213 were only identified by substance name/structure. This lack of CAS numbers may be due to the fact that those substances have been described for the first time by the respective author or are perhaps polymeric substances that do not necessarily have CAS numbers. In general, these numbers might also indicate that a lot of substances have been used that are currently poorly known. The following information relates only to those substances that were fully identified in terms of CAS/EC, substance name and/or acronym. Based on the CAS-identified PFAS-substances that were/are used in AFFF the following grouping is possible, indicated in brackets is the number of CAS-identified substances: Unsubstituted long chain PFAS (14); Unsubstituted short chain PFAS (8); Substituted short and long chain PFAS (12); Fluorotelomers (22); and Others (7). Long Chain PFAS The group of long chain PFAS (defined by OECD as perfluorosulfonic acids (PFSAs) with C6 and perfluorocarboxylic acids (PFCAs) with C8) encompasses the following substances: PFSAs with C6 PFHxS (C6); PFHpS (C7); PFOS (C8); 69 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS PFNS (C9); PFDS (C10); and PFUnDS (C11). As can be seen in the table below, the identified sulfonic acids exhibit chain length up to 11 perfluorinated carbons. Table B.4 PFSAs (identified by CAS) with C6 incl. CAS/EC identifier, the designation, the acronym and the supplier and/or product name CAS 355-464 EC Designation (synonyms) 206-5871 Perfluorohexane sulfonic acid Acrony m PFHxS 375-928 206-8008 perfluoroheptane sulfonic acid PFHpS 176323-1 217-1798 Perfluorooctanesulfon ic acid PFOS 68259- N/a 12-1 Perfluoronone sulfonic acid PFNS 335-773 206-4019 Perfluorodecanesulfo nic acid PFDS 749786- N/a 16-1 Perfluoroundecan sulfonic acid PFUnDS Supplier and Product Name Ansul AFFF Ansulite 3M LightWater Angus Fire, na Angus Fire, 2000 ; Niagara 1-3, Angus Fire, 1997; Forexpan Angus Fire, 2007; Hi Combat A TM 3M, 2005; ATC-603 Light water ATC3 3M, 1999; FC-203FC Light water Brand 3M 1999 3M 1992 3M 1993 3M 1998 (slightly different shares) 3M 1989 3M 1988 AFFF 3M 1992 3M 1993 3M 1998 (slightly different shares) 3M 1989 3M 1988 3M AFFF ("PFSAs have been components of 3M from the 1970s to 2001") 3M LightWater FC-203FC 3M, 2005; ATC-603 Light water ATC3 3M, 1999; FC-203FC Light water Brand AFFF 3M 1992 3M 1993 3M 1998 (slightly different shares) 3M 1988 3M 1989 Ansul Ansulite AFFF Angus Fire, na Angus Fire, 2000 ; Niagara 1-3, Angus Fire, 1997; Forexpan Angus Fire, 2007; Hi Combat A TM Hazard Control Technologies, Inc., 2003 F-500 Dr. Sthamer STHMEX-AFFF 3% AFFF 3 M Lightwater PFSAs have been components of 3M AFFF from the 1970s to 2001 3M Ansul AFFF Angus Fire, N/a Fomtec MB 5 No product/supplier is mentioned; Publications are based on environmental samples 70 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS The identified PFCAs encompass the following substances: PFCAs with C8: PFOA (C8); PFNA (C9); PFDA (C10); PFUnDA (C11); PFDoDA (C12); PFTrDA (C13); PFTeDA (C14); and PFOcDA (C18). The carboxylic acids exhibit chain length up to 18 perfluorinated carbons. All of the substances were identified in various "old" products (newest product is from 2007) from different manufacturers. This can be seen in the table below. Table B.5 PFCAs (identified by CAS) with C8 incl. CAS/EC identifier, the designation, the acronym and the supplier and/or product name CAS EC Designation (synonyms) Acronym Supplier and Product Name 335-671 206-3979 Perfluorooctanoic acid PFOA 375-951 206-8013 Perfluorononanoic acid PFNA Ansul AFFF Ansulite 3M LightWater Angus Fire, N/a Angus Fire, 2000 ; Niagara 1-3, Angus Fire, 1997; Forexpan 3M, 2005; ATC-603 Light water ATC3 3M, 1999; FC-203FC Light water Brand 3M 1999 3M 1992 3M 1993 3M 1998 (slightly different shares) 3M 1989 3M 1988 OneSeven B-AR ARC Milj Towalex plus Towalex 3x3 Towalex 3% super Towalex 3% master Sthamex AFFF-P 3% FC-203FC Light Water 3M AFFF Ansul AFFF Ansulite 3M LightWater Angus Fire, N/a Angus Fire, 2000 ; Niagara 1-3, Angus Fire, 1997; Forexpan OneSeven B-AR ARC Milj Towalex 3x3 Towalex 3% master Hazard Control Technologies, Inc., 2003 F-500 71 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS CAS 335-762 205894-8 307-551 7262994-8 376-067 1651711-6 EC 206-4003 218-1654 206-2032 276-7452 N/a 240-5825 Designation (synonyms) Perfluorodecanoic acid Perfluoroundecanoic acid Perfluorododecanoic acid Perfluorotridecanoic acid Perfluorotetradecano ic acid Perfluorostearic acid Acronym Supplier and Product Name PFDA PFUnDA PFDoDA PFTrDA PFTeDA PFODA Ansul AFFF Ansulite 3M LightWater 3M FC-203FC Light Water Fomtex Arc 3x3 Towalex plus Towalex 3x3 Towalex 3% master 3M LightWater 3M LightWater FC-203FC Ansul Ansulite ANSUL Ansulite 6 % AFFF (Formula 1559-22 ICAO-B) Ansul AFFF Ansulite 3M LightWater Sthamex F-15 Towalex 3% master PFCAs were primary components in early 3M AFFFs from 1965 up to 1986 3M AFFFs from 1965 up to 1987 Ansul AFFF FC-203FC Light Water 3M No product/supplier is mentioned; Publications are based on environmental samples Short chain PFAS Short chain PFAS were also identified in this study, namely: PFSAs with C<6: PFEtS (C2); PFPrS (C3); PFBS (C4); and PFPeS (C5). The list below shows that the identified sulfonic acids cover chain lengths from C2-C5. Table B.6 PFSAs (identified by CAS) with <C6 incl. CAS/EC identifier, the designation, the acronym and the supplier and/or product name CAS EC Designation (synonyms) Acronym 354-88-1 N/a Perfluoroethane sulfonic acid PFEtS 423-41-6 N/a Perfluoropropane sulfonic acid PFPrS 375-73-5 2067931 Perfluorobutanesulfoni c acid PFBS Supplier and Product Name 3M AFFFs Shorter chains C2-C3 PFSAs used in from 1988 to 2001 3M AFFFs Shorter chains C2-C3 PFSAs used in from 1988 to 2001 Ansul AFFF Ansulite 3M LightWater Angus Fire, N/a 72 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS 2706-914 2203012 Perfluoropentane sulfonic acid PFPeS Angus Fire, 2000 ; Niagara 1-3, Angus Fire, 1997; Forexpan Angus Fire, 2007; Hi Combat A TM 3M, 2005; ATC-603 Light water ATC3 3M, 1999; FC-203FC Light water Brand 3M 1999 3M 1992 3M 1993 3M 1998 (slightly different shares) 3M 1989 3M 1988 AFFF No product/supplier is mentioned; Publications are based on environmental samples Also carboxylic acids have been identified. Contrary to the sulfonic acids, the carboxylic acids were only found starting from C4. PFCAs with < C8: PFBA (C4); PFPeA (C5); PFHxA (C6); and PFHpA (C7). In the table below, the short chain PFCAs are shown. Table B.7 PFCAs (identified by CAS) with <C8 incl. CAS/EC identifier, the designation, the acronym and the supplier and/or product name CAS 375-22-4 EC Designation (synonyms) 206-7863 perfluoro-nbutanoic acid 2706-903 220-3007 Perfluoropentanoic acid Acrony m PFBA PFPeA Supplier and Product Name Ansul AFFF Ansulite 3M LightWater Angus Fire, N/a Angus Fire, 2000 ; Niagara 1-3, Angus Fire, 1997; Forexpan Angus Fire, 2007; Hi Combat A TM 3M, 2005; ATC-603 Light water ATC3 3M, 1999; FC-203FC Light water Brand OneSeven B-AR ARC Milj Towalex 3x3 Towalex 3% master Sthamex AFFF-P 3% AFFF 3M LightWater FC-203FC 3M 1999 3M 1992 3M 1993 3M 1998 (slightly different shares) 3M 1989 3M 1988 Angus Fire, 2000 ; Niagara 1-3, Angus Fire, 1997; Forexpan Ansul AFFF Ansulite 73 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS CAS 307-24-4 EC Designation (synonyms) 206-1966 Perfluorohexanoic acid 375-85-9 206-7989 Perfluoroheptanoic acid Acrony m PFHxA PFHpA Supplier and Product Name Ansul AFFF Ansulite 3M LightWater Angus Fire, N/a Angus Fire, 2000 ; Niagara 1-3, Angus Fire, 1997; Forexpan 3M, 2005; ATC-603 Light water ATC3 3M, 1999; FC-203FC Light water Brand 3M 1999 3M 1992 3M 1993 3M 1998 (slightly different shares) 3M 1989 3M 1988 OneSeven B-AR ARC Milj Towalex plus Towalex 3x3 Towalex 3% super Towalex 3% master Sthamex AFFF-P 3% AFFF Ansul AFFF Ansulite 3M LightWater Angus Fire, N/a Angus Fire, 2000 ; Niagara 1-3, Angus Fire, 1997; Forexpan Angus Fire, 2007; Hi Combat A TM Angus Fire, 2004 Tridol S 3 % 3M, 2005; ATC-603 Light water ATC3 3M, 1999; FC-203FC Light water Brand FC-203FC Light Water 3M OneSeven B-AR ARC Milj Towalex 3x3 Towalex 3% master Sthamex AFFF-P 3% AFFF In general, both short and long chain PFAS were identified as substances used in AFFF. One author highlights that PFCAs were primary components in early 3M AFFFs from 1965 up to 1986 (Barzen-Hanson und Field 2015). Derivates of perfluoroalkyl sulfonic PFAS (also PASF-based substances) All the named substances above are characterized by a perfluorinated alkaline carbon chain that is connected to a sulfonic- or carboxylic acid head group. In other PFAS substances, this head group is also equipped with additional chemical groups. This group is also called perfluroalkane sulfonyl fluoride substances (PASF), as their synthesis is based on perfluroalkane sulfonyl fluoride. This can be for example an amide (sometimes methylated or ethylated). However, in most cases, these substances were not found when the actual foam was tested but rather when environmental samples were tested. In addition, some of the substances are also known to be environmental transformation products. Other substances are raw materials for surfactant and surface protection products (EtFOSE and N-MeFOSe) (Buck et al. 2011). In this sub group, the following substances were found: PFOSaAm; C7-FASA (PFHpSA); C8-PFSiA (PFOSI); 74 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS EtFOSAA; EtFOSE; FBSA; FOSA; FOSAA; FOSE; N-MeFOSA; N-MeFOSE; PFBSaAm; N-[3-(Dimethyloxidoamino)propyl] -3,3,4,4,5,5,6,6,7,7,8,8,8-Tridecafluor-1- octanesulfonamid; and (Carboxymethyl)dimethyl [3- (gamma-omega-perfluor-1-C6-14- Alkansulfonamid)propyl)ammonium. In addition, some of those compounds are known PFOS-precursors (for example PFOSaAm, EtFOSAA, PFOSI, EtFOSE). Table B.8 Identified derivates of perfluoroalkyl sulfonic PFAS (also PASF-based substances) CAS 13417-01-1 EC 236-513-3 167398-54-1 N/a 647-29-0 N/a 2991-50-6 / 133661-4 221-061-1 4151-50-2 223-980-3 68298-12-4 N/a Designation (synonyms) PPerfluoroalkyl sulfonamido amines Acronym PFOSaAm Perfluoroheptane sulfonamidoethanol C7-FASA (PFHpSA) N/a N-Ethyl perfluorooctane sulfonamidoacetic acid C8-PFSiA (PFOSI) EtFOSAA N-Methyl perfluorooctane sulfonamidoacetic acid EtFOSE NMethylperfluorobuta nesulfonamide FBSA Supplier and Product Name National Foam ; Ansulite; 3M lightwater; 3M 3 M Lightwater was used from 1988 until 2001 OR Ansul (telomerbased foam) 3M 1988 3M 1989 No product/supplier is mentioned; Publications are based on environmental samples No product/supplier is mentioned; Publications are based on environmental samples No product/supplier is mentioned 75 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS CAS EC 2806-24-8 N/a 754-91-6 212-046-0 10116-92-4 N/a 2355-31-9 N/a 24448-09-7 246-262-1 68555-77-1 271-455-2 80475-32-7 279-481-6 133875-90-8 N/a Designation (synonyms) perfluorooctane sulfonamido acetic acid Acronym FOSAA Perfluorooctane sulfonamide FOSA N/a FOSE N-methyl perfluorooctanesulfo namidoacetic acid N-MeFOSA N-Methyl perfluorooctane sulfonamidoethanol N-MeFOSE perfluoroalkyl sulfonamido amines PFBSaAm N-[3- N/a (Dimethyloxidoamin o)propyl] - 3,3,4,4,5,5,6,6,7,7,8 ,8,8-Tridecafluor-1- octanesulfonamid (Carboxymethyl)dim N/a ethyl [3- (gammaomega-perfluor-1C6-14Alkansulfonamid)pro pyl)ammonium (inneres Salz) Supplier and Product Name No product/supplier is mentioned; Publications are based on environmental samples No product/supplier is mentioned; Publications are based on environmental samples No product/supplier is mentioned; Publications are based on environmental samples No product/supplier is mentioned; Publications are based on environmental samples No product/supplier is mentioned; Publications are based on environmental samples No product/supplier is mentioned; Publications are based on environmental samples Dupont, Forafac 1183 Dupont, Forafac 1203 In addition to the tables above, the identified substances and their respective chemical relationship can be visualised in terms of a hierarchical clustering. This is shown in the figure below. 76 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Figure B.3 Hierarchical clustering of the identified short-, long-chain and substituted PFAs substances Fluorotelomers Fluorotelomers are defined by having an additional non-fluorinated spacer between the perfluorinated alkyl chain and the charged head group (denotated as number of perfluorinated carbons: number of non-fluorinated carbons). The fully identified substances (i.e. by CAS/EC number) are shown in Table B.9. As shown in the table below, the 22 identified fluorotelomers cover a wide range of positively/negatively charged head groups or combinations of those. Most of the fully identified substances, exhibit the xx:2 structure, where two non-fluorinated carbon atoms are inserted between the perfluorinated carbon chain and the head group. However, in the case of fluorotelomer betaines also xx:1:2 and xx:3 are found. In the latter case, three nonfluorinated carbon atoms are inserted between the perfluorinated carbon chain and the head group. In the case of the xx:1:2 substances, an additional fluorinated carbon is inserted between the perfluorinated alkyl chain and the non-fluorinated spacer. Based on the manufacturing dates that are cited in the respective publications, it can be assumed that the use of fluorotelomers in fire-fighting foams began later than the use of traditional PFAS substances without a non-fluorinated spacer. The following head groups have been identified: Alkylbetaine (AB); Betaine (B); 77 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Carboxylic acid (CA); Hydroxy (OH); Thioamido sulfonates (TAoS); Unsaturated carboxylic acid (UCA); Sulfonamido betaines (SaB); Sulfonamide amine (SaAm); and Thio hydroxy ammonium (THN+). Table B.9 Fluorotelomer (identified by CAS) substances incl. CAS/EC identifier, the designation, the acronym and the supplier and/or product name CAS EC 34455-35-1 N/a 53826-13-4 N/a 70887-84-2 N/a 278598-45-1 757124-72-4 N/a 816-391-3 Designation (synonyms) 10:2 Fluorotelomer sulfonamide alkylbetaine Acronym 10:2 FTAB 10:2 Fluorotelomer carboxylic acid 10:2 FTCA 10:2 fluorotelomer unsaturated carboxylic acid 10:2 FTUCA Fluorotelomer sulfonamido betaines Fluorotelomer sulfonates 12:2 FtSaB 4:2 FTS Supplier and Product Name F-500, Hazard Control Tech., 1997 National Foam 2005 National Foam 2007 National Foam 2008 Fire Service Plus AFFF 2011 National Foam 2003-2008 No product/supplier is mentioned; Publications are based on environmental samples No product/supplier is mentioned; Publications are based on environmental samples 3M Ansul, 2006 Ansul Anulite ARC Angus Fire, 2004 Tridol S 3% Ansul 2002 Anslite 3% AFFF-DC-6 Hazard Control Tech 1197 F-500 National Foam 78 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS CAS EC 1432486-88-8 N/a 171184-02-4 N/a 171184-14-8 34455-29-3 N/a 252-046-8 647-42-7 211-477-1 Designation (synonyms) Acronym 4:2 fluorotelomer thioamido sulfonates 4:2 FtTAoS 5:1:2 fluorotelomer betaine 5:1:2 FTB 5:3 fluorotelomer betaine 6:2 Fluorotelomer sulfonamide betaine 5:3 FTB 6:2 FTAB 6:2 Fluorotelomer alcohol 6:2 FTOH Supplier and Product Name Ansul AFFF formulations Angus Fire, 2004 Tridol S Ansul, 2002 Ansulite 3% AFFF DC-3 Ansul, 2006 Ansul Anulite ARC Hazard Control Tech., 1997 F-500 Chemguard Ansul Angus 3M Ansul, 2002 Ansulite 3% AFFF DC-3 Buckeye 2009 Buckeye AFFF 2004 3M Buckeye Chemours, STHAMEX -AFFF 3% F-15 #4341 Dupont Forafac 1157 Dr. Sthamer, 3M National Foam F-500, Hazard Control Tech., 1997 (Foam 1) Angus Fire, 2004 Tridol S Angus Fire, 2000 Niagara 1-3 Chemours No product/supplier is mentioned; Publications are based on environmental samples 79 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS CAS 27619-97-2 EC 248-580-6 1383438-86-5 N/a 88992-47-6 N/a 88992-46-5 N/a 171184-03-5 N/a 171184-15-9 N/a 27854-31-5 N/a Designation (synonyms) 6:2 Fluorotelomer S ulfonate Acronym 6:2 FTS 6:2 fluorotelomer sulfonamide amine 6:2 FtSaAm 6:2 fluorotelomer thioether amido sulfonic acid 6:2 FtTAoS 6:2 fluorotelomer thio hydroxy ammonium 7:1:2 fluorotelomer betaine 7:3 fluorotelomer betaine 6:2 FtTHN+ 7:1:2 FTB 7:3 FTB 8:2 Fluorotelomer carboxylic acid 8:2 FTCA Supplier and Product Name Dr. Richard Sthamer GmbH & Co. KG STHMEX-AFFF 3% Hazard Control Tech., 1997 F-500 Angus Fire, 2004 Tridol S 3 % Angus Fire, 2000 ; Niagara 1-3, Angus Fire, 1997; Forexpan Angus Fire, 2004 Tridol S 3 % Ansul, 2002 Ansulite 3 % AFFF - DC-4 Ansul, 2006; Ansul Anulite ARC National Foam 2005 National Foam 2007 National Foam 2008 (slightly different shares) 3M, National Foam 2005 National Foam 2007 National Foam 2008 (slightly different shares) Angus Fire, 2004 Tridol S Ansul 1986 Ansul 1987 Angus Fire, 2000 Niagara 1-3 Ansul, 2002 Ansulite 3% AFFF DC-3 Ansul 2009 Ansul 2010 Chemguard 2008 F-500, Hazard Control Tech., 1997 3M 3M Buckeye 2009 Buckeye Ansul, 2002 Ansulite 3% AFFF DC-3 F-500, Hazard Control Tech., 1997 80 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS CAS EC 34455-21-5 N/a 39108-34-4 254-295-8 1383439-45-9 N/a 171184-04-6 N/a 171184-16-0 N/a Designation (synonyms) 8:2 Fuorotelomer sulfonamide betaine Acronym 8:2 FTAB Fluorotelomer sulfonates 8:2 FTS 8:2 fluorotelomer thioamido sulfonates 8:2 FtTAoS 9:1:2 fluorotelomer betaine 9:1:2 FTB 9:3 fluorotelomer betaine 9:3 FTB Supplier and Product Name National Foam, F500, Hazard Control Tech., 1997 National Foam 2005 National Foam 2007 National Foam 2008 (slightly different shares) Fireade Ansul, 2002 Anslite 3 % AFFF - DC-5 Hazard Control Tech., 1997 F-500 Angus Fire, 2000 ; Niagara 1-3, Angus Fire, 1997; Forexpan National Foam 2005 National Foam 2007 National Foam 2008 Chemguard, Ansul, 2006; Ansul Anulite ARC; Ansul, 2002 Ansulite 3% AFFF DC-3 Angus Fire, 2004 Tridol S Angus Fire, 2000; Niagara 1-3 Hazard Control Tech., 1997 F-500; 3M Buckeye AFFF 2004 Buckeye 2009 Buckeye 2009 3M 1988 3M 1989 3M 1993A 3M 1993B 3M 1998 3M 2001 Ansul, 2002 Ansulite 3% AFFF DC-3 In addition to this table, a hierarchical clustering was elaborated. This is shown in the figure below. 81 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Figure B.4 Hierarchical clustering of identified fluorotelomers Other PFAS substances In some cases, perfluorinated substances that do not belong to any of the named groups (long-/short-chain PFAS, fluorotelomers, and derivates of PFAS) were identified (Others). These substances are shown in the table below. Also shown below is the substance Dodecafluoro-2-methylpentan-3-one, a fluorinated ketone. 82 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Figure B.5 Chemical structure of Dodecafluoro-2-methylpentan-3-one, a fluorinated ketone Table B.10 Other per- or polyfluorinated substances (identified by CAS) incl. CAS/EC identifier, the designation, the acronym and the supplier and/or product name CAS 1280222-90-3 756-13-8 161278-39-3 70969-47-0 70829-87-7 13269-86-8 EC 480-310-4 616-243-6 / 436710-5 500-631-6 N/a N/a 236-267-7 Designation (synonyms) Acronym ammonium 2,2,3 trifluor-3(1,1,2,2,3,3hexafluoro-3trifluormethoxypropo xy), propionate ADONA Dodecafluoro-2- N/a methylpentan-3-one Poly(1,1,2,2- N/a tetrafluoro-1,2- ethanediyl), -fluoro- -2-[3- ((carboxylatomethyl) dimethylammonio)pr opylaminosulfonyl]et hyl- Thiols, C8-20, gamma-omegaperfluoro, telomers with acrylamide Thiols, C8-20, gamma-omegaperfluoro, telomers with acrylamide Sodium pperfluorous nonenoxybenzene sulfonate OBS Bis(trifluorovinyl)eth N/a er Supplier and Product Name Mentioned in annex_xv_svhc_ec_ 206-3979_pfoa_11549 as a substitute. However, no other source for this information. 3M NOVEC TM 1230 PROFOAM Profilm AFFF Towalex 3% master No product/supplier is mentioned; Publications are based on environmental samples Fire-extinguishing foam cited in Nordic working paper Conclusions from the substance identification In this substance identification process, three substance classes, that are/were used in firefighting foams, were considered: fluorine-free replacements, PFAS substances, and fluorinated but not-PFAS alternatives. The main outcomes of this task are as follows: 83 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS For the latter substance class (fluorinated but not-PFAS alternatives) no substances were found, as also confirmed by experts; In the case of PFAS substances, various carboxylic/sulfonic short- and long chain PFAS were found. Additionally, also a variety of fluorotelomers. These substances differ in chain length and substitution and only a relatively small amount of these substances could be identified by CAS/EC number. Furthermore, other PFAS substances were found, that do not belong to any of the named PFAS-categories; and The identified fluorine-free PFAS-replacements can be grouped into four classes: hydrocarbons, detergents, siloxanes and proteins. For the latter two classes, the gathered information and the amount of identified substances are relatively small. In the case of the siloxanes, the usage of these substances in firefighting foams is still under development. In contrast to this, a variety of hydrocarbons (around 24) and detergents (33) were identified, that are used as a replacement for PFASsubstances. In summary, a large number of highly diverse PFAS substances were found in the context of use in fire-fighting foams. This could be an indication of extensive replacement chemistry that was initiated due to industry and regulatory concerns about the potential health and environmental impacts of long-chain PFAS and lately also short-chain PFAS. Bibliography for Section B.1.1.1. Barzen-Hanson, K. A., Field, J. A. (2015): Discovery and Implications of C2 and C3 Perfluoroalkyl Sulfonates in Aqueous Film-Forming Foams and Groundwater. Environmental Science & Technology Letters, 2(4), 95-99. Buck, R. C., Franklin, J. , Berger, U. , Conder, J. M., Cousins, I. T., de Voogt, P. , Jensen, A. A., Kannan, K. , Mabury, S. A. and van Leeuwen, S. P. (2011), Perfluoroalkyl and polyfluoroalkyl substances in the environment: Terminology, classification, and origins. Integr Environ Assess Manag, 7: 513-541. doi:10.1002/ieam.258 Du, Z., Deng, S., Liu, D., Yao, X., Wang, Y., Lu, X.,Yu, G. (2016). Efficient adsorption of PFOS and F53B from chrome plating wastewater and their subsequent degradation in the regeneration process. Chemical Engineering Journal, 290, 405-413. doi:https://doi.org/10.1016/j.cej.2016.01.077 Harding-Marjanovic, K. C., Houtz, E. F., Yi, S., Field, J. A., Sedlak, D. L., Alvarez-Cohen, L. (2015): Aerobic Biotransformation of Fluorotelomer Thioether Amido Sulfonate (Lodyne) in AFFF-Amended Microcosms. Environmental science & technology, 49(13), 7666-7674. Hetzer, R., Kmmerlen, F., Blunk, D. Auf dem Weg vom Siloxantensid zum fluorfreien AFFF. Hetzer, R., Kmmerlen, F., Wirz, K., Blunk, D. (2014): Fire testing a new fluorine-free AFFF based on a novel class of environmentally sound high-performance siloxane surfactants. Fire Safety Science, 11, 1261-1270. Hetzer, R. H., Kmmerlen, F. (2016): The Extinguishing Performance of Experimental Siloxane-Based AFFF. Hetzer, R. H., Kmmerlen, F., Blunk, D. (2015). Fire Testing of Experimental Siloxane-Based AFFF: Results from New Experiments. Paper presented at the Conference Paper, Suppression, Detection and Signaling Research and Applications Symposium (SUPDET 2015), Orlando (Florida, USA). ECD 2018: Toward a new comprehensive global database of per- and polyfluoroalkyl substances (PFASs): Summary report on updating the OECD 2017 List of per- and polyfluoroalkyl substances (PFASs). Available at: 84 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS https://www.oecd.org/officialdocuments/publicdisplaydocumentpdf/?cote=ENV-JMMONO(2018)7&doclanguage=en Wang, D. Z., Goldenman, G., Tugran, T., McNeil, A., & Jones, M. (2020). Per- and polyfluoroalkylether substances: identity, production and use. Retrieved from Copenhagen: https://doi.org/10.6027/NA2020-901. Available at: http://urn.kb.se/resolve?urn=urn:nbn:se:norden:org:diva-5872. B.1.2. Composition of the substance(s) Based on ECHA's guidance for the preparation of an Annex XV dossier for restrictions, this section should present for each constituent/ impurity/ additive (particularly for those which influence the outcome of the dossier) the following information: Chemical Name EC Number CAS Number IUPAC Name Molecular Formula Structural Formula Molecular Weight Typical proportion % Real proportion (range) in % Chemical name, EC and CAS numbers are provided in the previous section. However, the other pieces of information have not been collected for the present study (with the exception of some example molecular structures provided in the previous section). This reflects that a large number of relevant substances has been identified and that the information is not considered to affect the outcome of the dossier, which proposes a restriction not of the individual substances but rather for the use of PFAS in fire-fighting foams as a group based on the definition provided in Section 1.1.1.7. B.1.3. Physicochemical properties Physicochemical properties of the substances have not been reviewed in detail here, for the same reasons as highlighted under `composition' above. This may need to be considered further when any full Annex XV dossier is drawn up. B.1.4. Justification for grouping See Section 1.1.2. B.2. Manufacture and uses (summary) The table below summarises some of the key results that have been discussed in more detail above (Annex A). 85 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Table B.11 Summary of key preliminary market analysis results PFAS-based fire-fighting foams Fluorine-free alternatives Tonnage of foam used [1] 14,000-20,000 tonnes per year 7,000-9,000 tonnes per year Tonnage by substance / Substances most commonly used 480-560 tonnes of fluorosurfactants used annually in EU. Breakdown of tonnage for 8 substances available (see Table A.1 in Annex A and directly below the table), but for majority of tonnage the substances are not known. No quantitative data. Main alternatives used are based on hydrocarbon surfactants and detergents. Specific products are discussed in Annex E.2 (analysis of alternatives). Breakdown of tonnage by use sector Chemical/Petrochemical: 59% Municipal fire brigades: 13% Marine applications: 11% Airports: 9% Military: 6% Ready for use products: 1% Chemical/Petrochemical: 29% Municipal fire brigades: 44% Marine applications: 16% Airports: 7% Military: 2% Ready for use products: 1% Prices Average (uncertain): 3 Reported range: 2 to 30 per litre Average (uncertain): 3 Reported range: 0.7 to 10 per litre Revenues [2] Best estimate: 60 million Potential range: 28-600 million Best estimate: 27 million Potential range: 5-90 million Functions provided and types of fires used for Surfactant to form a film over the burning surface. Particularly relevant for fire involving flammable liquids (Class B fires). Consultation suggests it is used both in training and true emergency responses. Those fluorine-free foams considered alternatives to PFASbased foams in principle provide the same (or a similar) function. Consultation suggests it is used both in training and true emergency responses, but in some cases in training only. Trends Rapid shift from PFAS towards fluorine-free foam in recent years, expected to continue. Notes: [1] The original data from Eurofeu covers approximately 70% of the market, therefore this has been inflated to reflect the whole market. The lower end of the range represents the original data, whilst the upper end represents the extrapolation to the whole market. [2] The best estimate is based on the upper end of the quantity range and a weighted average price of 3/litre. The potential range is based on the lower end of the quantity range multiplied with the lower end of the price range, and the upper end of the quantity range multiplied with the upper end of the price range. An average density of 1 kg/litre has been assumed. B.3. Classification and labelling To avoid duplication with the ongoing work of the PFAS working group, a review of the classification and labelling has not been undertaken. 86 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS B.4. Environmental fate properties B.4.1. Mobility and persistence PFAS is a term used to cover approximately 4,700 specific chemical species82. Longer chain ( C8) PFAS compounds have been used within industry as surfactants specifically because of their potent water and oil repellence at low concentrations (Buck, 2011). Prior to 2000 the use of PFAS within fire-fighting foams in Europe utilised the salts of C8 PFAS compounds such as PFOS and PFOA, particularly the ammonium salt of PFOA (APFO) (CAS 3825-26-1)83. As of the late 1990s growing concerns around longer chain PFAS compounds highlighted that they were highly mobile in the aquatic and terrestrial environment, highly persistent, and had the capability to bioaccumulate up food chains84. Many longer chain PFAS species also had toxic effects identified. The ECHA SVHC nomination dossier for PFOA (2013) indicated that PFOA (from the ammonium salt) is readily absorbed by the body and can pass to the foetus (by blood) and child (by mother's milk), and concentrates in the blood, liver and kidneys with toxic effects. The nomination also notes that the RAC identified sufficient scientific evidence to conclude that PFOA could also be a reproductive toxin for the unborn child. Concerns over the mobility and persistence of longer chain PFAS substances, along with potential health effects led to an industry initiative in the early to mid-2000s to switch to shorter chain ( C6) PFAS alternatives (UNECE, 2004). For fire-fighting foams this includes the salts of C6 or lower based PFAS substances85. However, concerns have continued that shorter chain PFAS substance are also mobile (if not more mobile) than C8 substances and are highly persistent albeit with potentially lower bioaccumulation86. The table below provides as an example of the mobility of PFAS compounds with different carbon chain lengths (based on log Koc) as an indicator that shorter chain PFAS are likely to be highly mobile. Kjolholt (2015)87 indicates that WWTPs are likely to be ineffective against shortchain PFAS, just as they are also ineffective against longer chain PFAS compounds. Table B.1 Overview of PFAS substances mobility using log Koc Carbon chain length PFCAs 11 10 9 Species Perfluoroundecanoate (PFUnDA) Perfluorodecanoate (PFDA) Perfluorononanoate (PFNA) CAS number 2058-94-8 335-76-2 // 3830-45-3 // 3108-42-7 375-95-1 Log KOC 3.3 to 3.56 2.76 to 2.96 2.36 to 3.69 82 OECD, 2018, PFAS database, toward a new comprehensive global database of per and polyfluoroalkyl substances. 83 Stockholm Convention risk management evaluation dossier for PFOA, its salts and related compounds UNEP/POPs/POPRC.14/6/Add.2 84 UNECE, 2004, PFOS dossier for purpose of nominating PFOS to the LRTAP Protocol and Stockholm Convention. 85 Tyco fire protection, 2016, `Transition if the firefighting foam industry from C8 to C6 fluorochemistry'. 86 Cousins et al, 2018, `short-chain perfluoroalkyl acids: environmental concerns and regulatory strategy under REACH', Environmental science Europe vol 30. 87 Kjoltholt et al, 2015, `short chain polyfluoroalkyl substances (PFAS) a literature review of information on human health effects and environmental fate and effect of short chain PFAS', Danish Ministry for Environment. 87 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS 8 Perfluorooctanoate(PFOA) 335-67-1 1.89 to 2.63 8 Perfluorooctane sulfonate (PFOS) 1763-23-1 2.4 to 3.7 6 Perfluoroheptane sulfonate (PFHxS) 355-46-4 2.4 to 3.1 6.1 Perfluorohexanoate (PFHxA) 307-24-4 1.3 4 Perfluorobutane sulfonate (PFBS) 375-73-5 // 59933-66-3 1.2 to 1.79 4 Perfluorobutanoate (PFBA) 375-22-4 1.9 Fluorotelomers 8 8:2 Fluorotelomer alcohol (8:2 FTOH) 678-39-7 4.13 6 6:2 Fluorotelomer alcohol (6:2 FTOH) 647-42-7 2.43 4 4:2 Fluorotelomer alcohol (4:2 FTOH) 2043-47-2 *reference ITRCP PFAS factsheet. https://pfas-1.itrcweb.org/ 0.93 B.4.1. Degradation This has not been assessed in detail in this study, beyond the discussion of persistence above. B.4.2. Environmental distribution This has not been assessed in detail in this study. B.4.3. Bioaccumulation This has not been assessed in detail in this study. B.4.4. Secondary poisoning See Section B.9.6. B.5. Human health hazard assessment A PFAS working group exists under ECHA's stewardship to assess the hazards associated with PFAS substances, including persistence, mobility, bioaccumulation and toxicity. It is expected that the ongoing work of the PFAS working group could form the basis of the hazard assessment needed for any future restriction proposal under REACH. To avoid conflicting with the work of the PFAS working group an in-depth assessment of the hazards for PFAS substances (as a family of chemicals used for fire-fighting foams) has not been completed under the current study. High level comments on the hazards associated with PFAS substances are provided in Section 1.1.4. However, in order to assess the potential human health and environmental impacts of a potential restriction, the hazards of fluorine free alternatives to PFAS-based fire-fighting foams were assessed in more detail. 88 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Review of hazards of fluorine-free alternatives In this sub chapter the hazards of the identified fluorine-free alternative substances have been assessed based on their PNEC (Predicted No Effect Concentration). As highlighted in ECHAs guidance document on information requirements and chemical safety assessment (Chapter R.10: Characterisation of dose [concentration]-response for environment)88, the PNEC represents "the concentration of the substance below which adverse effects in the environmental sphere of concern are not expected to occur". Mostly, PNEC values are derived from acute and chronic toxicity single-species or multi-species data. To extrapolate from this data, an empirical assessment factor is necessary to make assumptions for the entire ecosystem. In combination with predicted environmental concentration (PEC) values PNECs are used to calculate a risk characterisation ratio. For this the PEC is divided by the PNEC, thus if the PNEC exceeds the PEC, it can be concluded that there is no environmental risk based on the concentration of the observed substance. However, in this project, the sole consideration of a PNEC value is not advisable, based on the uniqueness of PFAS substances. In an ecotoxicological assessment, this uniqueness is for example expressed by the fact that they are not biodegradable. ECHA's guidance document highlights that the "degradation of organic substances in the environment influences exposure and, hence, it is a key parameter for estimating the risk of long-term adverse effects on biota"89. Thus, in the following not only PNECs but also data on biodegradation and bioaccumulation is considered. It should be noted that the following considerations are not meant as a full risk assessment; they are meant rather as an indicative comparison of the identified substances among each other and against the fluorinated substances. Based on their REACH registration dossiers it was possible to identify most of the PNECs, biodegradation and bioaccumulation data of the fluorine-free alternative substances and the selected fluorinated substances. In the following table an overview of the substances, their respective products, CAS numbers, PNECs, bioconcentration factors (BCFs), and biodegradation assessments are given. Due to the focus of this project the PNECs for freshwater and soil were considered. Table B.1 Overview on substances used in fluorine-free fire-fighting foams and one substance used in a fluorinated foam. Shown are the product, CAS/EC, PNECs, and the used reference. The respective lowest PNECs are highlighted in bold. Substance 1-dodecanol Product Respondol ATF 3/6 CAS PNEC aqua (freshwat er) mg/L PNEC soil (mg/kg soil dw) Biodegradation (... biodegradabl e in water) Bioaccumul ation (BCF) Reference 112-53-8 0.001 0.132 Readily 750 ECHA RD 88 https://echa.europa.eu/documents/10162/13632/information_requirements_r10_en.pdf 89 https://echa.europa.eu/documents/10162/13632/information_requirements_r7b_en.pdf 89 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Substance Product 1-tetradecanol Respondol ATF 3/6 Sodium laureth sulphate Respondol ATF 3/6 Alkylamidobetai ne Moussol FF 3x6 Re-Healing Foam RF1 1% 1,2-ethandiol Moussol FF 3x6 Orchidex BlueFoam 3x4 Triethanolammo niumlaurylsulfate Moussol FF 3x6 sodium decyl sulphate ( - ) Re-Healing Foam RF1 1% amides, coco, N-[3(dimethylamino )propyl] ( - ) Re-Healing Foam RF1 1% amides, coco, N[3(dimethylamino)p ropyl], N- oxides ( - )sucrose ( - ) Re-Healing Foam RF1 1% sulfuric acid, mono-C12-14alkyl esters, compds. with triethanolamine ( - ) Re-Healing Foam RF1 1% 1Propanaminium,N(carboxymethyl)N,N-dimethyl-3[[(3,3,4,4,5,5,6,6, 7,7,8,8,8tridecafluorooctyl) sulfonyl]amino],inner salt AFFF 1-Propanaminium, 3-amino-N(carboxymethyl)N,N-dimethyl-N[[(gamma-omegaperfluoro-C6-C16alkyl)thio]acetyl] AFFF CAS PNEC aqua (freshwat er) mg/L PNEC soil (mg/kg soil dw) Biodegradation (... biodegradabl e in water) Bioaccumul ation (BCF) Reference 112-72-1 0.0063 0.428 Readily 1000* ECHA RD 6889138-3 6178940-0 0.24 0.0032 0.0917 Readily 0.0419 Readily waived ECHA RD 71* ECHA RD 107-21-1 10 1.53 Readily waived ECHA RD 8566545-8 0.017 142-87-0 0.095 0.042 Readily 0.2445 Readily 6814001-2 No data 6815509-9 0.0059 3.68 Readily 9058318-9 0.012 0.083 Readily waived ECHA RD waived ECHA RD No data ECHA RD No data ECHA RD 3445529-3 0.0326 0.00133 Not readily 450 ECHA RD 8047532-7 0.009 1.17 Not readily No data ECHA RD 90 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Substance Product CAS PNEC aqua (freshwat er) mg/L PNEC soil (mg/kg soil dw) Biodegradation (... biodegradabl e in water) Bioaccumul ation (BCF) Reference derives., inner salts Explanatory note: Waived means, that the test was not required due to the results of other tests. *An asterisk means, that this value was extrapolated based on calculations. It is observable that the two fluorinated substances (CAS 34455-29-3 and 80475-32-7) are the only substances that are "not readily biodegradable in water" (data on biodegradation in soil is not available in the registration dossier)90. In addition, the substance with CAS 34455-29-3 also has the lowest PNEC for soil, meaning that, at concentrations higher than 1,33 g/kg (ppb) a risk cannot be excluded. The combination of this value and with its relatively low PNEC for freshwater (0.0326 mg/l), shows, that this substance exhibits more hazard to the environment than any of the non-fluorinated substances. This finding is also supported by the fact that the treatment at WWTPs is ineffective (as shown in the previous subchapter). In terms of partitioning the fluorinated substance CAS 34455-29-3 has a log koc of 1.5, suggesting strong partitioning to treated effluent within WWTPs and release to surface water. Use during live incidents is assumed to be released equally to surface water and soil. This may suggest that the bigger impact for soils would come from live incidents. However, some of the alternatives have both relatively low PNECs and relatively high biodegradation and/or bioaccumulation data. This is true for two alcohols (1-dodecanol and 1tetradecanol). However, in comparison to the two fluorinated substances listed in the table above, both of the non-fluorinated substances are readily biodegradable due to the rapid metabolism of long-chain fatty alcohols in fish, mammals and microorganisms (based on information taken from their registration dossiers). That means that, even if the substance is emitted to the environment in the context of a release from WWTPs or live incidents, it will be biodegraded rapidly. Furthermore, as highlighted in the previous section, based on these properties it could be expected that waste water treatment plants would have a high level of efficacy for the destruction of these substances. Taken together, this review of hazards based on PNECs and data on biodegradation and bioaccumulation shows, that the two fluorinated substances should be considered of higher priority compared to the non-fluorinated substances when it comes to hazards and potential risks to the environment. This is due to the PFAS being both non-biodegradable and having relatively low PNECs for water and soil. Some of the alternative substances exhibit low PNECs, however, this needs to be considered in the context of their ready biodegradation. Further discussion on the hazards of the shortlisted alternatives can be found in Section E.2.. 90 https://echa.europa.eu/de/registration-dossier/-/registered-dossier/17549/1 91 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS B.5.1. Toxicokinetics (absorption, metabolism, distribution and elimination) Not assessed in this study. B.5.2. Acute toxicity Not assessed in this study. B.5.3. Irritation Not assessed in this study. B.5.4. Corrosivity Not assessed in this study. B.5.5. Sensitisation Not assessed in this study. B.5.6. Repeated dosed toxicity Not assessed in this study. B.5.7. Mutagenicity Not assessed in this study. B.5.8. Carcinogenicity Not assessed in this study. B.5.9. Toxicity for reproduction Not assessed in this study. B.5.10. Other effects Add text B.5.11. Derivation of DNEL(s)/DMEL(s) B.6. Human health hazard assessment of physicochemical properties Not assessed in detail, see explanation in B.5. 92 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS B.7. Environmental hazard assessment Not assessed in detail, see explanation in B.5. B.8. PBT and vPvB assessment Not assessed in detail, see explanation in B.5. B.9. Exposure assessment B.9.1. General discussion on releases and exposure An exposure assessment was not in the scope of this study. However, Section B.9 presents estimates of the emissions of PFAS and of the constituents of the alternative fluorine-free firefighting foams to the environment, broken down by environmental compartment (Section B.9.3) and discusses the possible uptake by humans via the consumption of food and water (Section B.9.6). B.9.1.1. Summary of the existing legal requirements See Section 1.3.3. B.9.1.2. Summary of the effectiveness of the implemented operational conditions and risk management measures See Section 1.3.4. B.9.2. Manufacturing As discussed previously, this dossier focuses on the use of PFAS in fire-fighting foams. The manufacturing of PFAS has not been considered. However note that emissions from the formulation of PFAS-based fire-fighting foams are considered within the following section. B.9.3. Use 1: Fire-fighting foams B.9.3.1. General information The focus of this task is to estimate the emissions of PFAS and of the constituents of the alternative fluorine-free fire-fighting foams to the environment, broken down by environmental compartment (atmospheric, aquatic, and terrestrial environments) and the possible uptake by humans via the consumption of food and water. The development of emission estimates is expected to follow the relevant guidance provided by ECHA91. During the inception meeting it was clarified that the study should help to understand the emission pattern throughout the life cycle so that releases can be compared across foam products. For example, how much foam is used; how much of it is collected; how much is then 91 See available guidance documents at: https://echa.europa.eu/guidance-documents/guidance-on-reach 93 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS incinerated; do the foams contaminate other environmental compartments and if so, how much ends up in each compartment? Therefore, rather than using risk assessment models such as EUSES, a source-flow approach has been applied. Due to the persistent nature of PFAS and non-threshold effects, releases of PFAS are of primary importance, and these are to be considered a proxy for exposure, as discussed at the inception meeting. The starting point for this task, therefore, has been to focus on releases and to compare those amongst PFAS-based foams and the alternatives. It was agreed at the inception meeting that, only if the alternatives are particularly hazardous for the environment should modelling be considered92. One further point to note is that the emission estimates that have been developed are intended to provide an illustrative assessment to help better understand the material flow and key emission compartments. The findings presented here are not a detailed risk assessment and are not presented within any geographical disaggregation based on identified sites in the European Union. B.9.3.2. Approach B.9.3.2.1. Development of the source-flow model Based on guidance from ECHA, the UNECE inventory guidebook93, and OECD Emission scenario document for AFFF a basic source-flow model has been developed to make use of the data from the market analysis and substance identification (as a Microsoft Excel workbook). The development of this source-flow approach began with a consideration of what might be the key life-cycle stages and what kinds of emissions may occur at each life-cycle stage, which has incorporated the approach used within the PFOA restriction dossier under REACH. Based on this analysis the model development began with four basic life-cycle stages where it was possible for emissions to occur, or material to flow through into the next life cycle stage: Formulation of the fire-fighting foam concentrate. This includes consideration of the PFAS and fluorine-free substances used as surfactants within the foam concentrate. Note, that it was assumed that the life-cycle begins at this stage rather than the manufacture of the surfactants themselves. This distinction is made on the basis that the manufactured surfactants may have multiple applications, not limited to only fire-fighting foams. The full range of possible 92 If it is decided that modelling of exposure is useful the type of modelling usually applied for exposure estimation within risk assessment of chemicals is based on fugacity (i.e. the propensity for a substance, based on its physicochemical properties - such as the octanol-water partition coefficient and Henry's law constant), to move from one environmental medium to another. In this case the partitioning between interstitial water and organic carbon within the soil matrix will be of high significance, when foams are used for land-based fires and runoff is not contained by a bund. Comparison with reliable measured data is a useful validation of the model method used. 93 https://www.eea.europa.eu/themes/air/emep-eea-air-pollutant-emission-inventory-guidebook/emep 94 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS applications for a given PFAS or fluorine-free surfactant is outside the scope of the current study. Storage. Storage is considered a key life cycle stage with quantities of foam concentrate reaching expiry before active use94. During storage of foam concentrate it may be possible for leaks or spillages to occur, which directly contribute to environmental emissions. However, for usage sites (airports, refineries, terminals, industrial sites and military sites), appropriate risk management systems will generally be in place meaning that such leaks/spillages can be contained from direct release and will more likely act as an input to the waste/waste water system (e.g. sewers). Efficacy and management of materials put to sewer are further managed under waste. In-use. Active use of fire-fighting foams forms likely the most important life-cycle stage. The model developed defines two types of use. Firstly `training' exercises, which are assumed to happen within contained conditions (i.e. bunding / capture systems are in place to capture and retain runoff)95; and secondly `live' incidents which assumes no containment and full loss to the environment (following the approach adopted with the PFOA Annex XV dossier)96. Waste. The waste cycle includes two key pathways. Firstly, incineration of any expired stocks of foam concentrate. Secondly waste water treatment works processing of materials from leaks/spillage during storage, plus some runoff from training exercises. Formulation of the fire-fighting concentrate The model has been designed to allow calculation of both quantities of fire-fighting foams manufactured within the European Union, and quantities of finalised fire-fighting foam concentrate imported and used in the EU. Only quantities manufactured within the European Union are assumed to lead to emissions and exposure at the formulation stage. The PFOA Annex XV dossier assumes default worst case emission rates of 2.5% w/w to air, 2% w/w to water (assumed to be waste water system rather than direct release) and 0.2% to soil as a direct release from spillages / deposition during manufacture. In the absence of better data, the same release rates have been applied to the non-fluorinated alternatives. Storage Following manufacture and sale, the fire-fighting foam concentrates will pass into the storage phase of the life-cycle. A proportion of the annual sales will also go directly into use (see inuse phase), with the remainder held in store, sometimes for several years. Data on leakage 94 BiPRO, 2010, Study on waste related issues of newly listed POPs and candidate POPs - comments that the average lifespan of firefighting foams is 15 years. 95 It is recognised based on the stakeholder engagement that the standard of containment for training run-off has in the past not been optimal. However, because of the concerns raised around substances such as PFOS, it can be expected that the standards in use currently are a significant improvement upon standards from the early 2000s. 96 ECHA, 2018, `Background document - to the Opinion on the Annex XV dossier proposing restrictions on Perfluorooctanoic acid (PFOA), PFOA salts and PFOA-related substances', ECHA/RAC/RES-O-0000006229-70-02/F and ECHA/SEAC/RES-O-0000006229-70-03/F 95 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS rates / spillages was not identified during the study, and therefore a value based on expert judgement of 1% of total stocks has been applied. In-use phase The "in-use" phase of the model was then further refined to incorporate different kinds of use and application and how these may affect the type of emission and usage rate (i.e. use at airports vs municipal fire brigades for example). This included data from Eurofeu (see Annex A) on industry sector splits, and data from Brooke et al (2004)97 which highlighted that most of the fire-fighting foam in the private sector is used for training (93% w/w). In the absence of better data, it was assumed that, for public fire brigades, use will predominantly be focused on live incidents with a smaller quantity used for training, assumed to be 93% on live incidents and 7% on training. Data from BiPRO (2010)98 and Buser et al (2009)99 quote usage rates of between 15% and 20% annually100. The source-flow model therefore assumes usage rates of 17.5% for the majority of sectors. However, for the public fire service sector a usage rate of 50% per annum has been used101. The justification for this modification is that based on a survey of UK fire authorities public fire services primarily use fire-fighting foams for live incidents a quicker turnaround of stockpiles may be expected. A usage rate of 50% assumes a high rate of use for quantities purchased annually, with stockpiling of 50% to safeguard against larger emergency events where greater quantities of foam may be needed. Finally, for training exercises, a factor has been added for the efficacy of bunding / control measures designed to manage run-off of fire-fighting waters during the training exercise. Extremely limited data was available on these aspects and therefore best estimates have been made based on expert judgement. Efficacy of the bunding for terrestrial applications was extrapolated to estimate ranges from 90-97% (assuming captured waters are passed to sewer / on site waste water treatment)102, while for marine applications it is assumed all run-off is permitted to be released directly to sea with no capture and control. For live incidents we have used the values quoted within the REACH Annex XV dossier for PFOA, which assumes a 100% 97 Brooke et al (2004), "Environmental risk evaluation report: Perfluorooctanesulphonate (PFOS), Report produced for the England and Wales Environment Agency. 98 BiPRO (2010), "Study on waste related issues of newly listed POPs and candidate POPs", Commission report under framework ENV.G.4/FRA/2007/0066. 99 Buser et al (2009), `Substance flow analysis of PFOS and PFOA in Switzerland. Environmental Studies 0922. Federal Office for the Environment, Bern. 100 BiPRO 2010 base their estimates on usage rates against a survey of UK fire authorities completed by RPA in 2004. This suggested that annually 15% of total stocks are used across all sectors (public and private). Usage rates by municipal fire and rescue services were higher at between 40% and 50%. Buser et al 2009 base their estimates on remaining stocks of PFOS within all sectors (public and private services) using 20% of all stocks annually. To maintain a steady flow of business it is assumed that both public and private brigades will replace stocks as use occurs, so replacement foam would be purchased annually. 101 RPA, (2004), "Risk reduction strategy and analysis of advantages and drawbacks for PFOS", Report on behalf of Defra. 102 Responses from the stakeholder engagement stated that 100% of training run-off is expected to be captured and retained, however, further statements from fire-fighters indicated that full capture is challenging and not always possible. The model therefore makes an assumption that minor losses will occur equivalent to 3% in the best cases, and at worst 10% for sectors with less well-defined sites of use and capture. 96 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS release (which should be considered a worst-case scenario), split evenly between surface waters and soil. Table B.1 provides further details of how quantities of fire-fighting foam has been manipulated. Table B.1 Industry splits and usage rates based on data from Eurofeu and Brooke et al (2004)* Sector Percentage share of total Annual usage rates (of total quantity sold annually) Live incidents (as a percentage of total use) Training (as a percentage of total use) Efficacy of bunding/control measures for training Military 6% 17.5% 7% 93% 90% Civil Aviation 9% 17.5% 7% 93% 97% Municipal Fire Services 13% 60% 93% 7% 90% Chemical/petrochemical 59% 17.5% 7% 93% 97% Marine Applications 12% 17.5% 7% 93% 0% Ready to use 1% 17.5% 100% 0% N/A applications *For live incidents a 100% release is assumed split evenly between releases to surface water and soil. In the case of marine applications this is a 100% release to sea. Waste phase All material not lost directly to the environment during use will enter the waste phase through a variety of pathways (i.e. capture of run-off; spillages/leaks during storage entering on-site drains; unused foam concentrate which has expired), highlighting this phase's importance in the overall control and release to environment. The waste phase of the model aggregates the quantities of specific substances from different pathways to calculate total quantity per substance within the overall waste phase. This is then managed either by incineration (for end of life unused stocks) or waste water treatment works for retained runoff, losses to sewer from spillage/leakage during storage103. The model then applies two factors, firstly a distribution factor (as Koc104) taken from REACH registration dossiers to understand how the substance partitions between liquid and sludge phases of the waste water process. Then secondly an efficacy factor is applied to reflect how successfully the waste water process destroys the substance, and how much remains unchanged as a direct release to environment. Data on the efficacy of waste water treatment works against named substances was very limited for non-fluorinated alternatives. For the PFAS-based surfactants used in fire-fighting foam concentrates the efficacy is expected to be very low. The model assumes an efficacy of zero with all PFAS substances passing to environment unchanged. For the hydrocarbon-based 103 It is assumed that the sites in question will store these materials in secure areas with either bunding or on-site drainage. If there is a spillage/leak it is assumed that it will be contained and enter the waste systems. 104 Koc = Is a normalised partition coefficient used to calculate how much of a given substance will adsorb to organic matter. It is used as a measure for mobility of a given substance (primarily within terrestrial environments) but can be used as a measure of partitioning between liquid phases and organics within a wastewater treatment works. 97 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS alternatives, some are readily biodegradable, while others with more complex organic structures may be more resistant to degradation. For non-fluorinated alternatives the efficacy ranges from 99% for substances such as alcohols, and as low as 50% for aromatics. The model assumes all waste sludges are then applied to farmland as a release to soil. Note, that while we recognise that this is a common waste management practice for sewage sludge, this is not the case across the EU (for example the application of sewage sludge to land in Denmark is banned). The model acts as a high-level assessment of which compartments are the most important for emissions and key variables affecting emissions. No geopolitical splits are applied to the data for importance of environmental compartments in different Member States. In terms of the proportion of material sent to waste water treatment works and proportion sent for incineration, only limited information was available. It is assumed that all retained run-off water, and losses from spillage/leakage to drain on controlled sites are sent to either onsite WWTWs or municipal WWTWs dependent on the site. The use of incineration would be retained for unused expired fire-fighting foam concentrate, but on this matter, there is conflicting information. A number of references (RPA, 2004; Buser et al 2009; and BiPRO, 2010) suggest usage rates of around 15-20% of existing stocks per annum, with an AFFF shelf-life of up to 15 years, which would suggest all foam concentrate is used before expiration (on average). Discussions held at the 2018 POPs Review Committee (POPRC) meeting on exemptions for PFOA (its salts and related-compounds), included comments from a number of NGOs that significant quantities of expired foam concentrate was destroyed, particularly from private fire brigades, where live use was much less common. The assumed usage rate of 15-20% per annum of existing stocks is an average across all sectors of use. This means that there will be installations with potentially far lower usage rates annually, increasing the potential for quantities to reach expiry before use. However, no data has been identified to quantify the amounts sent for incineration beyond commenting that waste water treatment is likely to be the dominant method for management of material in the waste cycle based on the outputs of the source-flow calculations. The model developed for the current study is a high-level assessment using the available references (including usage rates and shelf-life) meaning that the model assumes no material is sent for incineration. Section E.4 (subsection j. Emissions from disposal of legacy foams) provides some further insight to incineration of PFAS. This notes that, in general, PFAS emissions from incineration are not well studied. However, the chemistry of PFAS makes it resilient to thermal destruction. The US EPA (2019)105 comments on studies (from 2004 and 2014) that showed for PFOA temperatures of 1,000 Celsius and residence time of 2 seconds were sufficient to destroy the PFOA. Kemi (2016)106. comments that more widely for PFAS compounds temperatures of at least 1,100 Celsius are needed, and that longer-chain PFAS species are more readily destroyed (potentially breaking down to shorter chain PFAS compounds), with the CF4 species the most 105 US EPA, 2019, `per and polyfluoroalkyl substances (PFAS): Incineration to manage PFAS waste streams', USEPA innovation report. 106 https://www.kemi.se/global/rapporter/2016/report-11-16-strategy-for-reducing-the-use-of-higly-fluorinatedsubstances-pfas.pdf 98 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS resilient. For CF4 chemistry temperatures of 1,400 Celsius are required, with the breakdown products including carbon dioxide and hydrogen fluoride. As a side note, the industrial emissions directive (2010/75/EU) requires waste incineration plants to operate at temperatures of at least 850 Celsius with residence time of at least two seconds. This would cover standard municipal waste incineration plants. For elevated temperatures >1,000-1,400 Celsius this is likely to require more specialised commercial hazardous waste incineration, noting that a more limited fleet of specialised high-temperature operators exist across Europe. Summary of assumptions applied in the model Table B.2 provides a summary of all factors applied within the model that manipulates the flow of substances from formulation to waste cycle, including emissions at different life-cycle stages. Table B.2 Summary of factors applied to data Life cycle stage Formulation Storage Storage In-Use Training In-Use Training In-Use Training In-Use - Live incidents Description Value Emissions during formulation of firefighting foam concentrates 2.5% w/w to air; 2% w/w to waste water; 0.2% to air Lifespan of concentrate 15 years Annual leak rate / spillage 1% w/w of total stocks Industry sector splits See Table B.1 Usage rates annually See Table B.1 Efficacy of capture systems for run-off Emission to environment See Table B.1 Assumed to be 100%; 50% surface water, 50% soil. For Marine applications 100% sea. Reference PFOA Annex XV dossier - assume same values for nonfluorinated alternatives. BiPRO (2010) Assumed value based on expert judgement. Eurofeu and Brooke et al (2004) BiPRO (2010) and Posner (2019) Assumed value based on expert judgement. PFOA Annex XV dossier. Waste cycle Waste cycle Waste cycle Efficacy of incineration 99%. Note for PFAS based foams could be lower, but in lieu of data assume 99% for all substances, and use of high temperature waste incineration Assumed value based on expert judgement. Partitioning for liquid/sludge Based on Koc values per substance REACH Registrations Efficacy of treatment Varies. For PFAS based substances assumed efficacy is zero. For hydrocarbons assumed efficacy varies from 50% - 99% depending on Feedback from workshop. 99 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Waste cycle Final disposal. complexity and physicochemical properties. Assume treated effluent is direct release to surface water. Assume treated sludge is placed on farm land as direct release to soil. Expert judgement. B.9.3.2.2. Selection of products and substances for emission estimation The selection process for named non-fluorinated substances was intended to identify those substances found in the products most commonly used, and where the hazards for human health and environment were of the greatest concern. To identify these substances a four-step process was followed as detailed below: Step 1 - Collation of all substances The outputs of the substance identification identified 168 non-fluorinated fire-fighting foam commercial products. In practice the surfactant action of the non-fluorinated products required the use of more than one substance, with most products therefore using a combination of named substances. Furthermore, the same substance is often found in multiple products across different manufacturers. However, the named substances identified could be broadly grouped into four categories (as identified in the substance identification): Proteins Siloxanes Hydrocarbons Detergents Step 2 - Most common products Based on the market analysis and stakeholder engagement, the most commonly named products in use were given priority and screened in for the final selection. Based on analysis of the "screened in" set, the highest priority products (most commonly named five) were passed into the next phase. This included: Respondol ATF 3/6 - manufactured by Angus Fire. Moussol FF 3x6 - manufactured by Sthamer Orchidex Bluefoam - manufactured by Orchidee Re-healing foam RF11% - manufactured by Solberg Re-healing foam RF3x6 ATC - manufactured by Solberg Step 3 - Final selection of substances Once the prioritised set of products was identified, the composition of products was identified (using safety data sheets) and hazard classification based on CLP. Using this approach those substances with hazard classifications relating to human or environmental toxicity were selected for use in the source-flow model. 100 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS The table below provides details of the specific substances where emission estimates have been developed. Note where ranges have been provided the upper limit has been used for the calculations as a conservative estimate. 101 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Table B.3 Final selection of substances (substances highlighted in blue selected) - see also footnotes at end of table. Product Respondol ATF 3/6 Respondol ATF 3/6 Respondol ATF 3/6 Respondol ATF 3/6 Substance 1-dodecanol 1-tetradecanol 1-butoxy-2propanol Sulfuric acid, mono-C8-10 (even numbered)-alkyl esters, sodium salts Respondol ATF 3/6 1,2-propanediol Respondol ATF 3/6 Moussol FF 3x6 Sodium laureth sulphate ALKYLAMIDOBETAI NE (SAME EC BUT OTHER CAS) Moussol FF 3x6 1,2-ETHANDIOL Moussol FF 3x6 2-(2BUTOXYETHOXY)ET HANOL Category Detergent Detergent Hydrocarbon Detergent Hydrocarbon Detergent Detergent D Hydrocarbon Hydrocarbon CAS number 112-53-8 112-72-1 131-66-8 5338-42-7 57-55-6 8891-38-3 61789-40- 0 107-21-1 112-34-5 Concentration in product % w/w 0.1 to 1 0.1 to 1 4 to 10 1 to 4 4 to 10 to 4 <5 <10 <10 Hazard classification Eye Irritant. 2 Aquatic Acute 1 Aquatic Chronic 2 Eye Irritant. 2 Aquatic Chronic 1 Skin Irritant. 2 Eye Irritant. 2 Skin Irritant. 2 Eye Damage. 1 Not classified kin Irritant. 2 Eye Damage. 1 Aquatic Chronic 3 Skin Irritant. 2 Skin Sensitiser. 1 Eye Irritant. 2 Aquatic Chronic 3 Acute Toxicity. 4 * STOT RE 2 Eye Irritant. 2 Degradation and fate* Short lived in air (<24 hours) and soil, likely to volatise from water to air. Short lived in air (<24 hours) and soil (5.5 days), likely to volatise to air from water and wet soil but remains in dry soil until degraded. (E) Likely to be short lived in air and soil, as an alcohol it should denature in water and would be expected to volatise. ECHA database of registered substances under REACH (ECHA DB): Water: 92% degraded after 30 days. When released to air will exist solely in the vapour phase, half-life in air is short (32 hours), Highly mobile in soil, but less likely to volatise, breakdown in soil processes important (<60 days). In water does not bind to suspended solids but remains in aqueous phase. Testing at WWTWs suggests readily breaks down in water. ECHA DB: notes that based on distribution modelling that the primary receiving environment is water. Based on REACH dossiers suggests it is readily biodegradable in water. ECHA BD: Half-life in water (at 25C) is 15 days; in sediment at (at 25C) is 4.5 months. Half-life in soil (at 25C) is 30 days. When released to air will exist solely in vapour phase, half-life in air is short (48 hours), Highly mobile in soil, but less likely to volatise, breakdown in soil processes important (half-life is <12 days). In water does not bind to suspended solids but remains in aqueous phase. Half-life in water was <14 days at 8 Celsius. Half-life in air is short (<5 hours). Within soils will be highly mobile but readily biodegradable. In water will not bind to suspended solids (remains in aqueous phase). Readily biodegradable in water. 102 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Product Substance Category CAS number Concentration in product % w/w Moussol FF 3x6 ALKYLAMIDOBETAI Detergent 147170- <5 NE 44-3 Moussol FF 3x6 TRIETHANOLAMMO NIUM- LAURYLSULFATE Detergent 85665-458 <10 Orchidex BlueFoam 3x4 107-21-1 Ethandiol (vgl. Glykol) 5 - < 10 % Hydrocarbon 107-21-1 5 - < 10 % Orchidex BlueFoam 3x6 Orchidex BlueFoam 3x3 9 D-Glucopyranose oligomeric C10-16- alkyl glycosides 2-(2Butoxyethoxy)etha nol Orchidex BlueFoam 3x5 Ammonium laureth sulfate Orchidex BlueFoam 3x7 Re-Healing Foam RF1 1% Re-Healing Foam RF1 1% Ammonium alkyl C10-C16 sulphate sucrose ( - ) 1-propanaminium, 3-amino-N- (carboxymethyl)N,N-dimethyl-, Ncoco acyl derivs., hydroxides, inner salts ( - ) Detergent Hydrocarbon Detergent Detergent Hydrocarbon Detergent 11061547-9 112-34-5 32612-489 68081-969 57-50-1 61789-400 1 - < 5 % 15 - < 20 % 1 - < 5 % 1 - < 5 % >1% 10% Hazard classification Acute Toxicity. 4 Skin Irritant. 2 Eye Damage. 1 Acute Toxicity. 4 STOT SE 3 (respiratory tra...) (Inhalation) Aquatic Chronic 3 Acute Toxicity. 4 Skin Irritant. 2 Eye Damage. 1 Acute Toxicity. 4 STOT SE 3 Aquatic Chronic 3 Acute Toxicity. 4 * STOT RE 2 Skin Irritant. 2 Eye Damage. 1 Eye Irritant. 2 Skin Irritant. 2 Eye Irritant. 2 Skin Irritant. 2 Eye Dam. 1 Not classified Skin Irritant. 2 Skin Sensitiser. 1 Eye Irritant. 2 Aquatic Chronic 3 Degradation and fate* ECHA BD: Half-life in water (at 25C) is 15 days; in sediment at (at 25C) is 4.5 months. Half-life in soil (at 25C) is 30 days. (E) Would expect this compound to be readily biodegradable in water. Half-life likely to be days- weeks (<30 days) When released to air exists solely in vapour phase for air, half-life in air is short (48 hours), Highly mobile in soil, but less likely to volatise, breakdown in soil processes important (half-life is <12 days). In water does not bind to suspended solids but remains in aqueous phase. Half-life in water was <14 days at 8 Celsius. ECHA DB: Half-life in air <5 hours; fully biodegrades in water. Half-life in air is short (<5 hours). Within soils will be highly mobile but readily biodegradable. In water will not bind to suspended solids (remains in aqueous phase). Readily biodegradable in water. (E) Only limited data available, review of multiple SDS all comment that this substance is readily biodegradable in water. Half-life likely to be days- weeks (<30 days) (E) Would expect this compound to be readily biodegradable in water. Half-life likely to be days- weeks (<30 days) (E) Readily biodegradable. ECHA BD: Half-life in water (at 25C) is 15 days; in sediment at (at 25C) is 4.5 months. Half-life in soil (at 25C) is 30 days. 103 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Product Re-Healing Foam RF1 1% Re-Healing Foam RF1 1% Re-Healing Foam RF1 1% Re-Healing Foam RF1 1% Re-Healing Foam RF1 1% Re-Healing Foam RF1 1% Re-Healing Foam RF1 1% Re-Healing Foam RF1 1% Re-Healing Foam RF1 1% Re-Healing Foam RF3x6 ATC Re-Healing Foam RF3x6 ATC Substance 2-(2butoxyethoxy)etha nol (012119475104-44) sodium octyl sulphate ( - ) sodium decyl sulphate ( - ) 1-propanaminium, N-(3-aminopropyl)- 2- hydroxy-N,Ndimethyl-3-sulfo-, N-coco acyl derivs., hydroxides, inner salts ( - ) amides, coco, N-[3(dimethylamino)pro pyl] ( - ) amides, coco, N-[3(dimethylamino)pro pyl], N- oxides ( - )sucrose ( - ) D-glucopyranose, oligomers, decyl octyl glycosides ( - ) sulfuric acid, mono- C12-14-alkyl esters, compds. with triethanolamine ( - ) alpha-sulfo-omegahydroxy-poly(oxy1,2- ethanediyl), C9-11 alkyl ethers, sodium salts ( -) sucrose ( - ) 2-(2butoxyethoxy)etha nol Category Hydrocarbon Detergent Detergent Detergent Detergent Detergent Detergent Detergent Detergent Hydrocarbon Hydrocarbon CAS number 112-34-5 Concentration in product % w/w 20% 142-31-4 142-87-0 10% <3% 68139-300 68140-012 68155-099 68515-731 10% <0.2% 1% <3% 90583-189 10% 96130-619 57-50-1 112-34-5 <3% >1% 20% Hazard classification Eye Irritant. 2 Skin Irritant. 2 Eye Damage. 1 Skin Irritant. 2 Eye Damage. 1 Aquatic Chronic 3 Eye Irritant. 2 Skin Irritant. 2 Eye Damage. 1 Aquatic Chronic 1 Acute Toxicity. 4 Skin Irritant. 2 Eye Damage. 1 STOT RE 2 Eye Damage. 1 Acute Toxicity. 4 Skin Irritant. 2 Eye Damage. 1 Aquatic Chronic 3 Pre-Registration process Not classified Eye Irritant. 2 Degradation and fate* Half-life in air is short (<5 hours). Within soils will be highly mobile but readily biodegradable. In water will not bind to suspended solids (remains in aqueous phase). Readily biodegradable in water. ECHA DB: Half-life in air 42 hours. Expected to fully biodegrade in water. ECHA DB: Half-life in air 32 hours. Expected to fully biodegrade in water (92% after 30 days). ECHA DB: Will biodegrade in water, 71% degraded after 28 days at 20 Celsius. (E) Would expect this compound to be readily biodegradable in water. Half-life likely to be days- weeks (<30 days) ECHA DB: Sewage sludge test showed 93% degradation after 28 days. ECHA DB: half-life in air <5hours; In soil and water fully biodegrades based on OECD test protocols. (E) Would expect this compound to be readily biodegradable in water. Half-life likely to be days- weeks (<30 days) (E) Would expect this compound to be readily biodegradable in water. Half-life likely to be days- weeks (<30 days) (E) Readily biodegrades Half-life in air is short (<5 hours). Within soils will be highly mobile but readily biodegradable. In 104 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Product Substance Re-Healing Foam RF3x6 ATC Re-Healing Foam RF3x6 ATC Starch Cocamidopropyl hydroxysultaine Category CAS number Concentration in product % w/w Hydrocarbon Detergent 9005-25-8 68139-300 >1% <2.5% Hazard classification Not classified Eye Irritant. 2 Degradation and fate* water will not bind to suspended solids (remains in aqueous phase). Readily biodegradable in water. (E) Biodegradable ECHA DB: Will biodegrade in water, 71% degraded after 28 days at 20 Celsius. * All degradation and fate data is based on Pubchem (https://pubchem.ncbi.nlm.nih.gov/), the ECHA database of REACH registered substances (ECHA DB) (https://echa.europa.eu/information-on-chemicals/registered-substances), or in cases where no information was found had been based upon expert judgement (E) 105 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Step 4 Selection of PFAS substances Additionally, based on the outputs of the market research (Annex A) and stakeholder engagement, the highest tonnage PFAS based substances were also selected for modelling in the source-flow model. This included the following two substances: Table B.4 PFAS based substances for selection Fluoro-compound CAS number 1-Propanaminium,N-(carboxymethyl)N,N-dimethyl-3- [[(3,3,4,4,5,5,6,6,7,7,8,8,8tridecafluorooctyl)sulfonyl]amino]- ,inner salt 1-Propanaminium, 3-amino-N(carboxymethyl)-N,N-dimethyl-N[[(gamma-omega-perfluoro-C6-C16alkyl)thio]acetyl] derives., inner salts 34455-29-3 80475-32-7 Tonnes per year 21.1 17.2 Share of the total market 6% 5% Extrapolation of activity data The outputs from the market analysis (Annex A) provided valuable information on which non-fluorinated products are most commonly in use. However, data on specific quantities per product was largely incomplete. Therefore, a different approach was needed to help develop emission estimates. Data provided by Eurofeu (which represents 60-70% of foam producers) provided data for total quantities of PFAS-based and non-fluorinated based products as an aggregated total. This has been further extrapolated to derive estimated total EU sales of 20,000 tonnes of PFAS-based concentrate annually, and 9,000 tonnes of non-fluorinated alternatives annually (see Annex A). The stakeholder engagement also identified 12 manufacturers of non-fluorinated alternatives. The aggregated 9,000 tonnes has therefore been allocated equally across all 12 manufacturers, and further disaggregated based on number of products per manufacturer. This approach allows a fair assessment of the source-flow of material and order of magnitude estimates. The key limitation however is that some products will likely be used more widely than others. Suitable market data to provide specific quantities per product was unavailable. B.9.3.3. Results and analysis B.9.3.3.1. Key messages from emission source-flow model The source-flow model has been used to produce emission estimates for 10 unique nonfluorinated substances (noting that two substances appear in multiple products, and further that alkylamidobetaine is listed with two different CAS numbers suggesting minor variation of the specific chemistry); as well as two PFAS-based substances. The non-fluorinated alternatives include a combination of hydrocarbons and detergents as defined by the selection methodology. Table B.5 and Table B.6 provide summary overviews 106 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS (as percentage ratios) of the key emission compartments and life-cycle stages for emissions. The initial overview of Table B.5 highlights that fresh surface water and soil are the key receiving environmental compartments. Furthermore, Table B.6 highlights that, for nonfluorinated substances, live incidents are the major point of release, while for PFAS the waste phase is the key life-cycle stage for emissions, primarily from losses associated with releases at WWTPs. The major reason for this difference is that, while non-fluorinated foams are readily expected to degrade within WWTPs (thus lowering the importance of the waste cycle), PFAS based foams are expected to undergo little or no degradation within WWTPs. Table B.5 Overview of ratios for emissions by different environmental compartment for all life-cycle stages combined. Substance group Non-fluorinated alternatives (range) Non-fluorinated alternatives (mean average) 1-Propanaminium,N-(carboxymethyl)-N,N-dimethyl-3[[(3,3,4,4,5,5,6,6,7,7,8,8,8tridecafluorooctyl)sulfonyl]amino]-,inner salt 1-Propanaminium, 3-amino-N-(carboxymethyl)-N,Ndimethyl-N-[[(gamma-omega-perfluoro-C6-C16alkyl)thio]acetyl] derives., inner salts *includes releases from WWTPs after treatment. Air 9 - 18% 14% 9% Fresh surface water* 33 -37% 35% 51% Marine waters 10 - 15% 13% 8% Soil 30 - 45% 38% 32% 9% 30% 8% 53% Table B.6 Overview or ratios for emissions by different life-cycle stages Substance Group Non-fluorinated alternatives (range) Non-fluorinated alternatives (mean average) PFAS based substances (mean average) Formulation 9 - 18% 14% 9% Storage and Training 12 - 18% 15% 9% Live 40 - 62% 52% 30% Waste 1% - 35% 19% 52% Further examination of the data helps elaborate on the summary findings within the two tables, with the following key points to help add context to the overview tables: Management of runoff during training The data from Brooke et al (2004) highlights that, aside from municipal fire brigades, the major use of fire-fighting foams is for training purposes. Feedback from the stakeholder consultation indicated that at least in some Member States and applications there will be local or national-level regulations in place governing containment and prevention of release of fire-fighting foam or firewater runoff to the environment, although it is not clear whether this is comprehensive. One possible exception is training for marine applications, where the more limited options likely means full loss of all firewater runoff to the marine environment. 107 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS An assessment of potential treatment scenarios developed in the study107 underlying this dossier suggests that for large infrastructure installations (e.g. airports, petrochemical facilities, and fire-fighter training complexes) the site should be engineered to allow for a 100% capture of materials used in the training activity. Furthermore, for live emergencies at such sites where larger volumes may be used and are expected to be handled, capture of firefighting water should be done as soon as practicable and safe. However, also note that, for live incidents, the releases of firefighting foams are very situation-specific and sitespecific, and, in reality, it may not be possible to retain all runoff from fire-fighting. The specific kind of engineered options (hard surfaces, bunded areas, on-site drainage systems, etc.) will vary from site to site and the specific kind of operation being undertaken. As a further example of the practical application of how a given site may be managed, the UNECE good practice guidelines provide some further insight108: "There are several possible types of systems for the retention of contaminated firefighting water. The systems can be installed permanently (i.e. pre-installed water barriers or permanent retention basins, if necessary with pumping installations) or be provided as mobile facilities (i.e. fire-fighting water barriers, hoods and sealing pads, mobile storage tanks)." Firewater run-off can then be pumped into tanks and transported e.g. by trucks to treatment facilities. There are several short case studies of fire incidents with a description of retention and disposal of fire-water in Annex 1 of the UNECE good practice guidelines. One further consideration is the management of fire-fighting foam or firewater runoff at either on-site waste water treatment works or municipal waste water treatment plants. Again, this is likely to vary from site to site and is determined in part by the frequency of training and quantities of material that need to be managed. On-site treatment plants would incur a significant cost in the construction and operational phases, as well as requiring a minimum level of throughput to make operations practical. In some cases (e.g. petrochemical works) it is possible that sites already have on-site WWTPs for other purposes and are able to manage firewater runoff as and when needed. In other cases where training is less frequent (e.g. only quarterly / twice a year) use of municipal waste water treatment plants under environmental permitting is more likely. However, also note that where firewater runoff enters drains and is sent to municipal waste water treatment plants, the environmental permits may require some pre-treatment steps. For example, these could include the use of sediment traps to remove solids, an oil/water separator and possibly a granular activated carbon filter before discharge. As a conclusion a distinction needs to be drawn between uses for training purposes and uses for live incidents, noting the potential for greater control over runoff from training 107 See Section 6 in: Wood, Ramboll, COWI: "The use of PFAS and fluorine-free alternatives in firefighting foams - Final report". Report for the European Commission DG Environment and European Chemicals Agency (ECHA) under specific contracts No 07.0203/2018/791749/ENV.B.2 and ECHA/2018/561. 108 https://www.unece.org/fileadmin/DAM/env/documents/2017/TEIA/JEG_MTGS/UNECE_Safety_Guidelines_and_Goo d_Practices_for_Fire-water_Retention_14_Nov_2017_clean.pdf 108 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS compared to live incidents. A review of the evidence suggests that at national level there are regulations in place in several countries over the design and management of firefighting runoff for training, and best practice guidelines for live incidents. However, further data on how comprehensive the coverage of these measures is across the whole EU and their practical implementation has been more difficult to obtain, and, based the evidence analysed, it is not possible to conclude that substantial quantities of runoff could not be released to the environment across Europe, particularly from live incidents.. Processing of substances in waste water Once within the waste water process two key factors determine how the substances identified are managed. Firstly partitioning (as Koc) and secondly the efficacy of the works to successfully destroy the chemical before release. The Log Koc values have been used a measure to help understand partitioning. In practice, the lower the Koc Value the more `water-loving' the substance, and the less likely it is to partition into the sludge phase. Table B.7 provides log Koc values for a range of substances to provide an indicative guide. Table B.7 log Koc values for a set of solvents, POPs and PFAS based substances as indicative guide to partitioning against Koc values. Substance Acetone Butanol Perfluorobutane sulfonic acid (PFBS) Perfluorooctanoic acid (PFOA) Perfluorohexane sulfonic acid (PFHxS) Perfluorooctanesulfonic acid (PFOS) Endosulfan Endrin Methoxychlor Polychlorinated biphenyls (PCBs) Poly aromatic Hydrocarbons (PAHs) Substance type Solvent Solvent PFAS PFAS / POP PFAS / candidate POP PFAS/POP Pesticide / POP Pesticide / POP Pesticide / Candidate POP POP POP Log Koc (l/kg) 0.24 0.84 1.0 1.3 - 2.4 1.8 2.5 - 3.1 3.3 4.09 4.9 5.5 6.2 Partitioning Hydrophilic Hydrophilic Hydrophilic Hydrophilic Hydrophilic Mixed Mixed Hydrophobic Hydrophobic Hydrophobic Hydrophobic Table B.8 log Koc values for non-fluorinated substances included within this assessment Substance 1,2-ETHANDIOL CAS number 107-21-1 Log Koc (l/kg) 0.0 Partitioning Hydrophilic 109 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Triethanol AmmoniumLaurylsulfate sodium decyl sulphate ( - ) Sodium laureth sulphate Alkylamidobetaine sulfuric acid, mono-C1214-alkyl esters, compds. with triethanolamine ( - ) 1-dodecanol amides, coco, N-[3(dimethylamino)propyl] ( - ) amides, coco, N-[3(dimethylamino)propyl], N- oxides ( - )sucrose ( - ) 1-tetradecanol 85665-45-8 142-87-0 68891-38-3 147170-44-3 90583-18-9 112-53-8 68140-01-2 68155-09-9 112-72-1 1.88 2.09 2.20 2.81 3.19 3.30 3.82 3.82 4.53 Hydrophilic Mixed Mixed Mixed Hydrophobic Hydrophobic Hydrophobic Hydrophobic Hydrophobic Table B.8 provides the log Koc values for non-fluorinated substances which range from 1.8 to 4.5, with the exception of 1,2 ethanediol which has a Koc value of zero. This means that while these substances are soluble, for many of them there is a greater tendency to partition to the sludge phase. The log Koc values for the two PFAS species are 1.5 and 3.8, which means the partitioning is more mixed, with the CAS 34455-29-3 species having much greater solubility and mobility. This places greater onus on the releases from WWTPs, noting that the efficacy of WWTPs for PFAS based substances is expected to be poor. The other major factor is the efficacy of the works itself to irreversibly destroy specific substances. For the hydrocarbon-based alternatives, waste water treatment works could be expected to have a high level of efficacy, particularly against substances like 1,2 ethanediol which will readily disassociate. For detergent-based alternatives the efficacy may be less than for hydrocarbons, although overall efficacy is expected to be high (70%). By contrast waste water treatment efficacy against PFAS substances is expected to be poor with close to zero effectiveness. This makes partitioning particularly important for evaluating final emission of PFAS substances. Summary conclusions The overviews presented within Table B.5 and Table B.6 illustrate that significant use occurs for training purposes, with an assumption applied that runoff is largely retained and treated within waste water treatment works (although also noting that feedback from the study workshop and literature review highlights efficacy of WWTPs for PFAS substances is poor). For the non-fluorinated alternatives, the effectiveness of WWTPs is relatively good, minimising the emission which is split between surface water and soil. The effectiveness of the WWTPs to irreversibly destroy the named non-fluorinated substances, increases the importance of live incidents - where there is a direct release without treatment. 110 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS For the PFAS-based substances there is a similar process with the majority of retained firewater run-off from training sent for treatment at WWTPs. However, the efficacy is expected to be poor, with WWTPs ineffective at treating PFAS, meaning direct release to surface water / soil depending on the partition coefficient. Waste is thus the most important lifecycle stage for the PFAS substances (shown in Table B.6). A further consideration within the results is the magnitude of emissions to different environmental compartments. Review of the data highlights a further two key points. Firstly, the PFAS-based surfactants are effective at low concentrations within the firefighting concentrate ( 3% w/w based on data from the stakeholder engagement), while the hydrocarbon/detergent alternatives are potentially less effective, meaning greater concentrations are needed within the concentrate product (aggregate of all substances within a given product equates to 10-20% w/w). Secondly, for the non-fluorinated alternatives a combination of substances is needed together to be effective. Based on the market analysis and stakeholder engagement, a small set of substances are used across multiple different manufacturers. This means that while the non-fluorinated fire-fighting foams make up approximately one third of the market, the volumes of alternative surfactants can be greater than their PFAS counterparts because of the greater concentration needed. By way of example: Taking uncertainty into account the emissions of alkylamidobetaine (CAS 61789-40-0) are estimated as 9.5 tonnes to water and 8 tonnes to soil annually for the European Union. This is based on an assumed annual sale of 86 tonnes (within different products). As means of comparison, the PFAS surfactant 1-Propanaminium,N(carboxymethyl)-N,N-dimethyl-3-[[(3,3,4,4,5,5,6,6,7,7,8,8,8tridecafluorooctyl)sulfonyl]amino]-,inner salt (CAS 34455-29-3) has annual sales of 21.5 tonnes (within different products) and estimated emissions to water of 3.3 tonnes and to soil of 1.8 tonnes annually across the EU. This reflects potentially higher emissions of the non-fluorinated alternatives, primarily due to greater concentrations within the product itself. However, it is important to recognise that emission alone is not an indicator of impact, and the degradation rates, potential for bioaccumulation, and harmful effects also need to be considered. The next sub-section provides a consideration of the hazards for non-fluorinated alternatives, before the final sub-section in this chapter combines the emission estimates with hazard data to consider potential risks from exposure via uptake / man-via-the environment pathways. B.9.4. Other sources (for example natural sources, unintentional releases) Not in scope. B.9.5. Overall environmental exposure assessment As Section B.9.3. 111 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS B.9.6. Combined human exposure assessment B.9.6.1. Further considerations for exposure via uptake from food This final sub-section considers the outputs of the emission model (See B.9.3) to identify further thoughts on the potential human exposure via uptake from food. This section is intended to provide first thoughts as a high-level review. Further work would be needed to assess the risks associated with specific sites or food production pathways, and that is beyond the scope of the current study. The output of the emission model highlighted that, because the major use of fire-fighting foams is dominated by training, the efficacy of bunding/control measures is critical in preventing direct release to the environment. Secondly, the capacity of waste water treatment plants to successfully remove and/or destroy substances and prevent emission to environment is key to limiting their release to the wider environment. The review of hazards highlighted that the fluorinated compounds have very low biodegradability and, in at least one case, very low PNEC values for soil. Furthermore, based on feedback from the workshop, the efficacy of waste water treatment plants against fluorinated compounds is typically poor. This suggests that the first major conclusion that can be drawn is that the PFAS-based compounds represent a greater risk to uptake and exposure than the non-fluorinated alternatives. Further review of the non-fluorinated alternatives highlighted a number of compounds (see Table B.8) that also have very low PNEC values for water and soil (albeit higher than their fluorinated counterparts). The emission model also highlighted that the efficacy of the nonfluorinated substances as surfactants is typically poorer than fluorinated substances and thus greater concentrations are needed within the fire-fighting foam concentrate. This means that the potential emissions are higher, particularly where the same substance is used in multiple products by different manufacturers (i.e. in aggregate). One further important consideration therefore could be in cases where fire-fighting foams are used multiple times at the same location. The emission model suggests that the majority of use would be for training. For those substances with particularly low soil PNECs and lower biodegradation properties a concern could be that, if the control measures are less effective in some locations, releases could repeatedly `shock' soil microflora and fauna (i.e. the release has toxic effects upon the soil, with secondary or repeated releases before the microflora and fauna communities have a chance to recover). The removal of such biological degradation pathways from the soil could also have knock-on consequences for the biodegradation of the substance itself, meaning that persistence may be greater than the values quoted within Table B.8. Based on consideration of these factors and in examination of the emission model alkylamidobetaine (CAS 61789-40-0) could be one such substance that meets these criteria, i.e. use concentrations (based on review of available SDS) are up to 10% w/w of the concentrate. It is used in at least four products by different manufacturers suggesting in use quantities could be significant. It also has PNEC values for fresh water of 0.0032 mg/l and soil of 0.0419 mg/kg dw (which can be considered low). In instances of sites with repeated use for training and less well-established control measures, effects for soil could highlight a need for further investigation. 112 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS B.10. Risk characterisation On the basis that neither a full exposure assessment nor a full review of hazards were in the scope of this study, a detailed risk characterisation was not undertaken. 113 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Annex C: Justification for action on a Union-wide basis See Section 1.2. 114 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Annex D: Baseline See Section 1.3. 115 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Annex E: Impact Assessment E.1. Risk Management Options E.1.1. Proposed option(s) for restriction It was agreed in discussions with the steering group to assess two main regulatory management options (RMOs): 1) Restriction (ban) on the placing on the market of PFAS-based fire-fighting foams (hereafter referred to as Scenario 1). The use of legacy foams, i.e. foams already in stock at producers' or users' sites, is still permitted; and 2) Restriction (ban) on the placing on the market and the use of PFAS-based firefighting foams (hereafter referred to as Scenario 2). The legacy foams, i.e. foams already in stock at producers' or users' sites, should be disposed of safely. E.1.2. Discarded restriction options Not applicable. E.1.3. Other Union-wide risk management options than restriction See Section 2.7.4. E.2. Alternatives E.2.1. Description of the use and function of the restricted substance(s) PFAS-based fire-fighting foams find application in a broad range of sectors, such as aviation, marine, oil and gas, offshore oil, refineries, chemicals and railways109. The main function of the PFAS contained in the foam is to act as a surfactant, i.e. to form a film over the burning liquid surface in order to prevent flammable gases from being released from it. This is a particularly relevant feature that enables applications in industrial fires for example tank fires, where large quantities of flammable liquid are stored. They are used for training purposes and in a variety of fire incidents, from small fires to the abovementioned large tank fires, and can be applied both with mobile and semi-stationary equipment. 109 A respondent responsible for railway maintenance stated that PFAS-based foams are used in railways; the use of fire-fighting foams is particularly relevant for fire-protection in railway tunnels. The reason is that railways can carry various chemicals and other dangerous goods and, if they catch fire in tunnels, it is particularly critical and fires can be much more difficult to extinguish. 116 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS E.2.2. Identification of potential alternative substances and techniques fulfilling the function A list of the most common alternative fluorine-free products that are widely used in the EU has been generated. These provide a starting point which can be compared to the risk, performance and cost of PFAS-based products. Alternative techniques could be changes in demand for flammable fuels which would reduce the need for AFFFs. Application of e.g. electric aircraft and phase out of hydrocarbon fuels for vehicles would reduce the needs for AFFFs, but are by the authors of this report not considered feasible alternative solutions in the short term. The selection of fluorine-free products for further analysis has been based on the following criteria: Use - The use of the products has been reported by several stakeholders, ensuring that the products analysed are commonly used in the EU as alternatives for PFAS-containing foams; Chemical group - The products represent different chemical groups according to the grouping in the substance identification, i.e. hydrocarbons, detergents, siloxanes and proteins. Some products may contain a combination of substances from these groups; Technical feasibility - The products do actually represent alternatives/replacements for PFAS- containing foams, including in critical situations (with large fires). Technical feasibility also considers the combination of the foam concentrate, the application system and the application rate to establish whether the alternative is a viable replacement. Case studies of critical applications serve as a starting point for successful replacement of PFAScontaining foams with fluorine-free alternatives. Training foams have been excluded as they are already available and widely used for all applications. ; Manufacturers - The products originate from different manufacturers; Availability - The products are known to be on the market in the EU and are available without further R&D delays or costs; and Complementarity - The products cover jointly all major applications of PFAScontaining foams and can be used in different conditions. An initial shortlist with 30 products from 8 manufacturers was presented at the workshop undertaken as part of the underlying study (see Annex G for more details on the workshop), and participants were asked which were the most commonly used and viable. On the basis of the workshop feedback, further review by the study team and responses from stakeholders, a list of products for further analysis was generated. This is shown in Table E.1 along with a justification of why these specific products have been chosen. For each of the manufacturers, one or two products in the product range has been selected for the more detailed assessment. The selection has been based on the available information on the feasibility of using the alternatives with particular emphasis on products demonstrated as viable alternatives to PFAS-containing foams in airports and the petrochemical sector. The information provided in Table E.1 is supplemented with two representative case studies in Section E.2.4. 117 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS The remaining products on the shortlist presented at the workshop were from the manufacturers Auxquimia (EE-3 Newtonian Training foam, and Unipol-FF), Fomtec (the Enviro product range) and the 3F Company (Freedol SF). None of the companies have answered the questionnaire and only limited information on the feasibility has been obtained from the stakeholder consultation. These products were not included in the list, but this does not indicate that these products are considered less efficient alternatives to the PFAS-based foams, merely that less information on the feasibility of using these foams was available for the assessment. Seven substances have been selected in order to strike a balance between ensuring variety in coverage of alternatives and depth of analysis that is possible. It is important to note that during the substance identification, a group of potential alternative fluorine-free products, the siloxane-based alternatives, were identified. These have not been identified as being widely used and, furthermore, at the stakeholder workshop, concerns were raised by governmental stakeholders in relation to PBT and/or vBvP properties of some siloxanes. They have therefore not been selected from the more detailed analysis. One protein-based product, PROFOAM 806G from the company Gepro has been mentioned to be in use during the stakeholder consultation. However, specific data on users, application or feasibility have not been provided by the stakeholder consultation and the manufacturer and products cannot be identified. Protein-bases foams are marketed by Profoam srl (PROVEX AR 6-6), Angus PFAS based foams (TF 3 and TF90 for training purposes) and Dr Stahmer (Foamousse product range). No information on these products has been provided for the stakeholder consultation but one product from the Foamousse product range has subsequently been added to the example list in the table below. Table E.1 Shortlist of fluorine-free alternative products for assessment Product name Manufacturer Chemical group(s) Current use sector of the product where PFASbased products are currently used Reason for shortlisting Other marketed fluorine- free products from the manufacturer for hydrocarbon fires Respondol ATF 3-6% Angus fire Hydrocarbons and detergents Petrochemicals -processing, storage and transport of hydrocarbons and polar solvents Applicable for all types of flammable liquid fires JetFoam ICAO-C (aviation) JetFoam ICAO-b (aviation) Syndura (aviation, forestry) Re-Healing Foam RF1 1% Solberg Hydrocarbons and detergents Petrochemicals - offshore oil installations and onshore terminals and refineries Widely used detailed information on the feasibility of using the substances as alternatives 8 other products in the Re-Healing Foam RF product range 118 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Product name Manufacturer Chemical group(s) Current use sector of the product where PFASbased products are currently used Reason for shortlisting Other marketed fluorine- free products from the manufacturer for hydrocarbon fires for PFASbased products in the petrochemical sector provided in Case 2 Re-Healing Foam RF3x6 ATC Solberg Hydrocarbons and detergents Aviation Widely used detailed information on the feasibility of using the substances as alternatives for PPFASbased products in the aviation sector provided in Case 1 Moussol FF 3x6 Dr. Sthamer Foammousse 3% F-14 Dr. Sthamer Hydrocarbons and detergents Aviation Petrochemicals Protein According to manufacturer: Petroleum industry and on oil tankers Widely used in several major EU airports Best available example of protein-based products A number of products in the Sthamex product range (municipal fire services, aviation, training foams) Training foam N (training) vaPUREx LV 1% F10 (extensive fires of non-polar liquids) vaPUREx LV ICAO B 3% F-10 (aviation) Ecopol Premium Bioex Hydrocarbons and detergents Aviation Mentioned by manufacturer and other stakeholders, BIO FOR 119 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Product name Manufacturer Chemical group(s) Current use sector of the product where PFASbased products are currently used Reason for shortlisting Other marketed fluorine- free products from the manufacturer for hydrocarbon fires as applicable for hydrocarbon fires, all types of flammable polar solvent liquids and applicable for tank fire fighting BIO FOAM 5 and 15 (storage facilities, marine) BIO T3 and BIO T6 (training foams) Ecopol F3 HC, Ecopol A Orchidex BlueFoam 3x3 Orchidee Hydrocarbons and detergents Aviation Has according to stakeholder response substituted for AFFF for one of the biggest airports in Germany Other products in the Orchidex Bluefoam product range E.2.3. Risk reduction, technical and economic feasibility, and availability of alternatives Additional information on the technical and economic feasibility and availability of shortlisted products has been collected through both the earlier literature review step and further follow-up with stakeholders. The properties of the shortlisted products are listed in the following tables and are further used in the impact assessment in subsequent sections. The full chemicals composition of the products is in general not available. The following tables indicate the substances listed in the safety data sheets i.e. the constituents classified as hazardous. It should be noted that not all human health or environmental hazard endpoints (e.g. endocrine disrupting effects) have necessarily been assessed in detail for each component by the foam manufacturers. Therefore, it should be kept in mind that the conclusion on risks in the tables below are based on the information provided in the product safety data sheets and hence other hazards may become evident in the future. A comprehensive list of identified substances in alternatives is provided in Section B.1. Table E.2 Assessment of Respondol ATF 3-6% Product name Manufacturer Chemical group Respondol ATF 3-6% Angus Fire Hydrocarbons and detergents. 120 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Product name Chemical composition Proposed PFAS foam substitution (as specified by manufacturer) Technical feasibility Applications areas (as specified in technical specification) Economic feasibility: Availability: Compliance with international performance standards Examples of use experience and performance compared to PFAScontaining foams Critical uses/applications where product do not meet (fully or partially) the required performance standard and why Need for changes in equipment Unit price Unit price as compared with PFAScontaining foam for same application Relative volume required to achieve comparable/best possible performance Storage, shelf-life Frequency of foam replacement Volume manufactured, sold and used in the EU Production capacity in the EU Respondol ATF 3-6% Substances listed in safety data sheet: 1-dodecanol 1-tetradecanol propylene glycol monobutyl ether disodium isodecyl sulfosuccinate sulfuric acid, mono-C8-10-alkyl esters, sodium salts reaction mass of C-isodecyl and C-isoundecyl sulphonatosuccinate. Replacing traditional AFFF and FFFP foam concentrates as well as fluoroprotein foam. Class B hydrocarbon fuels at 3% and polar solvent fuels at 6%. Class A fuels (as wetting agent). Used in high risk situations where hydrocarbons (such as oils, gasoline, diesel fuel, and aviation kerosene) are stored, processed, or transported and/or polar solvents (such as alcohols, ketones, esters, and ethers) are stored, processed, or transported. EN 1568 Part 3 and 4; Highest approval rating on all fuels using all waters; 1A/1A - 1A/1A - 1A/1A. (see Appendix 5 of the underlying study110) Used within the petroleum industry. No further details available. Marketed for use in Power and Industry (other than petrochemical), municipal fire brigades and forestry The product is not intended for the aviation sector for which the manufacturer markets other products (JetFoam and Syndura product ranges) The corresponding 3-3% product has passed Lastfire test in fresh water and sea water. Stakeholders have indicated that fires in very large tanks are still challenging In general no need for replacement of equipment, but adjustment and in some case change of components No data No data No data Max. continuous storage temperature 49 C (no performance loss after thawing), min. 10 years. Depending on application and difficult to compare with the PFAScontaining . Commonly, the foam is used continuously for training and system testing as well, thus not requiring replacement. No data No data Risks: CMR properties Other potential human health concern Substances in the product do not meet the CMR criteria Hazard classification of some constituents: H315 - Causes skin irritation. 110 Wood, Ramboll, COWI: "The use of PFAS and fluorine-free alternatives in fire-fighting foams - Final report". Report for the European Commission DG Environment and European Chemicals Agency (ECHA) under specific contracts No 07.0203/2018/791749/ENV.B.2 and ECHA/2018/561. 121 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Product name PBT or vPvB properties Other environmental risk concern Respondol ATF 3-6% H319 - Causes serious eye irritation. H302 - Harmful if swallowed No other health concern identified The product does not meet the PBT or vPvB criteria. Hazard classification of some constituents: -dodecanol (EC No 203-982-0; CAS No 112-53-8): H400 - Very toxic to aquatic life -tetradecanol (EC No 204-000-3; CAS No 112-72-1): H410 - Very toxic to aquatic life with long-lasting effects -dodecanol (EC No 203-982-0; CAS No 112-53-8): H411 - Toxic to aquatic life with long-lasting effects Sodium laureth sulphate (EC No 500-234-8; CAS No 68891-38-3): H412 - Harmful to aquatic life with long lasting effects GreenScreen level Level bronze[1]. Level Bronze Screening Requirements are[2] 1. Each intentionally added chemical compound present above 0% by weight (>0 ppm) and each impurity present at or above 0.01% by weight (100 ppm) in the product is screened with GreenScreen List TranslatorTM. 2. Each screened chemical compound in the Product Inventory has a GreenScreen List Translator TM score of LT-P1, LT-UNK, and/or NoGSLT. No LT-1 scores are permitted in certified products. 3. Product-level acute aquatic toxicity testing results in LC50 and/or EC50 values >10 mg/l for each of the following groups of organisms: fish, aquatic and invertebrates, and algae. Conclusion on risks References: As the substances are not classified with CMR properties and do not meet the PBT/vPvB criteria, the overall risks are considered lower than the risks of PFAS-based products. Some constituents are classified toxic or very toxic to aquatic life, for one constituent with long-lasting effects. [1] https://www.greenscreenchemicals.org/certified/products [2] https://www.greenscreenchemicals.org/images/ee_images/uploads/resources/GSCFirefightingFoamStandardV1.0_FINAL.pdf?cachebuster:38 Table E.3 Assessment of Re-Healing Foam RF3x6 ATC Product name Manufacturer Chemical group Chemical composition Proposed PFAS foam substitution (as specified by manufacturer) Technical feasibility Applications areas (as specified in technical specification) Equipment Re-Healing Foam RF3x6 ATC Solberg Hydrocarbons and detergents Substances listed in safety data sheet: 2-(2-butoxyethoxy)ethanol starch sucrose 1-propanaminium, N-(3-aminopropyl)-2-hydroxy-N,N-dimethyl-3sulfo-, N-coco acylderivs., hydroxides, innersalts Replacing traditional AFFF and FFFP foam concentrates as well as fluoroprotein foams Class B hydrocarbon fuels at 3% and polar solvent fuels at 6% Class A fuels Aspirating or non-aspirating devices 122 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Product name Economic feasibility: Compliance with international performance standards Examples of use experience and performance compared to PFAScontaining foams Critical uses/applications where product do not meet (fully or partially) the required performance standard and why Need for changes in equipment Unit price Unit price as compared with PFAScontaining foam for same application Relative volume required to achieve comparable/best possible performance Storage, shelf-life Frequency of foam replacement Re-Healing Foam RF3x6 ATC EN 1568 Part 3 and 4; levels not indicated ICAO Levels B and C (see Appendix 5 of the underlying study111) Airport Fire Service, both airport rescue firefighting and training. Examples: Used at Copenhagen Airport. Fulfilling the need of an alcohol resistant foam. Also used by the Melbourne Metropolitan Fire Brigade (MFB) on class B fires; Based on MFB's experience, Solberg RF3x6 foam concentrate performs just as well as the previously used fluorinated AFFF concentrate (IPEN 2019). None identified within aviation. Several stakeholders indicate that the performance standards required by the ICAO were developed for PFAS-based foams, are outdated and/or are not covering the multiple applications within the aviation sector. For this reason(s), several airports conducted internal testing schemes before implementation of PFAS-free foams. No identified. In the case of Copenhagen Airport, the investment in fire trucks was not strictly conditioned by the foam replacement, but the coincident introduction of new trucks and foam was seen as a cumulative benefit. Appr. 5/l Range from similar to +20%. No difference or differences/larger volumes depending on application. In certain applications, a 6% foam (ICAO Level C) has been found to work better than a 3% mixture (ICAO Level B). 1.7 to 49 C (no quality loss after thawing), 20 years Depending on application. Commonly, the foam is used continuously for training and system testing as well, thus not requiring replacement. Availability: Volume manufactured, sold and used in the EU Production capacity in the EU Produced in Norway and Spain No data Risks: CMR properties Other potential human health concern PBT or vPvB properties Other environmental risk concern Substances in the product do not meet the CMR criteria Hazard classification of one constituent: H319 - Causes serious eye irritation. According to SDS, due to insufficient data no statement can be made whether the components fulfil the criteria of PBT (vPvB criteria not addressed) Hazard classification of one constituent: 1-propanaminium, N-(3-aminopropyl)-2-hydroxy-N,N-dimethyl-3sulfo-, N-coco acylderivs., hydroxides, innersalts (EC No 268-761-3; CAS No 68139-30-0): 111 Wood, Ramboll, COWI: "The use of PFAS and fluorine-free alternatives in fire-fighting foams - Final report". Report for the European Commission DG Environment and European Chemicals Agency (ECHA) under specific contracts No 07.0203/2018/791749/ENV.B.2 and ECHA/2018/561. 123 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Product name Conclusion on risks Re-Healing Foam RF3x6 ATC H411 - Toxic to aquatic life with long-lasting effects Substances in the product do not meet the CMR criteria. No statement can be made on whether the components fulfil the PBT criteria. One constituent is toxic to aquatic life with long-lasting effects. Table E.4 Assessment of Re-Healing Foam RF1 1% Product name Manufacturer Chemical group Chemical composition (according to SDS) Proposed PFAS foam substitution (as specified by manufacturer) Technical feasibility Applications areas (as specified in technical specification) Compliance with international performance standards Examples of use experience and performance compared to PFAScontaining foams Critical uses/applications where product do not meet (fully or partially) the required performance standard and why Re-Healing Foam RF1 1% Solberg Hydrocarbons and detergents Substances listed in safety data sheet: d-glucopyranose, oligomers, decyl octyl glycosides sodium octyl sulphate sodium decyl sulphate alpha-sulfo-omega-hydroxy-poly(oxy-1,2-ethanediyl), C9-11 alkyl ethers, sodium salts 1-propanaminium, N-(3-aminopropyl)-2-hydroxy-N,N-dimethyl-3sulfo-, N-coco acyl derivs., hydroxides, inner salt amides, coco, N-[3-(dimethylamino)propyl] 1-propanaminium, 3-amino-N-(carboxymethyl)-N,N-dimethyl-,Ncoco acyl derivs., hydroxides, inner salts amides, coco, N-[3-(dimethylamino)propyl], N-oxides sucrose 2-(2-butoxyethoxy)ethanolsulfuric acid, mono-C12-14-alkyl esters, compound with triethanolamin Replacing traditional AFFF and FFFP foam concentrates as well as fluoroprotein foams Petrochemicals sector - offshore oil installations and onshore terminals and refineries Class B hydrocarbon fuels (not intended for polar solvent fuels) Class A fuels EN 1568 Part 3 (see Appendix 5 of the underlying study112) Used at offshore facilities in Norway. Partially implemented at onshore facilities as well According to data sheet, the product is not intended for use on Class B polar solvents fuels. Diverging opinions among stakeholders: Specific applications related to large storage tanks in the petroleum industry (e.g. terminals and oil refineries) may require PFAS-based foams. However, the use of PFAS-free foams has also been assessed as safe for sub-ground large storage tanks. One stakeholder noted that testing and qualification of non-PFAS foams and obtaining the necessary military approvals for use in all vessels / fire-fighting systems will take many years, and the associated costs will be very high. 112 Wood, Ramboll, COWI: "The use of PFAS and fluorine-free alternatives in fire-fighting foams - Final report". Report for the European Commission DG Environment and European Chemicals Agency (ECHA) under specific contracts No 07.0203/2018/791749/ENV.B.2 and ECHA/2018/561. 124 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Product name Economic feasibility: Availability: Risks: Need for changes in equipment Unit price Unit price as compared with PFAScontaining foam for same application Relative volume required to achieve comparable/best possible performance Storage, shelf-life Frequency of foam replacement Volume manufactured, sold and used in the EU Production capacity in the EU CMR properties Other potential human health concern PBT of vPvB properties Other environmental risk concern Conclusion on risks Re-Healing Foam RF1 1% The experience with the case from the Norwegian offshore sector (Equinor, case 2) is that at a few facilities, adjustment of equipment was necessary, but usually, the same equipment was used and additional costs for new equipment were not necessary. Furthermore, substitution was done in relation to scheduled maintenance stops, turnarounds or during upgrades, thus not imposing further additional costs to the company. Approx. 5.0-5.5/l Case 2 indicates approx. 30% more expensive than PFAS products Same volumes, no difference to PFAS foams -10 to 50 C (no quality loss after thawing), 20 years Depending on application. Commonly, the foam is used continuously for training and system testing as well, thus not requiring replacement. Available in EU (tonnage not known) Manufactured in the EU: no data Sold in the EU: no data Used in the EU: no data Substances in the product do not meet the CMR criteria Hazard classification of product: H315 - Causes skin irritation H318 - Causes serious eye damage. Hazard classification of some constituents: H302 - Harmful if swallowed H314 - Causes severe skin burns and eye damage According to SDS, due to insufficient data no statement can be made whether the components fulfil the criteria of PBT and vPvB Hazard classification of one constituent: amides, coco, N-[3-(dimethylamino)propyl] ( - ) (EC No 268-771-8; CAS No 68140-01-2): OH400: Very toxic to aquatic life he constituents of the product do not meet the CMR criteria. Due to insufficient data no statement can be made on whether the constituents fulfil the PBT and vPvB criteria. One constituent is very toxic to aquatic life. Table E.5 Assessment of Moussol FF 3x6 (F-15) Product name Manufacturer Chemical group Chemical composition Moussol FF 3x6 (F-15) Dr. Sthamer Hydrocarbons and detergents Substances listed in safety data sheet: 1,2-ethandiol 2-(2-butoxyethoxy)ethanol triethanolammonium-laurylsulfate alkylamidobetaine 125 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Product name Proposed PFAS foam substitution (as specified by manufacturer) Technical feasibility Applications areas (as specified in technical specification) Compliance with international performance standards Examples of use experience and performance compared to PFAScontaining foams Economic feasibility: Availability: Critical uses/applications where product do not meet (fully or partially) the required performance standard and why Need for changes in equipment Unit price Unit price as compared with PFAScontaining foam for same application Relative volume required to achieve comparable/best possible performance Storage, shelf-life Frequency of foam replacement Volume manufactured, sold and used in the EU Production capacity in the EU Moussol FF 3x6 (F-15) Replacing alcohol-resistant AFFF. Polar (water-miscible) and non-polar hydrocarbons as well as mixtures of the two (class A and B fires). Can be used as a low, medium and high expansion foam. DIN EN 1568: Part 3 (Heptane): IIIB/IIID, Part 1: Medium ex. - Part 2: High ex. ICAO Low expansion foam - Level B DIN EN 3 21A (see Appendix 5 of the underlying study113) Used within aviation, for example in Sweden, by Swedavia, and in the UK at Heathrow Airport. Swedavia is a state-owned company that owns, operates and develops Sweden's national basic infrastructure of airports. The product is used at all Swedish airports as well as for all aircraft applications at Heathrow airport including training. The foam has been tested and fulfils the requirements of International Civil Aviation Organization, European Aviation Safety Agency and the International association of fire and rescue service. One stakeholder states that the foam must be used aspirated, which reduces throw length. This may result in accessibility problems, for examples for large tanks. Other critical applications may be tank pit scenarios and large puddle fires (>400 m). No data No data Product costs about half of the corresponding PFAS-based foam, but approx. double volume is needed, thus the costs are the same. More storage capacity is required though. Depending on application. -5 to 50C (without quality loss below the specified frost resistance limit) Shelf life of >10 years, if stored according to recommendations 10 years Produced in Germany, data on volume considered confidential by manufacturer No data Risks: CMR properties Other potential human health concern PBT of vPvB properties Substances not classified with CMR properties Hazard classification of product; H319 - Causes serious eye irritation. Hazard classification of one constituent: H302 - Harmful if swallowed H319 - Causes serious eye irritation. H373 - May cause damage to kidneys through prolonged or repeated exposure if swallowed. Substances in the product do not meet the PBT/vPvB criteria 113 Wood, Ramboll, COWI: "The use of PFAS and fluorine-free alternatives in fire-fighting foams - Final report". Report for the European Commission DG Environment and European Chemicals Agency (ECHA) under specific contracts No 07.0203/2018/791749/ENV.B.2 and ECHA/2018/561. 126 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Product name Other environmental risk concern Conclusion on risks Moussol FF 3x6 (F-15) Hazard classification of one constituent: Triethanolammonium laurylsulfate (EC No 288-134-8; CAS No 85665-45-8): 412: Harmful to aquatic life with long-lasting effects C As the constituents are not classified with CMR properties and do not meet the PBT/vPvB criteria, the overall risks are considered lower than the risks of PFAS-based products. One constituent is classified harmful to aquatic life with long-lasting effects. Table E.6 Assessment of FOAMOUSSE 3% F-15 Product name Manufacturer Chemical group Chemical composition Proposed PFAS foam substitution (as specified by manufacturer) Technical feasibility Applications areas Economic feasibility: Compliance with international performance standards Examples of use experience and performance compared to PFAScontaining foams Critical uses/applications where product do not meet (fully or partially) the required performance standard and why Need for changes in equipment Unit price Unit price as compared with PFAScontaining foam for same application Relative volume required to achieve comparable/best possible performance Storage, shelf-life Frequency of foam replacement FOAMOUSSE 3% F-15 Dr. Sthamer Protein Is a low expansion protein foaming agent based on natural re-growing protein carriers, foam stabilisers and antifreezing compounds. Substances listed in safety data sheet: iron-(ii)-sulfate-7-hydrate ammoniumchloride Not specified Typically used in non-polar hydrocarbon fires in the petroleum industry and on oil tankers In particular used in the marine sector. Has the advantage that the product is compatible with black steel and does not require equipment made from stainless steel or plastics (same for other protein-based products). Has been in use for many years and not developed as an alternative to the PFAS-containing foams. Designed for the use with all mobile and stationary low expansion foam equipment and systems for fighting fires of class A + B. EN 1568 part 3 (heptane) Mainly used in the marine sector Only applicable for smaller fires and not applicable for e.g. the aviation sector and other sectors with higher requirements. No data Not specified but the price is indicated as relatively low Lower No data A shelf life of >10 years, if stored according to the manufacturer's recommendations No data 127 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Product name Availability: Risks: Volume manufactured, sold and used in the EU Production capacity in the EU CMR properties Other potential human health concern PBT of vPvB properties Other environmental risk concern Conclusion on risks FOAMOUSSE 3% F-15 Produced in Germany, data on volume considered confidential by manufacturer No data Substances in the product do not meet the PBT/vPvB criteria Hazard classification of some constituents: H302 - Harmful if swallowed H315 - Causes skin irritation H319 - Causes serious eye irritation Substances do not meet the PBT/vPvB criteria of REACH None of the constituents have hazard classification for environmental effects N As the constituents are not classified with CMR properties and do not meet the PBT/vPvB criteria, the overall risks are considered lower than the risks of PFAS-based products. The product is particularly applied in the marine sector, where volumes used for training are discharged directly to the sea. None of the constituents have hazard classification for environmental effects. Table E.7 Assessment of Ecopol Premium Product name Manufacturer Chemical group Chemical composition Proposed PFAS foam substitution (as specified by manufacturer) Technical feasibility Applications areas (as specified in technical specification) Compliance with international performance standards Ecopol Premium BIOex SAS Hydrocarbons and detergents Substances listed in safety data sheet: 2-(2-butoxyethoxy)ethanol Ethandiol Alkyl Sulfate Sodium octyl sulphate Equivalent to AFFF (certified 1A / 1A - EN 1568-3) and burn back resistance equal to fluoroprotein foams ECOPOL PREMIUM can substitute for FILMOPOL range from same company (other products from the company can substitute for other PFAS-based products) Industrial fires: landfills, plastics, tyres, etc. Hydrocarbon fires: fuel, diesel oil, petrol, kerosene, etc. Polar solvent fires: alcohols, ketones, ethers, etc. Urban fires: waste bins, furniture, textiles, etc. Effective at Low, Medium and High Expansion EN 1568 - 1: Conforms EN 1568 - 2: Conforms EN 1568 - 3: 1A / 1A (highest level) EN 1568 - 4: 1A / 1A (highest level) Oil industry: LASTFIRE Forest fire standards: CEREN Certificate Certification in progress : UL 162 / GESIP (see Appendix 5 of the underlying study114) 114 Wood, Ramboll, COWI: "The use of PFAS and fluorine-free alternatives in fire-fighting foams - Final report". Report for the European Commission DG Environment and European Chemicals Agency (ECHA) under specific contracts No 07.0203/2018/791749/ENV.B.2 and ECHA/2018/561. 128 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Product name Economic feasibility: Availability: Risks: Examples of use experience and performance compared to PFAScontaining foams Critical uses/applications where product do not meet (fully or partially) the required performance standard and why Need for changes in equipment Unit price Unit price as compared with PFAScontaining foam for same application Relative volume required to achieve comparable/best possible performance Storage, shelf-life Frequency of foam replacement Volume manufactured, sold and used in the EU Production capacity in the EU Ecopol Premium According to producer's datasheet is used in the oil and chemical industry, pharmaceutical industry, aviation, marine, and fire and rescue service. Used in industrial uses for tank fire fighting. Further details not available. Diverging opinions among stakeholders. One stakeholder notes that the product is not technically feasible for large scale tank fire fighting, high-hazard industry manufacturing, oil tankers fire suppression systems, large spillage of flammable liquids One stakeholder indicated that re-building of firefighting or fire protection systems would be very costly, but no detailed information is provided. 3.5 EUR/l Approximately the same effective price One stakeholder responds 30 - 50% more volume needed. -30C to 60C, 10 years warranty Depending on application. Commonly, the foam is used continuously for training and system testing as well, thus not requiring replacement. Production in EU: 700,000 l/year; Sale in EU: 500,000 l/year No data CMR properties Other potential human health concern PBT of vPvB properties Other environmental risk concern GreenScreen level Conclusion on risks Substances not classified for CMR properties Hazard classification of one constituent: H318 - Causes serious eye damage. No PBT or vPvB properties identified None of the constituents are classified with regard the environmental hazards. Level Bronze. Level Bronze Screening Requirements are 1. Each intentionally added chemical compound present above 0% by weight (>0 ppm) and each impurity present at or above 0.01% by weight (100 ppm) in the product is screened with GreenScreen List TranslatorTM. 2. Each screened chemical compound in the Product Inventory has a GreenScreen List Translator TM score of LT-P1, LT-UNK, and/or NoGSLT. No LT-1 scores are permitted in certified products. 3. Product-level acute aquatic toxicity testing results in LC50 and/or EC50 values >10 mg/l for each of the following groups of organisms: fish, aquatic and invertebrates, and algae. As the constituents are not classified with CMR properties and it does not meet the PBT/vPvB criteria, the overall risks are considered lower than the risks of PFAS-based products 129 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Table E.8 Assessment of Orchidex BlueFoam 3x3 Product name Manufacturer Chemical group Chemical composition Proposed PFAS foam substitution (as specified by supplier) Technical feasibility Applications areas (as specified by supplier) Compliance with international performance standards Examples of use experience and performance compared to PFAScontaining foams Critical uses/applications where product do not meet (fully or partially) the required performance standard and why Need for changes in equipment Economic feasibility: Unit price Unit price as compared with PFAScontaining foam for same application Relative volume required to achieve comparable/best possible performance Orchidex BlueFoam 3x3 Orchidee Hydrocarbons and detergents Substances listed in safety data sheet: L2-(2-butoxyethoxy)ethanol, diethylene glycol monobutyl ether ethanediol, ethylene glycol alcohols, C10-16,ethoxylated, sulfates,ammonium salts D-glucopyranose oligomeric C10-16-alkyl glycosides ammonium lauryl sulfate alcohols, C10-16,ethoxylated dodecanol -1 Products can be seen as 1:1 replacement on Sthamex AFFF and Moussol Products or other AR or usual AFFF products. Appropriate foaming is needed - as for all PFAS-free products - which can usually be realised with the equipment to hand. On systems the nozzles/sprinklers needs changing. Main strength on non-polar liquids. Aviation, petrochemical sector For all uses till tanks > 15 m diameter. EN 1568 - 3: 1B EN 1568 - 4: 1A / 2B Oil industry Lastfire (Heptane), ICAO Level B (see Appendix 5 of the underlying study115) Indicated by supplier that one of the biggest airports in Germany has changed to the product. After tests with their trucks to test the capabilities for their dosing-system, the airport has decided to change all trucks to PFAS-free and has now started a project to change also all systems. Indicated by supplier that fires in substances like isopentane (with low boiling points of 28C) are difficult and PFAS-containing foams may have an advantage. This could according to the supplier be overcome with a higher application-rate and/or more technical changes to technique and equipment. In the view of supplier and experience from dozens of tests done in the past 10 or more years it's generally possible to change 99.9 % of all current scenarios to PFAS-free. Indicated by supplier as normally none. Some information from airport in Germany that changes of trucks may be needed, but not indicated it this concerns adjustment or actual changes in equipment. Depending on concentration, the price in sales is in the range 2.5 - 6.0/l No data According to supplier, if there might be a gap, it's in between 5-10 % in the extinguishing-time for PFAS-containing products in regard to mainly unpolar and secondly polar liquids. In tests, nearly 1:1 results 115 Wood, Ramboll, COWI: "The use of PFAS and fluorine-free alternatives in fire-fighting foams - Final report". Report for the European Commission DG Environment and European Chemicals Agency (ECHA) under specific contracts No 07.0203/2018/791749/ENV.B.2 and ECHA/2018/561. 130 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Product name Availability: Risks: Storage, shelf-life Frequency of foam replacement Volume manufactured, sold and used in the EU Production capacity in the EU CMR properties Other potential human health concern PBT of vPvB properties Other environmental risk concern Conclusion on risks Orchidex BlueFoam 3x3 were found, but this is strongly depending on the fuels and additives. No data 5-15 years Stakeholder (not the manufacturer) estimates volume sold in the EU at 800 t/year No data Substances not classified with CMR properties Hazard classification of several constituents: H302 - Harmful if swallowed H318 - Causes serious eye damage H319 - Causes serious eye irritation H315 - Causes skin irritation Product has not been tested according to SDS Hazard classification of one constituent: Ammonium lauryl sulfate (EC No 218-793-9; CAS No 2235-54-3): H412 - Harmful to aquatic life with long lasting effects. None of the constituents are classified with CMR properties. Due to lack of information it cannot be concluded if the constituents fulfil the PBT and vPvB criteria. One constituent is harmful to aquatic life with long lasting effects. E.2.4. Representative case studies where fluorine-free alternatives are already in use in the EU An important issue in identifying the feasibility of alternatives is the consideration of the process that is involved in adopting the alternative, including systems that need to be changed and considerations such as additional training of users. Substitution examples from companies that are already using alternatives therefore act as a key starting point or proof of principle that a transition is (or is not) possible and the main costs and benefits from real world examples. In order to better understand the options and challenges of replacing PFAS-containing AFFFs, two cases where PFAS-containing AFFFs have been successfully replaced are described in more detail in the following case study examples. E.2.4.1. Case 1 Aviation sector - Copenhagen Airport in Denmark116 Foam used In general, the majority of firefighting foam is used for testing and training at airports. Only a very small percentage is used operationally for emergency response at live events. At 116 Case description is based on the following sources: IPEN position paper 2018 (https://ipen.org/sites/default/files/documents/IPEN_F3_Position_Paper_POPRC-14_12September2018d.pdf); IPEN position paper 2019 (https://ipen.org/sites/default/files/documents/the_global_pfas_problemv1_5_final_18_april.pdf) ; Kim T. Olsen, 2017, Crashtender med skumkanoner (https://beros.dk/skum/Kim_Thorbjoern_Olsen_CPH.pdf) ; Personal communication with Kim T. Olsen, 2019 131 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Copenhagen airport, the same fluorine-free foam (Solberg Re-healing foam RF3x6 ATC fluorine-free foam) is used for training and emergency response. Timeline in the shift from PFAS foams to fluorine free-foams In 2003, the airport recognised PFAS in the run-off firewater from the airport's training area and its burn pit. This resulted in restrictions on use of PFAS-containing AFFF and later, in 2006, all training with PFAS foams stopped; In 2008, testing with fluorine-free foams was started. Re-Healing foams from Solberg were identified as suitable alternatives; and In 2009, the airport conducted additional tests required by the ICAO ARRF working group. All tests (ICAO foam test and test according to the US Mil-Spec protocol, including the NFPA 403), were passed by the fluorine-free foam carrying airport crash tenders. The results from the UK CAA/ICAO tests also showed that CAFS (Compressed Air Foam System; application of foam with non-aspirating turret)117 were about 40% more efficient in fire extinction compared to aspirated foams. CAFS with PFAS and PFASfree foams were both shown to be efficient. The PFAS-free foam was implemented jointly with three new airport crash tenders (specialised firefighting trucks designed for use in aircraft rescue and firefighting at aerodromes) with CAFS on all low-pressure outlets. Challenges Along with the implementation of the new firefighting trucks, the training of the firefighters with the new equipment and foams was a crucial issue and initial testing and training caused additional costs (exact cost estimates are unknown). Also, the different viscosity of the PFAS-free foam caused some initial challenges, which were later solved by the adjustment of equipment; and Some of the old trucks continued to be in use and, even though the tanks were cleaned thoroughly, a contamination of the PFAS-free foam with PFAS occurred initially. Costs of replacement Upon implementation of the new fluorine-free alternative, testing and training required ~5,000 litres foam/year. However, with some modifications to the equipment and training, the volume has now been reduced to 3,000 litres foam/year. Optimal efficiency was found at a 6% foam concentration (ICAO Level C) instead of 3% (ICAO Level B), thus larger foam volumes may still be used in certain situations; Costs incurred in the replacement comprised mainly costs for destruction of PFAScontaining foams and additional training and testing. More specific cost estimates were not available in this case. However, it should be noted that the foam supplier also had an interest in supporting the implementation of the PFAS-free foam and carried out some of the foam testing and covered the additional costs; and The investment in new airport crash tenders (specialised fire engines designed for use in aircraft rescue and firefighting) was not strictly linked to the foam replacement, but the coincident introduction of new trucks and foam was seen as having a cumulative benefit. 117 The difference between aspirating and non-aspirating equipment is that the aspirating device mixes air in the foam/water solution within the nozzle or foam maker, whereas non-aspirating devices do not. Typical examples of non-aspirating devices are water/fog nozzles, water spray heads and conventional sprinkler heads (Ansul Technical bulletin no. 55, https://www.ansul.com/en/us/DocMedia/F-83115.pdf). 132 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Benefits Copenhagen Airport is still working on the remediation of previous pollution from PFAS foams. In 2014, works on clean-up, containment and reconstruction of the fire training area were started and required an initial investment of more than 15 million. Currently, the maintenance of the drainage system around the fire training ground costs more than 1.5 million per year and this expenditure is expected to continue for at least the next 80 years. The biggest benefit of switching to a fluorine-free alternative foam is that rainwater and firewater runoff can be discharged though the normal sewer system to the municipality's waste water treatment, thus avoiding long-term clean-up issues and remediation costs in the future. E.2.4.2. Case 2 Offshore production in Norway118 Foams used Equinor, representing 80% of all production on the Norwegian Continental Shelf and equivalent to 50% of total production for the North Sea, have managed to substitute PFAScontaining foams with PFAS-free foams at almost all installations. The substitution is close to completion for ~40 offshore installations and is ongoing for five onshore facilities (terminals and an oil refinery). Fire-fighting foams at offshore installations are used for multiple applications including training, system testing and emergency response of live events. At most facilities, Re-healing RF1, 1% foam from Solberg is used, while some older facilities use Re-healing RF1 3% foam. For a few installations (where there is risk of methanol fire), alcohol resistant foam was used. The 1% and 3% foam products are used for petroleum fires and were chosen because they are regarded as a drop-in replacement for fluorinated AFFF. For methanol fires specifically, Solberg Re-Healing Foam RF3x6 ATC (alcohol resistant foam) is used. Basically, all foam is used for training and systems testing as emergency responses are seldom (have not occurred since the implementation of the substitution). Environmental discharges may also occur due to accidental spills. The crude oil and products are stored in caverns i.e. underground storage tanks. The typical size is 50,000 - 280,000 m3 for crude oils and 10,000 - 50,000 m3 for products. The caverns are filled up with fluids to prevent them from catching fire. Timeline in the shift from PFAS foams to fluorine free-foams In 2010-2012, development and testing of a 1% fluorine-free firefighting foam was carried out as a collaborative project between Solberg Scandinavian and Equinor (named 118 Case description based on the following sources: IPEN position paper 2019 (https://ipen.org/sites/default/files/documents/the_global_pfas_problemv1_5_final_18_april.pdf) Personal communication with Lars Ystanes, Equinor, 2019 133 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Statoil at that time). The driver for the replacement was concern of the environmental consequences of PFAS-containing firefighting foam released to the sea; In December 2012, the Re-healing RF1, 1% foam (RF1) was first used successfully on the offshore installation Kvitebjrn; In 2013, the RF1 foam was technologically approved for use by Statoil after an approval and verification process; In 2014, approval for starting the multi-use transition project was obtained, with the aim of implementing the new foams at all Norwegian operated installations with 1% foam systems; By September 2016, 30 of 31 Equinor assets had successfully implemented use of RF1 foam; and In 2018, Solberg launched a modified 1% RF1, with lower viscosity at low temperatures and with a yellow environmental classification (compared to red classification for RF1)119 called RF1-AG. This product went into operational use in 2018 on all new offshore installations. Challenges During the substitution implementation, several technical issues occurred which had to be resolved using additional testing by Equinor: During full-scale testing with RF1, a break-down of the foam proportioner occurred which was initially linked to corrosion related to the use of the RF1 foam. Further investigation identified another reason for the break-down and it was concluded that RF1 had no influence on the foam proportioners; RF1 has a higher density and viscosity compared to the previously used AFFF. Higher density may be a problem for installations with substandard foam pumps. However, most Equinor installations were able to handle the increased viscosity and density with only minor system adjustments. At one installation, the pumps were not able to handle RF1 and the solution for this installation is still under evaluation; and Initial uncertainties related to the temperature tolerance of the foam have been removed. The products currently used have a freezing tolerance down to -19C and acceptable low viscosity at ambient temperature. Costs of replacement For Equinor, the total costs of substitution of PFAS-containing foams at about 40 offshore installations and five onshore facilities has been estimated to be approximately 7 million. This estimate does not include costs related to R&D, and regulatory approval costs, which were undertaken in this case by the foam supplier (Solberg). At a few facilities, adjustment of equipment was necessary, but usually, the same equipment was used and new equipment (and associated cots) was not necessary. These total headline costs can be broken down further to include the following: The cost for support in the multi-use phase has been estimated at 2,500 working hours in the period from August 2013 to September 2016, corresponding to a total cost of 119 Environmental colour marking system in Denmark and Norway of The Harmonised Offshore Chemical Notification Format under the OSPAR Convention 1992 indicating substances that should be considered candidates for substitution. "Red" substances may only be used in limited amounts and shall be substituted. 134 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS approx. NOK 3.5 million (approx. 360,000). This included activities such as planning of implementation together with the supplier, preparation of information letters, support team, follow up on technical issues, etc; The cost related to replacement of foam in storage ranges from 50,000 to 500,000 for the biggest oil installations, corresponding to tank storages of 20 - 120 m3. In total, approximately 1,100 m3 of foam was replaced over a 3 year period, resulting in a rough cost estimate of 1,100,000 litre * 5 /litre = 5.5 million. Substitution has always been done in relation to scheduled maintenance stops, turnarounds or during establishing new equipment, thus not imposing further additional costs to Equinor. Note that replacement costs listed here are not due to a higher price of alternative, but due to the costs of replacing the PFAS-based foams in storage (costs of alternatives as compared to the PFAS-based foams); Additionally, the cost related to destruction/incineration of old the PFAS-based foam contributed a further approx. 1 million to the transition costs (~1,000,000 litre * 1 /litre); and Costs of decontamination of equipment were not significant and no fire-fighting equipment or storage tanks were replaced as part of the decontamination process. The storage tanks were drained empty to >99% and the PFAS-based foams handled as waste (destruction/incineration as indicated above). Washing water containing low levels of PFAS was discharged to the sea or waste water treatment plants. Compared to continuous use of PFAS, it was considered that the small discharges of washing water were insignificant. Costs of alternatives The costs of the new foams as compared the PFAS-based foams used before varied between +5% to +30%, depending on foam type/application. For the majority of the foams, the costs increased by +30% and the overall costs increase was slightly below +30%. Benefits At onshore installations, PFAS foams have either been released during operations at the harbour or collected as hazardous waste water at the process plants. The disposal of hazardous waste water, consisting of appr. 1% foam and 99% water meant a significant cost item before the substitution. Waste water containing fluorine-free foams is treated at the biological waste water treatment plants of the onshore installations; Before the substitution, PFAS-containing AFFF were always discharged to the sea during training and system test at Equinor's offshore installations. The use of PFAS-free foams now means a significantly reduced environmental impact. The annual discharge of PFAS-based foams to the sea was reduced from 3-4 tonnes to (almost) zero; In 2014, Norwegian authorities required standard environmental documentation for all firefighting foam used in high volumes. Since Equinor have been successful in transitioning to PFAS-free foams, there is now a general pressure driving the Norwegian market towards the use of PFAS-free foams; and Equinor recognise the substitution as a good investment to be in position for future regulatory changes, but they also see value in reducing their chemical footprint and strengthening their market position as substitution leaders. 135 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS E.2.5. Further analysis of alternatives E.2.5.1. Technical feasibility Aviation Alternatives have successfully replaced the PFAS-containing foams in a number of airports. Based on the stakeholder consultation, three different products from three manufacturers have been reported to have replaced applications of AFFF in airports in Denmark (Copenhagen, Re-healing foam RF3x6 ATC), Germany ("one of the biggest airports", Orchidex BlueFoam 3x3, Sweden (Arlanda and other airports, Moussol 3/6-FF), and the UK (Heathrow, Moussol FF 3x6). The alternatives are used for all applications. According to the IPEN report "Fluorine-free firefighting foams (3F) viable alternatives to fluorinated aqueous film-forming foams", all of the 27 major Australian hub airports have transitioned to fluorine-free firefighting (F3) foams, as have the following major hub airports: Dubai, Dortmund, Stuttgart, London Heathrow, and Manchester, Copenhagen, and Auckland120. A case story from Copenhagen Airport demonstrates that some testing, modification of equipment and training has been required. The entire transition period was 6 years. Investment in new fire trucks took place at the same time, but this was not directly required due to the foam replacement. It has been indicated by stakeholders that some airports voiced concerns over efficacy and changes of equipment, but no specific information has been obtained. The same certification tests apply for all airports in Europe and the successful transition in several airports indicates that it should be possible for others. Some alternatives comply with the highest ratings of N 1568,1A/1A for both Part 3 and 4. One stakeholder noted that high ambient temperatures can influence the performance of foams as demonstrated in an incident in Dubai. However, as mentioned above all 27 major Australian hub airports have transitioned to fluorine-free firefighting (F3) foam indicating that PFAS-free foams are also being applied at high ambient temperatures. One stakeholder (a supplier of AFFF and alternatives) with experience in transition in a German airport states that that experience from a large number of tests done in the past 10 or so years indicates it is possible to change 99.9 % of all current scenarios to PFAS-free products. Upstream petrochemical sector Equinor, the largest operator on the Norwegian continental shelf, has successfully replaced AFFF in about 40 offshore installations and five onshore facilities. At a few facilities, adjustment of equipment was necessary, but usually the same equipment was used and new equipment was not necessary. t one installation, the pumps were not able to handle the alternative. The company had some challenges with the density and viscosity of the alternative foams initially used compared to the traditionally used AFFF, e.g. by lower ambient temperatures. This was 120 Fluorine-free firefighting foams (3F) viable alternatives to fluorinated aqueous film-forming foams (AFFF), IPEN Stockholm Convention POPRC-14, Rome, September 2018 136 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS solved by modifications of the alternative product. The shift took approximately eight years from the first tests to when the modified alternative was introduced on all installations. Municipal fire brigades and forestry PFAS-free alternatives are readily available for these areas and, as shown in the market analysis, account for more than 60% of the total market. No data on costs of substitution specifically for these application areas have been provided in the stakeholder consultation or identified in the literature. Marine applications A wide range of PFAS-free foams are marketed for marine applications and it has not been indicated by any stakeholders that there might be particular challenges in changing to PFAS-free foams apart from the general need for adjustment and testing of equipment. One of the example products is a low expansion protein-based foam which is typically used in non-polar hydrocarbon fires in the petroleum industry and on oil tankers. It has the advantage that the product is compatible with black steel and does not require equipment made from stainless steel or plastics (and the same is the case for other protein-based products). It is designed for use with all mobile and stationary low expansion foam equipment and systems for fighting fires of classes A and B. Military applications Alternatives are less well established in the military sector, but it has been indicated by stakeholders that alternatives are considered to be feasible, although not many have yet been certified or implemented by users. The military applications are similar to those seen in airports and municipal fire brigades and the foams used are, after the necessary testing and adjustment of equipment, considered to be useful for military applications as well. As an example, the IPEN publication on "Fluorine-free firefighting foams (3F) viable alternatives to fluorinated aqueous film-forming foams (AFFF)" states that the Danish and Norwegian armed forces have moved to PFAS-free foams. The specific foams used have not been identified, but these are thought to be foams from major producers. As mentioned before, one stakeholder noted that testing and certification of PFAS-free foams and obtaining the necessary military approvals for use in all vessels / fire-fighting systems will take many years, and the associated costs will be very high. However, this has not been confirmed by other stakeholders. Petrochemical processing and large storage tank farms Use areas where PFAS-free alternatives have not been fully tested, is in the downstream petrochemical sector (refineries and steam crackers) and large storage tank facilities. In particular, for large storage tank fires, combatting these fires requires foams capable of flowing on large burning liquid surfaces and sealing against hot metal surfaces to prevent reignition. The development of suitable test criteria for large storage tanks and fluorine-free foams is ongoing under the LASTFIRE project. Several of the shortlisted products in this report have been tested and reported to be in compliance with the LASTFIRE criteria. According to a presentation by Nigel Ramsden, LASTFIRE, at the stakeholder workshop on 24 September 2019, it has been shown that PFAS-free foams can provide equivalent performance to C6 foams and provide appropriate performance for hydrocarbon fires in a number of test conditions: 137 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS When used with NFPA application rates for the following applications: Tank fires ~15m+ diameter (no reason to doubt results can be extrapolated to >25m+): o Conventional pourer standard application rates; o Aspirating monitor121; and o "Non aspirating" monitor with appropriate foam characteristics. Tank fires ~60m+ diameter No reason to doubt results can be extrapolated to >80m +) or bund fires: o Foam pourer. When used at lower rates than NFPA using CAF application: Tank fires ~15m+ diameter (no reason to doubt results can be extrapolated to >25m+): o Monitor application. Tank fires ~80m+ diameter (no reason to doubt results can be extrapolated to >100m +) or bund fires: o Foam pourer. It is stated in the presentation that test results for some conditions are still missing and LASTFIRE is going to work on these issues: specifically, polar solvent tests - foam application from longer distances, other foams/combinations of foam/application methods, tactics for life safety situations and optimising properties. As indicated above, it can be concluded that even in large tanks alternatives can be applied, but the safety margin may be lower than for the PFAS-based foams. According to stakeholders, the largest risks are associated with fires in large tanks of crude oil because of the higher risk of boil-over. One stakeholder mentioned that fires in large tanks of ~40m are however very rare in the EU and they could not identify any such fires in Europe in the last 10 years. A recent study by the Fire Protection Research Foundation (USA) determined the fire extinguishment and burnback times for five fluorine-free foams (FFF) and one short chain C6 Aqueous Film Forming Foam formulation (AFFF) as a function of application rate and foam discharge density for a range of test parameters including foam quality/aspiration, fuel type, water type and fuel temperature122. In summary, the authors conclude that PFAS-free foams have come a long way but there is still a lot more to learn about their capabilities and limitations. Furthermore, they conclude: "As of today, FFFs are not a "drop in" replacement for AFFF. However, some can be made to perform effectively as an AFFF alternative with proper testing and design (i.e., with higher application rates/densities)."122 121 Fire fighting monitors are a controllable high-capacity water jet used for manual or automatic fire fighting 122 Back, G.G., Farley, J.P. (2010). Evaluation of the fire protection effectiveness of fluorine free firefighting foams. Fire Protection Research Foundation. 138 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS No specific cases with successful 100% transition in installations with large tanks have been identified. According to stakeholders some examples exist where PFAS-free foams are used for the majority of applications but PFAS-based foams are still stored for use in emergency situations with large tank fires. A reported challenge in petrochemical processing and storage tank farms is the presence of tanks with different liquids that may require different alternatives because one alternative cannot be used for all the liquids. One supplier indicated that in some instances in the petrochemical industry two different alternatives could be required whereas another manufacturer indicated that even more than two may be required if many different liquids are stored. As reported elsewhere, in the chemical/petrochemical sector approximately 93% of the foam volume is used for training. Most of the manufacturers provide PFAS-free training foams that mimic the AFFF and which are used for training. One manufacturer indicated that the PFAS-free training foams were not used in live-fire training ("hot training") As indicated in the market analysis, PFAS-free alternatives account for 19% of the volume used in the chemical/petrochemical sector, but a major part of this is likely to be for training purposes. E.2.4.2. Availability A large number of alternatives are available from at least eight manufacturers. Most of these manufacturers also manufacture AFFFs and the alternative product range is often designed to match the product range of AFFFs. As demonstrated with the successful transition in many airports, products from several manufacturers are applicable for replacing the AFFF for the same application. Only limited information on actual production volumes for the individual products has been available from manufacturers because this information is generally considered confidential. The PFAS-free alternatives currently represent 32% of the market and this share is growing. Based on interviews with three manufacturers of fire-fighting foams in Europe, it can be concluded that there is currently overcapacity in Europe e.g. one of the manufacturers indicated they are running at 10-20% of their capacity. One manufacturer indicated that they have also extra capacity for emergency situations. All three manufacturers estimated that the necessary volumes of alternatives could be supplied within a short time (one to a few years). All EU manufacturers are also formulators and the alternative products are formulated from common bulk raw materials for cleaning and washing agents, food products, etc. and not specifically produced for the alternative firefighting foams. The manufacturers indicated that raw materials are available in sufficient quantities. According to the manufacturers and other information from stakeholders, the main challenge in the transition would not be to meet the demand for those alternatives already on the market, but to develop alternatives for application areas where replacement is still challenging. E.2.4.3. Health and environmental risks For the shortlisted products, none of the components included in the Safety Data Sheets are classified with CMR properties. For most of the products, the Safety Data Sheets indicate that the products or components do not meet the PBT/vPvB criteria of REACH. For two products, it is reported in the Safety Data Sheet that sufficient data are available for assessing whether the components fulfil the PBT and vPvB criteria. None of the products, however, include substances demonstrated to be PBT or vPvB substances. The classification of the components of assessed alternatives indicates that other classified effects are "Causes skin irritation" (H302), "Causes serious eye irritation" (H319) and "Causes skin 139 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS irritation" (H315). Many of the products do not include substances classified with environmental effects whereas others include one or more substances classified "Harmful to aquatic life with long lasting effect" (H412). It should be recognised however that not all human health or environmental hazard endpoints have necessarily been assessed in detail for each component by the foam manufacturers (for example, endocrine disrupting effects). E.2.4.4. Economic feasibility The available data indicates that the most significant one-off costs to transition to fluorinefree foams are associated with the following: Replacement of foams in storage. For Equinor, the costs of replacement of AFFFs was 5/l corresponding to 5.5 million; Destruction of replaced AFFFs. In addition to costs of about 1/l for the destruction of the replaced AFFFs, corresponding to a total of 1 million; Decontamination of equipment. The available cases do not indicate significant costs of decontamination of equipment. The equipment has typically been drained and decontaminated by cleaning with washing water which was discharged to waste water or surface water. However, the costs of cleaning of equipment will depend on the requirements as to the decontamination level and discharge of cleaning water. According to information from manufacturers, it may in some instances be less expensive to change part of the equipment than to clean it especially for stationary equipment. Stakeholders have reported, the requirements are different between Australia and New Zealand resulting in large differences in the costs of decontamination of equipment (specific data have not been obtained); Management of the transition process. Reported at 0.36 million for Equinor i.e. less than 10% of total transition costs; R&D and regulatory approval costs. These costs are usually covered by the manufacturers of foams and reflected in the price of the alternative foams; Adjustment and replacement of equipment. The available cases indicate that the costs of replacing equipment has been small in comparison to the cost elements listed above. According to stakeholders, extra storage capacity is not always required; and Training in the use of new products. The available cases do not indicate additional training costs; these are covered by the costs of testing and adjustment of equipment. Regarding the effective price of alternatives, three interviewed manufacturers of PFASbased foams and alternatives consider that the effective price is more or less the same and within +/- 20%. In accordance with this, additional recurrent costs for alternatives used in the aviation sector, stakeholders have reported that the effective price of the alternatives (taking efficiency of alternative into account) is more or less the same as the price of the AFFF used before the transition. The case from the offshore sector reports extra costs varying between +5% and +30% depending on application with total extra costs slightly below +30% as compared with the AFFFs used before. This may reflect the more diverse scenarios in the off-shore petroleum sector. 140 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS The reported shelf lives of alternatives range from >10 years to 20 years. Shelf life of PFASbased foams is reported to be typically between 10 years and 20 years (to a maximum of 30 years)123. In general, the shelf life of the alternatives does not seem to be shorter than the shelf life of PFAS-based foams and no extra costs, as a consequence of differences in shelf life, have been indicated by stakeholders. The main advantages of using alternatives in the aviation sector are that the rainwater and firewater runoff from training grounds can be discharged though the normal sewer system to the municipality's waste water treatment system, thus avoiding long-term clean-up issues and remediation costs in the future. The case from Copenhagen airport demonstrates that works on clean-up, containment and reconstruction of the fire training area were started and required an initial investment of more than 15 million, and currently, the maintenance of the drainage system around the fire training ground costs more than 1.5 million per year and this expenditure is expected to continue for at least the next 80 years. At offshore installations, training foams are typically discharged directly to the sea and it is not considered feasible to avoid this discharge by collecting and treating the AFFFcontaining firewater. As indicated above, the costs of destruction of PFAS-based foams is about 1/litre (a more detailed description of destruction costs is provided in section E.4). The costs of destruction of the PFAS-based foams is likely to be incurred in any case when the foams expire (exceed their shelf life). In the past the PFAS-based foams were also used for training which meant that stocks were used before they reached the end of their shelf life. According to information from stakeholders it is today common to store PFAS-based foams which have reached their shelf-life whilst waiting for a less expensive solution for disposal. In a scenario where PFAS-based foams are used for emergency situations and PFAS-free foams are used for training, a cost of about 1/litre for destruction of the PFAS-based foams by the end of their service life should be expected. E.2.4.6. Comparison of application area An overview comparison of the use of fluorine-free alternatives in different applications is provided in the table below: 123 Proposal for a restriction: Perfluorohexane sulfonic acid (PFHxS), its salts and PFHxS-related substances https://echa.europa.eu/documents/10162/a22da803-0749-81d8-bc6d-ef551fc24e19 141 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Parameter Technical feasibility Availability Risks Current and future availability Timeframe Human health Questions Can alternatives perform the same functions as the PFAS-based foams for same application Will it require changes (in processes, equipment, storage facilities, training, etc.)? Is it available in the required tonnage / amount in the EU / worldwide? How fast could enterprises make the switch? What would be the downtime, if any? Information on the hazards: properties causing the concern for the substance to be restricted / other properties. Airports Off-shore facilities Petrochemical industry and large tank farms Municipal fire brigades Marine applications Training: Yes Actual fires: Yes Training: Yes Actual fires: Yes Most training scenarios: Yes Large-scale fires: Not demonstrated for some situations Training: Yes Actual fires: Yes Training: Yes Actual fires: Yes Adjustment of equipment, tests, training required. In some instances there may be a need for new equipment and increased storage capacity Yes Yes Yes for most Yes Yes training No - further tests of alternatives required for actual emergency situations in large tank farms and some other installations Meeting market requirements not considered a challenge as transition is expected to take some years Meeting market requirements not considered a challenge as transition is expected to take some years No challenge for training foams Further development required for large tank farms Meeting market requirements not considered a challenge as transition is expected to take some years Meeting market requirements not considered a challenge as transition is expected to take some years None of the constituents of the alternatives meet the CMR criteria. Classification of constituents of alternatives does not point to any significant health concern. This assessment is based on hazard information identified in safety data sheets for relevant products. The safety data sheets include constituents with a hazard classification, and the conclusion that the alternatives do not meet the CMR criteria are considered robust for the foams evaluated in more detail. However, there was insufficient information to conclude whether the underlying test/endpoint data was equivalent for these substances and the alternative products compared to the PFASbased products 142 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Parameter Risk to the environment Assessment of net risk Questions Information on risks related to properties causing the concern for the substance to be restricted / other properties. Information on other risks related to the alternatives. Information on the hazards: properties causing the concern for the substance to be restricted / other properties. Information on risks related to properties causing the concern for the substance to be restricted / other properties. Information on other risks related to the alternatives. Would the alternative result in a sufficient reduction in the net risk? Are there new risks associated with the alternative? Airports Off-shore facilities Petrochemical industry and large tank farms Municipal fire brigades Marine applications Some constituents are classified with hazard phrases such as harmful if swallowed and causes serious eye irritation and occupational exposure should be reduced by use of adequate protective equipment, but this would likely apply to any fire-fighting foam. PFAS are very persistent with a potential for exposure of humans via the environment. Shortchain PFAS accumulate in edible parts of plants and the accumulation in food chains is unknown124 In general, there is a high level of uncertainty as to whether the ongoing exposure to low concentrations of short-chain PFAS may cause adverse effects in organisms. It is therefore very difficult to estimate longterm adverse effects in organisms. The constituents of alternatives are in general not persistent, and exposure via the environment is not considered to be of concern based on data currently available. For some alternatives, data are not sufficient to conclude that they do not include persistent constituents. Alternatives do not generally meet the PBT or vPvB criteria. For some of the alternatives, data were not sufficient to determine whether some constituents are persistent. Many of the alternatives include constituents classified as toxic or very toxic to aquatic life. Short-chain PFAS are very persistent with high mobility in environmental media and high potential for longrange transport. * The constituents of the alternatives are in general not identified as persistent or of having a high potential for long-range transport and for accumulating in the environment. However, there was insufficient information available to conclude whether the underlying test/endpoint data was equivalent for these substances and the alternative products, compared to the PFAS-based products. In general, alternatives do not contain very persistent substances and are considered likely to provide a reduction in the net risk. The main constituents of alternatives are typically used in cleaning and washing agents, food, etc. Overall, no significant new risks have been identified based on the available information. However, not all human health or environmental hazard endpoints have necessarily been assessed in detail for each component by the foam manufacturers (e.g. endocrine disrupting effects). Additionally, the level of information available on the risk posed by some alternatives is insufficient to conclude whether the underlying test/endpoint data was equivalent compared to the PFAS-based products. 124 Short-chain perfluoroalkyl acids: environmental concerns and a regulatory strategy under REACH. Brendel et al. 2018. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC5834591/pdf/12302_2018_Article_134.pdf 143 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Parameter Economic feasibility Net costs Uncertainties. Questions Net compliance and other costs (taking into account both increases and decreases in costs) faced by actors in each link of the supply chain. Airports Off-shore facilities Petrochemical industry and large tank farms Municipal fire brigades Marine applications One off costs: The main costs of transition are reported to be costs of replacement of PFAS-containing foams in storage and destruction of these foams (such costs would not normally have been incurred outside of normal replacement after 10-20 years). Total costs of replacement and destruction is approximately 6/l. Costs of decontamination of equipment have been mentioned by stakeholders as potentially significant, but actual cases do not indicate significant costs of decontamination. Economic feasibility of the alternatives. Ability of the different actors to pass costs down the supply chain. Trade and wider economic and employment effects. What is the level of uncertainty in the assessment of the feasibility, risks and economic viability of alternatives? Recurrent costs: Extra costs of foams are reported to be in the range of 0 to +30%. Alternatives have successfully been implemented by many users Alternatives have successfully been implemented by some users Alternatives have successfully been implemented for training purposes; for specific applications alternatives are not available Alternatives have successfully been implemented by many users High (no competition with competitors outside the EU) Medium (some competition with competitors outside the EU) Medium (some competition with competitors outside the EU) High (no competition with competitors outside the EU) No effect expected No significant effect expected No significant effect expected No effect expected High certainty High certainty Medium certainty - many different and complex scenarios High certainty Alternatives have successfully been implemented by many users Low (significant competition with competitors outside the EU) No significant effect expected High certainty 144 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS E.3. Restriction scenario(s) See Section 2.3. E.4. Economic impacts E.4.1. Socio-economic analysis Section 2.3 summarises the main effects (i.e. anticipated responses from the supply chains along with associated impacts) resulting from the two restriction scenarios and identified theultimate impacts to be assessed. These ultimate impacts were labelled a. - l. in Figure 2.1 and Figure 2.2, and are discussed one by one in the following subsections. a. Cleaning of equipment: costs and remaining contamination A restriction on the placing on the market of PFAS-containing fire-fighting foams (Scenario 1) would allow users to continue using their stocks of foams, but once they are depleted, users would be forced to switch to alternative (fluorine-free) foams. A restriction on the use of PFAS-containing fire-fighting foams (Scenario 2) would require this switch to happen immediately when the restriction comes into force (or before). During the storage of PFAS-containing foams, fluorinated surfactants settle on the walls of the tanks as well as in pipe and hose lines of fire-fighting equipment. These would leach into any new foams filled into the equipment and therefore contaminate the new fluorine-free foams with PFAS, leading to continued PFAS emissions125. In order to control these emissions, equipment previously used for PFAS foams may be required to meet a minimum concentration limit of remaining PFAS, which can potentially be achieved through cleaning. This sub-section discusses the feasibility of achieving a certain (yet to be determined) concentration of PFAS through the cleaning of equipment, with a focus on the associated cost. The analysis of alternatives has concluded that currently available cases of transformation to fluorine-free foams do not indicate significant costs of decontamination of equipment (including disposal of the liquid used for cleaning), with relatively simple methods being applied. However, the costs of cleaning of equipment will depend on the contamination thresholds requirements. According to information from manufacturers, it may in some instances be less expensive to change part of the equipment than to clean it, especially for stationary equipment, so this is also discussed below. Techniques identified to clean PFAS-containing foam from equipment are: The use of hot water and detergents in a 32-stage legacy foam decontamination process (stakeholder consultation response). This technique is reported to result in all appliances achieving PFAS levels below 1000ppt and one-third of appliances being below 70ppt. An independent 125 Bavarian Ministry of the Interior, Sport and Integration, and Bavarian Ministry of the Environment and Consumer Protection: Environmentally friendly use of fire-fighting foams. Available at: https://www.bestellen.bayern.de/application/eshop_app000000?SID=578672032&ACTIONxSESSxSHOWPIC(BILDx KEY:%27stmuv_all_00001%27,BILDxCLASS:%27Artikel%27,BILDxTYPE:%27PDF%27) [In German] 145 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS body oversees the process and measures the PFAS concentrations achieved. The approximate cost of this process is 12,300126 per appliance.; and For stainless steel tanks, glass fibre reinforced plastic and polyethylene tanks, following the discarding of the foam, tanks are rinsed with hot water (50-60C) and then filled again with hot water for at least 24 hours127. This process is repeated three times in both the tank and any foam carrying pipes and fittings, and the water from these rinsing operations passed into the sewage system and treatment plant. This is recommended in some government guidance128. No information could be identified concerning the costs of this technique or the remaining contamination levels achieved. Several stakeholders commented on the feasibility of cleaning techniques to remove PFAScontaining foams from equipment. One stakeholder considered achieving PFAS contamination levels below 100 ppb to be unrealistic in most cases (from the stakeholder workshop) and one stakeholder considered it to be almost impossible to achieve a contamination level of zero in a one-digit ppb framework with another stakeholder also commenting that the cleaning of systems and equipment is unlikely to bring the level of residual PFAS to zero. One stakeholder that has transitioned to fluorine-free foams (in the petrochemicals sector) reported that they had aimed for and achieved a level of 0.001% (10,000 ppb). To put this into context, the average concentration of PFAS in PFAS-based fire-fighting foams is some 2-3% (20-30 million ppb). One stakeholder commented that the level of cleanliness achieved by cleaning techniques would vary depending on the equipment and material being cleaned. The need to accommodate an allowance for residual legacy PFAS even after equipment has been cleaned was also discussed. Stakeholders also commented on how cleaning techniques and costs may be impacted by different PFAS contamination thresholds. Where contamination threshold levels are set high, following the cleaning of equipment, a higher level of residual PFAS-containing foam would be allowed to remain (compared to if a lower threshold limit were set). One stakeholder therefore considered the implementation of a high contamination threshold to be "pointless", due to its reduced effectiveness in eliminating PFAS emissions. With a low contamination threshold level, a lower level of residual PFAS-containing foam will be allowed to remain in equipment following cleaning and cleaning will be more costly than if a higher threshold level were set. Also, where contamination levels cannot be achieved through cleaning, equipment will need to be replaced at a cost. Equipment replacement is more likely to occur where threshold levels are set low. There are potentially significant costs associated requirements for cleaning or replacement of equipment, if a low threshold is set for residual PFAS concentrations (following use of the alternatives in the same equipment as PFAS-based products). The market analysis (Annex A) estimated that there are likely to be several tens or potentially hundreds of thousands of facilities with equipment that contains fire-fighting foams. If all of these require extensive cleaning using techniques such as the decontamination process described above (and costing 12,300 per appliance), the costs of cleaning could be in the region of 1 billion (based on an assumed 100,000 appliances needing cleaning). If a less stringent threshold 126 Conversion rate of 1 EUR = 1.62470 AUD applied. It is assumed that this cost includes treatment of the waste water generated, although the stakeholder response did not specify that. 127https://www.bestellen.bayern.de/application/eshop_app000000?SID=578672032&ACTIONxSESSxSHOWPIC(BIL DxKEY:%27stmuv_all_00001%27,BILDxCLASS:%27Artikel%27,BILDxTYPE:%27PDF%27 [In German]. 128https://www.bestellen.bayern.de/application/eshop_app000007?SID=147496132&ACTIONxSESSxSHOWPIC(BIL DxKEY:%27stmuv_all_00001%27,BILDxCLASS:%27Artikel%27,BILDxTYPE:%27PDF%27) [In German] 146 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS concentration is used, the costs would potentially be significantly lower. However, insufficient information is available to develop a more robust estimate of these costs. Regulation in Queensland, Australia, allows for threshold concentrations for replacement foam stocks to be 10ppm (mg/l) for PFOA/PFHxS and 50ppm (mg/l) for PFOA129. Additionally, one stakeholder commented that newer C6 foams are purer and have lower concentrations of impurities than older C6 foams and suggested that different threshold levels for different PFAS-containing foams may be required. For confirmation that threshold levels have been achieved, cleaning techniques may need to be professionally endorsed or, following cleaning, the presence and concentration of remaining PFAS tested. Stakeholder responses reported some concern over the suitability of existing methods to measure and detect the presence and concentration of remaining PFAS. One stakeholder reported that measuring very low concentrations e.g. at ppb-concentration was not possible. One stakeholder suggested that following cleaning, an assessment should be undertaken at an accredited laboratory for verification that threshold levels have been achieved. Stakeholder responses suggested that laboratories are able to analyse down to a level of 30-150 ppb. In the REACH restriction on PFOA, a concentration limit of 25 ppb of PFOA including its salts or 1,000 ppb of one or a combination of PFOA-related substances was adopted, based on the capabilities of analytical methods according to the RAC's opinion on the restriction dossier. Information on the cost of analysis was not provided. A cost analysis concerning the measurement of cleaning success could therefore be done as part of this analysis. Where threshold limits cannot be achieved through cleaning techniques or where cleaning techniques are too difficult or too costly to achieve, the replacement of equipment is likely to be required. The cost of replacing equipment will vary across industries and appliances. Table E.1 provides an example of the potential costs for the replacement of fire extinguishers, where cleaning techniques do not succeed in attaining threshold concentration levels, or the cleaning process costs more than the cost of replacement. It is assumed that these costs represent only the replacement cost of the equipment and do not include the replacement cost of equipment plus foam, nor the cost of disposal of the old equipment. Figures for the total number of fire extinguishers existing and currently using PFAS-based foam have been obtained from the Market Analysis (the lower end of the range is based on a Eurofeu position paper and the higher end considered a more uncertain highlevel estimate based on extrapolation from German data and expert judgement). The stakeholder consultation also revealed that the cost for a new extra foam tank in a fire truck is 35,000 for a fire brigade providing industrial fire protection. However, information of the number of existing foam tanks containing PFAS fire-fighting foam was not provided and therefore cost analysis for their replacement has not been estimated. Table E.1 Estimated costs for the replacement of fire extinguishers in the whole of the EU 1 per replacement extinguisher 3 per replacement fire extinguisher 5 per replacement fire extinguisher 15 million fire extinguishers to be replaced 15 million 45 million 75 million 129 Obtained from stakeholder consultation. Also available online here: https://www.qld.gov.au/environment/pollution/management/disasters/investigationpfas/firefighting-foam/policy-overview 147 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS 1 per replacement extinguisher 3 per replacement fire extinguisher 5 per replacement fire extinguisher 90 million fire extinguishers to be replaced 90 million 270 million 450 million Note that these costs do not include the cost of foam disposal from cleaning. Estimated costs of fire extinguishers were obtained from stakeholder consultation and it is not clear whether the costs of fire extinguisher replacement include the cost of alternative fire-fighting foam, as well as the equipment. Costs of fire extinguishers range from 1-5, and have been interpreted as low (1), medium (3) and high (5). All fire extinguishers are assumed to cost the same regardless of size and capacity. Overall, stakeholders considered the cleaning of equipment to be a costly operation, but little quantification of costs was provided in the consultation, making it difficult to undertake a cost analysis. Several users have already transitioned from using PFAS-containing firefighting foams to PFAS-free firefighting foams. Several consultees report there to be no significant costs associated with new equipment required. Although some stakeholders also report the replacement of fire-extinguishing systems and the cleaning of equipment to be costly. The cost of cleaning existing equipment will likely depend upon how effective cleaning techniques are for each appliance, as well as on the threshold contamination levels set. Where equipment cannot be sufficiently cleaned to meet threshold contamination levels (yet to be determined), replacement will be required. b. Other options and their impacts This section discusses what other responses to a restriction than using alternatives are likely (if any), and their socio-economic impact. Theoretically, in response to PFAS-based fire-fighting foams becoming unavailable, users could respond by eliminating the need for the use of fire-fighting foams. As discussed in the market analysis, the main application for PFAS-based fire-fighting foams are class B fires (flammable liquids and gases). Hence, to eliminate the need for fire-fighting foams would (in principle) require stopping the use of flammable liquids or gases, or accepting a situation where fires are less well controlled than at present. While this may be possible in a limited number of specific applications where they are not crucial, it seems unlikely in most cases. The consultation has also not specified any likely other responses than using alternatives. Therefore, no other options are considered. c. Fire safety: impacts of technical performance of alternatives Both scenarios 1 and 2 would lead to a transition to alternative foams. The transition associated with Scenario 2 would be faster as existing stock would need to be disposed of at the same time. The key socio-economic issue under both scenarios is the likelihood of fires being extinguished effectively and without delay, compared to the situation using PFAS based foams. The key issues in the technical feasibility of alternatives are three -fold. First, do the alternatives effectively put out fires so that life, environment and property are not at additional risk? Second, if so, are there delays in the duration over which the alternatives can address these fires, considering the technical ability to deliver greater volumes of foams to the fire? Third, do the alternatives have relevant and reliable safety standards so that downstream users can purchase and use these alternatives with confidence, making allowance for testing in users' specific systems? This sub-section discusses the difference in the fire safety performance through the use of alternative fire-fighting foams. These effects are quantified where possible, and drawn out qualitatively where not. This section draws directly on the analysis of alternatives (AoA). As in previous sections, whilst the AoA started with a long-list of some 30 alterative foam products, it focussed on a subset of seven judged to be illustrative of the efficacy of these. 148 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS The evidence below focusses on these specific products but refers to wider evidence were relevant. Table E.2 provides a summary of the key information. Table E.2 Effectiveness of alternatives - summary Alternative Attained performance standards? Information from `real world' use Respondol ARF 36% Yes - 2 (EN 1568 Parts 3 and 4) None Identified RE-healing foam RF3X6 ATC Yes x 4 (EN 1568 Parts 1 and 2, and ICAO Levels B and C)) Yes - Copenhagen Airport & Norwegian Offshore oil sector and Melbourne Fire Brigade. RE-healing foam RF1-1% Yes - 1 (EN 1568 Part 3) Yes - Norwegian Offshore oil sector. Moussol FF 3X6 (F15) Yes x 5 (DIN EN 1568: Part 3 (Heptane): IIIB/IIID, Part 1: Medium ex. - Part 2: High ex. Yes -Swedavia, Heathrow Airport (UK), Norwegian Petrochemical sector. ICAO Low expansion foam Level B DIN EN 3 21A). Foam Mousse 3% F-15 Yes (x1) (EN 1568 Part 3 heptane) None identified (but consultation has confirmed this is in use) Epocol Premium Yes x 6 and 1 in progress. EN 1568 - 1: Conform None identified (but consultation has confirmed this is in use) EN 1568 - 2: Conform EN 1568 - 3: 1A / 1A EN 1568 - 4: 1A / 1A Oil industry: LASTFIRE Additional stakeholder information Can be used for use in `all types of flammable liquid fires'. Has been in used in Municipal Fire Brigade applications - both in training and operational fires. Consultees state this alternative can be used at offshore oil installations and onshore terminals and refinery. Has been in use at Heathrow Airport (UK) since 2012. See case study. Consultees state this alternative is largely used in marine applications and is only used for smaller fires (unsuitable for aviation, for example). Manufacturer states this alternative can be used in all sectors: airports, marine, military, chemicals, oil and gas, municipal fire fighters and from fixed mobile and CAFs. Hydrocarbon fires, all types of flammable polar solvent liquids Consultees indicated this as a possible substitute for large tank fires, but further testing was necessary. 149 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Forest fire standards: CEREN Certificate Certification in progress : UL 162 / GESIP). Orchidex Blue Foam 3x3 Yes x 4 (EN 1568 Parts 3 and 4, Oil industry: LASTFIRE, ICAO Level B)) Yes - German airport are reported to be using the product. Consultees indicated potential for additional volumes and/or time to suppress fires may occur for some fuel types, but for others, the performance is the same as for PFAS foams. Effectiveness of foams The central finding, based on evidence from the analysis of alternatives, the stakeholder consultation and the workshop is that from a technical standpoint, no stakeholder concluded that alternatives are not technically feasible, at least for the majority of uses. As noted in the AoA, in aviation several airports have successfully transitioned, as have Municipal Fire Brigades and companies active in offshore oil and gas operations and the marine sector. Evidence indicates that one segment - liquid fuel fires of large atmospheric storage tanks - is a concern for consultees. Large scale tests for fluorine free foams are ongoing and not yet complete, partly because the scale and cost of these tests. However PFAS-free foams have provided equivalent performance to C6 foams during hydrocarbon tank fires of 15, 60 and 80m diameter (during LASFIRE testing). Performance depends on application rate and equipment, but one stakeholder suggested that there is no real reason why these results cannot be extrapolated to bigger tanks (100m) or bund fires. More testing is required to prove performance of alternatives under some conditions. To date, no realworld examples of a successful transition in installations with large tanks are identified. Consultation has noted that, as such, AFFFs are still used when large fuel areas need to be extinguished quickly or in sprinkler systems. The available evidence suggests that elsewhere technically feasible fluorine free foams have been developed, are commercially available and have been used to the satisfaction of users. This transition has not occurred without some technical challenges (and cost) and has required testing in each users' system. Additional volumes of foam, compared to PFASbased products, have been necessary, but not uniformly. Several users have identified - and overcome - technical issues. These related to temperature tolerance of alternatives and the viscosity of foams. Some changes to foam delivery systems, nozzles and some additional storage capacity has been required. Speed of fire suppression (making allowance for additional volumes required) Limited detailed information was obtained on this specific aspect. One respondent highlighted there could be a 5-10% gap in the extinguishing time, but that this "mainly" concerned polar liquids. Other consultees noted that equivalent volumes were required and these yielded equivalent performances, but this was not consistently reported. Others noted additional volumes of fluorine free foams, compared to PFAS based products in at least some applications. Some consultees highlight that this was a particular concern with small extinguishers. Whilst one respondent noted that, in general, fluorine free foams are less flexible for users, because they have less margin for error in the proportioning (i.e. volumes 150 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS required), in their application type and of ease of use. However, other consultees provided feedback of use in specific applications (aviation), including an example of where a fluorinefree foam worked satisfactorily despite deliberate inappropriate application methods as part of testing procedures. Standards The analysis of alternatives (Section E.2) provides a list of specific international compliance standards for the various commercially available products, with more details for each shortlisted product above. The underlying study130 (Appendix 5) provides more detail on each of these standards. Foams are developed to meet specific standard requirements and it is important to note that tests used for standardisation and certification of PFAS-based foams are not necessarily appropriate for fluorine-free foams. Stakeholders highlighted during the consultation workshop that current testing protocols have often been designed with PFAS-based foams in mind. These testing protocols may not be adequately tailored to reflect the fire-fighting ability of fluorine-free foams, because the same application methods may not always be applied and read-across between different burning fuels may not be straightforward. Therefore, it is inherently challenging to compare the two types purely based on certification. Some fluorine-free foams are however capable of meeting standard firefighting certifications applicable to PFAS-based foams and this has been demonstrated in cases where some airports and municipal fire brigades for example have successfully transitioned to fluorine-free foams. d. Use patterns of alternative fire-fighting foams to achieve comparable/acceptable performance This section discusses the impacts associated with the use patterns of alternative firefighting foams and includes discussion on: (a) the quantity of alternative foams needed to achieve either comparable performance or performance that is acceptable from the standpoint of safety to PFAS foams. (b) different specific application methods and equipment used. a) Quantity of foams needed to achieve comparable/best possible performance The available evidence does not permit a quantitative estimate for the comparative volumes of fluorine free foams required, for each application and with specific foams. However, the consultation allow a range to be specified. The same approach is used for the availability assessment below. It is important to note that the available quantitative information received - despite extensive attempts for specific information and for clarification - was very limited. Based on the available data, the range specified was between no change in volume and up to a maximum of 100% additional foam required, note the 100% volume estimate was specified by just one consultee and it is understood that this relates to use in one application. The available information is not sufficient to conclude these are isolated cases. As noted in the previous section, this does not apply to liquid fuel fires of large atmospheric storage tanks/large scale tank fires. Here, consultation indicates that large scale testing is still needed to confirm performance. 130 Wood, Ramboll, COWI: "The use of PFAS and fluorine-free alternatives in fire-fighting foams - Final report". Report for the European Commission DG Environment and European Chemicals Agency (ECHA) under specific contracts No 07.0203/2018/791749/ENV.B.2 and ECHA/2018/561. 151 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS The details on specific shortlisted products - which are known to be in use within the EU (based on stakeholder consultation) - are set out below. Table E.3 Use patterns of alternatives - summary Alternative Comparative volumes required vs PFAS containing foam Respondol ARF 3-6% No specific data has been supplied, despite attempts to obtain this via consultation. RE-healing foam RF3X6 ATC Variable depending on application ("drop in replacement, with no additional volumes required in offshore oil installations, onshore terminals and refinery). RE-healing foam RF1-1% No difference to PFAS based foams (evidence available for some applications only). Moussol FF 3X6 (F-15) Volumes vary depending on application. From no difference to up to c. double the volume required in some applications. FOAMMOUSSE 3% F-15 No information available. Epocol Premium Range depending on application. Whilst stakeholder data is limited and relates to just one consultee, the potential ranges specified were between 30 - 50% greater volumes required. It is not clear whether the latter figure is only in exceptional circumstances. Orchidex BlueFoam 3x3 Consultation data unclear - potential need for up to 10% additional volumes. b) Specific application method for the foams or equipment used (if different for alternatives compared to PFAS-based foams) Several respondents report that for fluorine free foams used in sprinkler applications, special sprinkler nozzles have to be installed, which included "special low expansion nozzles". For extinguishers, consultees noted that greater expansion is required for PFAS free foams. Therefore, depending on the extinguisher, pressure may need to be increased and different nozzles required. Respondents also referred to challenges associated with temperature tolerance and viscosity of alternative foams. These appeared to have been satisfactorily resolved. Another noted that, as the chemical nature of the fuel varies, more than one agent may need to be stocked by users so that they may be able to deal with fires of different types on any one site. This was reported to be a reflection of a lower level of "flexibility" in Fluorine free foams. This has logistical, training and safety implications for users. The correct foam agents will need to be stocked, in appropriate locations, with ease of access along with processes and training to ensure users cannot use incorrect foam agents, particularly in fast moving emergency situations. Again, further specific information was not available to enable conclusion as to whether this risk applies differently to specific user sectors. e. Impacts associated with the economic feasibility of alternatives This section discusses the economic feasibility of alternatives. There are several elements assessed. First annual foam costs - based on the additional volumes required by industry in any one year, this is evaluated based on the price differences between alternative and PFAS-based foams are evaluated, considering whether additional volumes of the alternative are required to fulfil the same/acceptable functionality. So this is in effect, the cost for one annual replacement "cycle" as foams are used and/or disposed of as they pass their useful life. The net change in foam costs is then estimated. This is relevant for both Scenarios. Second, in Scenario 2 users would no longer be able to use the foam stocks they have purchased. The costs for this stock will have to be written off and new stocks purchased. 152 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS A range of other costs, associated with testing (and other R&D), storage, technical changes in foam dispensing and/or storage equipment and regulatory approvals are also summarised. The likelihood of whether additional costs would be passed down the supply chain is also considered. Lastly, costs may be partly offset by savings of using alternatives, e.g. from less costly waste management when they reach their expiry date. The assessment is associated with significant uncertainty and this is reflected in the wide ranges presented. There are uncertainties in several input assumptions, summarised in Table E.4. Existing use of PFAS based foams is between 14,000 and 20,000 tonnes per year. The best estimate used in the analysis is some 18,000 tonnes per year; The average price of existing PFAS-based foam is subject to uncertainty, reflecting the wide range of specific foam compounds used. It is understood that certain compounds are currently available containing high proportions of PFAS and, whilst these are judged to be effective foams, the price for these compounds is well above average, the market assessment noted that these are uncommon. The weighted average used is 3,000 per tonne of PFAS containing foam, as set out in the market assessment. Note the lowest and highest values identified in the market assessment and stakeholder consultation were 2,000 per tonne and up to 30,000 per tonne. The latter figure has a significant effect on the ranges in the socio-economic assessment, but there is insufficient data to conclude the extent of the market currently pay this price per tonne for product; Based on these parameters, the current baseline foam costs are somewhere between 28 million per year and a maximum of up to 600 million per year. The best estimate is current costs of 54million per year (i.e. 3,000 multiplied by 18,000 tonnes); The same uncertainties apply to the average prices per tonne of fluorine free foams. The market assessment concludes, based on information provided via the stakeholder consultation, that fluorine free foams, on average, are likely to be the same price, i.e. around 3,000 per tonne of foam. This value is used in the central estimate. The ranges in the table below are the lowest and highest prices quoted in the consultation, respectively. This indicates that the most expensive fluorine free foam is likely be less expensive than the most expensive current foams. As noted above, this has a significant effect on the result and is subject to particular uncertainty; and Finally, consultees noted a range of different volumes may be required to fulfil the same/acceptable functions. The comparative volumes required differed, depending on the specific application and customer need. Therefore, a range has been used, between a 0% increase and up to 100%more fluorine free product, over and above the volumes required for PFAS-based foams. Costs for one annual cycle of foam replacement (Total EU market) Table E.4 summarises the assumptions used in the following to estimate annual foam replacement costs. 153 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Table E.4 Annual foam costs - input assumptions Baseline PFAS foam market t/yr Central (L-H) Average price /tonne of foam Weighted average (L-H) Current foam costs (PFAS) EU market cost per year Best estimate (L-H) Average price per tonne of foam (Fluorine free alternatives) Additional volumes required % increase over PFAS based foams) L-M-H 18,000 (14,00020,000) 3,000 (2k-30k) 54m (28m - 600m) 3,000 (0.7k-10k) 0% - 50% - 100% Source: Market assessment, desktop research and stakeholder consultation exercise. Note, the maximum baseline used in the SEA is 21,000 tonnes, rather than the 20,000 in the market assessment due to rounding of volumes used at sector level. Using the assumptions above, Table E.5 sets out the potential costs expected to be incurred by the EU market as a whole through purchasing volumes of fluorine free foam in an annual cycle. Overall, this suggests demand for alternative foams of between 14,000 tonnes per year and up to a maximum of 40,000 tonnes per year, for the sector as a whole. The associated costs are estimated at between 21 million and 30 million per year, with c. 27 million considered to be the most likely average cost for the EU market as a whole. Again, it is recognised that individual companies/users would incur greater or lower costs per tonne and require differing volumes. The wide ranges in different foam costs indicates whilst the average company may experience some increases in costs, others would experience savings, potentially quite large savings for some very specific market segments. Table E.5 Scenarios, gross and net foam costs -annual cycle replacement costs for total EU market (M denotes millions) Costs for existing PFAS based foams (EU Market - best estimate (Range) Tonnes of alternative required (EU Market) (L-M-H) Potential foam costs using alternative products (EU Market) Best estimate (Range) Net change in foam costs (EU market) Best estimate (Range) Best estimate (assuming 18,000t) PFAS foam use p/yr) 54m (36m - 540m) 18,000 - 27,000 36,000 81m (13m to 360m) 27m (-23m to -180m) Assuming low PFAS foam use (14,000 t/yr.) 42m (28m - 480m 14,000 -21,000 - 28,000 63m (10m - 280m) 21m (-18m to -200 m) Assuming high PFAS foam use (20,000 t/yr.) 60m (40m - 600m) 20,000- 30,000 - 40,000 90m (14m- 400m) 30m (-26m to -200 m) Source: Market assessment, desktop research and stakeholder consultation exercise. It is important to note that the stakeholder consultation indicated many users had experienced no increase in foams costs and indeed no additional volumes required. The above has been undertaken to assess the potential scale in a best and worst case, using reasonable assumptions in the absence of complete data. 154 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Costs for stock write off and replacement (Total EU market) In addition to the annual replacement cycle, under Scenario 2 the entire stocks of PFAS foam would need to be disposed of and alternative volumes of foam would then need to be purchased. In the baseline, foam stocks would also have to be replaced once they are used or expired, so the restriction would bring the replacement costs forward. To reflect this, the value of the depreciation of stocks at the point of replacement due to the restriction is also considered. Assuming an even age distribution of stocks of PFAS-based foam and a linear depreciation of foams over their lifetime, the restriction would cut the life of the foams in half on average, and so half of their original purchase value would already have depreciated and should not be considered as a cost of the restriction. The restriction could also cause additional cost of purchasing alternatives instead of PFAS-based foam taking account of both the price differential and the potential difference in volumes required. As above there is significant uncertainty in the input assumptions and these are presented as a possible range of costs. Table E.6 Quantitative data - economic costs Baseline Existing stocks of PFAS-based foam: Average: 322,500 (Between 210,000 tonnes and 435,000 tonnes) Purchase costs (oneoff total for whole stock): Average: 970 million (range 420 million to 13 billion) Value of stock depreciated: Average: 485 million (range 210 million to 650 million) (half of purchase cost, assuming even age distribution and linear depreciation) Restriction Scenario Volume of replacement with fluorine-free alternatives: Average: 483,750 (Between 210,000 tonnes and 870,000 tonnes) Purchase costs (oneoff total for whole stock) : Average: 1.5 billion (range 150 million to 9 billion) Additional cost of the restriction: Average: 1.0 billion (range-60 million - 8.3 billion) (Purchase cost of replacement minus value of existing stock depreciated) Based on PFAS foam costs of 3,000 per tonne weighted average (with lowest costs of 2,000 and highest of up to 30,000 per tonne) and fluorine-free foam costs of 3,000 per tonne weighted average (with lowest costs of 700 and highest of up to 10,000 per tonne) The cost of the foam itself are only one aspect of the economic considerations of adopting alternatives. Additional transitional costs are described below. It has not been possible, despite attempts to obtain further quantitative information, to estimate costs for the market as a whole. However, several consultees noted that whilst additional costs were incurred, these were not significant and had proved manageable. Available quantitative information is summarised below. Further information is also presented in the case studies. Note that the cost of disposal of stocks of PFAS foam is covered in a later subsection (l. Costs of disposal of legacy foams). Table E.7 Quantitative data - economic costs Testing costs Storage costs No quantitative data has been obtained via Experience in the Norwegian petrochemical Costs from technical changes Consultation indicated that new nozzles had Other costs including regulatory approvals Experience in the Norwegian 155 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Testing costs Storage costs Costs from technical changes Other costs including regulatory approvals stakeholder consultation, despite several requests for such information. Testing would be associated with costs for sample volumes of foam (likely several different products) and with staff time and training. sector (Equinor) included additional costs related to purchasing additional volumes of foam, to replace the previous PFAS containing foams, no information was provided on whether there were costs implications related to the need for additional storage space.. been required in several cases. Typical costs for a range of firefighting nozzles are within an approximate range of between 5 or less, per piece for simple foam nozzle devices, to c. 30 and up to c.60 for marine firefighting nozzles or "heavy duty applicators" and up to c 200 for more specialist equipment [1] petrochemical sector (Equinor) indicates costs (labour time) in the region of 360,000 for a range of support in their transition at a total of 45 sites (so in the order of c. 10,000 per site). This would therefore appear to be an upper bound cost for a company transitioning. Mobile foam units are in the region of 2,700 [2] Notes [1]: Costs derived from search of widely available commercial products. See: https://www.made-inchina.com/products-search/hot-china-products/Water_Foam_Nozzle_Price.html See also https://www.orbitalfasteners.co.uk/products/heavy-duty-foam-dispenser-gun See also: https://www.dortechdirect.co.uk/heavy-duty-pu-applicator-gun-for-expandingfoam.html?gclid=EAIaIQobChMIudKHq9GP5gIVSbDtCh31AATEEAQYASABEgL5S_D_BwE See: https://www.safetyshop.com/lever-operated-nozzle-for-firehose.html?gclid=EAIaIQobChMI6cKnwNmP5gIVAuDtCh2KMwErEAQYAiABEgL91PD_BwE&gclsrc=aw.ds See: https://www.fireprotectiononline.co.uk/hv-series-low-expansion-foam-branchpipes.html?gclid=EAIaIQobChMItqqg_NmP5gIViLbtCh0ImgYXEAQYByABEgIFdvD_BwE [2]: https://simplyextinguishers.co.uk/df130-mobile-foam-units.html?gclid=EAIaIQobChMIn4yv79yP5gIVgpOzCh1PQghEAkYBiABEgKsIfD_BwE Testing costs Whilst there are several categories of foam designed to address fires from specific fuels, consultation stressed that there are many more different types of overall fire systems, each with slightly different requirements. There is evidence that several downstream users are currently testing fluorine free firefighting foams, and that several others have now successfully transitioned. All stressed the importance of testing the foam compounds. This imposes costs in purchasing (possibly several different types of product), along with storage, training of personnel, performance monitoring and evaluation, disposal and cleanup. Consultees also noted costs from periodic testing of the fluorine-free products once in storage, to ensure that performance is not degraded; this was in the context of some initial uncertainty over shelf life for some products, which now appears to have been addressed. Whilst these costs were acknowledged, the evidence indicates they are one-off, comparatively small and were absorbed by the downstream users. Storage costs (including storage during transition) Whilst technical performance of alternatives was concluded to acceptable in most cases, some noted a "higher sensitivity" of fluorine free foam, compared to PFAS based foam; i.e. they allow for less flexibility in use, requiring multiple types of foam to be stocked. The is associated with costs in purchasing foam, of storage capacity - particularly during a transition when both PFAS based and fluorine-free may have to be stored - as well as some training costs. Where evidence has been provided in the stakeholder consultation, it was noted that these costs were manageable and could be mitigated via phased transition. It 156 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS was acknowledged these costs are generally greater for fixed than for mobile applications, and where larger volume are used and stored. Costs from technical changes No consultees indicated that a transition from PFAS-based foams to fluorine-free required investment in entirely new foam delivery systems. However, problems have been encountered in specific components: such as proportioner pumps, jets and nozzles for discharge, including the need for replacement nozzles; including low expansion nozzles. These challenges appear to have been caused by differences in foam viscosity. Typical costs for a range of firefighting nozzles are within an approximate range of between 5 or less per piece for simple foam nozzle devices, to c. 30 and up to c. 60 for marine firefighting nozzles or "heavy duty applicators" and up to c 200 for more specialist equipment131. Mobile foam units are in the region of 2,700.132 Other costs These include regulatory approvals and those associated with bringing new products to market. Given that the market assessment noted at least some current use of fluorine free products in all sectors, further adopting fluorine-free foams would appear to be a continuity of an existing transition - so a lot of the initial costs associated with new products development will have already been incurred. Experience in the Norwegian petrochemical sector (Equinor) indicates costs (labour time) in the region of 360,000 for a range of support in their transition at a total of 45 sites (so in the order of c. 10,000 per site). Savings from adoption of fluorine free foam Many stakeholders acknowledged potential for savings from use of fluorine-free foams. The potential savings resulting from a reduction of firewater that requires disposal and hence the costs of disposal as well as from avoided long term liability for site contamination/ remediation and clean-up costs are discussed further in subsection "g. Remediation and clean-up". However, fire-fighting foams may also need to be disposed of when not used at the time of their expiry date. As discussed in more detail in Section "j. Emissions from disposal", incineration is considered the most appropriate disposal option for PFAS-based foams. The disposal method for fluorine-free foam would depend on the hazards of the specific foam. 131 Costs derived from search of widely available commercial products. See: https://www.made-inchina.com/products-search/hot-china-products/Water_Foam_Nozzle_Price.html See also https://www.orbitalfasteners.co.uk/products/heavy-duty-foam-dispenser-gun See also: https://www.dortechdirect.co.uk/heavy-duty-pu-applicator-gun-for-expandingfoam.html?gclid=EAIaIQobChMIudKHq9GP5gIVSbDtCh31AATEEAQYASABEgL5S_D_BwE See: https://www.safetyshop.com/lever-operated-nozzle-for-firehose.html?gclid=EAIaIQobChMI6cKnwNmP5gIVAuDtCh2KMwErEAQYAiABEgL91PD_BwE&gclsrc=aw.ds See: https://www.fireprotectiononline.co.uk/hv-series-low-expansion-foam-branchpipes.html?gclid=EAIaIQobChMItqqg_NmP5gIViLbtCh0ImgYXEAQYByABEgIFdvD_BwE 132 https://simplyextinguishers.co.uk/df130-mobile-foam-units.html?gclid=EAIaIQobChMIn4yv79yP5gIVgpOzCh1PQghEAkYBiABEgKsIfD_BwE 157 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS However, in general they are expected to exhibit lower hazards and higher biodegradability, so it is likely that they require less costly disposal methods, such as waste water treatment. While no specific data was available to estimate the disposal cost of fluorine-free foams, the costs of incinerating PFAS-based foams is expected to be typically around 1 per litre (range 0.3 to 11, see Section "l. Costs of disposal" for more detail). As discussed in the emission assessment (Section B.9.), a number of references suggest usage rates of around 15-20% of existing stocks per annum, with an AFFF shelf-life of up to 15 years, which would suggest all foam concentrate is used before expiration, while other sources suggest that significant quantities of expired foam concentrate is indeed destroyed. If the usage rate of 15-20% per annum of existing stocks is an average across all sectors of use, there will be some installations with potentially far lower usage rates annually that will likely have some foams that reach expiry before use. In the absence of specific data, below the potential costs are shown for 1%, 5% and 20% of annual foam purchases replacing foams that have reached their expiry date133. Note that these figures are hypothetical and are shown to illustrate the potential order of magnitude only: Total foam purchased per year (tonnes) % of annually purchased foam replacing foams not used (hypothetical) Foam to be disposed of per year (tonnes) Cost of disposal: 0.3/l (low) Cost of disposal: 1.0/l (best estimate) Cost of disposal: 11/l (high) 14,000 (low) 1% (low) 140 42,000 140,000 1,540,000 18,000 (average) 5% (central) 900 270,000 900,000 9,900,000 20,000 (high) 20% (high) 4,000 1,200,000 4,000,000 44,000,000 Sources: Foam tonnage per year based on Eurofeu data (see Annex A), disposal costs per litre based on Section "l. Costs of disposal". Based on the total foam purchased per year, foam disposal costs per litre and hypothetical shares of foams not used per year, it is estimated that the annual costs of PFAS-based foam disposal could be between some 40,000 and some 40 million, but more likely (as a central estimate) in the order of million Euros. Other potential benefits noted by consultees include emerging concerns over corporate reputation from continued use of PFAS foams and savings from avoided cross contamination of other waste streams, from monitoring, environmental permitting requirements, controls and personal protective equipment. Despite additional stakeholder consultation, and some specific examples of savings, it has not been possible to provide an overall estimate of these savings for the market or average firm. The savings were however noted as "significant" by several consultees. f. Environmental/health impacts of alternatives This section discusses the environmental and health impacts of alternatives to PFAS foams, in comparison with PFAS-based foams. A quantitative comparison of emissions and the associated risk under each scenario was not possible with the available data. The assessment focusses on the overall assessment of hazards (Section B.5) and emissions (Section 1.1.5) alongside an evaluation of the hazards and risks of most likely alternatives. 133 It is also assumed that all PFAS-based foams are incinerated, although it should be noted that not all PFAS-based foams are currently incinerated when they reach their expiry date (e.g. some of them are used for training), so this is likely an overestimate. 158 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS The evaluation in Section B.5 concluded, based on analysis of PNECs and data on biodegradation and bioaccumulation, that the two fluorinated substances (used as examples) are of higher environmental concern compared to the non-fluorinated substances when it comes to hazard for the environment. This reflects the former's non-biodegradable nature, along with the relatively low PNECs for water and soil. Some of the alternative substances also exhibit low PNECs, but are readily biodegradable. The assessment in Section B.5 notes that further work would be needed to assess the risks associated with specific sites or food production pathways. Table E.8 provides an overview of the hazards of the shortlisted alternatives based on information from the foam Safety Data Sheets (SDS). None of the components included in the Safety Data Sheets are classified with CMR properties. In terms of PBT/vPvB properties, whilst none of the alternatives include substances demonstrated to be PBT or vBvP substances, for two products insufficient data are available and tests had not been concluded for a third. The hazard posed by PFAS foams compared to the constituents of the alternative fluorine-free foams are considered further in B.5. However, a review of potential hazards based on PNECs, biodegradation and bioaccumulation shows that fluorinated substances (in PFAS-based foams) are of higher priority compared to the non-fluorinated substances (in fluorine-free alternatives) when it comes to hazard to environment. This is due to the fact that some PFAS are not readily biodegradable, are mobile and have relatively low PNECs for water and soil. Some of the substances used in the alternative products do however exhibit low PNECs, but this needs to be considered in the context of biodegradation and so far data is not available to examine these in detail. Table E.8 Overview of key hazards of alternatives based on information from SDS CMR Properties PBT or vBvP Criteria? Other HH concerns indicated in SDS Other Env concerns indicated in SDS Respondol ATF No 3-6% Re-Healing No Foam RF3x6 ATC Re-Healing No Foam RF1 1% Moussol FF 3x6 No (F-15) FOAMOUSSE No 3% F-15 Ecopol No Premium Orchidex No BlueFoam 3x3 No Uncertain (insufficient data on SDS) Uncertain (insufficient data on SDS) No No No Not tested Skin and serious eye irritation (H315, H319) Serious eye irritation (H319) None None Skin irritation and eye damage (H315, H318) Aquatic Acute 1 (H400) Serious eye irritation (H319); damage to kidneys if swallowed (H373) Harmful if swallowed (H302), skin irritation and serious eye irritation (H315, H319) Serious eye damage (H318) Harmful if swallowed (H302) and serious eye irritation (H319) Can harm aquatic fauna, can harm bacteria population in WWT plants None None Harmful to aquatic life with long lasting effects (H412). g. Remediation and clean-up This section discusses the economic implications in terms of reduced requirements for remediation potentially resulting from a restriction on PFAS-based fire-fighting foams under Scenario 1 or 2. Both scenarios will require a transition to alternatives. This means that in both Scenarios, emissions of PFAS related to fire-fighting foam use will cease. In Scenario 2 they will cease immediately upon the restriction taking effect, while under Scenario 1 further use, emissions and site-contamination could presumably take place. Emissions of 159 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS the substances used in the alternatives would likely increase proportionately, assuming no additional containment measures compared to the current use of PFAS-based foams. Remediation The study underlying this dossier134 (Section 6) has assessed the typical costs of remediation of PFAS contamination resulting from the use of fire-fighting foams. The results are summarised in the table below. This shows that the typical costs per site can range from around half a million Euros (only soil remediation required, lower estimate) to just over 100 million (sum of soil excavation and incineration, groundwater pump and treat and drinking water reverse osmosis, higher estimates).135 Table E.9 Typical cost per site of remediation of PFAS contamination resulting from the use of fire-fighting foams Compartment Technique Cost Soil Excavation and off-site disposal 0.5 - 18 million Excavation and incineration 2.5 - 38 million Capping 0.42 - 4.3 million Groundwater Pump and treat 1.2 - 30.3 million Drinking water Source: Wood 2019 Reverse osmosis 2.9 - 39.8 million Section B.9. has shown that the substances contained in fluorine-free alternatives exhibit lower concern than PFAS used in fire-fighting foams, due to their lower hazards and more rapid biodegradation. On this basis, underlying study136 (Section 6) has concluded that it is currently not predicted as likely that remediation will be required as a result of the use of fluorine-free alternatives. Therefore, no remediation costs are expected to be incurred from the use of fluorine-free alternatives, implying potential savings from substitution of PFASbased foams. It is important to note that the costs refer to the remediation of legacy contamination that occurred from historical fire-fighting and/or training activities. In particular, training activities, which account for the majority of fire-fighting foam use, either already avoid the use of PFAS-containing foams and/or are conducted at contained training facilities, according to current best practice. However, the consultation did not yield information on the extent to which best practice measures are being implemented, or their effectiveness. 134 Wood, Ramboll, COWI: "The use of PFAS and fluorine-free alternatives in fire-fighting foams - Final report". Report for the European Commission DG Environment and European Chemicals Agency (ECHA) under specific contracts No 07.0203/2018/791749/ENV.B.2 and ECHA/2018/561. 135 Please note remediation costs are highly site-specific and in certain cases can exceed the ranges provided. The estimates should therefore be considered order-of-magnitude cost ranges. 136 Wood, Ramboll, COWI: "The use of PFAS and fluorine-free alternatives in fire-fighting foams - Final report". Report for the European Commission DG Environment and European Chemicals Agency (ECHA) under specific contracts No 07.0203/2018/791749/ENV.B.2 and ECHA/2018/561. 160 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Section B.9. has estimated that the current levels of emissions from training are likely relatively low; however historical emissions are understood to have been much higher. Fire-fighting activities typically require more immediate clean-up (discussed further in the next paragraph) rather than long-term PFAS remediation. On this basis, it seems unlikely that the current use of PFAS-containing fire-fighting foams would lead to the same remediation costs as presented for legacy contamination above. In conclusion, the restriction scenarios could eliminate the potential risk of PFAS contamination which could cause costs of up to around 100 million per site. There are large uncertainties in the numbers of sites that may require remediation and remediation costs are very case-specific and would differ significantly across these sites, so the following estimate of total remediation costs caused by the use of PFAS-based fire-fighting foams is indicative only: The market analysis (see Annex A) estimated that there are likely to be several tens or potentially hundreds of thousands of sites that use or at least possess fire-fighting foams; If all of these would require remediation (costing some 10s of million per site), the costs of cleaning could be at most in the region of trillions of Euros (based on an assumed 100,000 sites needing remediation); However, in reality only a much smaller number of these sites would use PFAS-based foams in sufficient quantities and without adequate containment and immediate clean-up to require large scale remediation. More information on the total number of sites, real-world use of PFAS per site as well as implementation and effectiveness of best practices in terms of containment and immediate clean-up would be required to assess to which extent remediation is likely to be required in the future as a result of current use of PFAS-based fire-fighting foams; and Therefore, realistically avoided remediation costs are more likely in the order of magnitude of hundreds of millions of Euros (assuming tens of sites requiring remediation at tens of millions of Euros per site) to billions of Euros (assuming hundreds of sites requiring remediation at tens of millions of Euros per site). Clean-up In addition to remediation which is driven by long-term accumulated contamination from historical releases, releases to the environment in the short-term require "clean-up" (as defined by the underlying study137 Section 6). According to the stakeholder consultation, there is local or national-level regulation governing the containment or prevention of release of fire-fighting foam or firewater runoff to the environment138. One exception that has been identified is fire-fighting activities in close vicinity to open water bodies (sea, lake), where it is very difficult to recover fire-fighting water runoff discharged into the sea or lake. In the case of the lake, this could lead to remediation being required. This would relate to very specific sites in specific locations, so it would not be appropriate to estimate `typical' remediation or clean-up costs. In the case of the sea (particularly relevant for marine and 137 Wood, Ramboll, COWI: "The use of PFAS and fluorine-free alternatives in fire-fighting foams - Final report". Report for the European Commission DG Environment and European Chemicals Agency (ECHA) under specific contracts No 07.0203/2018/791749/ENV.B.2 and ECHA/2018/561. 138 This was confirmed by stakeholders at least for England/Wales (The Environmental Permitting (England and Wales) Regulations 2010 (EPR 2010)), Sweden (local authority requirements for applications for new operation licenses), France (no details provided), Netherlands (no details provided), Germany ("Lschwasser-RckhalteRichtlinie" and the more detailed Bavarian "Guideline foam" which is legally binding in Bavaria and but also applied elsewhere). 161 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS offshore applications), remediation or clean-up would likely not be feasible, which raises particular concerns over the environmental impact of using PFAS-based fire-fighting foams in these applications. In all other applications, it is assumed that in most cases, the majority of fire-water run-off is contained and sent for treatment. Treatment costs for run-off can vary depending on the fire-fighting foam used: Several stakeholders that have transitioned to fluorine-free foam reported that when fluorine-free foam was used, run-off was sent to water treatment, either though the normal sewer system to the municipal WWTPs; directly to on-site waste water treatment; to other biological/chemical/mechanical treatment plants; or even drained directly to sea. One stakeholder reported that all PFAS-containing run off must be treated as a regulated waste which they do using high-temperature incineration; Stakeholders did not provide information on the cost of waste water treatment. These can vary significantly, depending on the contamination of the run-off from the flammable liquid itself, the soot and other contaminants from the fire site. For instance, UNECE 2017139 reports a cost of 1 million for disposal of 2,000 m of firewater contaminated with chemicals in a sewage treatment plant and several chemicals waste disposal facilities, resulting from a fire in a factory in Germany in 2005. This is equivalent to 0.5 per litre, or 0.64 per litre in 2019 prices140. Typical costs for regular municipal waste water treatment are much lower, for instance reported in the range of 0.0002 to 0.0005 per litre by Pajares et al. 2019141 for various municipalities in Southern Europe. Hence, treatment costs for runoff for fluorine-free foam are likely between 0.0002 per litre and around 0.64 per litre. 0.3 per litre is assumed as an average for the purpose of the approximate estimation below; Assuming that PFAS-containing run-off has to be incinerated, and assuming similar incineration costs as reported for the disposal of fire-fighting foams (see Section "l. Costs of disposal"), the costs for treatment of PFAScontaining fire-water run-off could be around 1 per litre (range 0.3 to 11 per litre). Hence, treatment costs for run-off of fluorine-free foams could be around 0.7 per litre (range ca 0-11) lower compared to PFAS-based foams.142; and 139 https://www.unece.org/fileadmin/DAM/env/documents/2017/TEIA/JEG_MTGS/UNECE_Safet y_Guidelines_and_Good_Practices_for_Fire-water_Retention_14_Nov_2017_clean.pdf 140 2005 value converted to 2019 prices using Eurostat: HICP (2015 = 100) - annual data (average index and rate of change) (prc_hicp_aind). 141 Moral Pajares, E., Gallego Valero, L., & Romn Snchez, I. M. (2019). Cost of urban wastewater treatment and ecotaxes: Evidence from municipalities in southern Europe. Water, 11(3), 423. 142 Calculated as: Central estimate: 1/l cost of incineration of PFAS-based foams minus 0.3/l cost of waste water treatment for fluorine-free alternatives = 0.7/l cost saving; Low estimate: Waste water treatment could in some cases be more expensive (up to 0.64/l) than incineration (from 0.3/l). In these cases it is assumed that the less expensive option would be chosen and there would not be a saving of using fluorine-free foams compared to PFAS-based foams; and High estimate: The maximum possible difference is in case of the upper end of the range of incineration costs for PFAS-based foams (11/l) minus the lower end of the range of waste water treatment costs for fluorine-free alternatives (0.0002/l) 11/l cost saving. 162 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Data on the total amount of fire-water run-off containing fire-fighting foam per year in the EU was not available, but for illustration an example of costs per incident can be calculated. UNECE 2017143 reports five major fireincidents in which volumes of fire-water used ranged between 2,200 and 38,000 m3. For incidents of this size, the difference in run-off treatment cost would be around 1.5-27 million (range 0-418 million) per incident.144. In cases where fire-water run-off is not contained and further clean-up is possible (i.e. runoff was not discharged to sea), there may be savings from using fluorine-free foams in terms of reduced clean-up costs: When PFAS-based foam is used and contamination of the soil and water occurs then extremely persistent chemicals are involved, which is not necessarily the case with fluorine-free foams. Stakeholders suggested in the consultation that clean-up and complex treatment is not always necessary after the use of fluorine-free foams. This could lead to potential cost savings in some cases; However, the underlying study145 (Section 6) clean-up is driven to a large degree by the flammable liquid itself, the soot, water and "dirt" in general terms that contribute to the fire-fighting water runoff, rather than the firefighting foams. Therefore, a significant difference in clean-up costs between the different types of foam used is difficult to estimate, because the incremental costs of addressing PFAS contamination is difficult to separate from the wider clean-up costs; and Clean-up costs are generally expected to be lower than remediation costs. Based on the estimates of remediation cost per site presented above, as a worst case scenario, clean-up costs can be expected to be a few hundred thousand to a few million Euros per incident. In the absence of more specific data, for illustration of the potential order of magnitude of savings: Assuming several tens of incidents per year using PFAS-based foams where clean-up is required and could be avoided if fluorine-free foams were used, the savings would be in the order of several millions to several tens of millions of Euros. h. Availability of alternatives. This section discusses the supply-demand balance associated with a restriction on PFAS firefighting foams under Scenario 1 and 2. Both scenarios will require a transition to alternatives - the difference is the speed at which this will be necessary. Scenario 1 will result in a slower increase in demand as stocks are used in training and or incidents (or reach the end of their useful life) and are then replaced with new alternatives. Scenario 2 will result a more sudden increase in demand as the whole market disposes of and replaces 143 https://www.unece.org/fileadmin/DAM/env/documents/2017/TEIA/JEG_MTGS/UNECE_Safety_Guidelines_and_Goo d_Practices_for_Fire-water_Retention_14_Nov_2017_clean.pdf 144 Calculated as: 2,200 m3 volume of fire-water run-off * 0.7/l treatment cost difference= 1.54 million.38,000 m3 volume of fire-water run-off * 0.7/l treatment cost difference= 26.6 million. These figures are rounded to two significant figures. For the wider range, instead of 0.7l treatment cost difference, 0/l (lower) and 11/l (higher) have been applied. 145 Wood, Ramboll, COWI: "The use of PFAS and fluorine-free alternatives in fire-fighting foams - Final report". Report for the European Commission DG Environment and European Chemicals Agency (ECHA) under specific contracts No 07.0203/2018/791749/ENV.B.2 and ECHA/2018/561. 163 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS their existing stocks - potentially over a short timescale - and then require replacement stock, each year. In addition, and over and above the replacement demand, it can be assumed both scenarios will result in an increased short-term demand for testing; again the increase in demand would be greater in scenario 2 given the accelerated transition. The economic and logistical challenges of managing the transition - avoiding contamination in storage tanks and the requirements for disposal, for example - are discussed elsewhere in the SEA. Information on the specific shortlisted substances in the analysis of alternatives is summarised below - quantitative information is limited. These substances are however, illustrative and a subset of a larger range of alternative foams that are commercially available and currently in use. Table E.10 Availability of alternatives - summary Alternative Produced in the EU Currently commercially available Information on production volumes Respondol ARF 3- Unknown Yes 6% Not available. Stakeholders have indicated that they would not have a problem meeting increased demand in general terms. RE-healing foam Yes Yes RF3X6 ATC As above. RE-healing foam Yes Yes RF1-1% As above. Moussol FF 3X6 (F- Yes Yes 15) As above. FoamMousse 3% F- Yes Yes 15 As above. Epocol Premium Yes Yes 700 tonnes (production and import), 500 sold in EU. Orchidex BlueFoam Yes Yes (3x3) Stakeholder (not manufacturer estimates at c.800 t/yr) Source: Market assessment, desktop research and stakeholder consultation exercise. Stakeholder consultation has provided limited information on production and use volumes of specific foams but the market assessment indicated current supply is in the region of 7,000 to 9,000 tonnes. Anecdotal information from stakeholder consultation notes that "adequate" supply exists and no consultees noted that they had experienced supply constraints in any application. Further discussions with three suppliers indicated current excess production capacity alongside additional capacity for emergencies (not quantified). The consultees noted no constraints with raw material supply. Production and sales data on one shortlisted product, Epocol, was provided as noted above in Table E.10. This data indicated total production and import capacity of 700tonnes, with sales of 500tonnes. Quantitative information was provided on a small number of other specific products. These are not listed above but were stated by consultees as appropriate for use in several applications, including municipal firefighting, storage facilities and marine applications. For these, total volumes produced and imported into the EU totalled a further 550 tonnes, with sales of 380 tonnes. Qualitative information on the availability alternatives was provided via stakeholder consultation on a wider range of products. A total of 22 were 164 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS stated as being produced in the EU and all of these were commercially available (either in the EU, globally or both). Note that the substance identification and market assessment identified a larger number of products - in the order of 160 - but more detailed information on only a subset of these was obtained via the consultation and the assessment has focused on products for which stakeholders have indicated actual use is taking place. Using data from the market assessment, Table E.11 provides a quantitative summary of available information. First, the table provides a summary of existing EU demand for PFAS based firefighting foams. This has been split by application, based on Eurofeu survey information. Overall, this indicates current PFAS based foam demand in in the region of 18,000 tonnes per year146, with the largest use in the chemical and petrochemical sector. The second, central, column provides an overview of the volumes of alternative foams that may be expected after a restriction is imposed. This takes into account that additional volumes may be required in some applications. As in the economic feasibility section above, the analysis has been undertaken assuming no change in the volumes required (central estimate), and a 50% and up to 100% increase, respectively in the volume of foam required in all applications. It is not considered likely that this increase will be required uniformly across all applications; indeed the stakeholder consultation indicated that many users experienced no overall increase in the volumes required. Finally, the existing demand - again based on Eurofeu survey data - Is presented on current fluorine-free foam supply in the EU. The disaggregation of demand by sector is based on the proportions specified in the Eurofeu survey. For both PFAS-based and fluorinefree foams, sector specific volumes are subject to greater uncertainty than the overall totals. Table E.11 "Top down" assessment - annual demand and supply of PFAS and Fluorine free FFF Sector of use Current PFAS foam volumes (t/yr) Central (L-H range (000's)) Existing F- free volumes (t/yr) Expected future additional demand for F-Free foams Central (L-H range 000's) Chemical/Petrochemical 11,000 (8-12) 2,000 - 2,600 11,000 (8-24) Municipal Fire Brigades 2,000 (2-3) 3,100-4,000 2,000 (2-6) Marine Applications 2,000 (2-2) 1,100-1,400 2,000 (2-4) Airports 2,000 (1-2) 500-600 2,000 (1-4) Military 2,000 (1-2) 100-200 2,000 (1-4) Ready for use products <500 c.100 <500 Total 18,000 7,000 - 9,000 (14 - 20) Source: Market assessment, desktop research and stakeholder consultation exercise. 18,000 (14 - 40) The above information indicates that, for all uses, the volumes of fluorine free alternatives would need to increase to meet the replacement demand as users switch from PFAS 146 Note that the sum of the sectors is not equal to the total due to rounding. 165 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS containing foams under a restriction. Overall, the increase is likely to be in the order of 18,000 tonnes (i.e. sales of 18,000 tonnes of PFAS foam ceases, to be replaced by 18,000 of fluorine free foams), but potentially up to 40,000 tonnes, per year. Stakeholders indicated that spare foam production capacity exists and that users had not experienced a shortfall in supply. However, Scenario 2 may result in a more sudden and potentially significantly larger demand for fluorine free foams, as existing stocks would need to be disposed of and replaced. As noted above, this could be in the region of between 210,000 tonnes and up to a theoretical maximum of 870,000 tonnes of foam. This heightens the risk of a shortfall in supply, - depending on the timescales of any restriction. Overall, the available evidence clearly indicates a range of alternative foams are currently available on a commercial basis. Moreover, data obtained from stakeholder consultation suggests that in purely quantitative terms existing production capacities can accommodate some increase in demand. For Scenario 1, it has not been possible, despite further consultation attempts, to obtain quantitative information on the supply of specific products used in all applications, so whilst it is possible, that a shortfall may arise for a specific market segment, the available evidence does not suggest this would be likely. For Scenario 2 a much greater quantity of alternatives would be needed to replace existing stocks, with the potential for a shortfall in supply. As the largest single use, and with comparatively low current fluorine free sales volumes, the risks of supply constraints may be greater in the chemicals and petrochemical sectors (because this is the sector with greatest use) and in Scenario 2 (because this would require greater volumes to be replaced in the short term). It follows that appropriate transition periods would further ease this risk. Whilst there would be costs associated with increasing supply, the market assessment and economic feasibility sections noted above indicated that, on average, the costs for fluorine free foam, on a unit basis, are comparable to or less than those for PFAS based foams. It appears reasonable that manufacturers could continue to increase supply without significant costs having to be passed to downstream users. The range of suppliers and the number of fluorine free products that currently exist on the market would also serve to limit scope for significant price increases. i. Other impacts Other impacts briefly considered in this section include the potential for impacts on international trade and employment and economic competitiveness. Under Scenario 1, PFAS-containing foams in stock will still be able to be used and therefore the demand for replacement with alternatives will be more gradual. It is therefore unlikely that there will be any substantial impacts on competitiveness, trade and employment. Under Scenario 2, there will be a more sudden and larger increase in EU demand for PFASfree alternative fire-fighting foams and decrease in demand for PFAS-containing fire-fighting foams (again depending on transition period). Imports of PFAS-containing fire-fighting foams into the EU will therefore decrease and manufacturers (both global and EU) of PFAScontaining foams will see a decrease in EU demand. Whilst effects would be mitigated by the fact that at least some manufactures in the EU are involved in both PFAS and fluorine free foam manufacturing, a potential shortfall in supply - driven by a one off need for stock replacement - may impact imports of fluorine free foam from outside the EU. , Regarding employment, there is no information available on the number of people employed in manufacturing of PFAS-containing fire-fighting foam or manufacturing fluorine-free firefighting foam. Overall effects would be neutral or positive, depending on the net effect on volume, Overall, there are unlikely to be any significant macroeconomic impacts from the result of Scenario 1, but with some - albeit temporary risk of increase EU imports under Scenario 2. 166 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS j. Emissions from disposal of legacy foams During the process of disposing of PFAS-containing legacy foams, emissions occur from several sources. In Scenario 1, it is expected that a low quantity of legacy foam will be required for disposal. This low quantity will relate to `transitional wastage' which occurs when a user has some remaining PFAS-containing fire-fighting foam in existing equipment, yet their stock of PFAS-containing firefighting foam has depleted to zero. PFAS-containing and PFAS-free fire-fighting foam cannot be combined in the same system. The low level of PFAS-containing foam left in the container will need to be disposed of. The quantity of foam required for disposal under Scenario 1 cannot be accurately quantified as `transitional wastage' will likely vary across industries and appliances. In Scenario 2, all existing stocks of PFAS-containing foam will need to be disposed of. This section first discusses the disposal options and identifies the potential emissions associated with these disposal options. The quantity of emissions is then estimated and the impact of these emissions on health and the environment are discussed. Emissions considered relate to both the potential for remaining PFAS compounds as well as the by-products created from disposal. The analysis focusses on the disposal of unused PFAS-containing foams, rather than the disposal of used PFAS-containing foams. Little data and information was obtained from stakeholder consultation, therefore much of this section is based on desktop research. High-temperature incineration would appear the most likely disposal option for PFAS-containing legacy foams147; Existing incineration disposal methods used apply a range of temperatures from around 400-6000C148. The literature also indicates that CF4 requires temperatures above 1,400C to decompose and that CF4 is the most difficult fluorinated organic compound to decompose149; The effectiveness of PFAS compounds to be destroyed by incineration and "the tendency for formation of fluorinated or mixed halogenated organic by-products is not well understood"150; The incomplete destruction of PFAS compounds may result in smaller PFAS or products of incomplete combustion being formed151. These products may not yet have been researched and therefore have the potential to be chemicals of concern152; The complete combustion of PFOS/PFAS will result in CO2, H2O and HF153 and the incineration of PFAS at temperatures of at least 1,100C, usually degrade PFAS to carbon dioxide and hydrogen fluoride154. It has not yet been 147 Derived from stakeholder consultation responses concerning PFAS disposal methods. Note that WWT was also reported as a disposal method, but a judgement was made that these disposal techniques relate to used PFAS-containing firefighting foam rather than unused foam. 148 Obtained from stakeholder consultation. 149 https://www.epa.gov/sites/production/files/201909/documents/technical_brief_pfas_incineration_ioaa_approved_final_july_2019.pdf 150 https://www.epa.gov/sites/production/files/201909/documents/technical_brief_pfas_incineration_ioaa_approved_final_july_2019.pdf 151 https://www.epa.gov/sites/production/files/201909/documents/technical_brief_pfas_incineration_ioaa_approved_final_july_2019.pdf 152 https://www.epa.gov/sites/production/files/201909/documents/technical_brief_pfas_incineration_ioaa_approved_final_july_2019.pdf 153 https://www.diva-portal.org/smash/get/diva2:1155115/FULLTEXT01.pdf 154 UNEP, 2012 in: https://www.kemi.se/global/rapporter/2016/report-11-16-strategy-for-reducing-the-use-of-higlyfluorinated-substances-pfas.pdf 167 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS determined what is produced when PFAS is incinerated at temperatures lower than 1,100C155; Emissions (greenhouse gases and air pollutants) from creating high temperatures for incineration: There are emissions associated with the procurement and delivery of fuel and with incinerator operation (e.g. greenhouse gases and air pollutants such as particulate matter from the combustion of fuels). Associated emissions have not been analysed and it is assumed that the incinerators would continue to operate at the same temperatures regardless of the type of waste they process. Such emissions were not highlighted by stakeholders in the consultation; Leakage during storage and transportation: Incineration processes are typically provided off-site and foams will need to be stored and transported to incineration facilities for disposal or waste equipment to be installed on-site156. During the storage and transportation of PFAS-containing foam it may be possible for spillages or leakages to occur, resulting in environmental emissions. There has not been enough information identified during desktop based research or provided from stakeholder consultation to accurately quantify these emissions; and Direct emissions (greenhouse gases and air pollutants) from transportation: Where foams are stored and transported to incineration facilities, direct emissions of carbon and other pollutants (e.g. particulate matter and nitrogen oxides) from vehicles will also occur. Desktop based research revealed a lack of available data regarding the geographical position of PFAScontaining fire-fighting foam manufacturers and users in relation to incineration facilities and little to no information was obtained from stakeholder consultation. It is therefore unsuitable to accurately quantify emissions associated with foam transportation. Overall, PFAS emissions from incineration are not well studied157 and therefore, there is the potential for incineration to be hazardous158. Further research is needed to identify and quantify the emissions produced from the incineration of PFAS, as well as greater research undertaken to understand the thermal properties of PFAS. k. Technical feasibility / availability of disposal options (legacy foams) This section assesses the potential for existing disposal options to feasibly dispose of legacy foams in Scenario 2. The disposal of legacy foams is not considered in Scenario 1, as existing stocks will still be able to be used until they run out. With Scenario 2, a sudden increase in the short-term demand for disposal will likely occur as the whole market will dispose of their stocks to enable replacement. The level of demand for disposal will depend on what transition period is established (yet to be determined). In order to meet the demand, existing disposal options must have the capacity to process the quantities of foam to be sent for disposal. This subsection identifies the disposal options available and discusses their capacity to process and dispose of PFAS-containing foams given a sudden increase. 155 https://www.kemi.se/global/rapporter/2016/report-11-16-strategy-for-reducing-the-use-of-higly-fluorinatedsubstances-pfas.pdf 156 https://www.serdp-estcp.org/content/download/48955/466822/file/ER18-1593%20Final%20Report.pdf 157 http://norden.diva-portal.org/smash/get/diva2:1295959/FULLTEXT01.pdf 158 https://www.epa.gov/sites/production/files/201909/documents/technical_brief_pfas_incineration_ioaa_approved_final_july_2019.pdf 168 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS There are several incineration methods available. One stakeholder reported two specific and different incineration methods: cement kiln and plasma arc furnace. A cement kiln operating from around 400C has a retention time of 20 minutes. A cement kiln operating between around 850-1800C has a residence 16-24 seconds (with a minimum of 2 seconds). Estimated costs of PFAS disposal by cement kiln incineration are around 2/l. Another stakeholder who has transitioned to fluorine-free foams also reported that their stocks of PFAS-based foams were incinerated in a cement kiln, but reported costs around 1 per litre. Plasma arc furnace conditions can reach 6000C and have an estimated processing cost of 11/l.159 It would therefore appear that costs are higher for incinerators operating at higher temperatures and there is a potential trade-off between the cost of incineration, effectiveness of PFAS destruction and time, due to higher temperatures being more likely to completely destroy the PFAS. With the sudden increase in short-term demand for incineration, existing disposal methods would need to be sufficient to process the volume of legacy PFAS foams required to be disposed of. Where capacity is insufficient, the storage of the foam will likely be required. The following assumptions are made to derive the capacity for existing incinerators to process PFAS-containing foam and the time it would take to complete this (not taking into account transportation times): The literature indicates that there are 808 incineration facilities across EU28160. These include high temperature hazardous waste incinerators as well as municipal waste incinerators that probably operate at lower temperatures. However, according to the Industrial Emissions Directive161 Article 50, all incinerators need to be designed, equipped, built and operated so that a temperature of at least 850C is achieved for at least two seconds. It is therefore assumed that all 808 incinerators are able to operate at least at 850C. However, as discussed in the previous sub-section, at least 1,100C (or for some PFAS even at least 1,400C) are required to degrade PFAS to carbon dioxide and hydrogen fluoride and it has not yet been determined what is produced when PFAS is incinerated at lower temperatures. Data was not available to determine the share of EU incineration facilities that achieves 1,100-1,400C; The amount of PFAS-containing legacy foam for disposal is between 210,000 tonnes and 435,000 tonnes (average 322,500 tonnes); Information obtained from stakeholder consultation indicates that an incinerator operating at around 850-1800C can process one tonne of foam per hour and an incinerator operating at around 6000C has a throughput of around 25l per hour. It is assumed that 1kg = 1l; and It is also assumed that incinerators continuously operate with the same processing capacity and at the same temperature, 24 hours a day. Based on the above assumptions, the tables below provide estimates of the time it will take incinerators to dispose of fire-fighting foams based on 808 incinerators having a processing capacity of 25l per hour or one tonne per hour. As discussed above, to ensure adequate destruction of PFAS, it would appear to be preferable to dispose of PFAS-containing firefighting foams at incinerators with higher temperatures (at least 1,100-1,400C). This will therefore reduce the capacity available and increase the time period required for disposal. 159 Obtained from stakeholder consultation. Note that it is not clear whether this relates to foam concentrate or other foam types being processed. 160 The Cost of Inaction - http://norden.diva-portal.org/smash/get/diva2:1295959/FULLTEXT01.pdf 161 Directive 2010/75/EU of the European Parliament and of the Council of 24 November 2010 on industrial emissions (integrated pollution prevention and control) 169 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Table E.12 Processing time based on existing incinerator capacity processing 25l per hour. Foam to be disposed of (tonnes) Time for foam to be disposed of (hours) Time for foam to be disposed of (days) 210,000 (low) 10,400 400 322,500 (average) 16,000 700 435,000 (high) 21,500 900 Note that all cost values are assumed to represent the cost of disposal of unused PFAS-containing fire-fighting foams and not used PFAS-containing firefighting foam. Source: market assessment, desktop research and stakeholder consultation. Values have been rounded. Table E.13 Processing time based on existing incinerator capacity processing one tonne per hour. Foam to be disposed of (tonnes) Time for foam to be disposed of (hours) Time for foam to be disposed of (days) 210,000 (low) 260 10 322,500 (average) 400 20 435,000 (high) 540 20 Note that all cost values are assumed to represent the cost of disposal of unused PFAS-containing fire-fighting foams and not used PFAS-containing firefighting foam. Source: market assessment, desktop research and stakeholder consultation. Values have been rounded. Responses from the stakeholder consultation indicate that there is sufficient capacity for disposal of PFAS-containing foams. One stakeholder reports that there is sufficient capacity for disposal, but that getting high-temperature incineration capacities is becoming more difficult. Another stakeholder also reports that sufficient capacity for disposal by incineration is not guaranteed. Capacity for disposal is also likely to depend on the transition period chosen (yet to be determined) and was mentioned in the stakeholder consultation. If the transition period is short, there is the potential for demand for disposal facilities to outstrip supply. A longer transition period is more likely to result in the demand and the quantities sent for disposal being spread over a greater time period. Alternatively, a sector by sector introduction of Scenario 2 could be introduced to also spread the demand for disposal over time and avoid destruction capacity being exceeded162. Note that it is not clear whether stakeholder responses relate to used foams or whether responses relate to the sufficient capacity for the disposal of legacy foams if Scenario 2 were to occur. Additionally, the geographical locations of incinerators, the feasibility of storing and transporting PFAS to destruction facilities as well as the availability of transportation vehicles and labour has not been evaluated due to lack of information from both desktop-based research and stakeholder consultation. Further, the knock -on effects on other sectors requiring use of incineration facilities have not been considered. l. Costs of disposal (of legacy foams) This section discusses the costs associated with the disposal of legacy PFAS-containing firefighting foams under Scenario 2. Costs occur from the disposal process itself, as well as from transportation to disposal facilities and the storage of PFAS-foams. Costs of disposal are not considered to be incurred in Scenario 1, unless `transitional wastage' occurs, where 162 Obtained from stakeholder consultation. 170 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS the disposal of some PFAS-containing foam must happen to enable a switch to an alternative. Information and data is unavailable to accurately quantify the amount of `transitional wastage'. This subsection therefore focuses on costs associated with Scenario 2. First, the direct cost of incineration is calculated based on the stocks required for disposal. Costs associated with transportation to incinerators, labour costs and the potential costs of storage are qualitatively discussed. Incineration costs Incineration costs refer to the direct cost charged for the incineration of PFAS waste. Obtained from stakeholder consultation, the costs of disposal by incineration at temperatures between 850-1800C are between around 0.3-1.5 per litre163. Two stakeholders who have transitioned to fluorine-free foams both reported that their stocks of PFAS-based foams have been incinerated at costs of around 1 per litre. For incineration at a higher temperature of around 6000C, a cost of around 11/l is estimated. It is therefore considered more costly to dispose of PFAS-contained foams at incinerators with higher temperatures. Table E.14 provides estimates of the cost for the disposal based on the total amount of PFAS-containing fire-fighting foam to be disposed of at 322,500 tonnes (average), 210,000 tonnes (low) and 435,000 tonnes (high). Table E.14 Estimated costs of disposal Foam to be disposed of (tonnes) Best estimate Cost of disposal (/l): L-M-H 0.3 (low) 1.0 (best estimate) 11 (high) 210,000 (low) 63m 210m 2,310m 322,500 (average) 97m 323m 3,547m 435,000 (high) 130m 435m 4,785m Note that all cost values are assumed to represent the cost of disposal of unused PFAS-containing fire-fighting foams and not used PFAS-containing firefighting foam. Source: market assessment, desktop research and stakeholder consultation. Values have been rounded. However, it should be noted that at least part of the PFAS-containing fire-fighting foams would reach their expiry date without being used and therefore be incinerated in any case, just at a later date. For these foams, a restriction on the use of PFAS-based fire-fighting foams would only bring their incineration forward and therefore the incineration cost of firefighting foams that would have expired is not additional to the baseline, i.e. not a cost of the restriction. As discussed earlier164, it is not known what share of fire-fighting foams is used before its expiry date, but if reported usage rates of 15-20% per annum of existing stocks is an average across all sectors of use, there will be some installations with potentially far lower usage rates annually that will likely have some foams that reach expiry before use. Hence, an unknown share of the costs are not additional to the baseline and the costs presented in Table E.14 should be considered a higher boundary of the actual cost of the restriction in terms of the costs of disposal of legacy foams. 163 Note that it is not clear overall whether stakeholder consultation responses refer to foam concentrate or another measure of foam. One stakeholder explicitly reports disposal costs at 1 to 1.5/m3 of foam concentrate for high temperature incineration (1,100-1,200C). 1/l is considered a middle value due to stakeholder consultation reporting this is the cost of disposing of old foam. Not all costs were provided in euros and conversion rates have been used. It has also been assumed that 1kg = 1l. 164 In the emission assessment in Section B.9) and the section on savings from adoption of fluorine-free foams ("e. Impacts associated with the economic feasibility of alternatives"). 171 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Transportation costs Stakeholder responses did not identify transportation costs in relation to the costs of disposal. However, it is possible that transportation costs may occur where PFAS-containing fire-fighting foams need to be transported to incinerators off-site. These may include the costs associated with vehicle operation such as fuel costs (which will likely vary across the EU and be dependent on fuel prices) and distance covered between the pick-up point for PFAS and the site for incineration. Desktop based research reveals that Greece has the highest number of incinerators (132), followed by Belgium (100), Italy (100), Germany (93), the UK (87) and Poland (85)165. However, without detailed information concerning the location of PFAS foam users and manufacturers, it is not feasible to derive accurate transportation costs associated with disposal. Storage costs Stakeholder responses referred to storage costs within the context of requiring multiple foams to be stocked, particularly during a transition to PFAS-free foam, rather than within the context of disposal. This cost could be mitigated through phased transition. These costs have not been quantified here. Labour costs Labour costs may be incurred during the collection of PFAS-containing firefighting foams as well as during their transportation to incineration facilities. Stakeholder consultation did not provide any responses relating to labour costs for the disposal of PFAS and these would likely form part of the overall incineration costs. E.4.2. Human health and environmental impacts The human health and environmental impacts have already been considered and discussed alongside economic impacts above in the sections for each main effect of the possible restriction. A summary of the health and environmental imapcts identified in each of these sections is provided in the table in Section E.9.2. E.5. Risk reduction capacity Both scenarios will eventually lead to an elimination of the use and therefore the emissions of PFAS-containing fire-fighting foams. Therefore, they can both be considered effective in addressing the identified concern and eliminating any further human health and environmental impacts of PFAS exposure related to the use of fire-fighting foams (noting that impacts of exposure related to legacy emissions may continue for a long time, considering the persistence of PFAS). The reduction of emissions would be achieved more 165 http://norden.diva-portal.org/smash/get/diva2:1295959/FULLTEXT01.pdf 172 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS quickly in Scenario 2 and therefore Scenario 2 would also achieve a higher reduction of cumulative PFAS contamination. E.5.1. Cost-effectiveness Following ECHA's approach to the "Evaluation of restriction reports and applications for authorisation for PBT and vPvB substances in SEAC"166, the cost per unit (e.g. kilogram) of emission reduced are presented in the following. It should be noted that both the socioeconomic costs and the emission reduction of a potential restriction of PFAS in fire-fighting foams is associated with significant uncertainties and are presented in wide ranges or sometimes indicative orders of magnitude. Not all socio-economic impacts (costs or benefits) could be quantified and often their magnitude will depend on the specific design of the potential restriction (e.g. residual concentration limits). As a result, the cost effectiveness will be subject to the same uncertainties and can only be calculated as an indicative order of magnitude. Total emission reduction Some 14,000-20,000 tonnes of PFAS-based fire-fighting foams are used annually in the EU (the best estimate used in Section E.4. is some 18,000 tonnes) and the market analysis suggested these contain an average concentration of fluorosurfactants of around 2-3% (average of 2.5% used as best estimate below). The emission model developed in Section B.9. estimated that 26% of the two modelled example PFAS surfactants used in fire-fighting foams are released to the environment. A range was not calculated, so a 50% range around that central estimate is used below. These assumptions yield the following estimate of total annual tonnage of PFAS emissions reduced if the use of PFAS-based fire-fighting foams in the EU were to cease: Table E.15 Estimate of total PFAS emissions from fire-fighting foams Tonnes of foams used per year Concentration of PFAS surfactants in foams Share of PFAS surfactants released into the environment Low 14,000 t 2% 13% Tonnes of PFAS released 36 t Best 18,000 t 2.50% 26% 117 t High 20,000 t 3% 39% 234 t Sources: Annex A and Annex B (Section B.9.) It should be noted that this cost-effectiveness analysis only considers the reduction of PFAS emissions. The increased emissions of alternatives resulting from a potential restriction is not considered here, but the relative hazards of the alternatives are discussed in other relevant sections of this report. 166 https://echa.europa.eu/documents/10162/13580/evaluation_pbt_vpvb_substances_seac_en.pdf/af4a7207f7ad-4ef3-ac68-685f70ab2db3 173 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Total cost of emission reduction The main quantified costs (and benefits) of a potential restriction are listed below. Note that this list is for illustrating the approximate cost-effectiveness, but should not be understood as a total summary of costs and benefits. It should be read in conjunction with the economic impact assessment above to put these costs and benefits in context with the appropriate caveats and other unquantified impacts. In particular, benefits from avoided remediation costs have not been included here, because they constitute an environmental benefit rather than a cost of emission reduction. If these were included, they would significantly reduce the total costs (or even result in a net benefit)167. However, they remain an important benefit included in the SEA. In order to compare the costs with annual emission reductions, one-off costs need to be annualised. Annualisation requires the selection of a cumulative time period over which to assess the cost-effectiveness of the restriction. Following ECHA guidance on SEA for restrictions168, this should reflect a typical investment cycle. The typical shelf-life of firefighting foams of 15 years (as assumed elsewhere in this report) has been used here, although it should be noted that related equipment may have much longer investment cycles and so a longer period could be used which would reduce the annualised cost. A 4% discount rate has been applied169. The total of annual costs plus annualised one-off costs shows that (at least at the chosen cumulative time period, for the costs and benefits that could be quantified) the one-off costs clearly dominate the balance of overall costs and benefits. Table E.16 Estimate of total quantifiable cost of a potential restriction on PFAS in firefighting foams Cost One-off costs Disposal of stocks (only Scenario 2) Cleaning of equipment Low estimate 210 million 100 million (hypothetical 10% of best estimate) Best estimate 320 million 1 billion High estimate 435 million 1.5 billion (hypothetical 150% of best estimate) Notes Range based on central estimate cost per litre and likely range of tonnage to be disposed of. When considering full range of possible cost per litre, the range of total disposal costs could be 60m 4.8bn. Best estimate based on the only cleaning process (and associated 167 Avoided remediation cost would be considered a one-off benefit, due to the long timescales of accumulated releases that lead to remediation. They could amount to in the range of hundreds of millions to billions of Euros. Annualised over 15 years, using a 4% discount rate, this would be equal to tens to hundreds of millions of Euros per year (annualisation method is described in more detail below). 168 https://echa.europa.eu/documents/10162/23036412/sea_restrictions_en.pdf/2d7c8e06-b5dd-40fc-b6463467b5082a9d 169 The discount rate has been chosen as per the example in the ECHA guidance and as recommended by the European Commission's Better Regulation Guidelines. In accordance with ECHA guidance on SEA for restrictions, the annualised costs is calculated as the annualisation factor multiplied by the one-off costs. The annualisation factor is equal to r(1+r)n /((1+r)n -1), where r is the discount rate and n the cumulative time period. 174 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Cost Low estimate Best estimate High estimate Notes concentration of <1000ppt remaining PFAS achieved) for which a cost was available. Replacement of foam stocks (only Scenario 2) 320 million Total one-off costs Annualised total one-off costs Annual costs Additional volumes of alternative foams 100 million (Scenario 1) 630 million (Scenario 2) 9.0 million (Scenario 1) 57 million (Scenario 2) 21 million (Scenario 1) several millions (Scenario 2) Disposal of expired foams - several millions 1.0 billion 1 billion (Scenario 1) 2.3 billion (Scenario 2) 90 million (Scenario 1) 210 million (Scenario 2) 27 million (Scenario 1) 10 million (Scenario 2) (assumed midpoint between low and high estimate) -1 million (assumed midpoint between 2.0 billion 1.5 billion (Scenario 1) 3.9 billion (Scenario 2) 130 million (Scenario 1) 350 million (Scenario 2) Note that costs could be higher in Scenario 2 than Scenario 1, due to the shorter time available for cleaning, but no specific data was available to quantify this. Range based on central estimate prices per tonne of PFAS-based foam and alternatives, and likely range of tonnage of alternatives to be purchased. When considering full range of possible prices per tonne, the range of total replacement cost could be - 60m 8.3bn. As per the notes above, the possible range could be even wider (low estimates 530m lower, high estimates 10.7bn higher). As per the notes above, the possible range could be even wider (low estimates 48m lower, high estimates 960m higher). 30 million (Scenario 1) 20 million (Scenario 2) (assumed value <30 million) -100,000 Under Scenario 2, all PFAS foam stocks are replaced with new alternative foams at the beginning of the assessment period (already covered under the one-off cost replacement of foam stocks" above). These new foams would not expire within the assessment period, but an unknown share would be used and still need to be replaced again with new foams, thus incurring the costs associated with additional volumes again. Therefore, this cost is lower under Scenario 2 but it cannot be quantified by exactly how much. 175 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Cost Clean-up Low estimate -10s of millions Best estimate low and high estimate) -10 million (assumed midpoint between low and high estimate) Treatment of fire-water runoff per incident (annual unknown) Total annual costs -10s of millions - 10s of millions (i.e. a benefit) - several millions (assumed midpoint between low and high estimate) several millions (Scenario 1) Total annual costs + annualised one-off costs - 10s of millions (Scenario 1) ~0 (Scenario 2) - several millions (i.e. a benefit) (Scenario 2) ~100 million (Scenario 1) ~200 million (Scenario 2) Results rounded to two significant figures. High estimate -1 million (assumed value close to 0) 0 Notes High estimate based on the assumption that at least in some cases, savings from reduced clean-up will be incurred, so total savings will be somewhat larger than 0. 29 million (Scenario 1) 19 million (Scenario 2) 160 million (Scenario 1) 370 million (Scenario 2) As per the notes above, the possible range could be even wider (low estimates 48m lower, high estimates 960m higher). Cost effectiveness Based on the above, as a central estimate, it is calculated that the cost effectiveness could be around 850 (Scenario 1) to 1,700 (Scenario 2) per kg of annual reduction of PFAS emissions. This could range from savings in the tens of Euros per kg to costs around 10,000 per kg. Table E.17 Estimate of cost-effectiveness of the reduction of PFAS emissions from firefighting foams Low estimate Best estimate High estimate Total emission reduction (kg) 234,000 kg 117,000 kg 36,000 kg Total cost () - 10s of millions (Scenario 1) 100 million (Scenario 1) 160 million (Scenario 1) ~0 (Scenario 2) 200 million (Scenario 2) 370 million (Scenario 2) Costeffectiveness - 10s /kg (Scenario 1) 0/kg (Scenario 2) 850/kg (Scenario 1) ~1,700/kg (Scenario 2) 4,600/kg (Scenario 1) 10,000/kg (Scenario 2) Results rounded to two significant figures and reflect the likely range. However, as noted in the previous table, the range could possibly be even wider, from - 10s /kg (both Scenarios) to 31,000/kg (Scenario 1) and 37,000/kg (Scenario 2). 176 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS E.6. Other impacts, practicability and monitorability E.6.1. Social impacts No significant social impacts have been identified. As discussed in Section E.4 "i. Other impacts", there is potential for employment impacts but significant impact is deemed unlikely and any net effect at the EU level would be negligible. E.6.2. Wider economic impacts No significant social impacts have been identified. As discussed in Section E.4 "i. Other impacts", under Scenario 2, a potential shortfall in supply - driven by a one off need for stock replacement - may impact imports of fluorine free foam from outside the EU. However, overall, there are unlikely to be any significant macroeconomic impacts from the result of either Scenario 1 or Scenario 2. E.6.3. Distributional impacts No significant distributional impacts have been identified. E.7. Practicality and monitorability See Section 2.6. E.8. Proportionality (comparison of options) This section provides additional information to support the conclusions drawn in Section 2.7. E.8.1 Detailed table supporting the comparison of the different uses The table below summarises and compares substitution potential, socio-economic impacts and PFAS risk reduction potential across the main identified user sectors. Testing and training (across all sectors) are included separately because they vary significantly from application in actual fire incidents. The rows for user sectors refer to the use in actual fire incidents. Value judgements ("low", "high" etc.) are relative, based on a comparison between the different sectors and applications. A higher substitution potential, lower socioeconomic impacts and a higher PFAS risk reduction potential would suggest that stricter conditions can be imposed on the use/application in question, and vice versa. Use / application Chemical / petrochemical Substitution potential Low for some applications, medium/high for others: Sector includes many different and complex scenarios. Alternatives have successfully been implemented for some applications but may not be readily available for others. In particular, additional testing required to confirm Potential socio-economic impacts High: By far the largest user (59% of annual sales), so transition is large scale. Highest potential fire-safety risks from using alternatives, although relatively low risk of danger to human life. PFAS risk reduction potential High: By far the largest user (59% of annual sales), average potential for retention of run-off and clean-up after incidents. 177 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Use / application Marine Applications Military Civil Aviation Municipal Fire Services Ready to use applications Testing Training Substitution potential Potential socio-economic impacts PFAS risk reduction potential feasibility of alternatives for large atmospheric storage tanks. High: Feasible alternatives considered to be available and have successfully been implemented by many users. Medium: Average user (12% of annual sales), average potential for fire-safety risks from using alternatives. Very high: Average user (12% of annual sales), likely lowest potential for retention of run-off and clean-up after incidents. Medium: Feasible alternatives considered to be available but not many have been certified or implemented by users yet. Medium/High: Relatively small user (6% of annual sales), so relatively small scale of transition. Average potential for fire-safety risks from using alternatives, which could result in a relatively high potential of danger to human life. Medium: Relatively small user (6% of annual sales), average potential for retention of run-off and clean-up after incidents. High: Feasible alternatives considered to be available and have successfully been implemented by many users. Medium/High: Relatively small user (9% of annual sales), so relatively small scale of transition. Average potential for fire-safety risks from using alternatives, but any risks would result in a relatively high potential of danger to human life. Medium: Relatively small user (9% of annual sales), average potential for retention of run-off and clean-up after incidents. High: Feasible alternatives considered to be available and have successfully been implemented by many users. Low: Average user (12% of annual sales), so average scale of transition. Low potential for fire-safety risks from using alternatives. High: Average user (12% of annual sales), likely lower potential for retention of run-off and clean-up after incidents because not restricted to specific industrial sites. High: Feasible alternatives considered to be available. They have not yet been implemented by many users but ready to use applications rarely deal with large flammable liquid fires, so there is very little need for high performance foams. Low/Medium: Relatively small user in terms of quantities (1% of annual sales according to Eurofeu data, several % based on estimated number of all fire-extinguishers) but potentially large number of devices affected (including millions of fire extinguishers). Very low potential for fire-safety risks from using alternatives. Medium/High: Relatively small user, likely lower potential for retention of run-off and clean-up after incidents because not restricted to specific industrial sites. Very high: Feasible alternatives considered to be available and have successfully been implemented by many users. No need for high performance foams. Very low: Likely very small share of use, not the most expensive high performance foams required. Very low risk of damages resulting from performance of alternatives. Low: Likely very small share of use, relatively high potential for retention. Very high: Feasible alternatives considered to be available and have successfully been implemented by many users. Little need for high performance foams. Low: Likely very large share of use, but likely not the most expensive high performance foams required. Low risk of damages resulting from performance of alternatives. Low/Medium: Likely very large share of use, but relatively high potential for retention. 178 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Overall conclusions from this table are drawn in Section 2.7.1. E.8.2 Stakeholder input on transition periods Several users have provided input on manageable transition periods: One stakeholder claimed that a transition time of 10 years would be needed for the switch in the O&G / petrochemicals sector. Another stakeholder from the same sector cited 5-10 years, in order to minimise and spread the costs to change foam and re-build, or re-place fire extinguishing systems or equipment, but they would like to keep PFAS stocks in case of a big fire incident. As reported in the case study in Section E.2.4.2, Equinor took around 8 years to transition to fluorine-free foams. An industrial end user under consideration of discussions with some representatives from aviation industry groups and municipal users has developed a detailed draft proposed timeline covering a range of tasks required for a full transition to fluorine-free foams (across all sectors). The full timeline is provided in Annex 4, but key milestones suggested are (years from formal start of transition and introduction of legislation): No more PFAS foam use in training: Immediately No more PFAS foam use in systems testing: 4 years No more PFAS foams used for small incidents: 4 years Completion of transition: 10 years. The additional 6 years from the previous steps is largely driven by further replacement and disposal of stocks of legacy foam170, as well as the need for further development of fluorine-free foams by manufacturers. A stakeholder from the aerospace and defence sector suggested the system change to enable use of non-PFAS foam could be introduced at time of major refit, which typically occurs every 6 -12 years. On the other hand, the US Fiscal Year 2020 National Defense Authorization Act (NDAA) requires a phaseout of PFAS-containing firefighting foam in the US military (except on ships) by October 2024, i.e. within 4 years. Several stakeholders across different sectors stated at the workshop or in response to the written consultation that 3-6 years may be sufficient. One stakeholder suggested different transition periods for different uses. They explained municipal fire brigades should be able to transition quicker than operators of fixed installations for example. They argued that the use of fluorine free foam for tank fire fighting needs further testing and therefore more time. The PFHxA proposed restriction foresees the following transition periods: Concentrated fire-fighting foam mixtures placed on the market until 18 months after the entry into force of the restrictions can be used in the production of other firefighting foam mixtures until 5 years after the entry into force, except for use of fire-fighting foam for training and (if not 100% contained) testing. There is also an exception proposed for concentrated fire-fighting foam mixtures 170 Note that this does not necessarily imply that no more PFAS based foams are purchased during that period. 179 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS for certain defence applications until a successful transition to alternatives can be achieved, and for concentrated fire-fighting foam mixtures for cases of class B fires in storage tanks with a surface area above 500 m2 until 12 years after the entry into force.171 Conclusions from this input are drawn in Section 2.7.2. E.8.3 Stakeholder input on concentration thresholds The following thresholds were considered feasible by consulted stakeholders (all have been converted to ppb): Regulation in Queensland (Australia) allows up to 10,000 ppb for PFOA/PFHxS and 50,000 ppb for PFOA and PFOA related precursors and higher homologues. One stakeholder recommended these to be adopted in the EU as well. One stakeholder that has transitioned to fluorine-free foams (in the petrochemicals sector) reported that they had aimed for and achieved a level of 0.001% (10,000 ppb). One stakeholder reported experience with a relatively simple cleaning process (emptied tank, flushed two times with warm water) which can lead to very low remaining PFAS contamination (both when tested immediately and after a few years), but cautions a threshold below 100 ppb would be unrealistic. Two stakeholders suggested 1 ppb as the lowest achievable concentration in most cases. One of them linked this to a 32-stage legacy foam decontamination process costing 12,300 per appliance. In one-third of appliances this process can yield concentrations even lower (below 0.07 ppb). In terms of the lowest detectable concentrations, one stakeholder suggested laboratories are reported to be able to analyse down to a level of 30-150 ppb. This is contradicted by other stakeholders that cite lower concentrations having been achieved and tested (see above). In the REACH restriction on PFOA, a concentration limit of 25 ppb of PFOA including its salts or 1,000 ppb of one or a combination of PFOA-related substances was adopted, based on the capabilities of analytical methods according to the RAC's opinion on the restriction dossier. Conclusions from this input are drawn in Section 2.7.3. E.9.1. Comparison of Restriction Options See Section 2.7. E.9.2. Comparison of costs and benefits A brief summary of the main impacts (including costs and benefits), based on Section E.4.1. is provided in the table below. Insofar as costs and benefits could be quantified, they are also compared in the calculation of cost effectiveness in Section E.5.1. 171 Note that these transition periods and exemptions may change when (and if) the proposal is taken forward. 180 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Table E.1 Summary of socio-economic considerations for the main expected impacts of potential regulatory management options Impacts Economic Social Health/Environmental Wider economic implications a. Cleaning of equipment Costs vary by equipment, process and achievable concentration. None identified. According to one estimate up to 12,300 per appliance achieving PFAS levels below 1000ppt (1/3 of appliances below 70ppt), which could imply EU total costs in the order of 1 billion, but established simpler methods have also been reported (cost not quantified). Trade-off between cost for cleaning/replacement and threshold concentrations for remaining PFAS contamination. None identified. Replaced equipment and media (e.g. water) used in cleaning process must be disposed of or treated safely to avoid worker or environmental exposure. The replacement of equipment is likely to be required in some cases, depending on the threshold chosen. Replacement costs for extinguishers alone estimated at 15-450 million (EU total). Replacement cost for other equipment not quantified. b. Other risk management options c. Fire safety -impacts of technical performance of alternatives None identified. None identified. It is not expected that any damages would be caused, see Health/Environmental. This is however still uncertain for large atmospheric storage tanks. None identified. None identified. None identified. AoA concluded alternatives are technically feasible and successful transitions have been shown in most applications. Further testing required to confirm whether this covers also large atmospheric storage tanks (LAST), the application of most concern. None identified. 181 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Impacts Economic Social Health/Environmental Wider economic implications Speed of fire suppression may be slower and application of foams may be less flexible and less easy to use, according to some stakeholders. This has not been shown to be generally the case and resulting health/safety impacts could not be quantified. d. Use patterns to achieve comparable/acceptable performance using alternatives Between no change in volume and up to a maximum of 100% additional foam required (additional cost considered in e. below). None identified. In sprinkler applications, special sprinkler nozzles have to be installed (cost not quantified). More than one foam may need to be stocked by users to cover different flammable liquids, with logistical, training and safety implications for users. None identified. e. Economic feasibility of alternatives More than one foam may need to be stocked by users to cover different flammable liquids, with logistical, training and safety implications for users. For both Scenarios: None identified. None identified. None identified. 182 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Impacts Economic Social Most likely there is no significant price difference (per litre) between PFAS-based foams and alternatives, but up to 100% more volume may be required (central estimate 50%) to achieve desired performance. This would lead to costs around 27m per year (EU total, central estimate) Potential additional economic costs for transitioning may include testing costs (not quantified), storage costs, (not quantified) costs from technical changes to delivery systems (e.g. 5-200 pre nozzle or around 2,700 for a mobile foam unit, but generally conceived as manageable), and regulatory approvals (not quantified). Potential savings may include lower foam disposal costs at expiry date (likely order of magnitude 100,000 to several million) lower fire-water disposal costs (covered under g. Remediation and clean-up), avoided cross contamination of waste, reduced regulatory requirements and reduced PPE requirements (not quantified). Additionally for Scenario 2: Costs for existing stock of PFAS-based foams (estimated 210,000-435,000 tonnes) will have to be written off (and new stocks Health/Environmental Wider economic implications 183 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Impacts Economic Social f. Environmental/health - impacts of alternatives purchased causing an additional cost (central estimate 1.0bn) over the baseline. None identified. None identified. g. Remediation and clean-up Potential risk of PFAS contamination could be eliminated, which could save up to around 100 million remediation costs per site. Depending on the extent of containment and immediate clean-up, the number of relevant sites is likely low, but overall savings could still be in the order of magnitude of 100s of millions to billions More information on the total number of sites and real-world implementation and effectiveness of best practices would be required to be more precise. None identified. Health/Environmental Wider economic implications Based on the assessed substances, nonfluorinated alternatives are of lower environmental concern, primarily due to greater biodegradation. A quantitative comparison of risk under each scenario was not possible with the available data. Potential trade-off between remediation cost and remaining PFAS contamination. None identified. None identified. h. Availability of alternatives Treatment of fire-water run-off and shortterm clean-up largely driven by other contents of fire-water run-off and cost saving estimates are very uncertain. Run-off treatment savings could be 0.7 per litre (range ca 0-11) or 0 to 10s of millions per incident, and clean-up cost savings up to 10s of millions in total. Range of alternatives and capacity to increase production likely available. No significant None identified. None expected in Scenario 1. The risk of supply supply-shortages is higher in Scenario 2 (depending on timescales of a restriction), None identified. 184 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Impacts Economic Social supply shortages or additional costs expected in Scenario 1. Scenario 2 may result in a more sudden and potentially significantly larger demand for fluorine-free foams to replace existing stocks of PFAS-based foam. This heightens the risk of a shortfall in supply, - depending on the timescales of any restriction. As the largest single use, and with comparatively low current fluorine free sales volumes, the risks of supply constraints may be greater in the chemicals and petrochemical sectors. Health/Environmental which could potentially lead to additional firesafety risks. Wider economic implications i. Other impacts None identified. There is potential for employment impacts but significant impact is deemed unlikely and any net effect at the EU level would be negligible. None identified. Under Scenario 2, a potential shortfall in supply - driven by a one off need for stock replacement may impact imports of fluorine free foam from outside the EU. 185 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Impacts Economic Social j. Emissions from disposal of legacy foams None identified. None identified. k. Technical feasibility / availability of disposal options If the transition period is short, there is the demand for disposal facilities may outstrip supply, leading to potential additional costs and potential for emissions. None identified. l. Costs of disposal Total EU costs estimated at up to 320 million (range up to 60m-4.8bn) depending on the method used (with implications on effectiveness, see Health/Environmental) and the share of foams that would have reached expiry date without use. None identified. Additional transport, storage and labour costs may be incurred (not quantified). Health/Environmental Wider economic implications Overall, there are unlikely to be any significant macroeconomic impacts from the result of either Scenario 1 or Scenario 2. High temperature incineration has been identified as main disposal method. There are potential hazards (emissions of hydrogen fluoride and PFAS), but further research is needed to identify and quantify the emissions produced from the incineration of PFAS. None identified. Trade-off between temperature of incineration (with lower capacity and higher costs) and effectiveness of PFAS destruction. None identified. If the transition period is short, there is the demand for disposal facilities may outstrip supply, leading to potential additional costs and potential for emissions. Trade-off between temperature of incineration (with lower capacity and higher costs) and effectiveness of PFAS destruction. None identified. 186 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS 187 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Annex F: Assumptions, uncertainties and sensitivities The above conclusions are subject to a range of assumptions and uncertainties. Assumptions have been made based on the results of other sections and are discussed in more detail within those sections. However, the assumptions and uncertainties that could most significantly affect the results are discussed briefly below: Environmental/health benefits of the reduction of PFAS emissions could not be quantified, primarily due to a lack of knowledge about the hazards of PFAS. The estimated emissions of PFAS and hazards of the constituents of alternatives are also subject to a range of uncertain assumptions. Hence, costs and benefits could not be directly compared; Cost of transition are subject to uncertain assumptions about price difference between foams and the quantity of alternative foams needed to achieve the desired performance. Which and how much alternative foam is needed to achieve the desired performance varies on a case by case basis. It has been judged most likely that there is no significant price difference (per litre) between PFAs-based foams and alternatives, and assumed that 50% additional volume of alternatives is needed. If a more/less expensive alternative foam or larger/smaller quantities would be needed to achieve the desired performance, this would increase/decrease the costs of the restriction. Savings related to the transition are sensitive to assumptions about the amounts of foam that would reach their expiry date without use under the baseline; Costs of cleaning and technical changes or replacement of equipment are very casespecific and could largely not be quantified with the available data. This means that the quantified costs of both scenarios are underestimates; It should be noted that there was a divergence in the stakeholder input about technical feasibility of alternatives. A few stakeholders have voiced concerns over the potentially reduced fire safety, at least in specific applications. This means there is a risk of additional health, safety and economic (fire damage) impacts; however our analysis has concluded that they are not the most likely outcome and that LAST are the main application for which there is still further testing required; It is uncertain to what extent current practices involving the use of PFAS-based fire-fighting foams already manage to eliminate the need for significant new remediation requirements under the baseline. This is because most experiences with PFAS remediation relate to legacy contamination resulting from historical emissions before current measures (e.g. containment and clean-up after use) were widely implemented. However, stakeholder input suggests that such measures are likely not 100% implemented or effective. Furthermore the incremental costs of addressing PFAS contamination in short-term clean-up is difficult to separate from the wider clean-up costs involved after fire incidents. In addition, there is a lack of data about the number of sites that use PFAS-based foams in sufficient quantities to potentially require clean-up or large scale remediation. Therefore remediation savings from the transition to fluorine-free alternatives are very uncertain and only illustrative estimates of the potential order of magnitude of such benefits were provided; and There is a wide range (60-4,800 million, with best estimate 320 million) in the potential costs of disposal of legacy foams in Scenario 2, which largely depends on the disposal method used. This is due to uncertainty about the amounts of foam that would reach their 188 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS expiry date without use under the baseline and the effectiveness of PFAS-destruction at different incineration temperatures and times. There is also uncertainty about the potential emissions and therefore associated environmental/health risks. 189 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Annex G: Stakeholder information Introduction In the inception of both Commission and ECHA projects underlying this dossier, it was recognised that effective engagement with key stakeholders from across the fire-fighting foam sector, particularly the manufacturers and users of the foams, would be critically important in the data collection process of both projects. It was also noted that the relevant stakeholders, who would be likely to be able to contribute key information, would be able to feed into both projects. Therefore, to conduct both projects with optimal efficiency, and to ensure the consistency of the data feeding into both projects, it was agreed to carry out a joint stakeholder consultation across the two projects in parallel. It was agreed that it was essential that the consultation cover all the relevant sectors and backgrounds across the fire-fighting foam supply chain, as well as regulators, researchers and special interest groups. The consultation therefore aimed to target the following stakeholders: Foam manufacturers / suppliers; Users of foams in major sectors (including airports, oil and gas, chemical plants, ports, railways); Key trade associations; International organisations; National-level authorities and agencies; Academics and R+D (especially those involved in developing alternative foam products); and Key NGOs and interest groups. It was agreed during the inception meeting that Wood, Ramboll and COWI would map stakeholders identified so far, indicating the best means of consulting each one of them: e.g. advisory group, questionnaire, one-to-one consultation, workshop, etc. An initial list of stakeholders was provided in the Inception report, and a finalised list was agreed with the Commission and ECHA prior to commencing the consultation activities. Approach The agreed approach to collecting key information from the main categories of expert stakeholders (detailed above) was to carry out a consultation through a combination of i) scoping interviews, ii) a targeted stakeholder questionnaire, and iii) a stakeholder workshop. Our approach to carrying out these consultation activities is outlined in the following sections. Scoping interviews To inform the main data collection steps of the project (the stakeholder questionnaire and workshop) a series of initial scoping interviews was organised with a selected small number of key stakeholders. The purpose of the interviews was to: 190 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS I. Introduce and discuss the aims and scope of the project with key experts; II. Identify where the key data gaps were in relation to the objectives of the project(s); and III. Identify other key stakeholders in this sector to target in the next stages of the consultation. The stakeholders involved with the scoping interviews were: Eurofeu; Fire Fighting Foams Coalition; Copenhagen Airport; Heathrow Airport; LASTFIRE project; and IPEN. An interview template was developed, and shared with the interviewees ahead of the call, to guide the conversation more effectively and efficiently. Teleconference interviews of 30-60 minutes were held with each stakeholder. During the call, brief notes of the key discussion points were made. Since the purpose of these scoping interviews, was as an introductory discussion, rather than an evidence gathering exercise as such, a limited amount of specific information about the use of fire-fighting foam products was gained. A number of key outcomes from these scoping interviews are highlighted below: All stakeholders interviewed expressed an interest in the project and agreed to participate in the consultation; In some cases, for example, for key industry associations, it was agreed they would coordinate joint industry responses, and stakeholders provided the details of additional stakeholders to contact, and/or agreed to forward the consultation on directly; Both industry, users and others (e.g. NGOs) commented on the increased move towards and the rapidly increasing market share of fluorine-free foams, and their increasingly better overall performance now than previously; It was re-emphasised that alternative foams are designed for very specific applications, requiring compliance with specific performance criteria, so the analysis of their technical and economic feasibility will be challenging as it requires assessment of each product individually; There is likely to be variation in the situations with regards to alternative foams in different sectors of use (e.g. between aviation and oil and gas sectors) and in different locations/countries (e.g. certain countries have switched to alternatives, others have not); and 191 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS The potential for contamination of foams was raised, leading to the inclusion of specific questions in the survey about the level of PFAS as impurities in foam products (both PFAS-based and fluorine-free). The scoping interviews were then used to better inform our approach to the following consultation steps, allowing the survey and workshop to be designed more systematically to address the key knowledge gaps and target the most relevant stakeholders. This also helped to identify additional stakeholders to include in the next consultation steps. Consultation questionnaire The main consultation activity conducted involved the development of a written questionnaire, based on an assessment of the required data needed to generate and/or complement the information already gathered under the separate Tasks under the two projects. It was agreed that the most appropriate format of the questionnaire would be a Word document that could be sent to targeted stakeholders directly via email, allowing the respondents to fill in relevant details and return the completed questionnaires. The questionnaire covered the following aspects: Introductory information; Background information on the respondent; Chemical identity, functionality of PFAS in fire-fighting foams; Alternatives to PFAS in fire-fighting foams; Foam use and environmental emissions; Potential restrictions on PFAS in fire-fighting foams; and Additional information. The full consultation questionnaire is provided in Appendix 1 of the underlying study172. Consultation questionnaire results A total of 33 written responses to the questionnaire were received173. Of the different types of stakeholder targeted, the most responses were from users/industry (11), with smaller numbers of responses from individual manufacturers (2), authorities/agencies (6), industry associations (2), NGOs (3) and `other' stakeholders (7) 172 Wood, Ramboll, COWI: "The use of PFAS and fluorine-free alternatives in fire-fighting foams - Final report". Report for the European Commission DG Environment and European Chemicals Agency (ECHA) under specific contracts No 07.0203/2018/791749/ENV.B.2 and ECHA/2018/561. 173 Correct as of July 18 2019. 192 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS e.g. academic/testing/training professionals/technical consultant. It is noted that the responses from the users of foams cover all the main sectors of use the consultation aimed to cover (airports, oil refineries/storage, chemicals, petrochemicals, and rail). Responses to the consultation from a number of stakeholders also included the provision of previously published data or reports in addition to, or instead of, the questionnaire. This included published reports and analyses from national authorities174, research and testing information175, and special interest groups176 Since the questions in the stakeholder questionnaire were designed to gather information that will best feed into the delivery of tasks under each of the two projects, the responses received have generated useful information in this context. In particular, we highlight the following aspects, where the consultation yielded useful information: Identifying some of the key foam products containing PFAS on the EU market, and nonPFAS alternatives actually used in key sectors; Identifying specific PFAS, precursors and impurities present in some foam products; The functionality of PFAS-containing foams useful to the major users of foams and reasons why products containing PFAS have not been fully replaced; Volumes of production and use, and unit price for a small number of individual products; Information on available alternatives, including specific products on the market in the EU, the type and sector of use, their availability, volumes of sale and use, their perceived technical feasibility and economic feasibility; Some details of fire-fighting foam use e.g. volumes, frequency; Some details of methods, regulations, and guidelines in place to prevent release to the environment; Some information on the methods/approach to disposal of individual foam products; Preliminary stakeholder opinions and feedback on different potential restriction options were provided; and Additional data, reports and other resources were provided by a number of stakeholders with their consultation response. For some sections, a number of information gaps, where the level of detail provided by respondents was less substantial, were identified. These data gaps helped to inform the approach to the organisation and format of the following stage of the consultation process, the stakeholder workshop, where these data gaps were explored further (see next section). 174 KEMI (2015) Chemical Analysis of Selected Fire-fighting Foams on the Swedish Market 2014 175 Published testing data, as provided by LASTFIRE: www.lastfire.co.uk/ 176 IPEN (2019) The Global PFAS Problem: Fluorine-Free Alternatives as Solutions, https://ipen.org/documents/global-pfas-problem-fluorine-free-alternatives-solutions 193 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS Consultation workshop The final stage of the consultation involved the organisation of an expert stakeholder workshop. This was hosted by ECHA in Helsinki on 24 September 2019. The purpose of the workshop was to present, validate and seek feedback on the preliminary project findings; gather views on possible risk management options; and explore the feasibility of replacing PFAS-based foams with fluorine-free alternatives. Stakeholder views were sought during the workshop through a series of breakout groups on key topics which focused on specific questions designed to inform possible future regulatory activities. The workshop was attended by a total of 36 participants, including manufacturers, users from different sectors (airports, chemical plants, oil and gas), researchers, NGOs, national authorities, and remediation experts. The format of the workshop included: Introductions from DG Environment, ECHA and the study team; Presentation of initial results; Plenary discussion on study findings to date; Presentations from invited speakers; and Breakout session on remaining data gaps. The invited speakers, who presented at the workshop were from the following organisations: Eurofeu (industry perspective); Finavia Corporation (user perspective - airports); Total HSE (user perspective - oil and gas); and LASTFIRE project (testing and efficacy perspective). There were four breakout sessions for the workshop, each covering a specific set of questions, partly informed by the identified data gaps remaining from the consultation questionnaire and the other tasks relating to the two projects. The breakout sessions covered the following aspects: Different Risk Management Options; Essential uses and availability of alternatives; Remediation costs and technologies; and Current/ future market trends in PFAS-based and fluorine-free foams. 194 PRE-ANNEX XV RESTRICTION REPORT - PFAS IN FIREFIGHTING FOAMS The workshop report with more details about the set-up and results of the workshop is included in Appendix 2 of the underlying study177. Additional consultation and resources The stakeholder consultation and workshop also resulted in a number of stakeholders providing additional information to supplement their consultation responses. This additional information was used, where relevant, in each of the specific tasks. Following the consultation questionnaire and workshop, a number of specific areas were identified as needing additional data or clarification, for example on volumes of firefighting foams produced, marketed and used in the EU. Where these additional data needs were identified, the project team undertook direct consultation with specific stakeholders identified as being the best source of the required information. Contact was made with these stakeholders via email or telephone to discuss the remaining data needs and obtain the required data. This additional consultation has provided additional detail and clarifications relating to critical uses, volume of production and use in the EU, and experiences from previous transitions. 177 Wood, Ramboll, COWI: "The use of PFAS and fluorine-free alternatives in fire-fighting foams - Final report". Report for the European Commission DG Environment and European Chemicals Agency (ECHA) under specific contracts No 07.0203/2018/791749/ENV.B.2 and ECHA/2018/561. 195 This page is intentionally blank June 2020 Doc Ref. 41288-WOD-XX-XX-RP-OP-0009_A_P03