Document NedG1k9Qg7wD54mbD1r62ao9y

Schaffhausen, May 2023 PFAS Consulting Annex XV Non-confidential Attachment Georg Fischer Piping Systems Ltd. We tried to keep this rather simple and exemplary but we can always provide more content on request GF v3.0 SECTION III. Non-confidential comments General Comments (repetition of online input) Piping Systems made from Fluoropolymers (FPs) are used for conveyance of critical media (e.g. high purity water and/or harsh chemicals) from high-tech industries (related to Green Deal, digitalization etc.) to basic chemical industry uses. Irrespectively of the used pipe materials (polymeric/non-polymeric), piping for these specific uses do need Fluoroelastomer gaskets and diaphragms for valves. Industrial FP piping are designed for 25 years lifetime, can be handled safely in industrial facilities. We can prove on selected practical use cases in this document with our research (see confidential/non-confidential attachment), that there are currently no technical alternatives (polymeric/non-polymeric) in the upper tier of our specific uses, neither are there any alternatives visible to cover the given FP performance range in piping system incl. worker and environmental safety. Fluoropolymers constitute a specific group of substances within PFAS, as their properties are completely different. These substances are considered polymers of low concern and therefore their use does not pose any risk to human health and the environment. The proposed PFAS restriction does not differentiate between relevant PFAS and Fluoropolymers /-elastomers (-> US and UK PFAS restriction proposal excl. FPs). Furthermore, as reported by industry/fluoropolymer suppliers, progress is being made in relation to manufacture of fluoropolymers without the use of PFAS polymerization aids, introduction of abatement techniques during manufacture, and incineration conditions to grant full mineralization of fluoropolymers at end of life. For this reason, a broad exemption for this group of substances should be considered within the PFAS restriction proposal. GF v3.0 2 For ECHA Annex XV Consulting only, 2023 Georg Fischer Piping Systems Ltd., All rights reserved #1: Sectors and (Sub) Uses Introduction Piping System and Jointing Semicon Fab Please allow us a few general statements at the beginning to better explain the uses of Fluoropolymer (FP) piping with HP water systems (to avoid too much repetition in our selected more data-driven use cases for specific applications): treatment skid 1. The various advantages of Fluoropolymer as such have been cited many times, in the world of piping system there are two distinct sectors/uses for our critical applications: Semicon Manufacturing -> high-purity (hp) piping for water and harsh chemicals Energy -> Cooling for High Voltage Direct Current conversion Chemical Industry -> conveying of specific harsh chemicals incl. disinfection methods. These applications are used in uncounted industrial sub-uses or companies (e.g. metal pickling, food, life science, productmanufacturing etc., some not even known to us) 2. Any piping systems (see pictures) consists of pipe, fittings, valves incl. diaphragms, gaskets, sensors, semifinished sheet for tanks and specific jointing technologies (size range from d16mm (at least in SEMI) to d400mm!). This includes polymer liner piping which are reinforced with glass-fiber reinforcements (GRP) for more safety. 3. Just naming an alternate material as in the dossier is not sufficient, the whole product range (> 5000 individual product designs and manufacturing thereof, developed and improved over the last 25 years) for piping including on-site jointing, installation and operation conditions need to be taken into account for a sound assessment. Use of harsh chemicals GF v3.0 3 For ECHA Annex XV Consulting only, 2023 Georg Fischer Piping Systems Ltd., All rights reserved #1: Sectors and (Sub) Uses Introduction Piping System and Jointing HVDC conversion for green energy Cooling application 4. Our piping environment is heavily regulated, e.g.: CEN Product Standards (and non EU standards ISO/ASTM for EU export business), Many public/individual company approvals for products audited by certified auditors, Building approvals such FM (e.g. fire safety), Food approvals, EU10/2011, FDA Positive list of chemical resistance for piping system by e.g. the public German DIBt* or ISO TR 10358* Any new alternative piping must comply or a complete new framework must be developed (time frame 5-10 years); we can provide a detailed list of all regulatory requirements on request. Acid purification * DIBt (German Institute for Construction Technology): https://www.dibt.de/de/service/listen-und-verzeichnisselists ISO/TR 10358:2021 Plastics pipes and fittings for industrial applications -- Collection of data on combined chemical- resistance https://www.iso.org/standard/77005.html GF v3.0 4 For ECHA Annex XV Consulting only, 2023 Georg Fischer Piping Systems Ltd., All rights reserved #1: Sectors and (Sub) Uses General Alternate Discussion - Polymers (see slides with detailed facts with our selected specific use case to prove these statements) With regard to other plastic materials (PE, PP, PVC named alternatives in the dossier): In SEMI uses, true high-purity polymer materials are a must (no additives, no stabilizers etc.)! It is not possible to process listed alternate materials without additives and resulting leach-out levels are not accepted by SEMI. The performance of piping in SEMI is directly related to the (high-end) micro-chip yield rates in the factory and at the essence of a 20-30 B$ factory investment. In Chemical uses, the public positive list by DIBt (and others for EU export business) shows clearly for our critical selection of harsh chemicals that only FP piping is allowed. Less proven performance with spilling e.g. H2SO4/98% at elevated temperatures or HF are serious safety risks. With regard to new plastic solutions: Welding is the preferred jointing technology (mechanical joints/gaskets can leak due to mechanical stresses in the system) however, some plastics can not be welded properly (moisture content) To our knowledge, there is no polymeric material offering the same wide application use coverage for piping as FPs today however, there might be in single sub-uses other materials thinkable (discussion in our confidential attachment) but this will be a persistent material as well! If the restriction forces substitution of fluoropolymers by less efficient materials in applications where there may be some room for use of other materials, and considering that alternatives will likely be persistent materials, the outcome will be more frequent maintenance and replacement, leading to increased amounts of waste of persistent materials that society will need to handle. GF v3.0 5 For ECHA Annex XV Consulting only, 2023 Georg Fischer Piping Systems Ltd., All rights reserved #1: Sectors and (Sub) Uses (see slides with detailed facts with our selected specific use case to prove our statements) General Alternate Discussion - Non Polymers With regard to piping made from glass (as mentioned in the dossier): This might be a solution in a laboratory environment but not in manufacturing plants (e.g. metal pickling) because of people safety (e.g. H2SO4) or environmental hazards due to breaking glass Some chemicals will simply not work with glass (e.g. HF) Plus, jointing, installation stresses, larger tanks, pipe sizes up to 400 mm made from glass, high weight vs. building structure, transport of pre-manufactured skids for export .... With regard to metal piping (as mentioned in the dossier): There might be some specific, quite expensive metals (e.g. Tantalum, Hastelloy) as a raw material for specific use cases of today's plastic piping system somewhere. But as mentioned, it must be possible to have fittings and valves plus (orbital) welding (inherent stresses) in the full dimension range and must withstand all harsh chemicals used as well. Metal piping lined with PTFE/PFA are commonly used for highly corrosive fluid handling at high temperatures, but liners are FPs! In any case, this will not work for SEMI -> metal atoms/ions from the piping material in hp water loops may already short-circuit the wafer to be scrap Chemical -> metal pickling chemicals are not really suited for being conveyed in metal piping. (e.g. Tantalum has a limited corrosion resistance against bases and reducing media, it is not resistant against fluorides, Source: MERSEN Global) High-voltage DC conversion (wind-/solar power) cooling, high voltages with metal piping is obviously rather risky GF v3.0 6 For ECHA Annex XV Consulting only, 2023 Georg Fischer Piping Systems Ltd., All rights reserved #1: Sectors and (Sub) Uses General Alternate Discussion - Gaskets (see slides with detailed facts with our selected specific use case to prove our statements) Gaskets made from FP (e.g. FKM): Any piping solution (polymeric/non-polymeric) will need gaskets as mechanical joints cannot be completely avoided. In general, EPDM/NBR/silicone gaskets are either not suited for our harsh chemical or too dirty for hp applications in upper tier applications (please refer to the confidential attachment, data were developed by GF Piping Systems) Any new technical Fluoroelastomers alternatives will need to be elastomeric, there is currently no such material to our research. GF v3.0 7 For ECHA Annex XV Consulting only, 2023 Georg Fischer Piping Systems Ltd., All rights reserved #7: SEMI (Potential derogations marked for reconsideration) Over view 1. Critical uses and technical alternate discussion (2 slides to follow and confidential attachment due to company knowhow) 1. Ambient Ultrapure Water (UPW) / Hot Ultrapure Water (HUPW) 2. Mixed Waste Lines 2. Socio-economic Analysis (considered business relevant information, please refer to confidential attachment) GF v3.0 8 For ECHA Annex XV Consulting only, 2023 Georg Fischer Piping Systems Ltd., All rights reserved Georg Fischer Piping Systems PFAS Consulting Section IV, Non-confidental Attachment #7: SEMI (Potential derogations marked for reconsideration) Use Case: Piping Systems for Semiconductor Manufacturing Infrastructure and Equipment*** Subuse/ Media conveyed Ambient Ultrapure Water (UPW) Hot Ultrapure Water (HUPW) System needs/ Typical Operating Conditions Sizes 20-400 mm UPW (also with disinfectants (ozone/ H202)) T = ambient p up to 10 bar t up to 25 years Plastic piping used today (state of the art) High Purity PVDF Elastomers*: FKM, PTFE Other materials used Low-end applications: "clean" PVC/ PP Elastomers*: None Consequences of using other piping materials Other Polymers: Yield losses, extended ramp/rinse-up times, high end processes** impossible to run. Metal: no go due to "metal" pollution Technical Alternatives Alternative option feasibility study in the confidential attachment (considered company knowhow) Sizes 20-225 mm High Purity PVDF None known n.a. HUPW Elastomers*: T = 70-85C FKM, PTFE p up to 16 bar t up to 25 years Alternative option feasibility study in the confidential attachment (considered company knowhow) * Elastomers: Various gaskets and diaphragms for valves ** Details see submissions by our customers organized in SEMI SIA and SEMI Europe *** Please see attachment for public high-purity and ozone related publications 9 For ECHA Annex XV Consulting only, 2023 Georg Fischer Piping Systems Ltd., All rights reserved GF v3.0 Georg Fischer Piping Systems PFAS Consulting Section IV, Non-confidental Attachment #7: SEMI (Potential derogations marked for reconsideration) Use Case: Piping Systems for Semiconductor Manufacturing Infrastructure and Equipment Subuse/ Media conveyed Mixed Waste Lines (customer desires max. safety as mix of chemical waste may change over time or even "unknown" during planning) System needs/ Typical Operating Conditions Sizes 20-110 mm Mixed chemical waste (HF, H202, H2SO4, etc.) T = ambient p up to 10 bar t up to 25 years Plastic Piping used today ECTFE Elastomers*: FKM, FFKM, PTFE Other materials used Consequences of using other piping materials Technical Alternatives PVC, PTFE- lined steel PVC: replaced by ECTFE because of temperature and corrosion resistance. Risk of failure and very frequent exchange, all with risk to the environment and safety of workers. PTFE- lined steel: replaced by ECTFE. PFAS as liner hard to joint, very expensive Yes, but all are fluoropolymers *Elastomers: Various gaskets and diaphragms for valves with no known alternative 10 For ECHA Annex XV Consulting only, 2023 Georg Fischer Piping Systems Ltd., All rights reserved GF v3.0 #8: Chemical Industr y and Energy (Other identified (sub) uses) Over view 1. Uses and technical alternative discussion (3 slides to follow and confidential attachment on gaskets (non-public research institute study) 1. Sulfuric Acid under harsh conditions in various sub-uses under Chemical Industry 2. Various harsh chemicals under harsh conditions in metal-pickling (sub-use under sector Chemical industry) 3. Sub-use cooling in Energy (high-voltage dc conversion for green energy 2. Socio-economic Analysis (considered business relevant information, please refer to confidential attachment) 11 For ECHA Annex XV Consulting only, 2023 Georg Fischer Piping Systems Ltd., All rights reserved GF v3.0 #8:Chemical Industry (Other identified uses) Uses: Conveying harsh chemicals in various industries (or sub-uses) Overview industries vs. various chemicals Chemical media Sulfuric acid, H2SO4 Industrial applications Phosphate Fertilizers Petroleum refining Batteries Metal mining Leather/Textile Water treatment Pulp and paper Pickling operations in steel mills Ethanol production Role Reactant Catalyst pH adjustment Characteristics Strong acid Exotermy Powerful oxidising agent Extremely corrosive Nitric acid, HNO3 Hydrochloric acid, HCl Hydrofluoric acid, HF Mixed acids Fertilizers Explosives Pickling operations in steel mills Reagent Etchant Powerful oxidising agent Extremely corrosive Steel production Oil production Textile Rubber Pool sanitisation Food production and processing Pharmaceuticals Gasoline Stainless steel Aluminum Electrical components Incandescent light bulbs Reagent pH adjustment Disinfectant Corrosive to metals Slimicide (prevents the High diffusion rate growth of slime in paper stock) Etchant Reagent Cleanser Catalyst Extremely corrosive High diffusion rate Metal pickling operations Nitrophosphate fertilizers Etchant Powerful oxidising agent Extremely corrosive 12 For ECHA Annex XV Consulting only, 2023 Georg Fischer Piping Systems Ltd., All rights reserved GF v3.0 #8: Chemical Industry Sub use: Sulfuric Acid* applications including sulphur burning acid plants, metallurgical plants, concentration and regeneration plants, transport and distribution, recycling Subuse/ Chemical media System needs/ Typical Operating Conditions Plastic Piping used today Other materials used Consequences of using other piping materials** Concentrated sulfuric acid: H2SO4 96-98% Spent acids: H2SO4/SO3 H2SO4/HNO3/HNO2 H2SO4/HCl H2SO4/HF H2SO4/ ClO2 Temperature: 20-100 C Pressure: various ECTFE PVDF PFA PTFE lined steel Elastomers: PTFE FKM PE, PP, FRP PVC-U, PVC-C, Stainless steel Tantalum Hastelloy Elastomers: EPDM, NBR, Silicone PE: corrosion by concentrated oxidizing media (H2SO4, HNO3, ClO2), strong diffusion by HCl and blistering by HF, not suitable above 60Cnot usable PP: corrosion by concentrated oxidizing media (H2SO4, HNO3, ClO2)not usable PVC-U & PVC-C: oxidation, embrittlement, jointing by solvent cements favors accelerated corrosion, require FRP enforcement above 60C partially suitable material (see results in confidential attachment) Stainless Steel: strongly corrosion by spent acids not an alternative material Tantalum & Hastelloy: corrosion resistance depending on temperature, not resistant against reducing media (HF, HCl), (orbital) welding stresses EPDM, NBR & silicone (elastomers): not chemical resistant to oxidizing media not suitable materials * "Sulfuric acid is the single most widely used chemical in the world today": Source: U.S. Sulfur/Sulfuric Acid Market Analysis Supply/Demand and Pricing, June 2009, Nexant ** For metals see SiemensChemical-ResistanceChart.pdf (jaspereng.com) *** See ISO /DTR 10358:2020(E) Chemical resistance classification 13 For ECHA Annex XV Consulting only, 2023 Georg Fischer Piping Systems Ltd., All rights reserved Further technical alternatives for piping*** Not known GF v3.0 #8: Chemical Industry Sub-use: Metal Pickling (fabrication process of metals pickling process (removal of the oxidation layer on the metal surface) Subuse/ Chemical media Concentrated strong acids: HCl 35-37% HNO3 62%, HF 71-75% System needs/ Typical Operating Conditions Temperature: 40-85 C Pressure: 2-3 bar Acid mixtures: HNO3 10-22 wt% & HF 2-8% Metal ions (3060g/litre): Fe, Cr, Mn Plastic Piping Other used today** materials used ECTFE PVDF PFA Elastomers: PTFE FKM PE, PP, FRP PVC-U, PVC-C Elastomers: EPDM, NBR, Silicone Consequences of using other piping materials PE: corrosion by concentrated oxidizing acids (H2SO4, HNO3) and not suitable up to 85Cnot an alternative material PP: corrosion by concentrated oxidizing acids (H2SO4, HNO3) and by mixed acids not a suitable alternative PVC-U & PVC-C: embrittlement by mixed acids, jointing by solvent cements favors accelerated diffusion and corrosion, require FRP enforcement above 60C partially suitable material (see results in confidential attachment) Metals: strongly attacked by the pickling media --> not an alternative material EPDM, NBR & silicone (elastomers): not chemical resistant to oxidizing media not suitable materials Further technical alternatives for piping** Not known * For schematic drawing of the pickling plant and use of plastics for infrastructure please see confidential attachment **Following publications available on request (non-public research): 1. Report C2010-10 Corrosion properties of plastic materials in pickling plants (Swerea Kimab, 2010), 2. Investigation of the condition of PVDF piping used for 71-75% HF, HNO3 68% and HS2SO4 96% respectively after 20-30 years of service (Swerea Kimab, 2008) 3. Nearly 30 years in use and still going strong, GF Piping systems, March 31, 2009 14 For ECHA Annex XV Consulting only, 2023 Georg Fischer Piping Systems Ltd., All rights reserved GF v3.0 #8: Energy Sector Use Case: Connection of offshore wind farms with shore national grids via HVDC transmitters Sub-use Purified cooling water Operation conditions Temperatur e: up to 50C (in error case: 95C) Pressure: max. 5 bar Plastic Piping used today PVDF Other 3m&a4terials used PE, PEX, PP, PB Metals Elastomers: PTFE FKM Elastomers: EPDM, NBR, Silicone Consequences of using other piping materials Technical alternatives PE: not flame retardant, not suitable for excessive temperatures not an alternative PEX, PP, PB: not flame retardant, not pure enough not alternatives Metals: conductive materials not an alternative EPDM, NBR, Silicone (elastomers): not flame retardant, not high purity Not known PVDF loop for cooling 1&2 15 For ECHA Annex XV Consulting only, 2023 Georg Fischer Piping Systems Ltd., All rights reserved GF v3.0