Document Rjaxd6VNZjB8dDL1ZE7eXG90V

September 22, 2023 Comments for Annex XV Restriction Report on the Manufacture, Placing on the Market and Use of PFASs; Evidence for Question 3: Emission in the EndofLife Phase. Submitted via the webform made available by the European Chemicals Agency at https://comments.echa.europa.eu/comments_cms/AnnexXVRestrictionDossier.aspx? RObjectId=0b0236e1885e69de This information is submitted on behalf of the American Chemistry Council's (ACC) Performance Fluoropolymer Partnership (hereafter "PFP"), whose members include the world's leading manufacturers, processors, and users of fluoropolymers, including fluoroplastics, fluoroelastomers and perfluoropolyether polymers.1 The PFP's mission is to promote the responsible production, use, and management of fluoropolymers. We invest in research to support our mission and inform a scientifically sound, riskbased approach to regulation. This submission provides an updated schedule to the data generation described in our submission on June 2, 2023 (ID# 9823e8c96f2f4973807d77dfcba3dc2b). Continued interest in rigorous sampling and analytical methods has led to refining benchscale reactor design in order to provide sufficient exhaust flow to enable PFAS detection limits on the order of 1 nanogram per dry standard cubic meter. The breadth of analytical results will provide important insights into the fate of fluoropolymers in municipal wastetoenergy plants and inform the need for regulatory action based on questions about the incineration of fluoropolymers at the end of their service life. The objectives of this study are: 1. Determine sampling and analytical techniques necessary to measure full mass balance on organic fluorine across a combustion system and achieve tracelevel detection limits for C4 C14 perfluorocarboxylic acids (PFCAs), C4 C12 perfluorosulfonic acids (PFSAs), and trifluoroacetic acid (TFA) at benchscale exhaust gas flow rates. 2. Identify, minimize, and monitor sources of external PFAS contamination. 3. Evaluate the generation of nonpolymer PFAS and other products of incomplete combustion from the combustion of commercial fluoropolymers under conditions representative of full scale municipal wastetoenergy plants in the EU and US. The PFP has developed the following timeline for achieving these objectives: No. Task 1 Design impinger system for efficient halide collection to enable benchscale mass balance determinations. 2 Develop experimental plan for operating bench-scale reactor system. 1 https://fluoropolymerpartnership.com/ 700 2nd Street, NE Washington, DC 20002, USA Completion Date 3 Nov 2023 1 Dec 2023 1 Performance Fluoropolymer Partnership Comments on Emission in End-of-Life --Annex XV Restriction Report I September 22, 2023 Page 2 of 2 3 Develop GC-MS method to determine Ci - C4 fluorocarbons in exhaust 5 Jan 2024 gas. 4 Share Quality Assurance Project Plan with USEPA technical staff for 2 Feb 2024 review. 5 Conduct process hazards review of design for integrated reactor system 1 Mar 2024 and revise system design based on results of review. 6 Revise Quality Assurance Project Plan based on feedback from USEPA. 15 Mar 2024 7 Characterize elemental composition and thermogravimetric behavior of 19 Apr 2024 fluoropolymer test material(s). 8 Test capability of key components of reactor system to meet design 3 May 2024 criteria for inherently safer operation. 9 Fabricate and assemble integrated bench-scale reactor system. 7 Jun 2024 10 Conduct preliminary testing to test stable operation of integrated 2 Aug 2024 bench-scale reactor system at conditions representative of full scale, perform calibrations, and develop detailed operating plans. 11 Demonstrate measurement capabilities of FTIR (HF, COF2, SiF4) and 16 Aug 2024 continuous gas analyzer (O2, CO2, CO, NOx). 12 Evaluate background PFAS and fluorine contamination of key 4 Oct 2024 components of integrated reactor system. 13 Assess fluorine transport efficiency across reactor system via mass 18 Oct 2024 balance. 14 Under conditions representative of full-scale municipal waste-to-energy 28 Feb 2025 plants in the EU and US, conduct fluoropolymer combustion experiments to determine levels of C4 - C14 PFCAs, C4 - C12 PFSAs, other Method 1633 analytes, TFA, C1- C4 fluorocarbons, and fluoride ion in exhaust gas. 15 Conduct independent review of experimental results to verify the data 28 Mar 2025 were generated in accordance with the Quality Assurance Project Plan, evaluate blanks to assess external contamination, and validate data quality. 16 Document experimental program methods, results, and conclusions in 23 May 2025 comprehensive report. 17 Review comprehensive study report with stakeholders. 20 June 2025 18 Submit final study report to European Chemicals Agency and USEPA. 11July 2025 Sincerely, Jay West Executive Director Performance Fluoropolymer Partnership AmericanChemistry.com 2 700 2nd Street, NE Washington, DC 20002, USA