Document XR9pBjQ4gzjvKBGzKnp7KOz5y

Ref. Ares(2024)2544971 - 08/04/2024 PFAS emissions during manufacturing of fluoropolymers (PTFE) Gujarat Fluorochemicals Limited 15th June 2023 Case study - PTFE emulsion polymerization PFAS are used as raw materials for following 2 functions: Intermediates & Processing aids Monomer (Tetrafluoroethylene) Intermediate substance that gets converted to PTFE. Unreacted TFE is recovered and reused in a continuous closed loop recycling process TFE according to OECD PFAS definition is not a PFAS Any accidental release of TFE leads to decomposition yielding carbonyl fluoride (COF2) that is further hydrolyzed in the presence of atmospheric water to form hydrogen fluoride (HF) and carbon dioxide (CO2)* Recycling is also important for manufacturers to improve the productioncost efficiency Modifier (Perfluoropropylvinyl Ether, PPVE) PTFE is modified to impart special properties reduced deformation under load, improved flexibility, lower porosity, lower permeability, good electrical and mechanical properties and better processing 25% of total commercially produced PTFE is chemically modified during polymerization; 0.050.1% of PPVE is incorporated in the PTFE polymer matrix; Approximately 1.5 times of PPVE is added to the reactor PPVE requirements for PTFE: 0.25 * 25000 tons * 0.001 * 1.5 = 9.375 tons per annum Around 70% is recovered for reuse and remaining is captured and destroyed using abatement * ECETOC JACC No. 42Tetrafluoroethylene (CAS No. 116143) Case study - PTFE emulsion polymerization As processing aids / surfactants Fluorosurfactants (FS) do not get consumed during polymerization Hundreds of tons of PFAS are intentionally used as polymerization aids leading to serious environmental pollution FS usage per ton = 310 kgs: For 25000 tons of fluoropolymers produced by emulsion polymerization: 75250 tons Manufacturing, Packaging, Storage and Transportation of FS are also contributing to PFAS emissions Raw materials to manufacture FS are also PFAS FS break down to low temperature volatile PFAS that are difficult to abate FS can be partially recovered and reused: GFL has been recycling 8085 % of FS for reuse Most fluoropolymers can now be produced without the use of FS Fluoropolymers should be exempted; instead, regulate fluorinated polymerization aids PTFE emulsion polymerization process chart Development of NonFluorinated Polymerization Aid (NFPA) Gujarat Fluorochemicals: GFL has developed NFPA technology to manufacture PTFE, PVDF, FKM, PFA GFL commits to completely stop the intentional use of PFAS as polymerization aids from 2024* Solvay: Working towards the objective of manufacturing nearly 100% of fluoropolymers without the use of fluorosurfactants in Spinetta Marengo, Italy by 2026** Goal is to phase out the use of fluorosurfactants globally Arkema: Voluntarily committed to manufacture its fluorinated polymers in PierreBnite without the use of fluorosurfactants by the end of 2024, as well as its other production sites around the world*** Honeywell: Voluntarily committed to completely stop using fluorosurfactants in their manufacturing processes * https://www.gfl.co.in/upload/pages/a6132d2292fc0ad3a9a0751dad818450.pdf ** https://www.solvay.com/en/innovation/sciencesolutions/pfas *** https://www.arkema.com/global/en/media/newslist/news/global/corporate/2023/20230221arkemapositiononeuropeanproposaltorestrictpfas/ NonFluorinated Polymerization Aid (NFPA) The NFPA used by GFL is an organic compound based on sulfonated hydrocarbon chemistry The specific NFPA substance is nonpersistent, nonbioaccumulative, nontoxic and nonmobile It is EU REACH registered and is not listed under Substance of very High Concern (SvHC) and Toxic Release Inventory (TRI) NFPA based fluoropolymers exhibit equal or even better properties/specifications NFPA can be used to manufacture High molecular weight fluoropolymers Modified fluoropolymers Copolymers and terpolymers A slight change in color may be noticed which is purely an aesthetic parameter and does not impact the performance PFAS as byproducts using NFPA technology Compatibility in terms of nonreactivity of hydrocarbon surfactants with monomers is critical to prevent formation of PFAS byproducts EU has proposed PFAS concentration limits of 250 ppb as sum of targeted PFAS analysis Fluoropolymers produced using GFL's NFPA have negligible PFASs measured using targeted analysis (LCMS/MS) There is no method or concentration limits defined for nontargeted PFAS analysis. GFL is confident to meet such requirements as and when they are notified By shifting to NFPA, annual EU PFAS exposure can be reduced to a maximum of 250 ppb * 50,000 tons of fluoropolymers = 12.5 kgs of PFAS Thank you