Document d6j6xmb2KZxdDrbezKxE5kD5

== A r 5 . A == no ustna use o uoropo ymers in u tra i tration mem.ranes == Do ument == n.ustna u... == Til: restrictiePFAS ( E7 ), DE ( El ( El ), P1 ( El ), Toke Winther (M@mst.dk), E2 ( E2 ), P2 ( E3 ) Cc: P3 (WTS ( E4 ), P4 (WTS ( E5 ), P5 , P6 (WTS ( E6 ), P7 , P8 (WTS ( E7 ) Fra: P9 , P9 (WTS) ( E8 ) Titel: Industrial use of fluoropolymers in ultrafiltration membranes Sendt: 17-06-2022 22:47 Bilag: 2022 06 17 Suez Letter to EEA Members.pdf; Appendix A - Case Studies on PFAS Removal.pdf; Appendix B - Information on WTS PVDF membrane.pdf; Appendix C - Suez OF & MBR Installations.pdf; Appendix D - 2018 01 30 HENRY Polym of low concern.pdf; Appendix E - 2022 06 09 SUPPLIERS Polym of low concern.pdf; Dear Madam or Sir, Suez Water Technologies and Solutions (WTS) is a global provider of ultrafiltration membranes used for water and waste water treatment. We manufacture both fluoropolymer (PVDF) and poly ether sulfone (PES) hollow fiber membranes in our factory in Europe. In light of the ongoing review of regulations for PFAS compounds in the EEA, we have decided to reach out directly to provide the attached letter and supplemental documents to highlight the industrial use of these polymers for membrane filters and explain the importance related to the need for clean water and protection of the environment throughout the European community and the world. We hope the information provided will be useful in your assessment and we are available to answer any questions or provide further information if needed. We remain at your disposal. P9 , Ph.D., P. Eng. Til SUEZ Water Technologies & Solutions &DV, sues M + 1 T +1 T1 E8 www.suez.com 3239 Dundas St. W. I Oakville, ON, L6M 4B2, Canada The acquisition of SUEZ by Veolia has closed, as of January 18, 2022. The Water Technologies & Solutions business is now part of Veolia and operating under the conditions putforth by regional regulatory authorities. During this transition period, our business operations will continue as normal, independentfrom the rest of Veolia, and also independentfrom the newly created "New Suez". lIMICIESIMINEIEWNIIMIMIMMUISTIMIrraMIMMFAITHWATMMONTTWEIERMO"TZWEIEWOMMIIVAIMIgii &cc.. )O3sue2 Tuesday 7 June 2022 Mr. P1 - Netherlands Dr. P2 - Germany Ms. P3 - Sweden Mr. Toke Winther -- Denmark Mr. P4 - Norway Mr. P5 - ECHA P3 M @ M S t . d k E7 El El E2 E3 Water Technologies & Solutions 3600 Horizon Blvd Trevose, PA 19053 Dear Madam or Sir, Suez Water Technologies and Solutions (WTS) is a provider of ultrafiltration membranes made of fluoropolymer (PVDF), as well as Polyether Sulfone (PES). We supply our technologies to Water and Wastewater plant constructors and operators in Europe and the rest the world, who are like us, committed to healthier potable water, and water resource protection and sustainability through direct reuse for irrigation, industrial usages, and replenishment of our surface and ground waters. Suez WTS has also developed and introduced a range of removal and remediation technologies and services to address contamination of PFAS for industrial, military, and municipal sites as described in the Appendix A. This offer is unmatched in ability to be tailored to specific situations at the lowest possible capital and operating expenditure. We made the decision to contact you directly through this letter in order to provide an explanation of the criticality of both PES and PVDF filtration membranes for water and wastewater treatment which are both essential to our society. WTS manufactures membranes at our factory located in Europe (Hungary) and we are able to provide solutions for different applications and achieve the highest finished water purification, including eliminating pathogens (parasites, bacteria and viruses), micropollutants (such as pesticides, pharmaceuticals, personal care products (PCPs), endocrine disruptors (EDCs)) and microplastics. The WTS PES membrane is used for potable or industrial water production where source water contains low levels of solids and dissolved organic matter (e.g., ground water sources or low turbidity surface water). The WTS PVDF membrane is used for treating municipal sewage and industrial wastewaters and, increasingly, surface water bodies subject to runoff due to Climate Change. These impacted surface waters contain high levels of turbidity and pollutants. PVDF membranes have superior properties that allow them to be used in these challenging applications, whereas PES membranes are not suitable. For this reason, the water and wastewater industry relies on PVDF membranes for these critical applications and considers this polymer to be essential to sustaining a substantial install base of existing water and wastewater treatment plants and to meet the growing need for this advanced treatment solution across Europe and the rest of the world. Our PVDF membrane characteristics and applications are described in more details in the Appendix B. Our list of references can be found in the Appendix C, detailed by country and essential uses for water and wastewater treatments. WTS is aware of the concerns raised over certain PFAS compounds. For this reason, it is important for us to highlight the significant differences in the properties between PVDF which belongs to the "polymeric PFAS" group of compounds and the "non polymeric PFAS" type of compounds (e.g., PFOA and PFOS). PVDF has high molecular weight, is insoluble in water and is not able to penetrate human and animal cells. WTS is not aware of any issues raised in regard to the break-down of our PVDF membranes or PFAS compounds leaching from our PVDF membranes throughout our extensive installations of water and wastewater treatment plants. In summary, we see no risks associated with PVDF and to the contrary we see PVDF as necessary in the industrial use of membranes for water and wastewater treatment which is critical to public health and to protecting the environment. We attached in Appendix D and E two position papers that illustrate more in details the impact of both categories of PFAS and the distinction that should be made between the "Polymeric" and the "Non Polymeric". We are at your disposal for any questions that you may have before completing your evaluation on PFAS. You can contact: P6 , UF Commercial Leader in Europe, E4 P7 , UF and RO Global Technology Leader, E5 P8 , Ti1 , E6 Best regards, P9 Ti2 Global ZeeWeed Business P20 Attached Appendices: Appendix A: WTS brochure for PFAS remediation and removal, Appendix B: Information on WTS PVDF membrane applications, critical properties and impact of transitioning to a non-fluoropolymer alternative, Appendix C: WTS installed base in Europe of PVDF membranes, Appendix D: A critical review of the Application of Polymer of Low Concerns (Author: P10 - 30 January 2018), Appendix E: A critical review of the Application of Polymer of Low Concerns II (Author S.H Korzeniowski- 5 June 2022). 2 == AKT 5396341 == [ Industrial use of fluoropolymers in ultrafiltration membranes ] == Dokument 3 == [ Appendix A - C... == Water Technologies & Solutions Technical Paper PFAS removal in the United States Two Case Studies Compare Three Removal Technologies Background Companies in sectors as diverse as power generation, semiconductors, refining, chemical manufacture, consumer packaging, outdoor equipment, clothing, and flooring materials are grappling with the rapidly growing concern over the use, discharge, and remediation of Poly- and Perfluoroalkyl substances, known as PFAS. With the list of PFAS compounds growing continually, and with the list now numbering more than 4700 different species, the characterization, testing, removal, concentration and destruction challenges are multiplying in complexity. Fortunately, there is an answer to address and manage the complexity. Industry is increasingly turning to SUEZ - Water Technologies & Solutions, for assistance in mitigating the challenges of PFAS in their processes, wastewater, groundwater, and the local environment. SUEZ deploys its expertise in recognition, testing, characterization, pretreatment, concentration, removal, remediation, destruction and regulatory compliance. We are the one stop shop for any industrial, municipal or military organization, that is today grappling with the complex questions surrounding this increasingly recognized threat. Many companies are getting themselves "ahead of the curve." While the use and discharge into either a receiving body of water, or into the atmosphere, may not currently be regulated by the EPA, or subject to local or state Environmental limits, companies are nevertheless taking stock of their use and potential release mechanisms for various PFAS materials, including air emissions. Whether the original source is from an Industrial Process, Fire Fighting Foam, whether manufactured via Electrofluorination, or Telomerization, whether the material is an original PFAS or a so called NEW PFAS material (or a mixture), SUEZ has the answers for our customers today. In this paper, we share1 two recently introduced solutions for customers located in the United States. Figure 1 SUEZ responds immediately when you have a need, where you have a need, with the combination of technologies that you need, and at the flow rate required, anywhere in the world. Find a contact near you by visiting www.suezwatertechnologies.com and clicking on "Contact Us." *Trademark of SUEZ; may be registered in one or more countries. 2021 SUEZ. All rights reserved. TP1220EN.docx Apr-21 CASE STUDY #1 - PFAS Removal at a US Customer Site Challenge This customer faced a challenging mix of PFAS materials in their process water, resulting from both incoming source water and material aids needed in the process. The incoming challenge was thought to be a mix of PFCAs (perfluoro carboxylic acids) and PFSAs (perfluoro sulfonic acids). Upon testing, SUEZ identified PFOA (perfluorooctanoic acid), PFOS (perfluorooctane sulfonic acid), PFHpA (Perfluoroheptanoic acid), PFNA (Pefluorononanoic acid), and new PFAS compounds including PFPA (Perfluoro-2-propoxypropanoic acid), together with other interfering components including alcohols and hydrocarbons. Table 1 shows a partial list of the process parameters and water chemistry are shown below: Figure 2: SUEZ has extensive analytical laboratory capabilities globally Table 1: process parameters and water chemistry at customer site Desired flow rate 350 gpm Pressure 80 psi Temperature 70F P-Alkalinity 210 ppm as CaCO3 M-Alkalinity 330 ppm as CaCO3 Chlorides 120 ppm Sulfate 8 ppm Nitrate as NO3 11 ppm pH 9 Suspended solids <1 ppm Turbidity <1 NTUs TOC (ppm) <20 Aromatics Non-detect PFOA (perfluorooctanoic acid) 0.2 ug/L PFOS (perfluorooctane sulfonic acid, sulfonate) 1.2 ug/L PFHpA (Perfluoroheptanoic acid) 0.7 ug/L PFNA (Pefluorononanoic acid) 0.1 ug/L NEW PFAS compounds (total) 0.5 ug/L PFPA (Perfluoro-2-propoxypropanoic acid) 0.3 ug/L Other PFAS 0.2 ug/L Grand Total PFAS in water 2.9 ug/L Desired PFAS - treated product water 0.01ug/L SUEZ engineers modeled various removal and concentration mechanisms to arrive at the optimal solution. Three well known technologies available for PFAS removal include, but are not limited to, Reverse Osmosis, Carbon Adsorption, and Specialty Anion Exchange Resin. Some of the advantages and disadvantages of these technologies are shown in the summary table below: Page 2 TP1220EN.docxTP1220EN.docx Solution SUEZ evaluated alternative technologies to meet this customer's challenges Reverse osmosis (RO) - As one may surmise from the table, RO (figure 3) often has exceptional ability to remove PFAS materials. The molecular weights are typically above 200 Daltons, and furthermore, most PFAS materials are charged in normal aqueous solutions, having ionized one hydrogen (proton) from the carboxylic or sulfonic functional group. This ionization can be expected to be complete across the full range of normal pH encountered in ground, process, and waste water. In any case, since the pH in this situation is high (pH = 9) there is no concern that the PFAS materials were not fully ionized. Because of the molecular weight, the hydrophobicity of the molecule, and the charge, SUEZ determined RO would be able to remove the PFAS materials to greater than 99.9% - at least 3 logs of removal with a single pass membrane system. TP1220EN.docx In addition to this removal, the RO also removes a range of other contaminants, such as TOC, suspended solids, and ionic contamination, which would be helpful to the customer's process. While this would have been sufficient for the process involved at this customer, a second challenge presented itself. The RO--any RO--produces a waste stream that contains all the contaminants that do not pass through the membrane. Thus, all the PFAS materials would be concentrated into a stream of approximately 35 gpm, and this stream would have to be further treated to permanently remove the PFAS before discharge. While SUEZ makes RO systems that can achieve 90%+ recovery, the existence of this waste stream was deemed to be too complicated for the application. The customer wanted something simpler. Page 3 factors tilted the decision away from carbon in this case. First, a high removal efficiency for the benign `other' organics was found to be not necessary. Second, and more importantly, the use of carbon would have necessitated over 5 times the number of vessels, quantity of media, plus associated piping, space, pumping and monitoring, to achieve the same result. Figure 3: SUEZ proprietary membrane purification element and Membrane System. Capable of 3+ log removal of PFAS. Carbon Adsorption - The second solution considered was carbon adsorption (Figure 4). Carbon has been used from time immemorial, for purifying drinking water, process water, air, and a host of other process streams. Due to its vast surface area, and because of the attraction of van der Waals forces at the atomic level within granular carbon, the material is capable of removing a vast variety of contaminants from water, air and other streams. The advantage of carbon in this case, is that it can remove a lot of different contaminants, and is somewhat forgiving of particles and turbidity in the water. Carbon also attracts traditional organic molecules (molecules that contain lots of C-C bonds saturated with Hydrogen) very strongly, and with high capacity. In many cases, there are few alternatives for the use of carbon adsorption, as it may be difficult or impossible to find a suitable substitute. Unfortunately, PFAS is not a traditional organic molecule. It is purely man-made, never occurring in nature. The very name PFAS signifies the near or complete saturation of the Carbon bonds with Fluorine atoms, rather than with Hydrogen atoms, and this aspect renders the PFAS molecule much less readily attracted to carbon. Therefore, while carbon can adsorb some PFAS, both the kinetics and capacity of carbon suffer when compared to other removal materials. Nevertheless, since the customer's water contained other organics, and since organics normally would need to be removed in conjunction with PFAS removal, carbon was carefully considered, either for use by itself, or in conjunction with (upstream of) Specialty Ion Exchange resin. Two Page 4 Figure 4: Tanks at the Manufacturing Plant. Figure 5: Specialty Ion Exchange Resin Specialty Anion Exchange Resin - The third technology evaluated for the application was Specialty Anion Exchange Resin (Figure 5). Anion Exchange Resin has advantages and disadvantages, depending on the water matrix, the type of PFAS encountered, and the floor space available for equipment. Two exceptional advantages of resin are: The kinetics of resin removal are 5-8 times higher than those of Carbon. So the speed of removal is in the same order of magnitude as Reverse Osmosis. Not instantaneous, but fast. In general, an EBCT2 or Empty Bed Contact Time of approximately 1.5 to 3.0 minutes total, is needed for the removal of various PFAS materials to a level of non-detect (Non-detect is variously reported as around 1 - 5 ppt, or 0.001 - 0.005 ug/L). For comparison, Carbon might need an EBCT of TP1220EN.docxTP1220EN.docx 8-10 minutes (or more), also depending on the water matrix, and the type of PFAS encountered. For both carbon and resin, Carboxylic acids are not removed as well as sulfonic acids, and short chain PFAS such as butanoic (C4) are not removed as effectively as long chains such as nonanoic (C9). Since carbon does not rely upon ionic charge as a removal mechanism, it's kinetics are not as favorable as those for resin. The dual removal mechanism of resin (both ionic charge, and affinity/van der Waals) tends to give resin approximately 5-20 times as much mass loading capacity per cubic foot of media. The capacity sometimes allows resin to last longer before breakthrough of the offending PFAS compound. Typically, PFOA or another carboxylic will break through first, and especially so for shorter chain lengths. After evaluating all the choices at this customer, SUEZ engineers determined that the most cost-effective solution would be a two-pass container system with resin loaded into a lead lag configuration. Lead lag typically adds 30% to 50% to the capacity of a resin system compared to single pass, and thus is generally preferred for long term commitments (Figure 6). Figure 6: SUEZ proprietary multi vessel water purification system with interstage testing and automation control Results 1. Specialty Anion Exchange Resin, for broad range PFAS removal, was selected as the final choice. 2. The selected treatment train was a simple pumpvessel arrangement, with the two vessels able to exchange place readily in the lead - lag operation paradigm. 3. The resin was briefly backwashed to stratify the resin. This is not required but is recommended to maximize capacity. 4. The resin was then forward rinsed with approximately 100 to 500 bed volumes to equilibrate to the alkalinity, and anionic content of the feed. 5. PFAS-out Specification was met immediately. 6. PFAS testing was completed at least weekly for the first few months, then switched to monthly thereafter. 7. An uptick in testing frequency is planned toward the end of the expected run length minus 3 months. 8. When the lead vessel "breaks through", typically to a level of 30-40 ppt of PFAS, the lead vessel is emptied, refilled with new resin, and converted into the new lag vessel (with valves, not by vessel relocation). 9. The extracted used resin is put into super sacks, allowed to drain for 7 days to `drip dry' over an approved drain, then picked up by the vendor and incinerated at high temperature (accompanied by certificate). 10. The used resin is typically not considered hazardous unless chemically altered. The PFAS is bound strongly to the resin. 11. Meantime the former lag vessel, at that time typically has plenty of capacity left. 12. Thus, the former lag vessel is switched to the new lead position. 13. Each vessel holds 95 cubic feet of Specialty Anion Exchange Resin supplied by the industry leader in specialty resins. 14. The expected throughput for the water encountered, was estimated to be 150,000 Bed Volumes, which would equate to approximately 200-300 days of run time before vessel exchange, based on the customer's 70% - 80% expected up (running) time. 15. After several months of successful running time, the system continues to perform to expectation and is consistently reducing the PFAS-out to a level of <0.01 ug/L. 16. The customer is extremely happy with the result. TP1220EN.docx Page 5 CASE TWO--PFAS Removal at a Different Customer in the United States Challenge As before, this customer faced a mix of PFAS materials, together with many other components in the process water. In this case there were four significant PFAS compounds, some found to be already in the incoming feed water for the process (intake contamination), and some being added by the customer as a process aid. Part of the incoming challenge was thought to be a mix of PFCAs (perfluoro carboxylic acids) and PFSAs (perfluoro sulfonic acids). However, customer and SUEZ testing identified PFOS (perfluorooctane sulfonic acid), PFBA (Perfluorobutane sulfonic acid), PFHxA (Perfluorohexanoic acid), and PMPA (known variously as Perfluoro methoxy propanoic acid or Perfluoro-2methoxypropanoic acid) together with several potentially interfering fluorinated compounds, some of which are not PFAS. The main challenge for the customer was to reduce the volume of water that needs to be treated for safe disposal. This customer had been removing the waste from site, for treatment by incineration or other techniques. By substantially reducing the volume of treated water the customer was enabled to save over $1,000,000 per year in operating costs. Furthermore, the in-process water was able to be converted to PFAS free boiler feed water, thus reducing the water footprint of the facility by over 80%. This became a double win for the customer. Table 2 shows a partial list of the process parameters and water chemistry. Table 2: process parameters and water chemistry at customer site Desired flow rate 110 gpm Pressure 30 psi feed Temperature 65F Desired Recovery of Overall System 80% P-Alkalinity 4500 ppm as CaCO3 M-Alkalinity 6300 ppm as CaCO3 Sulfate 6630 ppm Sodium 6520 ppm TDS 17,335 ppm pH 9.6 Suspended solids 10 ppm Turbidity 5 NTUs TOC 550 ppm Various Alcohols (<C7) 150 ppm Aromatics Non-detect PFOS (Perfluorooctane sulfonic acid) 1.15 ug/L PFBA (Perfluorobutanoic acid) 0.12 ug/L PFHxA (Perfluorohexanoic acid) 0.50 ug/L PMPA (Perfluoro methoxy propanoic acid) 0.94 ug/L Grand Total PFAS in water 2.80 ug/L Desired PFAS - treated product water Non-detect Page 6 Solution As in Case One, SUEZ engineers evaluated the potential contribution of all three key technologies in the effort to treat the in-process water. It quickly became apparent that multiple technologies would likely be needed to meet the objective of non-detect for boiler water, together with 80% recovery of the process water. The solution was pilot tested for a period of months and proved to be feasible and cost effective. The best solution was a combination of all three SUEZ technologies: Membrane + Carbon + Ion Exchange, as shown in the "results" item 2, below. TP1220EN.docxTP1220EN.docx The challenge could be summarized by: 1. Suspended Solids removal 2. Concentration of PFAS into 20% of original water volume 3. Removal of residual organics from Membrane per- meate 4. Polishing of the 80% purified water to prepare it for boiler feed. After the successful pilot test the customer asked SUEZ to install a full-scale Mobile system to begin treatment immediately. The results have been excellent, and the customer is pleased. Results 1. A combined technology approach, for broad range PFAS removal, was selected as the final choice. 2. The selected treatment train is SUEZ FiltrationSUEZ Membrane pass 1SUEZ Membrane pass 2Carbon AdsorptionIon Exchange Polish 3. The first SUEZ Membrane is for high TDS applications. The second is for polishing the permeate further. Each of the 2 membrane passes, reduces PFAS concentration in the permeate by at least 3 logs of reduction, so that the product is below the detection limit. 4. The standard ion exchange resin was then able to produce 0.06 micro-Siemen water for boiler feed. 5. PFAS-out and boiler feed Specifications were met within the first week as the system stabilized. 6. Periodic PFAS testing and other parameter testing was planned and implemented. 7. Membranes will be tested at the end of the engagement to ensure there is no "cycling up" or concentration of PFAS in the membrane. None is expected. 8. The ion exchange resin is not being relied upon to remove any PFAS since the two Membrane passes have already achieved that objective. Thus, the resin is standard, rather than specialty resin. 9. The 80% recovery objective was met, saving water, and the concentration of waste to a 20% volume was also met. 10. The customer is very happy with the result. Overall Summary SUEZ leads in the technology of PFAS contamination removal and remediation, drinking water treatment, waste water treatment, plant operation and maintenance, sludge waste management, and many other aspects of water resource management. In these two case studies we reviewed the solutions for two challenging in-process PFAS control, concentration, and removal issues. In the first case, after a thorough technical comparison, it turned out that a simple 2 vessel, specialty resin-based solution in the lead lag configuration proved to be the most effective and economic solution. It was implemented within a matter of weeks, and the client is delighted with the result. In the second Case Study, a more complex challenge presented itself. SUEZ designed and installed a system to a) treat 110 gpm of waste water, b) remove PFAS from the waste water, c) concentrate the PFAS waste water to 20% of the original volume, d) achieve non-detect PFAS in the Membrane permeate, e) polish the permeate with Ion exchange, and f) recycle the 80% to the boiler. This solution saved the customer more than $1,000,000/year after treatment costs were factored in. Figure 7: SUEZ offers systems from 5 gpm up to 5000 gpm and beyond. Fully Mobile, ready for immediate emergency deployment. TP1220EN.docx Page 7 SUEZ Difference When you engage with SUEZ, we will start with testing your water streams, perform a mass balance, evaluate your discharge conditions, understand and master your regulatory framework, measure your economics, consider local and national "headline risks", and provide you the best, tailored, overall solution. We may use technologies including Ion Exchange, Carbon Adsorption, Reverse Osmosis, along with pretreatment including Clarification, Ultrafiltration, Media Filtration; as well as concentration technologies such as thermal/crystallization/zero liquid discharge, along with Laboratory and on-site Water Analysis, among many other services. Understanding of the special needs of Industrial, Municipal, Military and Firefighting use cases, for remediation, process treatment, drinking water, discharge, regulatory knowledge, solids management, and PFAS destruction. As an owner or operator of dozens of municipal and private drinking water systems, municipal drinking and wastewater systems, and solid waste handling or treatment facilities, SUEZ knows your challenge from the perspective of the owner/operator--in other words, from your perspective. Our own operations specialists are available to help with your needs. SUEZ serves over 450,000 industrial and business customers globally, generates over $17Bn in annual sales, invests over $120M per year in research and development in 17 R&D centers, located throughout the world, and has been granted over 3,200 patents. We serve the entire range of Industrial, Municipal and firefighting site applications, with over 90,000 employees worldwide. SUEZ is the world leader in Total Organic Carbon Analysis with our TOC Analytical instruments, in Remote Monitoring and Diagnostics with our InSight Cloud Based Reporting, and in Analytical Testing with our many laboratories located around the world. With over 80 years in the water business, SUEZ is your best available partner to address your PFAS treatment needs. Figure 8: InSight* Remote Monitoring and Diagnostics with Cloud Based Analytics Package. Results available 24/7/365. 1 NOTE: Details and figures in the case studies included have been altered or blended between various SUEZ locations, to maintain confidentiality, while preserving valid conclusions regarding technical solutions. 2 EBCT means the amount of time the flowing water remains in contact with the bed of resin or carbon through which it is flowing. It does not refer to the interstitial space, which is why it is called EMPTY bed contact time. For example, a flow of 100 gallons per minute through a bed of 300 gallons (40 cubic feet) of media (carbon or resin) would take 3 minutes. This would equate to an EBCT of 3 minutes. Page 8 TP1220EN.docxTP1220EN.docx == AKT 5396341 == [ Industrial use of fluoropolymers in ultrafiltration membranes ] == Dokument 4 == [ Appendix B - I... == Appendix B Information on WTS PVDF membrane applications, critical properties and impact of transitioning to a non fluoropolymer alternative 1. Applications where WTS PVDF membranes are used Case # Application Case 1 Filtering water for Drinking water quality with Ultrafiltration membranes (outsidein hollow fiber type) Case 2 Filtering water of industrial quality with Ultrafiltration membranes (outsidein hollow fiber type) Case 3 Filtering biologically treated wastewater with Ultrafiltration membranes (outsidein hollow fiber type) for discharge in surface water bodies, for replenishing depleted groundwaters, or for agricultural or industrial use. Industries involved Municipal drinking water plants Industrial water treatment plants Industrial and municipal wastewater treatment plants 2. Technical properties of PVDF critical to the applications Case 1 Category Technical property Mechanical strength Relevant to application Y Specification & Measurement standard Tensile strength >45 MPa (ASTM D638 Wear resistance Durability Mechanical properties (e.g., flexibility) Inertness - stability Low coefficient of friction Resistance to harsh chemicals Y >10 years accelerated test (Suez standard test) Y Elongation at yield > 25% (ASTM D638); Tensile modulus <2200 MPa (ASTM D638) Y 1,000,000 ppmhrs NaOCl exposure for membrane cleaning (NaOCl is a critical 1 chemical used for removing organic constituents and disinfection Resistance to high temperatures Resistance to low temperatures (e.g., cryogenic properties < 50C) Wide temperature range of operation Weather resistance Biocompatibility High limiting oxygen index Electrical insulator (high data transmission range) Ionic conductivity Piezoelectric properties Dielectric strength Barrier properties Functionality Nonstick properties Y Resistance to fouling by organic constituents present in surface waters Optical clarity Fire retardancy / smoke suppression Low bacterial / algae growth Low refractive index for optical effects Other (please specify): Case 2 Category Durability Technical property Mechanical strength Relevant to application Y Specification & Measurement standard Tensile strength >45 MPa (ASTM D638 2 Wear resistance Y >10 years accelerated test (Suez standard test) Mechanical properties (e.g., flexibility) Low coefficient of friction Y Elongation at yield > 25% (ASTM D638); Tensile modulus <2200 MPa (ASTM Resistance to harsh chemicals Inertness - stability Resistance to high temperatures Y 1,000,000 ppmhrs NaOCl exposure for membrane cleaning (NaOCl is a critical chemical used for removing organic constituents and disinfection Resistance to low temperatures (e.g., cryogenic properties < 50C) Wide temperature range of operation Weather resistance Biocompatibility High limiting oxygen index Electrical insulator (high data transmission range) Ionic conductivity Piezoelectric properties Dielectric strength Functionality Barrier properties Nonstick properties Y Resistance to fouling by organic constituents present in surface waters and in wastewater Optical clarity Fire retardancy / smoke suppression 3 Low bacterial / algae growth Low refractive index for optical effects Other (please specify): Case 3 Category Durability Technical property Mechanical strength Wear resistance Mechanical properties (e.g., flexibility) Low coefficient of friction Resistance to harsh chemicals Inertness - stability Functionality Resistance to high temperatures Resistance to low temperatures (e.g., cryogenic properties < 50C) Wide temperature range of operation Weather resistance Biocompatibility High limiting oxygen index Electrical insulator (high data transmission range) Ionic conductivity Piezoelectric properties Relevant to application Y Y Y Specification & Measurement standard Tensile strength >45 MPa (ASTM D638 >10 years accelerated test (Suez standard test) Elongation at yield > 25% (ASTM D638); Tensile modulus <2200 MPa (ASTM Y 1,000,000 ppmhrs NaOCl exposure for membrane cleaning (NaOCl is a critical chemical used for removing organic constituents and disinfection 4 Dielectric strength Barrier properties Nonstick properties Optical clarity Fire retardancy / smoke suppression Low bacterial / algae growth Low refractive index for optical effects Other (please specify): Y Resistance to fouling by organic constituents present in wastewater 3. List of potential nonfluoropolymer alternatives (second best alternatives) for each application Case # Potential alternatives to fluoropolymers that could be considered as alternatives Case 1 Polyether sulfone (PES) Case 2 Polyether sulfone (PES) Case 3 None 4. Possible tradeoffs that could be expected when alternatives to fluoropolymers are used in these applications Case 1 Criteria With Fluoropolymer With nonfluorinated alternatives Amount of product used: 75100 tonnes/year 75100 tonnes/year Property comparison: Tensile strength >45 MPa Elongation at yield 25% Tensile modulus 2200 MPa Tensile strength >45 MPa Elongation at yield 6.5% Tensile modulus 2700 MPa NaOCl resistance >1,000,000 ppmhrs NaOCl resistance <250,000 ppmhrs Combination of functionalities PES based outsidein hollow fiber membrane is less flexible resulting in lower 5 Overall performance Safety & Reliability Application life Circularity Suez uses PVDF free from PFAS processing aids. No low molecular weight PFAS compounds have been measured in the manufacturing of the membranes. 1520 years Suez is working with our PVDF supplier to develop a recovery and recycling program for membranes. efficiency (less flow per sqm of membrane area) and is therefore less competitive compared with PVDF based membranes. Furthermore, due to the lower chemical resistance, the PES membrane will undergo embrittlement during the product life, resulting in broken fibers and reduced life expectancy. Reduced product performance (flow per sqm of membrane) and reduced life expectancy will make the Suez outsidein hollow fiber membrane noncompetitive in the global market. NonEU suppliers of outsidein hollow fiber membranes will continue to use PVDF. 100% of Suez membranes are produced in EU. 57 years (represents more cost and more raw materials due to more frequent replacement) 6 Decarbonisation (Eco)toxicity comparison Other (please describe): Case 2 Criteria Reduce carbon footprint through recycling of PVDF. Fluoropolymers including PVDF have thermal, chemical, photochemical, hydrolytic, oxidative and biological stability. They have negligible residual monomer and oligomer content and low to no leachables. Fluoropolymers are practically insoluble in water and not subject to long range transport. With a molecular weight well over 100,000 Da, fluoropolymers cannot cross the cell membrane. Fluoropolymers are not bioavailable or bioaccumulative. (Henry, Barbara J., Joseph P. Carlin, Jon A. Hammerschmidt, Robert Buck, L. William Buxton, Heidelore Fiedler, Jennifer Seed, and Oscar Hernandez. 2018. A Critical Review of the Application of Polymer of Low Concern and Regulatory Criteria to Fluoropolymers. Vol. 14.) Suez is currently carrying out a study on aged membranes (collected from customer sites) to provide further evidence that no PFAS compounds will leach from the membranes over the longterm. With Fluoropolymer With nonfluorinated alternatives 7 Amount of product used: Property comparison: Combination of functionalities Overall performance Safety & Reliability 75 100 tonnes/year Tensile strength >45 MPa Elongation at yield 25% Tensile modulus 2200 MPa NaOCl resistance >1,000,000 ppmhrs Suez uses PVDF free from PFAS processing aids. No low molecular weight PFAS compounds have been measured in the manufacturing of the membranes. 75 100 tonnes/year Tensile strength >45 MPa Elongation at yield 6.5% Tensile modulus 2700 MPa NaOCl resistance <250,000 ppmhrs PES based outsidein hollow fiber membrane is less flexible resulting in lower efficiency (less flow per sqm of membrane area) and is therefore less competitive compared with PVDF based membranes. Furthermore, due to the lower chemical resistance, the PES membrane will undergo embrittlement during the product life, resulting in broken fibers and reduced life expectancy. Reduced product performance (flow per sqm of membrane) and reduced life expectancy will make the Suez outsidein hollow fiber membrane noncompetitive in the global market. NonEU suppliers of outsidein hollow fiber membranes will continue to use PVDF. 100% of Suez membranes are produced in EU. 8 Application life Circularity Decarbonisation (Eco)toxicity comparison 1520 years Suez is working with our PVDF supplier to develop a recovery and recycling program for membranes. Reduce carbon footprint through recycling of PVDF. Fluoropolymers including PVDF have thermal, chemical, photochemical, hydrolytic, oxidative and biological stability. They have negligible residual monomer and oligomer content and low to no leachables. Fluoropolymers are practically insoluble in water and not subject to long range transport. With a molecular weight well over 100,000 Da, fluoropolymers cannot cross the cell membrane. Fluoropolymers are not bioavailable or bioaccumulative. (Henry, Barbara J., Joseph P. Carlin, Jon A. Hammerschmidt, Robert Buck, L. William Buxton, Heidelore Fiedler, Jennifer Seed, and Oscar Hernandez. 2018. A Critical Review of the Application of Polymer of Low Concern and Regulatory Criteria to Fluoropolymers. Vol. 14.) Suez is currently carrying out a study on aged membranes (collected from customer sites) to provide further evidence that no PFAS compounds will leach 5 - 7 years (represents more cost and more raw materials due to more frequent replacement) 9 Other (please describe): from the membranes over the longterm. Case 3 Criteria Amount of product used: Property comparison: Combination of functionalities Overall performance Safety & Reliability Application life Circularity Decarbonisation (Eco)toxicity comparison Other (please describe): With Fluoropolymer 150- 200 tonnes/year Same comments as case 1 and 2 Same comments as case 1 and 2 Same comments as case 1 and 2 Same comments as case 1 and 2 Same comments as case 1 and 2 Same comments as case 1 and 2 Same comments as case 1 and 2 Same comments as case 1 and 2 Same comments as case 1 and 2 With nonfluorinated alternatives No known alternative No known alternative No known alternative No known alternative No known alternative No known alternative No known alternative No known alternative No known alternative No known alternative 5. In case that fluoropolymers were not available for use in the EEA what would happen in these applications? Case 1 If the use of PVDF is prohibited, we will have to stop the entire business for wastewater treatment because there is no alternative polymer for the application (Case 3). Without the wastewater market (largest and strongest market), our manufacturing plant located within the boundaries of the EEA will no longer be viable. If the use of PVDF is prohibited for drinking water only, Suez would have to evaluate whether there is a 10 Case 2 Case 3 business case for a PES based outsidein hollow fiber membrane for use in municipal drinking water and industrial water applications since the properties of this membrane would be inferior to PVDF based membranes. Suez would not be competitive in global markets where nonEU membrane manufacturers could continue to supply PVDF membranes. 100% of Suez membranes are produced in the EU. See above. See above. 6. Expected socioeconomic impact if fluoropolymers were no longer available for these applications Case 1 Economic impacts: Societal impacts: The PES membrane alternatives for Case 1 require engineering studies and equipment changes to make PES membranes work. Because the solutions using PES membranes will be more complex with additional treatment steps, the cost is expected to be 100's millions euro for making the necessary retrofits. Additionally future membrane treatment plants will also be much more expensive to construct if PVDF membranes are no longer available. As a general statement. Suez's perspective is that PVDF Membrane filtration should fall under Industrial use in the category of ENVIRONMENT and Health rather than a Textile category. PVDF filtration membranes are used in the treatment of water and wastewater and are critical to public health and protecting the environment. PVDF filtration membranes are used to filter out contaminants such as pathogens (parasites, bacteria and viruses), micropollutants (such as pesticides, pharmaceuticals, personal care products (PCPs), endocrine disruptors (EDCs)) and microplastics for drinking water production. Without this technology, more complex and expensive solutions will have to be employed to provide removal of these contaminants. For many of the more challenging surface water sources impacted by increasing weather events brought on by climate change, good alternative solutions do not exist. Case 2 Economic impacts: Societal impacts: Same as Case 1 Same as Case 1 Case 3 11 Economic impacts: An alternative for case 3 does not exist. This means that customers in Europe and globally who have used the technology for up to 2 decades would not be able to obtain replacement membranes for existing municipal and industrial wastewater treatment plants. They would need to go back to conventional concrete clarifiers that would not fit the requirements in term of footprint and not provide the barrier to pathogens and other contaminants previously mentioned. This would result in disruptions and 100's millions euro to retrofit to alternative treatment solutions. In some cases this would mean constructing completely new plants in alternative locations due to existing footprint constraints. Additionally, future wastewater treatment needs would have to be met with more expensive solutions. Since the annual MBR market is estimated at around five Billion , solutions costing 50100% more would result in 2.55 Billion /year additional investment to meet future wastewater treatment needs. For Suez only (not considering the other producers of membranes or subsuppliers), 1000 jobs would be lost in Hungary, including high level manufacturing, engineering and R&D jobs. Another 500800 jobs could be lost in other functions within the EEA countries (sales, project engineering, field service, planning, logistics, etc.). The revenue loss for Suez from membrane sales alone would be 250 350 Million /y. 12 7. Additional information 1. It is critical to distinguish the two types of hollow fiber ultrafiltration membranes: inside out type and outsidein type. For insideout hollow fiber membranes, the feed water is fed to the inside bore of the hollow fiber and the clean water passes through the polymer matrix (the separation barrier) to the outside of the hollow fiber. This type of membrane is used on easier to treat applications (e.g., post treatment of potable water, low turbidity surface water). For insideout hollow fiber membranes, poly ether sulfone can be used effectively. For outsidein hollow fiber membranes, dirty water is on the outside of the hollow fiber and the clean water is collected from the inside of the hollow fiber. Outsidein hollow fiber membranes are used on higher solids and more fouling feed waters (e.g., industrial applications, wastewater treatment, high turbidity surface water). Due to the challenging applications, outsidein hollow fiber membranes are subjected to more aggressive cleaning, including agitation with air scouring and use of high concentrations of cleaning chemicals (e.g., sodium hypochlorite and acids). For these reasons, outsidein hollow fiber membranes are almost exclusively made from PVDF (~100% the case for outsidein membranes used to treat wastewater). Suez makes both insideout (PES based) and outsidein (PVDF) hollow fiber membranes. However, 90% of the membrane applications require the robust outsidein (PVDF) type hollow fiber. (External references: https://www.thembrsite.com/blog/choosingmbrmembranematerials/) 2. Suez uses only PVDF produced without fluorinated processing aids. Suez has confirmed the absence of low molecular weight PFAS compounds in the manufacturing of our membranes. 3. Due to the economic value of PVDF and interest in sustainability, Suez has been actively involved with our supplier of PVDF looking at the potential for recycling end of life membranes. Although this is an early stage initiative, we see a strong potential for recovery and recycling of used PVDF to be used in membranes and other applications employing PVDF. Since industrial and municipal endusers typically have 100's - 1000's of membrane modules and maintain ongoing connection to the Suez Aftermarket organization, we would anticipate a high recovery potential compared with other industries (e.g., consumer type products). 4. Suez PVDF membranes have been rigorously tested and meet drinking water standards throughout the world. Certifications include: NSF 61, NSF 419, KTW (Germany), KIWA (Netherlands), ACS (France), DWI (UK), ICIM (Italy), Hungary, Poland, Czech, MOH (China), KWWA (Korea). Additional references: https://www.fpp4eu.eu/case-studies/multifunctional-membrane/; https://www.arkema.com/global/fr/resources/post/kynar-pvdf-membrane-ultrafiltrationof-toulouse-wastewater/; https://hpp.arkema.com/en/markets-and-applications/waterand-environment/water-filtration-membranes/ 13 == AKT 5396341 == [ Industrial use of fluoropolymers in ultrafiltration membranes ] == Dokument 5 == [ Appendix C - Suez UF & MBR Installations ] == Suez UF & MBR Installations As of 2022  Above is all installs in the globe 3233 total installs 1515 Case 1 and 2 (Muni/ind Water) 1718 Case 3 (MBR) Aktdetaljer Akttitel: PFA Restriction Proposal Aktnummer: 18 Sagsnummer: 2020 - 15422 Akt-ID: 3826794 Dato: 06-10-2021 11:16:12 Type: Indgende Dokumenter: [1] PFA Restriction Proposal.eml (MEDTAGES IKKE) [2] 20211006_mcp engineering plastics.pdf Den 12. juli 2024