Document jx3Rp7MZmLXyNg4dkk3gVZnQ
Sectors and (sub-)uses
About caprolactam Caprolactam is the precursor for the polymer nylon-6. Nylon polymers have significant commercial applications in fabric and fibers (apparel, flooring and rubber reinforcement), in shapes (molded parts for cars, electrical equipment, etc.), and in films (mostly for food packaging to provide an oxygen barrier).
About FIBRANT Our story begins in 1952, when we commissioned our first factory for the production of Caprolactam in The Netherlands. Nowadays, Fibrant is part of HSCC (also known as Highsun Group China). This makes our group the largest Caprolactam and Ammonium Sulfate producer in the world with production facilities in The Netherlands (Geleen) and China (Fuzhou and Nanjing). From our headquarters in the chemical heart of the Netherlands, Fibrant aims to be the undisputed market leader in Caprolactam, Cyclohexanone and Ammonium Sulfate. EcoLactam is our new and extraordinary generation of products with a world class carbon footprint(CFP). Fibrant serves via her valued business partners the majority of all textile, automotive, food packaging, and agricultural value chains. All relying on Fibrant's high-quality and sustainable products. In the Netherlands Fibrant employs a staff of 350 employees, located at the head office in Urmond and the Chemelot-site in Geleen. Fibrant stands for `pure chemistry' which not only refers to setting the benchmark in sustainable products and innovation but also to the chemistry among employees and business partners.
Our transformation towards climate neutral 2040 EcoLactam is Fibrant's sustainable Caprolactam with a world class carbon footprint (CFP) of 3.3 (expressed in kg CO2-eq/kg Caprolactam) achieved by continuous process improvement. (Carbon footprint data of our products are the result of a calculation model certified by an independent authority and is based on primary data for scope 1 & 2 and some scope 3 emissions. Where primary data for scope 3 emissions are not available generic data from external databases are used.) With this new and extraordinary generation of products, we reduced our CFP by over 50%. This is accomplished via significant N2O emission and energy consumption reductions and by applying our proprietary HPO and Hydranone technology, while keeping the excellent performance and quality at the same high level. Together with our suppliers we will continue to reduce the (in)direct environmental impact. As of 2022 the use of green electricity is implemented in our production process, this will lead to further reduction of our carbon footprint.
Technological improvements Our new generation Ammonium Sulfate plant effectively uses the residual heat from our Caprolactam process. This reduces energy consumption by no less than 80%. Having successfully implemented the reduction of our N2O emissions, the environmental impact of the production of EcoLactam is over 50% lower than the European average and amongst one of the lowest in the world.
Figure 1: carbon footprint example (case: nylon shirt)
Chemicals overview Typical chemicals in the manufacturing process of caprolactam are
sulfur sulfuric acid sulfur dioxide sulfur trioxide (oleum, fumic acid) nitric acid phosphoric acid ammonia ammonia nitrate/nitrite/ammonia sulfate hydroxylamine carbon dioxide nitrogen oxide/nitrogen dioxide phenol benzene toluene cyclohexanone cyclohexanone oxime cyclohexanol
Fluoroplastics (i.e., PTFE, PFA, ...) are the only plastics that combine both the broadest chemical resistance with the highest operating temperature with an acceptable compliance to counter surface and therefore are used when other alternative plastics cannot offer the required chemical & thermal resistance combination for industrial applications.
3 references are given of chemical resistances of different materials used in all kinds of sealings and other uses in the chemical industry, like pipe/valve/instrumentation linings, rupture disks, compensators, gaskets, O-rings and full body inserts, manifolds and pipings. Emerson's technical datasheet of RosemountTM Magnetic Flow Meter Material Selection Guide Chemical Compatibility Chart - LDPE, HDPE, PP, Teflon Resistance (calpaclab.com) Design and Manufacturing of Micro-Turbomachinery Components with Application of Heat
Resistant Plastics (researchgate.net)
Reference 1
Technical Data Sheet: Rosemount Magnetic Flow Meter Material Selection Guide (emerson.com) Emerson's technical datasheet of RosemountTM Magnetic Flow Meter Material Selection Guide includes the chemical resistances of the materials used in flow meters. These are typical materials that are also used in pipe linings and flange gaskets or full body applications.
Sodium Hydroxide
5%
Al
Al N
N
Al Al
N
A
A
Sodium
10% Al
A3
Al AS
A3
A4
Al Al
N
A
A3
Hydroxide
Sodium Hydroxide
25% A
A
N
N
Al Al
N
A
A
Sodium
30% Al
A2
Al AS
A3
A4
A3 Al
N
A
A3
Hydroxide
Sodium
40% A
A
Hydroxide
A3 A2
N
A
A
Sodium
SO% Al
A2
Al AS
Al
A4
B
A2
N
A
AS
Hydroxide
Sulfur Dioxide 100% Al
A2
Al
(Wet)
N
N
84 A4
81
Al
N
Sulfur Trioxide 100% Al
AS
Al
N
A4
81 81
N
N
Sulfuric Acid
10% Al
Al
Al N
A3
A4
N A3
Al
Al
N
Sulfuric Acid
30% Al
Al
Al N
A3
A4
N AS
Al
Al
N
Sulfuric Acid
SO% Al
Al
Al N
A3
AS
N
AS
Al
Al
N
Sulfuric Acid
60% Al
Al
Al N
A3
N
N
Al
Al
Al
N
'sulfuric Acid
70% Al
Al
Al N
A3
N
N
83
Al
Al
N
'sulfuric Acid
80% Al
Al
Al N
N
N
BS AS
Al
Al
N
'sulfuric Acid
90% Al
Al
Al N
N
N
BS A4
Al
Al
'sulfuric Acid
95% Al
Al
Al N
N
N
B3 A4
Al
Al
'sulfuric Acid
98% Al
Al
Al N
N
N
B3 AS
Al
Al
N
'sulfuric Acid
100% Al
Al
Al N
N
N
B3 AS
N
N
Sulfuric Acid
100% Al
AS
Al
N
(Fuming)
AS 85
N
Al
N
Sulfurous Acid 100% Al
A2
Al N
N
N
AS 81
Al
A2
A4
Toluene
100% Al
Al
Al N
N
N
Al A3
Al
A2
A3
`
Reference 2 Chemical Compatibility Chart - LDPE, HDPE, PP, Teflon Resistance (calpaclab.com)
Reference 3
(PDF) Design and Manufacturing of Micro-Turbomachinery Components with Application of Heat
Resistant Plastics (researchgate.net)
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Environmental emissions Fluoropolymers are harmless in their use and have no emissions themselves during their use in the manufacture of caprolactam. They do, however, prevent emissions of acids used in the manufacturing process of caprolactam, simply because alternatives do not exist and would fail in use within weeks to months. Thus fluoropolymers contribute significantly to environmental protection and safety of personnel.
We have approached our suppliers for possible alternatives. Alle of them have replied by stating that they do not have alternatives; not now and not even in the 5 or even 12 years to come (see also the attached European Sealing Association (ESA) position statement relative to the European proposal for PFAS regulation in relation with the Sealing Industry).
Banning the use of fluoropolymers articles and the use of low molecular weight PFAS intermediates at the fluoroplastic manufacturing locations would step the science of sealing backward to the 1950s timeframe (even before the start of the industrial manufacturing of caprolactam) when asbestoscontaining alternatives, which have been banned before, were used. The leakage rate of acids like sulfuric acid, phosphoric acid, hydroxylamine and nitric acid would increase strongly. This means that the safety of the operators in the caprolactam plants will become at risk.
Fibrant asks that the use PFAS fluoropolymer (Fluoroplastic & Fluoroelastomer) materials in the caprolactam manufacturing process are exempted from the proposed regulation until sealing manufacturers have found suitable alternatives. It is important to note that because fluoropolymers are manufactured using low molecular monomers and short chain intermediates. PFAS monomer feedstock must continue to be allowed for manufacturing with use controls, if appropriate, put in place. Fibrant is assured that there is no other chemistry available to replace the performance that Fluoropolymers provide for chemical, thermal, plasma and radioactive resistance as seals in the manufacture of caprolactam. By definition any chemical that could withstand those situations would also be considered persistent. A ban, or a class regulation, of polymeric PFAS materials and their raw materials will have a profound impact on the viability of Fibrant B.V. as the plants will not be able to run continuously anymore as leakages will have to be repaired. Expectation is that with the corrosive nature of acids the plants will have to be stopped every few weeks to few months for repairs. Per stop-repair-start this is likely to lead to operational efficiencies will drop by more than 10% (assumed 1 week per 2 months). This will drop the financial efficiency of a continuously operating plant as caprolactam to below feasible.
Please note that if suitable alternative materials for gaskets, etc would exist now or in the foreseeable future, Fibrant would not have asked for derogation or exemption.
Fibrant also uses a PFAS containing foam forming agent in emergency response situations and is in the process of replacing the current foam forming agent by available PFAS-free alternatives.
Annual usage
Fibrant B.V. comprises of 7 chemical plants with approximately 15000 flange-pairs in pipelines, instrumentation and equipment; mostly stainless steel, but there are also some carbon steel sections. Approximately 60% of these are in acid service. On a yearly basis approximately 3% of the equipment
is opened for inspections. This means that approximately 1200 fluoropolymer gaskets need to be replaced to ensure the leak-tightness of the connections.
Next to that, within Fibrant over 3000 instruments (especially manual and automated valves, flow measurements, analyzers and pressure measurements) hold fluoropolymer containing components, like O-rings and lining to provide sealing. Yearly approximately 100 are replaced by newer ones and approximately 100 are maintained off-line. Approximately 60% of these are in acid service. This means that an additional 200 fluoropolymer gaskets need to be replaced to ensure the leak-tightness of the connections.
Missing uses
a. Fibrant B.V. comprises of 7 chemical plants with approximately 15000 flange-pairs in pipelines, instrumentation and equipment; mostly stainless steel, but there are also some carbon steel sections. Approximately 60% of these are in acid service. On a yearly basis approximately 3% of the equipment is opened for inspections. This means that approximately 1200 fluoropolymer gaskets need to be replaced to ensure the leak-tightness of the connections. Next to that, within Fibrant over 3000 instruments (especially manual and automated valves, flow measurements, analyzers and pressure measurements) hold fluoropolymer containing components, like O-rings and lining to provide sealing. Yearly approximately 100 are replaced by newer ones and approximately 100 are maintained off-line. Approximately 60% of these are in acid service. This means that an additional 200 fluoropolymer gaskets need to be replaced to ensure the leak-tightness of the connections.
b. Key functionalities provided by PFAS are all kinds of sealings and other uses in the chemical industry in general and caprolactam in specific, like pipe/valve/instrumentation linings, rupture disks, compensators, gaskets, O-rings and full body inserts, manifolds and pipings.
c. In general the whole chemical industry dealing with acids is affected by the restriction. d. Fibrant is not aware of any alternatives other than the already banned asbestos. Our known
suppliers are grouped together in the European Sealing Association (ESA), who has made a position statement relative to the European proposal for PFAS regulation in relation with the Sealing Industry. The summary of their statement is following:
Linked to the high strength of the Carbon-Fluorine (C-F) bond, fluoropolymers (fluoroplastics and fluoroelastomers) uniquely offer chemical inertness vs aggressive media with thermal stability.
Many applications are enabled in our everyday life thanks to the use of fluoropolymers:
Reduction of engine emissions both for planes (Increased efficiency allowed by higher operating temperature) and cars (higher thermal resistance allowing engine downsizing)
Production of more powerful and more energy efficient computer processors which are now part of our everyday life (Smartphone, Datacenters, Artificial Intelligence)
Reduction in fugitive emissions linked to lower permeation in chemical production Reduced worker exposure linked to longer seal lifetime in the application. Every seal changed
is a potential exposure for workers to the sealed media Sealing of drug production vessels to allow to production of the latest disease treatment
thanks to their extremely low to no extractable materials
Banning the use of fluoropolymers articles and the use of low molecular weight PFAS intermediates at the fluoroplastic manufacturing locations would step the science of sealing backward to the 1950s timeframe.
The ESA asks that PFAS fluoropolymer (Fluoroplastic & Fluoroelastomer) materials are exempted from the proposed regulation. It is important to note that because fluoropolymers are manufactured using low molecular monomers and short chain intermediates. PFAS monomer feedstock must continue to be allowed for manufacturing with use controls, if appropriate, put in place. e. Given the position of the ESA, Fibrant cannot indicate when any alternative would become available as for alternatives Fibrant has to rely on suppliers and these currently claim to not have good leads to become commercially available within the 12 year derogation time. f. Should the use of fluoropolymers be banned without available alternatives, Fibrant will not be able to run the 300 kta cyclohexanone, 250 kta caprolactam and 700 kta ammonia sulfate business. European alternatives will need to be found for nylon 6 in the majority of all textile, automotive (alternatives for the low weight, high resistance nylon materials with good fire resistance), food packaging (alternative solutions for especially oxygen barrier in packaging), and agricultural value chains. Note that all current European alternatives do have a higher carbon footprint than Fibrant's while non-European alternatives have a carbon footprint that is at least twice as high as any European.
