Document x5bwjm1zRed1XeaZNKZbwzk90

== AKT 7248157 == [ Re: Gujarat Fluorochemicals - UPFAS - Fluoropolymers ] == Dokument 2 == [ GFL - EU regulators meeting - 29th March 2023 ] == Fluoropolymers in PFAS restriction proposal Gujarat Fluorochemicals Limited Date: 29.03.2023 1 Contents Fluoropolymers in PFAS restriction proposal GFL's position on the restriction proposal GFL's contribution to the restriction process for exemption of fluoropolymers We do not defend PFAS Regulators and environmentalists are mainly concerned about PFAS that are mobile, bioaccumulative and toxic Fluoropolymers have nothing in common in terms of risk when compared to such PFAS of Concern Fluoropolymers fall within the PFAS group due to the structural definition only and do not share the toxicological and environmental profiles associated with such PFASs GFL supports initiatives aimed at regulating PFAS of concern that pose an unacceptable risk GFL does not defend PFAS of concern Fluoropolymers in PFAS restriction proposal 1. Dossier proposes a restriction on all fluoropolymers with few time limited derogations 2. CPI and pharma industry where safety and well being is of importance are not covered 3. Industrial applications like semiconductors, medical & pharma, automotive, aerospace, renewable energy where use of fluoropolymers is critical are not given time unlimited derogations Fluoropolymers in PFAS restriction proposal Use of PFAS polymerization aids in the manufacturing 1. PTFE, PVDF and FKM produced with fluorinated polymerization aids are proposed restrictions without derogations because safer non-PFAS alternatives are available 2. All other fluoropolymers can be produced with PFAS polymerization aids until 6.5 years after EiF 3. More than 50% of fluoropolymers do not require the use of polymerization aids 4. With above proposed restrictions, PFAS emissions contributed by manufacturing of fluoropolymers are greatly reduced 5. Historically, the use of PFAS polymerization aids is the main cause of PFAS pollution in the environment. E.g.: PFOA, PFOS, ADONA... Fluoropolymers in PFAS restriction proposal Concentration limits of PFAS 1. 25 ppb for any PFAS as measured with targeted PFAS analysis 2. 250 ppb for the sum of PFASs measured as of targeted PFAS analysis, optionally with prior degradation of precursors sum polymeric PFASs excluded from quantification Any substance/mixture/article containing more than 50 ppm of fluoropolymers (total fluorine exceeds 50 mg F/kg) are restricted unless derogated polymeric PFASs included 250 ppb * 50,000 tonnes of Fluoropolymers = 12.5 kgs Use of non-fluorinated polymerization aid technology + Abatement techniques will further reduce PFAS emissions associated with manufacturing and processing of fluoropolymers. Data requirements during Risk Assessment Committee analysis Safety of fluoropolymers during its lifecycle mainly manufacturing and end of life phases Risks Manufacturing Use of PFAS Polymerization aids & processing (FPA) & its emissions thereof Phase Safety of fluoropolymers during lifecycle Use Phase No risk identified Degradation into small PFAS molecules End-of life Incomplete incineration phase Leachate from landfills Information on remediation Substitution of FPA with Non-FPA: GFL has developed NFPA technology for PTFE, FKM, PVDF and PFA Implementation of abatement technologies to control emissions Fluoropolymers satisfy OECD Polymers of Low Concern criteria Fluoropolymers do not degrade - Danish EPA 1. RIVM, Gore studies on incineration prove complete decomposition of fluoropolymers 2. GFL's incineration project in collaboration with KIT and other stakeholders Fluoropolymers are inert, non-toxic and do not leach - Gore study GFL's Incineration project - Combustion of fluoropolymers PFAS measurements along the flue gas pathway Objective: Conducting a pilot scale trial at conditions similar to waste-to-energy incineration units that typically burn products containing fluoropolymers to analyze generation of any statistically significant uncontrolled emissions of PFAS substances at levels that might present a risk Initiated & funded by Research partner Laboratory partner Feed sampling Incineration Advisor Academic Consultant Observers PFAS analysis collaboration partner Study Report generation Project Report generation Gujarat Fluorochemicals (GFL) Institute for Technical Chemistry (ITC), at Karlsruhe Institute of Technology (KIT) SGS, PFAS Competence centre Pro-K, Fluoropolymer processing and downstream user association Dr. Phillip Taylor, P Taylor & Associates, LLC Dr. Bruno Ameduri, Senior Researcher at ICGM, University of Montpellier UBA BAM Institute for Technical Chemistry (ITC), KIT Chemservice GmbH, Germany BRENDA facility GFL GUJARAT FLUOROCHEMICALS Fuel Gas Rotary Post- Kiln -- Combustion Chamber Waste Heat Boiler Spray Drier s Air -- Process Steam g [ -- 40bar250%C 7" Fabric Filter Flue Gas Scrubber Scrubber1 Scrubber 2 SCR Stack Catalyst Solid Water Boiler Ash Sample locations for HF and PFCs as well as flue gas composition and flow measurement LJ Fig 1 Schematic of the BRENDA pilot combustion facility at KIT = AmLimqounoira Gas Burner Induced Draught NaOH Data to be provided during public consultation Manufacturing & Processing phase Use phase End of life phase Incineration Landfill Recycling Persistency Analysis of Alternatives Proportionality Data on lifecycle of fluoropolymers Technical report on NFPA technology by Dr. Bruno Ameduri, Dr. P12 Schlipf, Dr. Jaime Sales Independent lab reports on PFAS analysis in fluoropolymers Data on effective abatement technologies in product and effluent Paper on Closed loop fluoropolymer production process Data on emissions during processing of fluoropolymers Tox/Ecotox read across on Fluoropolymers by GSI Conversio report on Fluoropolymer waste GFL Incineration study Gore's biodegradation study Degradation report - Fluoropolymers vs Side chain fluorinated polymers by Chemservice Paper on Use of PTFE membrane for landfill lining by Textiles Coated Inc., USA Review paper on recyclability of fluoropolymers by Dr. Bruno Ameduri Scientific arguments against P-sufficient approach by GSI Exhaustive study on AoA covering major fluoropolymers and main applications by Chemservice Costs/risks to benefit ratio on Fluoropolymers & sensitivity analysis by Ramboll Emission analysis on fluoropolymers vs other PFAS by Ramboll Suggested decision tree for fluoropolymer regulation FLUOROPOLYMERS Yes MawnituhfaPcFtAurSed No EPXFEAMSPinTIfOinNal(<p2ro5d0upcpt)b Critical use Yes for society No RESTRICTION Alternatives No available Yes DEROGATIONS (<250 ppb PFAS in final product) TThhaannkk yyoouu GUJARAT FWOROCHEMICALS VALUE THROUGH GREEN CHEMISTRY = L