IOGP Europe statement on the ECHA proposed PFAS restriction proposal related to the Carbon Capture, Transport and Storage (CCS) Technology

Please note this statement is intended to be submitted as part of the ECHA consultation as an attachment to IOGP Europe’s response related to IOGP Subsea Flexible Pipes (on behalf of the ‘Petroleum and Mining’ sector, as per ECHA annex XV).

1. Executive summary

IOGP Europe acknowledges that Per-and polyfluoroalkyl substances (PFAS), due to their characteristics, need to be controlled to prevent health risks for people and the environment. However, because of their unique characteristics, some PFAS, provide the safest operating parameters for multiple applications across many usages including the Carbon Capture and Storage (CCS) value chain, while CCS technologies are recognized as critical ones to achieve the net-zero climate objective of the EU. For these reasons, we propose that PFAS, in particular fluoropolymers (used in the CCS value chain), be excluded from the PFAS restriction, or failing that, benefit from an unlimited-time derogation period from the proposed restriction.

CCS, a rapidly growing industrial sector, aims to upscale the secure, long-term containment of carbon dioxide (CO2) within geological formations, prioritizing environmental and human health safeguards. This proven technology offers an effective and environmentally benign strategy for mitigating climate change through the geological sequestration of human-made emissions from industrial and energy sources. CCS projects are mandated to ensure the safe, enduring confinement of CO2 and minimize leakage risks across the entire value chain, encompassing capture, transportation, and sequestration processes.

The CO2 stream, consisting overwhelmingly of carbon dioxide, includes impurities derived from the source materials or the capture processes (H2O, O2, H2, N2, NOx, SOx, etc.). The stream being acidic, it requires appropriate processes and equipment, including those with PFAS, which prevent the formation of impurities and the risk of leakages.

IOGP Europe would like to draw the attention on the fact that CCS does not have yet a category in Annex XV of ECHA Universal PFAS Restriction Report (the ECHA report).

However, for the purpose of responding to the ECHA consultation, many processes, equipment and facilities used for CCS, may be compared to those included in the ‘Petroleum industry’ sector such as:
• Use of same equipment & operating ranges as in the gas extraction, treatment, and transport

• CO2 management requires high resistance to corrosion, to temperature & mechanical degradation as (natural) gas management

• Large amount of Petroleum codes and Standards are applicable with some codes (API/ISO) specific to CO2 as fluid

• Chemical processes required for capture & conditioning are equivalent to those found in refineries and upstream petroleum sector for gas treatment, separation and conditioning

• The equipment found in the CCS sector is the same as equipment and piping used in extraction/production, transport, and storage of petroleum resources

• CO2 Capture & Conditioning (i.e. natural gas processing and CO2 EOR operations)

• Cryogenic Export/Import Terminals (i.e. LNG)

• Transport modalities (pipelines onshore/offshore, shipping, rail, and trucks)

• CO2 export stations/terminals (compression/pumping) (i.e. natural gas processing and CO2 EOR operations)

• Injection facilities

• Wells

• Monitoring Tools

Capture & CO2 conditioning facilities (dehydration, filtration) are/will be present in many other industries (Power plants, oil and gas facilities, steel, petrochemicals, waste, cement industry, refineries, fertilizers/ammonia production, Hydrogen production) and are essential to the safe operation of the many CCS projects under development, as per figure 1 taken from IOGP Europe map of CCS projects (September 2023).

For these reasons, IOGP Europe urgently requests ECHA to provide an unlimited-time derogation for fluoropolymers used in the evolving CCS value chain.