Table 8.15 below summarises the results for all impacts discussed in this chapter.
140 In the emission assessment in Task 3 (Section 5) and the SEA section on savings from adoption of fluorine-free foams (“e. Impacts associated with the economic feasibility of alternatives”).
141http://norden.diva-portal.org/smash/get/diva2:1295959/FULLTEXT01.pdf
Table 8.15 Summary of socio-economic considerations for the main expected impacts of potential regulatory management options
Impacts Economic Social Health/Environmental Wider economic
implications a. Cleaning of equipment Costs vary by equipment, process and achievable
concentration.
According to one estimate up to €12,300 per appliance achieving PFAS levels below 1000ppt (1/3 of appliances below 70ppt), which could imply EU total costs in the order of €1 billion, but established simpler methods have also been reported (cost not quantified).
The replacement of equipment is likely to be required in some cases, depending on the threshold chosen.
Replacement costs for extinguishers alone estimated at €15-450 million (EU total). Replacement cost for other equipment not quantified.
None identified. Trade-off between cost for cleaning/replacement and threshold concentrations for remaining PFAS contamination.
Replaced equipment and media (e.g. water) used in cleaning process must be disposed of or treated safely to avoid worker or environmental exposure.
None identified.
b. Other risk management options
None identified. None identified. None identified. None identified.
c. Fire safety –impacts of technical performance of alternatives
It is not expected that any damages would be caused, see Health/Environmental. This is however still uncertain for large atmospheric storage tanks.
None identified. AoA concluded alternatives are technically feasible and successful transitions have been shown in most applications. Further testing required to confirm whether this covers also large atmospheric storage tanks (LAST), the application of most concern.
Speed of fire suppression may be slower and application of foams may be less flexible and less easy to use, according to some stakeholders. This has not been shown to be generally the case and resulting health/safety impacts could not be quantified.
None identified.
Impacts Economic Social Health/Environmental Wider economic
implications d. Use patterns to achieve
comparable/acceptable performance using alternatives
Between no change in volume and up to a maximum of 100% additional foam required (additional cost considered in e. below).
In sprinkler applications, special sprinkler nozzles have to be installed (cost not quantified).
More than one foam may need to be stocked by users to cover different flammable liquids, with logistical, training and safety implications for users.
None identified. More than one foam may need to be stocked by users to cover different flammable liquids, with logistical, training and safety implications for users.
None identified.
e. Economic feasibility of alternatives
For both Scenarios:
Most likely there is no significant price difference (per litre) between PFAS-based foams and alternatives, but up to 100% more volume may be required (central estimate 50%) to achieve desired performance. This would lead to costs around €27m per year (EU total, central estimate)
Potential additional economic costs for transitioning may include testing costs (not quantified), storage costs, (not quantified) costs from technical changes to delivery systems (e.g. €5-€200 pre nozzle or around €2,700 for a mobile foam unit, but generally conceived as manageable), and regulatory approvals (not quantified).
Potential savings may include lower foam disposal costs at expiry date (likely order of magnitude
€100,000 to several million) lower fire-water disposal costs (covered under g. Remediation and clean-up), avoided cross contamination of waste, reduced regulatory requirements and reduced PPE requirements (not quantified).
Additionally for Scenario 2:
Costs for existing stock of PFAS-based foams (estimated 210,000-435,000 tonnes) will have to be written off (and new stocks purchased causing an additional cost (central estimate €1.0bn) over the baseline.
None identified. None identified. None identified.
Impacts Economic Social Health/Environmental Wider economic
implications f. Environmental/health –
impacts of alternatives
None identified. None identified. Based on the assessed substances, non-fluorinated
alternatives are of lower environmental concern, primarily due to greater biodegradation. A quantitative comparison of risk under each scenario was not possible with the available data.
None identified.
g. Remediation and clean-up Potential risk of PFAS contamination could be eliminated, which could save up to around €100 million remediation costs per site. Depending on the extent of containment and immediate clean-up, the number of relevant sites is likely low, but overall savings could still be in the order of magnitude of
€100s of millions to € billions More information on the total number of sites and real-world
implementation and effectiveness of best practices would be required to be more precise.
Treatment of fire-water run-off and short-term clean-up largely driven by other contents of fire- water run-off and cost saving estimates are very uncertain. Run-off treatment savings could be €0.7 per litre (range ca €0-€11) or €0 to €10s of millions per incident, and clean-up cost savings up to €10s of millions in total.
None identified. Potential trade-off between remediation cost and remaining PFAS contamination.
None identified.
h. Availability of alternatives Range of alternatives and capacity to increase production likely available. No significant supply shortages or additional costs expected in Scenario 1.
Scenario 2 may result in a more sudden and potentially significantly larger demand for fluorine- free foams to replace existing stocks of PFAS-based foam. This heightens the risk of a shortfall in supply, - depending on the timescales of any restriction.
As the largest single use, and with comparatively low current fluorine free sales volumes, the risks of supply constraints may be greater in the chemicals and petrochemical sectors.
None identified. None expected in Scenario 1. The risk of supply supply-shortages is higher in Scenario 2 (depending on timescales of a restriction), which could potentially lead to additional fire-safety risks.
None identified.
Impacts Economic Social Health/Environmental Wider economic
implications
i. Other impacts None identified. There is potential for
employment impacts but significant impact is deemed unlikely and any net effect at the EU level would be negligible.
None identified. Under Scenario 2, a
potential shortfall in supply – driven by a one off need for stock replacement - may impact imports of fluorine free foam from outside the EU.
Overall, there are unlikely to be any significant macroeconomic impacts from the result of either Scenario 1 or Scenario 2.
j. Emissions from disposal of legacy foams
None identified. None identified. High temperature incineration has been identified as main disposal method. There are potential hazards (emissions of hydrogen fluoride and PFAS), but further research is needed to identify and quantify the emissions produced from the incineration of PFAS.
None identified.
k. Technical feasibility / availability of disposal options
If the transition period is short, there is the demand for disposal facilities may outstrip supply, leading to potential additional costs and potential for emissions.
None identified. Trade-off between temperature of incineration (with lower capacity and higher costs) and effectiveness of PFAS destruction.
If the transition period is short, there is the demand for disposal facilities may outstrip supply, leading to potential additional costs and potential for emissions.
None identified.
l. Costs of disposal Total EU costs estimated at up to €320 million (range up to €60m-€4.8bn) depending on the method used (with implications on effectiveness, see
Health/Environmental) and the share of foams that would have reached expiry date without use.
Additional transport, storage and labour costs may be incurred (not quantified).
None identified. Trade-off between temperature of incineration (with lower capacity and higher costs) and effectiveness of PFAS destruction.
None identified.
Scenario 1: Restriction on the placing on the market of PFAS-containing fire-fighting foams