The proposal intends to restrict the use of Terphenyl, hydrogenated as a substance, in mixtures and articles or parts thereof.
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Use as high temperature Heat Transfer Fluid (HTF)
Any robust, representative data on the Operational Conditions and Risk Management Measures that are in place in heat transfer systems where terphenyl, hydrogenated is used?
* Compulsory Fields
The Dossier Submitter states that Directive 2014/68/EU - the Pressure Equipment Directive (PED) - would apply to heat transfer systems containing terphenyl hydrogenated and that as such this already sets requirements to these installation in terms of safety. What robust representative evidence is there that these OC and RMM are appropriate and effective in containing the substance and avoiding emissions?
The Dossier Submitter states that (Section E.3.4 of the Annexes to the terphenyl, hydrogenated Restriction report) that the following measures must be in place to contain the substance: general leakage collection systems, containment devices installed beneath flanges and pumps, retention systems in pumps and valves to ensure that any leakage of terphenyl, hydrogenated through the seals is safely drained off and collected in a contained space, terphenyl, hydrogenated level monitoring. Do you have robust representative data on the extent that these measures in place throughout the sector? What are the costs of installing and operating these OCs and RMMs if not already available?
The top-up or refill demand in heat transfer systems is driven by the degradation rate of the HTF and the separated low-boiling and high boiling degradation products. Do you have any information on releases of these degradation products and on the presence of o-terphenyl in the degradation products? How are releases to the environment avoided when e.g. fluids are replaced or topped-up, when accidental spills occur or when installations are decommissioned at the end of service life. Do you have robust, representative information on the likelihood and severity of accidental releases of terphenyl, hydrogenated including accidental spills, disposals, decommissioned installations? Do you have any robust representative data on how wastes are managed in heat transfer systems?
The Dossier Submitter has identified (Section E.A.1 of the Annexes to the terphenyl, hydrogenated Restriction report) that the heat transfer systems play a role in the further development of renewable energy sources (in e.g. solar panels) and that as such the use of terphenyl-h in these applications is assumed to grow. What is the expected Compound Annual Growth Rate for HTF? Would a restriction on terphenyl-hydrogenated be an impediment to the further development of renewable energy sources?
Considering the use of terphenyl, hydrogenated, as a heat transfer fluid, the Dossier Submitter discards some alternatives based on boiling point. However, the boiling point depends on the type of process in which the HTF fluid is used. Could other alternatives for HTF like biphenyl, (hybrid organic) silicones or mineral oil be used for some processes (for example Concentrated Solar Panels (CSP) or Organic Rankine Cycle (ORC) or some chemical plant)? Could you provide justification, to support a derogation or why alternatives to terphenyl, hydrogenated are not suitable? We would particularly welcome information on any specific technical criteria relevant to specific uses that could not be fulfilled by alternatives.
Any robust, representative information on uses of terphenyl, hydrogenated as a plasticiser in coatings, sealants, adhesives, polymers, cables and inks? Although the above uses have been identified by the Dossier Submitter, very limited information is reported. Is terphenyl, hydrogenated used in processes and articles other than those mentioned in the restriction proposal? What is the function of terphenyl, hydrogenated in articles, in what type of articles is it applied and at what is the concentration of terphenyl, hydrogenated in the articles that is needed in order to achieve this function? How are the markets for the articles including terphenyl, hydrogenated? Is there competition from alternatives? Which markets are expected to grow, and which are not?
Any further robust representative information on specific uses of terphenyl, hydrogenated in the aerospace applications to justify the proposed derogation by the Dossier Submitter? Relevant information for these uses (i.e. articles and aerospace applications) could include, amounts currently used, site-specific emission data (associated with manufacture, service-life or end-of-life (management at waste stage)), and any impacts (costs and benefits to society) of the proposed restriction on these uses (in line with the elements of a socio-economic analysis (SEA) as outlined Annex XVI of REACH.
Information on analytical method(s): which analytical methods are available to quantify terphenyl, hydrogenated (or its constituents such as o-terphenyl) in substances, mixtures and articles (apart from NIOSH 5021 “o-Terphenyl”) and what is the applicability of these analytical methods at EU level?
Any further information on actual concentration of Terphenyl, hydrogenated in recycled materials (or as impurity in substances and mixtures) and information on how the proposed restriction could potentially affect the concentration of terphenyl hydrogenated in recycling (especially of plastic materials)
As terphenyl, hydrogenated and biphenyl are produced together in the same process as coproducts, if terphenyl, hydrogenated would be banned, how would it affect to the biphenyl final cost? In case of maintaining biphenyl production how would terphenyl, hydrogenated be disposed of?
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