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Good Afternoon Commissioners of the US International Trade Commission:

My name is Sina Ebnesajjad and I am a PhD chemical engineer - from the University of Michigan. I am currently president of the FluoroConsultants Group that provides fluoropolymer consulting services globally.

I worked for DuPont for 23 years until 2006, mainly in PTFE in the fluoropolymers division.

I have authored 6 books about fluoropolymers in the last 20 years including the two volume industry handbooks of PTFE and other fluoropolymers.

I am going to highlight and clarify some certain distinguishing characteristics of the three forms of PTFE, namely granular, fine powder and dispersion.

The paramount question before this Commission is whether all three forms of PTFE are equivalent in terms of physical characteristics and end-uses and whether they are interchangeable. The short answer is NO. Indeed, I am astonished at the suggestion of equivalency of the three forms of PTFE because they are anything but equivalent, superficial reasoning not withstanding.

If the three product lines were indeed equivalent, the industry would have almost exclusively produced only the cheapest of them, that is the granular form but we know that is not the case.

Granular PTFE was invented first but due to its limitations the industry later developed dispersion and fine powder PTFE forms, based on an entirely different technology.

Granular PTFE is produced in a vertical reactor using Suspension Polymerization.

On the other hand, dispersion and fine powder forms are produced in a horizontal reactor, based on Dispersion polymerization.

Rupture Disk

Inspection Port

Evacuation Line

High Purity Water Port

Initiator and Additives Line

Steam and Coolant Jacket

PT FE Auxiliary Discharge Port Discharge

Port

Agitator

T FE In

Heating/Cooling Jacket

Discharge Port

Wall Sweeping Agitator

Monomer (TFE, HFP, ..) Supply

Precharge: 1. High purity

H20 2. APS 3. Surfactan 4. Wax

High Pressure N2

PPVE Supply Tank

Vent Line

Rupture Disk

APS Solution

Tank

Surfactant Solution Tank

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Figure 1. Vertical Reactor for manufacturing PTFE Granular by suspension polymerization — no surfactant and vigorous agitation

Source: Ebnesajjad S., Fluoroplastics: non-melt processible fluoropolymers, vol 1, 2nd ed, Elsevier, Oxford, UK, 2015.

Figure 2. Horizontal Reactor for manufacturing PTFE Dispersion and Fine Powder — ample surfactant and mild agitation

Source: Ebnesajjad S., Fluoroplastics: non-melt processible fluoropolynners, vol 1, 2nd ed, Elsevier, Oxford, UK 2015.

Figure 3. PTFE Dis ersion A earance

PTF_Epiwe on

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As such, granular PTFE is in an entirely separate family of PTFE than dispersion and fine powder.

Finally, dispersion form distinguishes itself from fine powder since it is in a liquid state similar to paint while fine powder is a solid.

Despite the obvious stark differences among the three forms, Petitioners attempt to erase the clear dividing lines among them by underscoring an incidental overlap in particle sizes of granular and fine powder forms, disregarding a myriad of fundamental differences between the two forms. Given that granular and fine powder forms are entirely different PTFE forms, produced by totally different technologies, an overlap in particle sizes is irrelevant.

Next, Petitioners allege an overlap in their uses. This is simply not true. In general, Granular form as polymerized is stringy in appearance, must be cut into small particles before it is fabricated into parts using compression molding techniques.

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Figure 4. As-produced Granular PTFE form is stringy (at 30 times magnification)

Figure 5. Parts made from filled Granular PTFE

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Fine powder is produced by coagulation of dispersion resulting in a powdery substance. The analogy is individual grapes and grape bunches.

Figure 6. Primary Particles of Dispersion and Fine Powder Forms

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Figure 7. Agglomerates of Primary Particles results in a powdery substance

Fine powder is extruded by paste extrusion to form tubes, aerospace hose liners, electric insulation or porous membranes. Fine powder is the only form that can be used in applications where a porous membrane is required. Fine powder is again the only PTFE form for fabrication of liners for aerospace fuel hoses.

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Figure 8. Plumber's Tape

Figure 9. Porous PTFE Membranes can be made only from fine powder •• .1.--m,,,,-...-,..,.... -.t.,..-..;.„-tw.:...-...

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Dispersion form is in liquid state and is primarily used to produce coatings on metals or fabrics.

Figure 10. Non-stick coatings for cookware and bakeware

similar to seelin. an a. • e

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When Petitioners speak about overlapping uses of the three PTFE forms, they are referring to their uses in a general application such as in producing films. However, Film A, Film B and Film C are fundamentally different form one another.

Fine powder is used to produce porous films for waterproof fabrics or sealant tape for which granular form cannot be used. If granular form is used for film, then it is a completely different type of film that is not porous — almost a sheet - and must be produced by a skiving method using a molded granular cylinder, as in peeling an apple.

Figure 11 PTFE Granular skived film (cut from a molded PTFE cylinder,

Figure 12. Skiving Granular PTFE Film WI3 pm) from a Molded Cylinder

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Figure 13. Peeling an Apple

Cast Film is made from dispersion form PTFE, and can be as thin as 5 pm or less. It has the same mechanical properties in length and width directions unlike film made from granular form PTFE. It has poor economics because it is manufactured by coating a "carrier" belt made from steel or a polyimide. An application of cast film is in fabrication of non-porous food belting.

In terms of thickness, there is a bright line distinction among the three types of films. Dispersion films are not porous and can be as thin as 5 microns while fine powder film thickness ranges from 5 to 200 microns. Granular films are generally much thicker and their thickness can even exceed 3 mm.

Conclusions I have described the reasons for uniqueness and distinction of PTFE types from different perspectives. It should be eminently clear that the three PTFE product lines have: 1. Different physical characteristics; 2. Manufacturing equipment; 3. Unique applications; and 4. Little interchangeability. Further, those who buy these PTFE products must employ different equipment, facilities and handling methods for processing each product line. There are indeed clear dividing lines among the three PTFE product line that have kept them completely apart some seven decades into the commercial production and consumption of these resins.