Document Z8RnRYa4qpj3mVjjE3Ry1V1KJ

2965554 SM Science. Applied to Life." or the IEEE To: German CA Bundesanstalt fiir Arbeitsschutz und Arbeitsmedizin (BAuA) Re: 3M responses to questions received via email on 21 April 2021 Date: 24 MAY 2021 What are the market applications of immersive cooling liquids? Response: The 3M specialty fluids used in the data center/server immersion cooling application are standard 3M heat transfer fluids used in semiconductor processing and other industrial processes. The heat transfer fluids that are candidates for use in data center immersion cooling include: 3MTM FluorinertTM Electronic Liquid FC-3284, 3MTM FluorinertTM Electronic Liquid FC-72, 3MTM FluorinertTM Electronic Liquid FC-40, 3MTM NovecTM 7100 Engineered Fluid, 3MTM NovecTM 7000 Engineered Fluid and 3MTM NovecTM 649 Engineered Fluid. 3M has been producing the Fluorinert-branded heat transfer fluids since the 1970s and the Novec-branded fluids fom the late 1990s. What is the (EU) market size (and expected (EU) growth)? Volumes & preferably also net production value for the EU? Response: Though it has been worked on for many years, there is no commercial installation of immersion cooling with 3M fluids in data centers in the European Union. It is believed that 1-2% of all data center megawatts deployed could represent the addressable market size for immersion cooling by 2025. According to a March 18, 2021 ,, Europe Data Center Market Report" issued by ReportLinker, the Europe data center market by investment is expected to grow at a CAGR of over 4% during the period 2021-2026. They also cite data from the Uptime Institute indicating that Europe has around 217 certified data centers spread over 29 countries, which include local and global facilities. A majority of them are in the UK, Russia, Spain, Lithuania, Luxembourg, Italy, and France. In another report issued by ReportLinker on May 5, 2021 titled ,Western Europe and Nordic Data Center Market -- Industry Outlook and Forecast 2021-2026", the market size by tier standard will reach $12 billion USD by 2026 growing at a CAGR of over 5% from 2020. Since when is immersive cooling being marketed? Response: The first work with immersion cooling of supercomputers was done in the late 1970s. In 2010, 3M published a new approach to two-phase immersion cooling and server demonstration systems were built. The first sytems were built for bitcoin mining in 2012 and 2013. Though bitcoin mining was an early adopter due to the need for a need for high processing power, the benefits of immersion cooling are now being appreciated in the hyperscale data center market, supercomputing, enterprise high performance compute and edge/5G. Since this first large scale installation, 3M has continued to work with data center customers on proof-of-concept installations in several countries outside of the EU and has supported commercial installations outside of the EU. 2965554 4. What are the advantages of immersive cooling? Response: Immersion cooling is a method for cooling data center IT hardware by directly immersing the hardware in an electrically non-conductive liquid such as 3MTM FluorinertTM Electronic Liquid or 3MTM NovecTM Engineered Fluid. Use of 3M fluids for immersion cooling can reduce the cost and energy associated with cooling these facilities, which in turn can reduce facilities' energy footprint, capex costs and impacts on natural resources. Immersion cooling with 3M fluids offers many benefits compared to traditional air cooling, including increased thermal efficiency (reduced power usage effectiveness (PUE) as low as 1.02) and increased performance and reliability of data centers. Heat generated by the electronic components is directly and efficiently transferred to the fluid. This reduces the need for interface materials, heat sinks, fans, shrouds, sheet metal and other components that are common in traditional cooling methods making simpler data center designs that scale more efficiently. Optimized immersion-cooled data centers can lead to reductions in capital and operating expenses, as well as a reduction in construction time and complexity. With increased cooling efficiency, electricity costs that were dedicated to ancillary cooling needs can be reduced. With PUEs as low as 1.02, it's possible to build more power-efficient and sustainable data centers. Immersion cooling also eliminates the need for complex airflow management. The increased compute density from immersion cooling allows for more flexible data center layouts and removes barriers to data center location choices such as areas with high real estate costs or space limitations. Data centers employing immersion cooling are geographically and environmentally agnostic, allowing for deployment of data center with more consistent cooling infrastructure globally regardless of location. Finally, immersion cooling with 3M fluids can help eliminate the trade-off between water usage, energy efficiency and cost by eliminating the need for chillers with economizers and complex controls used in air cooling. This can potentially eliminate the use of water needed to cool the data center by, instead, utilizing natural water temperatures in many climates to allow for full capacity cooling without evaporation infrastructure. Water waste can be reduced or eliminated with either single-phase or two-phase immersion cooling through the use of dry coolers. The 3MTM NovecTM Engineered Fluids may also be used as heat transfer fluids in direct-to-chip (also known as cold plate) cooling. 5. Is 3M the only company marketing immersive cooling, or are there also other companies within this market? If yes, do they use similar kind of liquids or alternative ones? Response: There are other companies who are marketing the use of fluids for immersion cooling. Some of these companies supply fluorochemical fluids. Other non-PFAS fluids used in immersion cooling applications are mineral oils, synthetic oils and natural oils. These materials are prone to dissolving hydrocarbon-based polymers and are therefore less likely to be compatible with adhesives, elastomers, and thermal interface materials. Moreover, most hydrocarbons are combustible and/or flammable. Therefore, hydrocarbons may pose an unacceptable risk to safety and infrastructure for many applications, particularly in two-phase immersion cooling. Hydrocarbon fluids with sufficiently high boiling points and flash points 2965554 can be used in some single-phase applications, but they have the disadvantage of being relatively viscous (especially at low temperature) and do not evaporate readily from hardware when it is removed for service. Which fraction of datacenters is using immersive cooling? Response: Today, there are no commercial data centers in the EU using 3M fluids in immersion cooling. There have been announcements of installations with other fluids. As the European economy and society continue to digitize and as Europe is striving to become more digitally independent, there will be a greater use of data centers and subsequently an increase in their cooling needs in Europe. The data center immersion cooling application, though having been in development for many years, is now emerging at larger scale and offers important benefits to data center owners versus traditional cooling methods. 3M is engaged with EUbased companies in the development of immersion cooling systems and planned proof-ofconcept installations. We believe the potential market for immersion cooling to be 1-2% of all data center megawatts deployed with immersion cooling by 2025 What is the PFAS identity & content in immersive cooling fluid? (Maybe from SDS?) Response: The 3M specialty fluids used in the data center/server immersion cooling application are standard 3M heat transfer fluids used in semiconductor processing and other industrial processes. The heat transfer fluids that are candidates for use in data center immersion cooling include: 3MTM FluorinertTM Electronic Liquid FC-3284, 3MTM FluorinertTM Electronic Liquid FC-72, 3MTM FluorinertTM Electronic Liquid FC-40, 3MTM NovecTM 7100 Engineered Fluid, 3MTM NovecTM 7000 Engineered Fluid and 3MTM NovecTM 649 Engineered Fluid. Trade Name Chemical name CAS Numb EC Numb 3MTM FluorinertTM Electronic Liquid FC-3284 3MTM FluorinertTM Electronic Liquid FC-72 3MTM FluorinertTM Electronic Liquid FC-40 3MTM NovecTM 7100 Engineered Fluid 3MTM NovecTM 7000 Engineered Fluid (2,2,3,3,5,5,6,6-octafluoro-4-(trifluoromethyl)morpholine Reaction mass of 1,1,1,2,2,3,3,4,4,5,5,6,6,b-tetradecafluorohexane and 1,1,1,2,2,3,3,4,5,5,5- |undecafluoro-4-(trifluoromethyl)pentane Reaction mass of 1,1,2,2,3,3,4,44-nonafluoro-N,Nbis(nonafiuboutraonb-1u-taymiln)e and 1,1,2,2,3,3,4,4,4-nonafluoro-N-[1,1,2,3,3-hexafluoro-2-(trifluorpormopeytlh]y-lN)- |(1,1,2,2,3,3,4,4,4-nonafluorobutyl }butan-1-amine Reaction Mass of 1,1,2,3,3,3-hexafluoro-1-methoxy-2-(trifluorompertohpyalne) and 1,1,2,2,3,3,4,4,4-nonafluoro-1-methoxybutane Methyl perfluoropropyl ether 3MTM NovecTM 649 Engineered Fluid 1,1,1,2,2,4,5,5,5-nonafluoro-4-(trifluoromethyl)-3-pentanone 382-28-5 1064697-81-9 206-841-1 943-336-1 1064698-37-8 939-511-7 163702-08-7 & 163702-07-6 | 422-270-2 375-03-1 484-450-7 756-13-8 436-710-6 The Fluorinert electronic liquids have the following benefits in performance: remain liquid at wide range of temperature with low viscosity, have high chemical and thermal stability, high dielectric strength and are electrically non-conducting. They are also non-corrosive, nonflammable, have low reactivity, low toxicity, and have a wide margin of safety. These fluids remain stable over time, offering consistent performance and uniform temperatures. The Fluorinert liquids have zero ozone depletion potential (ODP) and are VOC-exempt but do have relatively higher global warming potential (GWP) levels. This can be managed by minimizing emissions. The products are filtered in situ and can be recycled. The Novec fluids also have excellent properties for heat transfer applications including excellent dielectric properties, wide range of boiling points and good materials compatibility. They require little maintenance and offer dependable performance. They have high resistivity and will not damage electronic equipment. They have low toxicity, are non-flammable, low 2965554 global warming potential and zero ozone depletion. The chemical inertness and noncorrosivity offer workers more safety in handling. In general, the emissions of fluids are managed and minimized by customers using the fluids. The products are filtered in situ and can be recycled. 8. Which alternatives are available? Response: The most common alternative to immersion cooling is conditioned air cooling. Other methods include direct-to-chip / cold plate cooling. Other non-PFAS heat transfer fluids used in immersion cooling applications are mineral oils, synthetic oils and natural oils. These materials are prone to dissolving hydrocarbon-based polymers and are therefore less likely to be compatible with adhesives, elastomers, and thermal interface materials. Moreover, most hydrocarbons are combustible and/or flammable. Therefore, hydrocarbons may pose an unacceptable risk to safety and infrastructure for many applications, particularly in two-phase immersion cooling. Hydrocarbon fluids with sufficiently high boiling points and flash points can be used in some single-phase applications, but they have the disadvantage of being relatively viscous (especially at low temperature) and do not evaporate readily from hardware when it is removed for service. 9. Is it possible to estimate emission during installation and application? Are specific measures being taken to prevent emissions? Response: The immersion cooling tanks are closed sytems. Operators strive to minimize emissions. The tanks are opened for maintenance purposes, such as server replacement. Customers with installations report fluid loss to evaporation of 1-2% per year. However, we understand that some system integrators / tank suppliers are providing warranties for 1% or lower loss of fluid per year. From 3M`s observation of the evolution in tank design and from our knowledge of losses in similar closed systems, we believe emissions could approach 0.1% with proper measures. 10. What is the End of Life stage of the liquids? How is the waste collected? What measures have been taken to prevent emissions at the waste stage (both in pumping, transport & final treatment)? Response: These fluids have an indefinite service time if they are kept clean during operation. This is achieved by filtering. There is a three part strategy to life cycle management. The primary goal is to maintain fluid cleanliness to extend the life of the fluid to the life of the data center. If the data center is decomissioned and the fluid is no longer needed by the customer, it is possible for the fluid to be recycled. 3M does not currently have a recycle program operating in the EU; however, there are companies who collect and re-process fluids currently. 3M is also investigating the development of a program to support data center customers. If the fluid cannot be re-processed, it can be disposed of via incineration. There are incineration companies in the EU who are capable of incineration of fluorochemicals. It should be possible during pumping of the fluid into containers for transporation to recycling or incineration to minimize emissions.