cba for change over of hg-cell to membrane cell technology in chlor-alkali industry

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INFORMATION MANUAL ON POLLUTION ABATEMENT AND CLEANER TECHNOLOGIES SERIES : IMPACTS/14/2006-07 Cost Benefit Analysis for Changeover of HgwCell to Membrane Cell Technology in Chlor,wAlkali Industry z z ai o ^I/moo CLEAN CENTRAL POLLUTION CONTROL BOARD MINISTRY OF ENVIRONMENT & FORESTS Website: www.cpcb.nic.in e-mail: [email protected] September, 2006

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Page 1: CBA for Change Over of Hg-Cell to Membrane Cell Technology in Chlor-Alkali Industry

8/4/2019 CBA for Change Over of Hg-Cell to Membrane Cell Technology in Chlor-Alkali Industry

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INFORMATION MANUAL ON POLLUTION ABATEMENT ANDCLEANE R TECHNOLO GIES SERIES : IMPAC TS/14/2006-07

Cost Benefit Analysis for

Changeover of HgwCell toMembrane Cell Technology

in

Chlor,wAlkali Industry

z

z

aio I/moo

CLEAN

CENTRAL POLLUTION CONTROL BOARD

MINISTRY OF ENVIRONMENT & FORESTSWebsite: www.cpcb.nic.in e-mail: [email protected]

September, 2006

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INFORMATION MANUAL ON POLLUTION ABATEMENT AND

CLEANER TECHNOLOGIES SERIES: IMPACTS/14/2006-07

Cost Benefit Analysis for

Changeover of Hg-Cell toMembrane Cell Technologyi n

Chlor=Alkali Industry

t____+

FCLEAN!

CENTRAL POLLUTION CONTROL BOARD

(Ministry of Environment & Forests, Govt. of India)

Parivesh Bhawan, East Arjun Nagar

Delhi--110032Website : www.cpcb.nic.in-mail : [email protected]

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CPCB 200 Copies, 2006

Published By : Dr. B. Sengupta, Member Secretary, Central Pollution Control Board, Delhi - 32Printing Supervision & Layout : P.K. Mahendru and Mrs. Anamika SagarComposing & Laser Typesetting : Mohd. Javed

Printed at : SIDC

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VÍI\\ I/

c[v

c W I('ffá1)9 ^Tci 1

Central Pollution Control Board

(A Govt. of India Organisation)Ministry of Environment & Forests

Phone: 22304948/22307233

FOREWORD

Mercury is bio-accumulative, toxic and poses health hazards. In India, one of the

industrial sectors using mercury is the chlor-alkali industry which manufactures

caustic soda, chlorine and other co-products. Indian Chlor-Alkali industry hasconverted many existing mercury cell process to Hg-free technology — Membrane

Cell Process in many plants. In India, still there are plants operating on Hg cellprocess and the Central Pollution Control Board (CPCB) is pursuing for their earlyconversion. One of the action points of Corporate Responsibility of Environment

Protection (CREP) is the plan for switching over to membrane cell from Hg cell

process. The Task Force, constituted by the Ministry of Environment & Forests for

implementation of CREP action points, has agreed for conversion by 2012 or earlier.

In order to examine the problems being faced by the chlor-alkali industry in the

conversion process, CPCB had sponsored a study to National Productivity Council

(Energy Group), New Delhi on "Cost Benefit Analysis for Changeover of Hg-Cell to

Membrane Cell Technology in Chlor-Alkali Industry". The findings of the studyestablish techno-economic feasibility of such conversion based on IRR estimate

considering power, labour, raw material costs & capacity utilisation, etc. The findings

also recommend speeding up of the conversion process and that the industry be

provided some incentives.

The study was coordinated and report finalized by Dr. Inamul Haq, Addl. Director,Shri N.K. Verma, Addl. Director and Dr. B. Sengupta, Member Secretary. Theinformation provided by Alkali Manufacturers Association of India (AMAI) and

individual industries for completing the study is acknowledged. Typing assistancewas provided by Shri K.P. Rathi, DEO. We hope, this report would be useful to all

concerned.

V rz, -n-

(Dr. V. Rajagopalan)

'Parivesh Bhawan', C.B.D.-cum-Office Complex, East Arjun Nagar, Delhi-1 10 032Fax: (011)22304948/22307078 e-mail : [email protected]

Website : http://www.cpcb.nic.in

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CONTENTSPage No.

Executive Summary- V I

1.0 Introduction 1

1.1

ercury Cell Process 2

1.2

embrane Cell Process 3

1.3iaphragm Process 31.4lobal Scenario 3

2.0 Background, Objective & Scope of the Study 5

2.1ackground 52.2bjective 62.3

cope of the Study 6

3.0 Emission Standards for Chlor-Alkali Sector 7

4.0 Chlor-Alkali Industry — India 9

4.1mport/Export of Caustic Soda 94.2tatus of Mercury Units in India 104.3roduction Cost of Caustic Soda 124.4rice of Caustic Soda 14

4.5

nternational Price of Caustic Soda 15

5 .0 Survey Findings 15

5.1

perating Cost Profile 15

5 .2

apacity Utilization of Mercury Cell Plants 17

6.0 Need for Conversion 17

6.1asis 19

7.0 Economics of Conversion 22

7.1

ash Inflow 22

7.2

ash Outflow 25

7.3

alculation of Internal Rate of Return- 26

7.4

cenarios Considered for Conversion 28

7.5nalysis Result 297.6ample Calculation for Internal Rate of Return 30

8.0 Recommendation 36

Annexure 1 — 6 38-45

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EXECUTIVE SUMMARY

The chlor alkali industry in India is around 60 years old. It began with a modestcapacity of a few thousand tonnes per annum and has since grown into a 2.468 million(2004-05) tons per annum capacity industry. The domestic consumption of causticsoda during the year 2004-05 was around 1.856 million tons.

In India there are at present 32 units manufacturing caustic soda, chlorine andassociated products. The share of membrané process in the overall installed capacityof caustic soda production is 75 % (2004-05) and 24 % is constituted by mercuryprocess. The diaphragm process constitutes a very negligible share in the productionof caustic soda and chlorine. As per the latest feed back a number of units are in thevarious stages of conversion/phasing out the mercury process. By the year 2010,when majority of these units expected to be converted to membrane cell technology,the percentage of mercury cell process (installed capacity) will come down to 5% ofthe total share of caustic soda production capacity. The industry association has

agreed .for conversion of Hg cell to membrane cell process by 2012. However, theindustry is advancing the conversion process and as reported majority of the existingHg cell plant would be completed by 2010.

The technology share has seen a major shift towards the membrane process duringthe last twenty years and the migration tend of technology in the country is shownbelow

Though there are a lot of factors influencing the cost viability of the conversion oftechnology, few important are the market, capacity utilization, energy price & specificenergy consumption. As per the data, caustic soda units are unable to achieve 100 %capacity utilization mainly due to the market constraints. The average capacityutilization by the Indian industries is about 87% (2004-05).

The power consumption is higher in mercury cell pltints compared to membrane cellplants (higher by 20 % to 35% depending on the plant) and is one of the driving forcefor the existing mercury units for considering for conversion. The average share of

electrical energy in the total production cost is around 70 %. Hence the cost benefits

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for conversion would mainly dependent on the cost of power and the specificelectricity consumption of the unit At present except few units the average specificpower consumption of the mercury cell units is in the range of 3100 - 3250 KWh/Ton ofcaustic soda. If the power cost increases more than the inflation rate then the InternalRate of Return (IRR) for the investment would become more attractive.

Apart from the electricity cost other major factors contributing to the production cost islabour cost and maintenance cost. The average manpower cost in a new membranecell units is less by 85 % compared to mercury cell units whereas the averagemaintenance cost is higher by 180 % for mercury cell units in comparison withmembrane cell units. There are a few mercury plants whose man power andmaintenance cost are almost at par with a membrane plants but they are exceptions.

Though the cells have to be converted for any changeover, the investment required fora unit for conversion of technology varies on case to case basis based, on rectifiercapacity, salt quality, available Chlorine cooling capacity etc. However after

discussions with vendors and units, converted, an investment of Rs 600 Million Rupeesto Rs 700 Million Rupees is taken for a 100 TPD plant conversion.

The internal rate of return (IRR) for an investment of Rs 600 million was calculated tobe 23.1 % for a typical 100 TPD plant for one to one conversion with 100 % capacityutilization. All the annual operating costs viz, labor, maintenance, brine treatment,energy etc were considered for evaluating the IRR. Except for a very few mercury cellunits which are highly energy efficient (<_ 3000 KWh/Ton), access to cheap source ofelectricity (<_ Rs 3/KWh) having good maintenance practices and having captiveconsumption, all other units would have to make some major decision in near future

due to non viability of operation & stiff competition. The units are aware about theeconomic benefits due to the conversion, however are not venturing to invest mainlydue to the high price fluctuation of the caustic soda and chlorine as well as financialposition of the units etc.

The above IRR which is reasonably attractive is achieved in an ideal case suggestingthat the industry can go for conversion. However the actual scenario is different inmany cases i.e. in terms of reduced capacity utilization, inability of the units to reducemanpower cost, 'fluctuation of product selling price, low electricity tariff etc. Thesefactors can make the returns from investment less attractive. The IRR would become

17.23 % in the above case for 85% capacity utilization (Average capacity utilization-ofmajority of Mercury cell plant is 85%, 2002-03) of the plant. Along with reducedcapacity utilization, if the units are unable to reduce the manpower cost, the IRR wouldbecome unattractive. The IRR of the scheme worked out under different conditions areprovided in Table:1. In different part of the country, the raw material cost varies and asthe energy constitutes the major production cost, IRR for the conversion of technologyhas been worked out (Table 2) with different energy price on a regional basisconsidering the average price of the major raw materials in that region.

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Though the present price of Rs 17200 /Ton of electrochemical unit (ECU) isreasonably good, the IRR for the conversion is not highly attractive, mainly dueto the low price increase of caustic Soda, as the price is scheduled to increaseat average of 2 % (considered after observing the price index of caustic soda inthe last 10 years) compared to the inflation rate considered at 5%. In spite ofthese factors, there are units going ahead with the plans for conversion and thereasons can be attributed to some of the factors like the products are consumed

in-house, plan of expansion of the entire company, stringent environmental lawsand also due to the long term vision of staying in the market.

However some of the units would take more time for actually going ahead withconversion due to the above mentioned reasons. In order to speed up theconversion process it is suggested to provide incentive to these units by meansfinancial support by providing technological up gradation fund/loan at a lowerinterest. This can be considered in similar line to the scheme introduced byGovt. of India for Textile & Jute Industries, whereby interest reimbursement of5% p.a. would be made available to borrowers availing assistance under

Technology Up gradation Fund. With a 5 % interest reimbursement supportfrom the Government, the IRR for a typical 100 TPD plant conversion (100 %capacity ululation) requiring 600 Million Rupees or 700 Million Rupees would be26.27 % and 19.84 % respectively. Along with the interest reimbursement asmentioned, providing 100% depreciation benefits for the capital goods for thenew plant could further act as an incentive for conversion for profit makingunits.

In IRR calculation, the site remediation cost is not considered as adequate sitespecific data on mercury contamination in soil and ground water, quantum of

ground water etc are not available. In case of ground water, depending on thelevel of contamination, treatments like conventional chemical methods followedby activate carbon column or ion exchange has to be done to bring mercuryconcentration consistent with drinking water standards. In order to determineindustry wise cost, separate study may be required. Keeping in view largevolume of ground Water required to be treated, the remediation cost would beenormous and if the same is worked out for individual units based on sitespecific conditions and included in the IRR, the conversion to membranetechnology would become attractive. Further it is to be noted that if the groundwater is being used for irrigation, there are chances of soil contamination with

Hg, which may require soil remediation which is highly expensive option.However, authenticated actual ground water and soil contamination of Hg atnear by site are not available, it is suggested to regularly monitor the Hgcontamination in ground water, soil and air near to the individual site and toestablish the level of contamination for remedial measures. In order todetermine such remedial cost industry wise, a separate study is required.

The investment for conversion on purely cost economics for the units is a riskyproposition and it is difficult to provide a time frame for conversion on costeconomics basis. However as the operating - cost is very much on the higherside, most of the mercury units would be finding it very difficult to stay in themarket for long. However, a financial incentive would help units planning to

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convert for long to speed up The process. It is, therefore, recommended toprovide

(a ) 100% depreciation benefits for the capital goods for plants converting tomembrane cell may be provided. This 100% depreciation benefit may alsobe extended to units which are fully converted to membrane celltechnology after implementation date (i.e. after March 2003) of CREP

recommendations.

(b ) An assistance of minimum 5% interest reimbursement in order to facilitatethe units to speed-up conversion.

The schemes may be available till March 2010 to help maximum number of unitsto take its advantage. The units however have to make the .financial closure forthe deal latest by December 2009 to avail the scheme.

The above financial incentives along with a very strict environmental norms and

monitoring of Hg in groundwater, effluent and air for mercury emission, wouldhelp in speeding up the technology conversion process.

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1.0 INTRODUCTION

Sodium Hydroxide or caustic soda is an important chemical which is requiredfor various sectors viz, pulp & paper, alumina, soaps & detergents, inorganic,etc. Chlorine and sodium hydroxide are co-products that are produced throughelectrolysis of common salt in a fibrine solution. About 1.1 tons of sodiumhydroxide and 0.028 Tons of Hydrogen is produced for every ton of chlorineproduced.

The caustic soda is usually sold in the form of liquid (lye with 48 — 50 %concentration) and in solid form (flakes, prills). The solid form which requiresconcentration is an expensive product and the users are limited, whereas liquidform is widely used.

The largest consumption sector of caustic soda is paper including newsprintfollowed by viscose and aluminum respectively. The percentage breakup of

various caustic soda consuming sectors is depicted in the pie-diagram shownbelow.

The largest consumption sector of chlorine in India is pulp & paper. Thepercentage breakup of various chlorine consuming sectors is shown below:

1

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The following three process are used for the production of caustic soda &chlorine.

•ercury Cell process•iaphragm Process•embrane Cell process

In India, mercury and membrane cell technology are predominantly used forcaustic soda production and share of diaphragm process is negligible. Thepercentage share of technology in India for the production of caustic sodaduring the year 2003-04 is depicted below:

1.1ercury Cell Process

In mercury cell process the electrolysis of brine takes place in main cell withMercury as cathode and dimensionally stable Titanium anodes. At cathodesodium ions are converted into sodium, which forms an amalgam with mercury.This amalgam is made to react with DM/soft water over graphite in secondarycell (decomposer) to produce sodium Hydroxide at 47 % to 50 % concentrationwith the evolution of hydrogen. Mercury is pumped back to the cells. Chlorinewhich is the other byproduct is cooled, dried, compressed and liquefied beforestorage or sale.

Ener & Environmental Facts of Mercury cell process

Energy Emissions Effluents Other Wastes!

ByproductsNet Electricity Source: Source: Waste Spent graphite fromUse: 3250 Fugitive & water from decomposer cells, spentkWh/ton of point source brine pumps, caustic filtration cartridgesCaustic Soda emissions brine section, from the filtration of caustic

(Chlorine, cell wash water, soda solution, spilledHCI and sumps. mercury from sumps, andMercury) mercury cell "butters", brine

mud, spent H2SO4, ETPsludge, etc.

2

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1.2 Membrane-Cell Process

In the membrane process, the anode and cathode section are separated by acation—exchange membrane that selectively transmits sodium ion but suppressesthe mitigation of hydroxyl ions from the cathode section into the anode section.

Saturated brine is fed into the anode compartment, where chorine gas isevolved at the anode and sodium ions migrate into the cathode section throughthe membrane. In the cathode section, hydrogen is evolved at the cathode,leaving hydroxyl ions, which together with sodium ions constitute the causticso da.

Energy & Environmental Facts of Membrane ce ll process _ JEnergy Emissions [ffluents Other Wastes/

Byproducts

Net Electricity Source: Fugitive Source: Process Scrapped CellUse: 2400 & point source waste water from parts (Used

kWh/ton of emissions C12/H2 handling Membranes,Caustic Soda (Chlorine & HCI) section, HCI Anodes &

section, ion Cathodes) spentexchange, waste H2SO4 brine mudwater etc. etc.

1.3 Diaphragm Process

Diaphragm cells contain a porous diaphragm, which is used to separate twohalves of the cell, allow a flow of brine, and to prevent chlorine and hydrogen

from mixing. Brine flows continuously into the anode chamber and then throughthe diaphragm to the cathode. Chlorine gas is formed at the anodes, andsodium hydroxide solution and hydrogen gas are formed directly at the cathode.

Ener y & Environmental Fac ts of d iaphragm proiis

Energy Emissions EffluentsOther Wastes/

Byproducts

Net Electricity Source: Fugitive Source: Wash water ScrappedUse: 2550 & point source from chlorine diaphragm (leadkWh/ton of emissions processing and asbestos) and Cell

C austic Soda (Chlorine, HCI)ther section parts, spent H2SO4 .

1.4 Global Scenario

There are around 500 Chlor alkali industries world wide with an installedcapacity of around 58 million tons of caustic soda production. USA is the largestproducer of caustic soda with an installed capacity of 15.3 million tons closelyfollowed by Western Europe with an installed capacity of 12.5 million tons. Theglobal annual consumption of caustic soda is around 45 million tons and as perone study it is growing at a rate of 3 % per annum.

3

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The technology share for production of caustic/chlorine by various processworld over is depicted in the following pie-diagram.

The percentage technology share of the various process in major caustic sodaproducing countries is as followed:

Mercury Membrane Diaphrag i OthersUSA ^0% 21 % 65% _ 4%W.Eu rope 5 0 % 2 0% 4%Brazil  25 % 4 % 71 % - %Japan -% 100% -% %

India 28% 72% -% -%Source: WCC Indian Chlor Alkali Plants Mercury Conference (15-16 th April 2004)

There are around 125 Mercury Based Chlor Alkali Plant in the world andWestern European Countries with 55 plants (1999) has the maximum number ofmercury based plants.

The major share of Chlorine production by western European countries isthrough mercury process. The distribution of chlorine production process inWestern European Countries is given in Annexure-2. Through sustained efforts,the mercury cell units in Western European Countries have substantially reducedthe mercury emission. The following graphs indicates the mercury emission toair, water and products /Ton of chlorine in European countries.

Source: Mercury Em ission from W estern Chlor-Alkali Industry, Euro Chlor

4

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From 1977 to 1995 the ch.foralkali industry in the Europe reported decreasedemissions of mercury to the environment from 220 tons to 18 tons, a decreaseof 92%. The above results were achieved by the European countries byinvesting more than 800 million ECU for plant sophistication and stricter control.

As per Euro Chlor report, a voluntary commitment was made by 28 Europeanchlorine producers using mercury cell to reduce the mercury emission and thesalient features are given below

Commitments:

No new mercury chlor-alkali plantsMercury cells not to be shipped to third partiesA challenging and quantified mercury emissions reduction programmeReporting and auditing of individual plant emissionsEnd of existing mercury plants by 2020Safe disposal of metallic mercury from shutdown cells

Western European countries, which are having the maximum chlorine productionthrough mercury cell technology, are decommissioning the plants. However themajor reasons for the decommissioning is economical. Following table illustratesthe decommissioning rate of mercury cell plants in Western European Countries.

Scenario Annual decom m issioning rate

1982-95 150000 Tons _199 5 - Til l date 70000 Tons

The list of decommissioned mercury cell units in Western Europe (1986-2002),United States (1989-2002) and Canada (1973 — 1995) is depicted in Annexure —5(a), 5(b) and 6 respectively.

2.0 BACKGROUND, OBJECTIVE & SCOPE OF THE STUDY

2.1 Background

The chlor alkali industry in India is around 60 years old. !t began with a modestcapacity of a few thousand tons per annum and has since grown into a 2.077

million tons per annum (2004-05) capacity industry. As per the informationduring 2004-05 there were thirteen units in India operating with mercury celltechnology and contribute around 24% of the total production. The mercury celltechnology process that is more than a century old is currently facing severepressure from strict environmental regulations as well as from rising cost ofenergy. In India, last two decade showed very clear shift towards the membranecell technology mainly due to environmental regylation and energy efficiency.Considering the hazardous nature of. mercury, the government along withindustries cooperation made an action points under Corporate Responsibility ofEnvironmental Protection (CREP) for regulation of mercury release. Conversion

of Hg cell to membrane cell process is one of the action points and AMAI as

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member of Task Force has agreed that for conversion of mercury cell tomembrane cell technology will be completed by 2012.

However, it was felt the lower energy consumption of the membrane cellprocess itself can be an incentive for Mercury cell units for early conversion inorder to be competitive in the market. In this background Central PollutionControl Board has entrusted National Productivity Council the task ofconducting a cost benefit analysis for changeover from mercury cell technologyto membrane cell technology.

2.2 Objective

To conduct in-depth study in (i) caustic soda plants based on mercurycell process, (ii) plants which have already converted from mercury cellprocess to membrane cell process, and (iii) units which are based onmembrane cell technology, for comparative evaluation of energy

consumption and cost savings etc.

2.3 Scope of the Study

To collect information from all Chlor-alkali units through a detailedquestionnaire in consultation with CPCB with an objective to assimilatevarious details required for comparative assessment of switch over ofmercury cell process to membrane cell process.

2. To carry out detailed literature survey through internet to understand theabove changeover scenario in other countries.

3 . To conduct preliminary field visit (six units) covering two units each fromthe following categories.

• Units, operating with membrane cell process.

• Units operating with mercury cell process.

• Units which are switched over to membrane cell process from mercurycell process.

a .

ithin the six units where preliminary field visits will be conducted, indepthfield study will be taken up in two units under the following categories:

• One unit, which had already switched over to membrane cell processfrom mercury cell process.

• One unit that is going to switch over to membrane cell process frommercury cell process.

The field study in the unit which has switched over to membrane cellprocess will bring out the advantages gained by the unit in terms of

resources conservation & environmental benefit etc and also about the

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hurdles faced, if any. The field „study in the other unit which is in theprocess of switching over will help to -identify the constraints, cost involvedand time required for switching over to the membrane cell process.

5 . Efforts will be made to interact with technology vendors to collect theinformation available for the above said conservation.

6. Based on findings of the field studies. and vendor interactions, a detailedanalysis will be made to establish the economics and time required fortechnology change over. The payback for technology shift will beestablished, considering the following:

• Net energy saving.

• Cost saving & environmental benefits accrued due to avoidance ofmercury sludge disposal requirement. The report will also consider theimport duties of Government for investment envisaged for themembrane cell process.

• Addtional Investment to be incurred by the unt to meet the

recommended norms as per CREP's action points (Annexure-I)dealing with mercury release.

7.o conduct preliminary study at few units committed for change over within two to three years to assess the problems being considered for earlychangeover to compare with those proposed for changeover at later date.

3.0 EMISSION .STANDARDS FOR CHLOR-ALKALI SECTOR

Various countries have made stringent norms for the consumption and emissionof mercury. In Japan, use of mercury has been totally banned since 1984,whereas Mercury consumption in European countries s extremely low incomparison to India. In India commissioning of new mercury plants is totallybanned. Comparison of international standards is given in the table:

USA Germany Japan China India

Waste 0.1 gm/MT 0.04 gm/MT Banned 0.05 mg/I 0.1 gm/MTwater

Air Refer Annex Totalmission 0.012 gm/m3 H2gasolder

_ 4 b 1.3gm/MT stack: 0.2 m /Nm3

Brine Under

on Recovernd Leachedtandard

Sludge hazardous then BDL at

.1

g/I

category after (proposed)recovery _

Legislative Measures and/or Voluntary Programme to change over to membranecell technology for the major Chlorine producing countries are as given

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USA > No requirement to adopt membrane technologyMembrane technology investment are made on economicgrounds by private companiesMany mercury cell factories have closed. Supercedingfactories are often located in a new geographic location, owingto economic grounds. (e.g. better proximity to customers)

Since 1996, voluntary program-

by US mercury cell firms toreduce consumption of mercury (70% reduction to date)W Europeo legislation/regulation except in Belgium, Netherlands,

Sweden which requires phasing out Hg Based Plants by 2010Voluntary commitments of Euro Chlor to fully change over tomembrane cell by 2020, based on `end of economic life' ofeach plantVoluntary program by EUro Chlor members to reduce mercuryemissions and consumption

Japanovernment requirement to replace 20+ mercury cell factories.

This was completed by 1986Brazil y No new plant or expansion can be based on mercury or

asbestoso legislation to phase out existing mercury cell plantsVoluntary program by Abiclor members to reduce emissionsand consumption

India No new plant or expansion based on mercury cellVoluntary commitment to phase out/change over latest by2012 , many plants planning to change over before 2012

Country Legislative Voluntary Target

Norms

USA Max 2300 None New regulation by Decgms/day to 2006 — 2.2 gm/tonatmosphere per caustic productionplant

W Europe 1.8 gm/ton 0.9 gm/ton by 0.9 gm/ton by 2007caustic capacity 2007to atmosphere.

0.9 gm/ton inGermanyBrazil 0.04 m /NM3 None No Change

India. 0.05 mg/NM3 in•

2 gm/T caustic 2 gm/T causticwork zone and production by production by Dec 2005

Dec 2005

Regulations that control releases from environmental sources that containmercury with respect to Chlor alkali sector (CANADA) & National EmissionStandards for Hazardous Air Pollutants: Mercury Emissions From Mercury Cell

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Chlor- Alkali Plants (Environmental Protection Agency) is given in Annexure 4a &

4b respectively.

4.0 CHLOR ALKALI INDUSTRY - INDIA

The chlor alkali industry in India is around 60 years old. It began with a modest

capacity of a few thousand tons per annum and has since grown into a 2.077

million tons per annum (2004-05) capacity industry. The domestic consumption

of caustic soda during the year 2004-05 was around 1.856 million tons.

The last few years have shown a small but steady increase in the production of

caustic soda and the same is shown below:

There are 32units (2004-05) in India manufacturing caustic soda, chlorine and

associated products. The membrane process accounts for 76 % of totalproduction and 24 % is constituted by mercury process during the year 2004-05.

In India the diaphragm process constitutes a very negligible share in the

production of caustic soda and chldrine.

4.1 ImportiExport of Caustic Soda

As per the available data (2002-03), the total import of caustic soda is around

118098 Tons. This constitutes around 6.8% of the total domestic consumption

during that year. The percentage break up of the total import of caustic is as

given below

ti^

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The import of caustic soda in India during the last three years is depicted below:

The total export of Caustic soda by Indian companies during the year 2002-03

was 41804 Tons, which includes lye, flakes and prills.

As per the available data there is a decreasing trend in the import of caustic sodaduring the year 2003-04. One of the reasons for this may be the antidumping lawagainst cheap import of caustic soda.

4.2 Status of Mercury Units in India

In India at present (2005) thirteen units are using mercury process, which areenergy and labor intensive and also it release mercury to the environment. Five

of these unts are operating both mercury & membrane process for

manufacturing caustic soda. Some of these units during the various stages haveincorporated membrane process along with the mercury process. The mercuryconsumption per ton of caustic soda production ranges from 30-85 ton. Therehas been a steady effort by the plants to reduce the mercury consumption. Theperformance of Indian units in comparison with the western European countries,which are operating with Hg requires much improvements. The annual mercuryconsumption of the chior alkali units in Western Europe is around 112 Tons forproducing 6.6 million Tons of caustic soda, which include the mercury released tothe environment as well as in sludge and the un-accounted losses.

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As per the latest information, few of the caustic soda plant which are operatingwith mercury cell technology will be converting to membrane cell technology orwill phase out the mercury process within the next four years. The details of suchunits are given below:

S. Name of the Unit Installed Actual RemarkN.

_capacity Hg

ppcess T/Yr

Production*T/Yr_

1. Bihar Caustic & 51048 52452 Likely conversionChemicals Ltd., Dist. Feb. 2006Palamau, Jharkaha nd

2. Kanoria Chemicals & 52000 47569Industries Ltd.,Sonebhadra, UP

3 . The Travancore- 33000 33000+ ClosedCochin Chemicals Ltd., (Aug. 2004)Kochi, Kerala

4. Shriram Fertilisers & 49600 45074 ConvertedChemicals, Kota, March 2006Rajasthan

5 . Andhra Sugars, 46200 25,410 Hg Cell convertedKovvur, (July 2005)AndhraPradesh likely conversion

of KOH plant by2006

6. M/s. Standard Alkalies 43,325 - Closed 2004

& Chemicals Ltd . _TOTAL

----,75,173 j2,03,505 _

* Average of previous few years (through Hg cell process)

Field visit were made to some of the units to understand their decisions forconversion in spite of the stiff market conditions.

Shriram Fertilizers & Chemicals has a major plan for expanding its PVCplant and as Chorine is the raw material, the Chlor-Alkali plant has to go forcapacity addition. The group has high technical capability and hence they

planned for conversion by getting different equipments from various vendorsto reduce the initial investment.

Travancore Cochin Chemicals Ltd has already converted and for the newcapacity addition of 25 TPD, the unit is getting assistance from Kerala StateFinancial Corporation. The energy & mercury consumption for theTravancore Cochin Chemicals Ltd was also very high.

The central pollution control board, India has enforced many standards forreducing the mercury consumption in caustic soda and the latest is the CREP

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recommendation, which is a voluntary agreement in concurrence with industries

and association. The CREP requires several measures to be implemented by the

units for reducing the mercury consumption. As per the feedback received from

the units through questionnaire, to adhere to the CREP recommendations most

of the mercury cell units will have to incur an average maintenance & monitoring

expenditure of around Rs 40 Lakhs (cost varies from unit to unit). The total

investment so far been made (2005-06) by the Hg cell Chlor-Alkali units under

CREP were about 2.5 crores.

The existing mercury cell technology based units are under pressure from

various environmental monitoring agencies and other organizations. It is highly

likely that the environmental laws will be more stringent in near future and the

investment required by the units to adhere them will be higher.

4.3 Production Cost of Caustic Soda

In case of mercury cells the fixed costs are usually labour and maintenance

considering that most plants are fully depreciated by now. Variable costs mainly

constitutes of salt, handling of lye and power costs. In case of membrane plants

the cost structure is similar except for the steam required for concentrating

caustic solution.

Energy is the most important component in caustic soda production. On an

average the energy cost varies from 63% to 72% of the total production cost.

The percentage share of the various components in the production of caustic

soda and chlorine for a typical membrane cell and mercury cell technology

operating units is given in the following table.

Components_Power

Concentration (49% NaOH )Con tract Demand

Salt

Mercu— _ _Membrane _

Rs/MT11375

01757

NaOH

8400

330

1500

1600 1600

Brine T rea tment Cost 45 0 55 0Mercury Cost ___ __-- ___—_30 ___ 0

Sala ries & Wages

__ __— _1

3 00

__

700_

M ai ntenance 650

M arketing

142                                                                                                                                                                 5_

430  430

Slud ge Treatment/Disposa l —25 5 0__Ov e rheads 300 200_

CREP Recommendation Operating &

Mai ntenan ce cost OTAL PR ODU CTION COST _

150

t_1906_

0

_—14410

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The percentage share of various components in production for a typical mercury& membrane cell unit is shown below:

The average unit electricity cost in most of the countries, which are majorproducers of caustic soda, is less than that in India and considering that theelectricity accounts for the major share in the total manufacturing cost, the chloralkali industries in those countries are in a better.footing. It is imperative that tocounter the onslaught from abroad, Indian companies have to adopt the latesttechnology along with highly disciplined operational practices. The electricityprice of various countries are presented below (also refer annexure-3 )

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4.4 Price of Caustic Soda

The caustic soda is one chemical whose price fluctuation is very high. The pricecan vary from Rs 10,000 — Rs 18,000/ Ton. The price index fluctuation of causticsoda and chlorine for a period of 10 years (1994-2003) is depicted in thefollowing graphs. It can be broadly stated that the price of the caustic soda isstrongly influenced by chlorine, which is a co product. If the caustic demandgrows at the same rate as chlorine, then the price of both the products will bestable. When the chlorine demand is less the caustic production has to bereduced, as chlorine is difficult to store and this situation increases the price ofcaustic, with reduction in chlorine price.

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4.5. International Price of Caustic Soda

The price of caustic soda also fluctuates highly in the international market. Duringthe last 8 years the price of caustic soda fluctuated from 90 US$ to 260 US$. Thegraph below represents the average price of the caustic soda during thecorresponding years

5.0 SURVEY FINDINGS

The survey sample covered sixteen caustic chlorine units across the country,operational during the study period (2004-05), using mercury amalgam as wellas membrane process. Among the unit's responded, installed capacities rangesfrom 10500 TPA to 82800 TPA in mercury cell technology and 41250 TPA to156950 TPA in membrane cell technology.

5.1perating Cost Profile

The key constituents considered in operating cost profile for caustic sodamanufacturing are overall energy cost, salt, brine treatment chemicals, cellmaintenance, cathode, anode, membrane, effluent treatment.

(i)nergy Cost

The overall energy cost in Rs/MT is seen to range from 8400 to 14060 and thekey variants are process, specific energy consumption, cost of energy. Extent ofsourcing from captive/other sources is also a key to lower energy costs in someunits. The SEB electricity cost ranges from Rs 1.9 - 5.4/KWh and hencedependence on other sources viz, captive power generation is increasingtowards cost effectiveness. Another reason for dependence on captive powergeneration is the impact of power trips on plant performance. The number of•hours lost during 2003-04 is in the range of 30 Hrs to 150 Hrs due to voltagefluctuations/power trip and in one of the unit 361 Hours was lost due to abovereason. The impact on pollution level, cell stability etc are felt to be more

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predominant due to the tripping. The average KVA requirement per TPAcapacity is around 0.54 for mercury process and 0.45 for membrane process.

(ii) Salt

Salt, a key raw material . in caustic soda process is also emerging as a major costcomponent. On account type of salt source, transportation costs and quality, saltcosts have a major bearing on the competitiveness of caustic production andimportantly, the resultant pollution levels. The salt cost per MT caustic producedis seen to range from Rs 450 to Rs 1700 in the survey sample, a variation of375% range, which is very significant. The units in the Western part of thecountry have significant advantage in terms of low cost of salt.

(iii) Brine treatment Chemicals

Cost of brine treatment chemicals, variant with process and salt quality are

seen to range from Rs 440/MT NaOH to Rs 540/MT NaOH, being on higherside for membrane plants.

(iv) Maintenance Cost

The maintenance costs of mercury cell units varies from Rs 520/MT to Rs2500/MT of caustic and the average cost is around Rs 1400/MT caustic. Theaverage maintenance cost of membrane cell units is Rs 500/MT of Caustic.The costs is inclusive of maintenance cost towards recoating of anode/cathodeits maintenance etc

(v ) Rectifier Efficiencies

AC to DC conversion efficiency is a crucial stage where energy losses rangingfrom 5-10% takes place. Design rectifier efficiencies range from 91.6% (oldplant) to 98%, while the operational efficiencies are 0.5 to 1.0% less thandesign as reported. Thyrister converters and rectiformers are both in vogue.Apart from contact cleanliness, cooling, ventilation, the actual loading on therectifier system is understood to have an influence on the efficiency. Also onload tap changers (OLTC) are being deployed to take care of voltage variations.

(vi) Instrumentation

Metering accuracy is a point of serious concern and there is a prevalence ofstatic (electronic) energy meters as well as the conventional electromagneticinstruments. Accurate testing of rectifier system efficiency with both AC sideand DC side measurements is called for at regular intervals.

(vii) Current Efficiencies

Current efficiencies are seen to range from 92% to 96% mainly variant with typeof coatings deployed, condition and frequency/periodicity of recoating.

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(viii) Captive Power Usage

Many Chlor Alkali Units are having captive power generation and among theunits surveyed, the installed. capacity ranges from 1095 KVA to 70 MVA. Withcaptive power generation, the power cost on an average reduces by 50-60% ofSEB cost and hence the industry is benefited by better energy cost

effectiveness.

5.2 Capacity Utilization of Mercury Cell Plants

The mercury cell unit in the country has a capacity varying from 30 TPD to 240TPD. Six broad categories covering all the mercury cell units is given below

Capacity No of Units30 TPD 240 —60 TPD 4

100 TPD __ 1120 —150 TPD

660 — 170 TPD 225 TPD

^ 1

As per the published data of caustic soda production (2002-03), the average

capacity utilization of the units in the above mentioned capacity range is givenbelow:

6.0 NEED FOR CONVERSION

Among the various technologies available for commercial production of causticsoda, the most energy efficient one is the membrane cell technology. The worldover new capacity addition is based on the membrane technology. The mercury

cell technology, which is an alternative technology for production of caustic soda,

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not encouraged due to the obvious reason of the release of highly toxic mercuryto the environment. In this back ground during the last three decades themembrane cell technology slowly gained ground and has now become anestablished technology. There exist several advantages for membrane celltechnology vis-à -vis a mercury cell technology and some of them are as depictedbelow

n/ Highly Energy EfficientNo Reduced operating cost due to reduction in chemicals, manpower

requirement etc* Higher product purityn/ Reduced cell downtimen►ncrease in capacity* Avoidance of short-circuiting• Avoidance of mercury

During the study period in 2004-05 there were thirteen units operating withmercury cell technology. As mentioned earlier the mercury cell unit in the countryhas a capacity varying from 30 TPD to 240 TPD. The average installed capacityof different mercury cell units are depicted below

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Most of the units are very old and using vintage technologies for manufacturingof caustic soda. The unit Bihar Caustic & Chemicals Ltd., Jharkhand establishedin 1984 is the latest mercury based plant in India. As per the available data theage of the existing mercury plants in India are depicted in the following graphs

The mercury-based plants are located in different parts of the country and thebreakup along with production capacity is shown below:

The majority of the plants based on mercury cell process are located in Eastern& Southern part of the country.

6.1asis

Though in general plant lifetimes can be of the order of > 45 years, predicting theeconomic viability of chlor alkali plants much beyond 18-20 years is difficultconsidering the dynamic nature of developments in the chemical industry. Henceto calculate the return of investment an economic life of 18 years is consideredfor Hg cell plant.

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6.1.1 Technical Issues

Normally the conversion to membrane cell is carried out for the entire cell roominstead of the sporadic conversions over a period of time within the cell room.The reasons for that are given below

A separate re circulated brine system could be required because even tracesof mercury can significantly deter the performance of the membranes.

The cell layouts are totally different for membrane and mercury cells, and thepower densities and heat loads are also different. This suggests need for aseparate power supply system (rectifiers).

The mercury cell room layout is designed to enable mercury to be contained.Operating membrane cells within the samo cell room would require somemercury containment activities.

This can be done by either retaining the building shell and replacing totally themercury cells with membrane cells or building a new cell room altogether. Thefirst option depends on the quality of the building structure and thedecontamination required prior to installation of membrane cells. In building acompletely new cell room either in the same location, will reduce the downtime required and the decision will be unit specific.

The reuse of the rectifiers, a major cost item, will depend on the type ofmembrane cell configuration and its power requirements, the rectifier

refurbishment options if any, and the age of the rectifier etc. However anysavings from the reuse of inefficient rectifiers (the achievable efficiency ofnew rectifier is around 96%) could potentially be offset to some extent,depending on the circumstances, due to loss of production (includingdownstream processes) from disruption during changeover.

Another factor, which is not considered here is while the conversion has to bedone, relocate the factory to a new location to take advantage for theeconomic factors. This has to be considered keeping in mind the relocation ofemployees and the cost of erecting and commissioning a new grass root plant

that will be higher by around 50 %.

It has been observed that there is no major variation in the price ofmembrane during the last six years.

Increased current density reduces capital costs of an installation because theproduction per unit cell capacity is higher. However there is a trade-offbecause higher current densities mean higher power consumption, and theunit cost of electricity can be a factor when determining the appropriate trade-off between capital cost and power consumption.

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The quality of salt is of utmost importance for caustic soda production usingmembrane cell technology. The survey revealed that few of the mercuryunits are using very law quality salts and they will have to change the sourceof salt when considering the replacement.

6.1.2 Other Issues

The other major issues related to the conversion is given below

1. The price of the caustic soda as mentioned earlier is highly fluctuating.This along with varying price of energy and raw material especially NaClmakes it very difficult for the mercury cell plant operators to make a majordecision like the conversion. The good quality salt purchased by units inEastern Coast is almost three times the cost that is purchased by units inWestern Coast.

2. The units before taking a decision for conversion is looking for assuredmarket but unfortunately for the sector there is no such market. With thePVC market not growng as expected and also pressure due to

environmental aspects to avoid the usage of Chlorine in some of the

important user sectors, the market is really tough. The way out is to have

drastic cost cutting measure, improve the product quality and improve themarketing strategies.

3 . There are very large capacity caustic soda plants coming up in Middle

East. The cost of energy is much cheaper and with latest technology theyare at much better footing. Though there exist , antidumping law againstcheap import, to keep track of imports from various sources will be adifficult task. in that scenario, the mercury cell units especially the smallerunits will find it extremely difficult to sustain in the market..

4. When the plant is converted or shut down there is a possibility of releaseof the mercury to environment and, therefore, very careful planning andexecution of mercury removal and disposal is to be carried out.

5 . The investment required for converting a typical 100 TPD plant isconsidered as Rs 600-700 Mllion, however, it can also be less

depending upon the vendor selection, type of the equipments ordered,technical capability of the concerned units etc.

6. Power failure can deteriorate the life of the membrane, while consideringthe investment the captive power plant cost is not,considered due to thefoïlowings reasons

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Many mercury plants are already having captive power

generation.

A 15 MW power plant may require an additional investment ofaround Rs 450 million

2 Based on an average 1.8 tons mercury in cells for each 1000 tons of chlorine

production capacity (Mercury Cell & Alternative technologies, prepared for EuropeanCommission

7.0 ECONOMICS OF CONVERSION

The following points illustrates the financial benefits for conversion of a mercurycell unit to a membrane cell unit.

7.1ash Inflow

7.1.1 Reduction in energy cost

The reduced energy consumption is the most important economic benefit forconversion of mercury cell technology to membrane cell technology. In mercurycell technology, the average specific energy consumption by Indian industries isaround 3250 KWh/Ton which is inclusive of auxiliary power consumption. Incase of membrane cell technology the average specific energy consumption isaround 2400 KWh/Ton. The reduction in specific energy consumption is to thetune of around 850 KWh/Ton, The average electricity cost is around Rs 3.5/KWh. The reduction in specific electricity cost by going in for membraneprocess would be around Rs 2975/Ton. However in membrane cell the steam isrequired for concentrating the caustic lye from 33% to 48%. The averagespecific steam required for this would be 0.6 Ton/Ton of Caustic. The steamcost (@Rs 550/Ton) would be Rs 330/Ton of Caustic. Hence the reduction inenergy cost by converting a mercury cell plant to a membrane cell plant wouldbe around Rs 2645/Ton of Caustic during the first year. There will be an annualincrease in specific electricity consumption by the membrane plant to the tuneof 40 KWh/Ton from second year till the end of the life of membrane i.e. 4.5years. Hence by the end of 4.5 year the average reduction in energy cost would

be around Rs 2015/Ton of Caustic with out considering the present value ofmoney.

7.1.2 Reduction in maximum demand

As per the feed back received the average KVA requirement per TPA capacity isaround 0.54 for mercury process and 0.45 for membrane process. The averageContract Maximum Demand (CMD) for a typical 100 TPD mercury cell plantwould be around 20 MW and the average CMD for a 100 TPD membrane cellplant would be around 16.5 MW. Considering the average monthly demand

charges as Rs 200/KVA, the annual saving G"hieved by surrendering the

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excess demand would be to the tune of Rs 84 Lakhs. How ever the units whoseproduction is increased after the conversion and the units which rely on 100%captive power generation, the above advantage cannot be realized.

7.1.3 Reduction in electrode coating cost

In case of membrane plants generally both the anode and cathode needs re

coating. The recoating is done by TITANOR Components Limited, Goa and thelife of coating is nine years (Nowadays the guaranteed period by the recoatingagents are 8 years, however the survey revealed that many units are easilyachieving a recoating period of 9 years by proper maintenance). The costincurred for recoating the electrode is around Rs 25000/r 2 . In case of mercuryplants the guaranteed period by the supplier for anode recoating is around 2.2years, however the average reported figures by the units are 2 years. The costof the recoatrng is Rs 18000/m 2 . In both the cases the transportation cost arenot included and also the units will have a spare electrodes and the productionwill not be hampered during the period in which one set of electrodes are sentout for re-coating. Though the coating cost per m 2 of electrodes for membraneplants is higher compared to the coating cost of mercury plants, the overall cashout flow on this account by membrane plants is less due to increased coatinglife.

7.1.4 Reduction in manpower cost

The issues related to manpower reduction by the various units under differentstates is not under the preview of the study. However it is felt appropriate to

mention the difference in manpower cost incurred for production of caustic sodaby both the technology. As per the feed back received from the user units, themanpower cost required can be reduced by around 40 % from mercury celltechnology (based on the financial outflow of the units). However actualmanpower required and its cost implications can be ascertained only afterconducting a detailed manpower study, which would be unit specific. Themanpower cost for a new membrane plant which started its operation withmembrane cell technology is around Rs 700/Ton caustic, which includes salaryand wages. In case of mercury cell plants the average manpower cost is aroundRs 1300/Ton of caustic soda The average percentage of the salary in the total

turn over of the company is around 7% and the same is found to be as high as41% in one of the unit operating with mercury cell technology.

The likely reduction in cost due to reduction in manpower by switching overwould be around Rs 600/Ton of caustic soda, while accepting the different wagestructures prevalent in various units. It has to be thought off redeploying theemployees in a productive manner. Further it is suggested that the individualunit may conduct a detailed man power study from a reputed third party toestablish the manpower requirement with the new process. Based on therecommendation the actual manpower required can be established.

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7.1.5 Reduction in maintenance cost

The prevailing maintenance cost of the mercury cell plant is around Rs1425/Ton of Caustic Soda. In case of membrane plants the averagemaintenance cost is only around Rs 650/Ton of Caustic Soda.

7.1.6 Reduction in mercury abatement measures

At present the unit operating with mercury cell have following operational &maintenance cost from environmental point of view for reducing the mercuryrelated hazards.

1. Waste Water Treatment Plant for mercury bearing effluents2. Brine sludge filtration system3 . Hydrogen demercurisation system4. Mercury bearing sludge Treatment &. Disposal (Stabilization)

Apart from this the unit will incur additional cost for further reducing mercuryemission to atmosphere as per the CREP recommendations. The action pointunder CREP are given below

1. Complete recycle of mercury bearing effluent2. Treatment of cell room ventilation gas for Mercury3 . De — mercurisation of caustic soda4. Mercury reduction in H2 gas5 . Capping of existing completed disposal site

6. Brine sludge treatment, disposal & water leachable mercury content inbrine mud before secure landfill etc

The average operating and monitoring cost incurred under this head would bearound Rs 150Ton of caustic soda. Hence the total operating and

maintenance/monitoring cost incurred by the units for controlling the mercuryemission control would be around Rs 395/Ton of caustic soda.

In case of units operating with membrane cell technology the annual savingincurred by avoiding the operating and maintenance cost of mercury abetment

measures would be around Rs 114 Lakhs for a 100 TPD plant.

7.1.7 Miscellaneous cost savings

Apart from the above mentioned recurring benefits there are some minor onei.e. time cost savings while switching over to membrane cell technology whichare shown below

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(a ) Avoidance of new mercury abatement measures

As per the CREP requirements, the units have to incur around Rs 40 Lakhsannually (based on feedback from units and the cost varies from unit to unit) forvarious mercury abatement measures. If the unit decides for technology changeover they can avoid this expenditure.

(b ) Selling the mercury, copper/aluminium

A typical 100 TPD plant will have around 60 tons of elemental mercury within.the cells. At present the units purchase the mercury at an average price ofaround Rs 350-400/Kg. Even a price of Rs 250/kg Hg, while selling 1100 thecollected Hg after conversion can fetch for a 100 TPD plant around Rs 150Lakhs. After proper de mercurisation, there are some equipments/parts whichcan fetch good value from the market and the prominent one are the copperand aluminum that are used in the plants. There exist a re-melting/recyclingmarket for the above metals. Even by considering the unit receive 60 % ofmarket value of these, the income that can be earned from selling these metalsby a 100 TPD plant would be around Rs 45 lakhs.

In IRR calculation the cash inflow from selling these were taken in the third yearof operation of membrane plants considering the various procedures that maybe involved.

7.2 Cash Out Flow

The major cash outflow due to the investment for technology change over arementioned below

7.2.1 Interest

It is assumed that the unit would have internal funds to provide the advancepayment for the technology (i.e 150-200 Million Rupees) and the balance israised through loans from various lenders. To have corporate loans fromfinancial institutions would be difficult for a few mercury plants as one of criteriafor eligibility is that the unit has to show profit for the last three years. Actual

rate within the prevailing rate would depend upon creditworthiness of borrowerand risk perception. The interest rate considered for finding the IRR is 14 % andthe term for loan is 7 years. Though many of the lenders require therepayments on quarterly basis, which of course would be case to case basisdepending on the projected cash flow of borrower, in this report annual

repayment is considered for simplicity in calculation.

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7.2.2 Membrane Cost

The membrane is the most important component in a membrane based chloralkali plant. The most commonly used membrane size by the Indian industriesis 2.7 m 2 . The membrane is supplied by either M/s' Dupont or M/s Asahi Kasai,

M/s Asahi Glass and Dupont has the major market share in the country. Theaverage cost of the membrane is around US $550/m2 which can vary marginally

depending on the client and order value. At present the customs duty formembrane is 5 %. The membrane deterioration extent can vary depending onbrine purity and stability of cell house operations. There is a tendency amongsome of the units to prolong the use of membrane even after their life span todefer high re-membraning investments at the cost of incremental specific powerconsumption.

The new generation membrane have a guaranteed life of around 4 years(current density of 4.0 kA/m2 ), however due to better operating & maintenance

practice some of the units have achieved 4.5 years with out compromisingmuch on membrane performance. The total cost for replacement of membranefor a 100 TPD plant at the end of 4.5 years would be around Rs 186 Lakhs.

7.3 Calculation of Internal Rate of Return

The conversion project involves cash flows at different point of time and hencesimple payback period which does not consider the time value of money is notconsidered for establishing the cost economics. Hence IRR, which gives the

rate of return the investment is expected to yield is considered for evaluatingthe cost benefits of conversion.

Major Basis/Assumptions for IRR Calculation

The plant is converted from an existing 100 TPD mercury cell plant to a 100TPD membrane cell plant.

The selling price of Electrochemical Unit (ECU) is taken as Rs 17200/Tonand from the past ten years trend, the average annual increase in caustic

soda price is considered as 2%, and average annual increase in Chlorineprice is considered as 5 %.

The selling price of caustic soda is highly fluctuating and market dependent.However the cost index during the past 10 years suggest that averageannual increase of price of caustic soda and chlorine are 2% & 5 %respectively. The inflation rate considered is 5 %.

The electricity cost of the plant is Rs 3.5 /KWH. In the year 2002-03 theaverage electricity cost of SEBs of Southern & Eastern India is Rs

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3.88/KWh. However considering some of the units are using captive powergeneration, the cost is taken to Rs 3.5/KWh.

The project life is 18 years.

The unit has internal resource of 25 % of the total value of the project andthe balance is raised through loans.

The interest rate for the loan amount is 14 % and the repayment has to becompleted within a time frame of 7 years.

The repayment is done on annual basis and the payment will be done at theend of each year as the returns from the investment will be received afterthe end o f the year.

The total project execution period is 2 years which include floating of the

tender, selection of vendor, project execution and commissioning.

The electricity consumption by a membrane plant is 2400 KWh/Ton ofcaustic soda including the auxiliary power consumption. The electricityconsumption by a mercury plant is 3250 KWh/Ton of caustic soda includingthe auxiliary power consumption.

The cost incurred for steam which is required for caustic lye concentration istaken as Rs 330/Ton of caustic soda (Rs 550/Ton of steam & 0.6 Ton ofsteam/Ton of caustic soda)

y The market will be available for the converted unit during the projected life ofthe project.

Though the guaranteed membrane life is 4 years due to better operating &maintenance practice, many of the units have extended the membrane lifeto four & half years with marginal increase in energy consumption. Thecalculations are based on membrane life of 4.5 years.

The recoating of electrode is usually done during the second re-membraning

period and recoating period assumed is 9 years.

There would be annual incremental energy consumption of 40 kWh/Ton tillthe end of the life of membranes.

The Individual units conversion cost benefits is not considered, as thereexist a various cost dynamics involved in the conversion, which are highlyunit specific.

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As it is obvious that the varying cost electricity price and selling price of ECUwill effect the IRR, a table depicting the IRR vis a vis the selling price andelectricity cost is presented at 7.6.4.

7.4 Scenarios Considered for Conversion

The following Scenarios were considered for the conversion of mercury cellplant to a membrane cell plants. To understand the benefits the base capacityof the converted plant is kept as 100 TPD (except scenario #6)of caustic soda.In all scenarios except # 2 it is assumed that the unit would be able to reducethe manpower cost, whereas in scenario #2, the IRR for conversion is workedout with the existing manpower cost.

Scenario #1

The plant is converted by changing the cell house and investment required forconversion is Rs 600 Million for a 100 TPD plant. Here the primary brine systemis same as that for the existing mercury cell plant. The internal rate of return isestablished assuming that 100 % capacity utilisation can be achieved.

Scenario #2

Everything similar to the first scenario, except the unit operates with the existingmanpower cost.

Scenario #3

The plant is converted by changing the cell house and Investment requiredwould be same as scenario #1 i.e Rs 600 Million. The internal rate of return isestablished assuming that 85 °ó capacity utilisation can only be achieved.

Scenario #4

The plant is converted by changing the cell house and replacing existingrectifiers and brine system with new one and investment envisaged is Rs 700Million for a 100 TPD plant. The internal rate of return is established assumingthat 100 % capacity utilisation can be achieved.

Scenario #5

The plant is converted similar to Scenario # 4 and the internal rate of return isestablished assuming that 85 % capacity utilisation can only be achieved.

Scenario #6

The plant is converted by changing the cell house and investment required forconversion is Rs 900 Million for a 150 TPD plant. Here the primary brine systemis same as that for the existing mercury cell plant. The internal rate of return isestablished assuming that 100 % capacity utilisation can be achieved.

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Scena rio #7

The plant is converted by changing the cell house and investment required forconversion is Rs 600 Million for a 100 TPD plant. The unit gets an interestreimburseme nt support 5 % .

7.5 Analysis Result

The detailed internal rate of return has been calculated for the various optionsmentioned in the above chapter and the results are as summarized below

S. ^Option Invest Capacity Interest IRR RemarksNo1. Scenario # 1

ment

60 100 % 14%Utilisation

23.10 % Scheme reasonably

2. Scenario # 2Crore

60 100% 14% 14.93 %Attractiv eScheme is on the

Crorefringeequires

_ _I ____ _ _ critical analVsis_3 . Scenario # 3 60

Cro re

85 % 14% 17.23 % Scheme

is

marlt alit ' a ttractive4. Scenario # 4 70 100% 14% 16.40% Scheme

is

Crore marginally attractive5 . Scenario # 5 70 85% 14% 1 10.12 % Scheme is not viable

Crore6. Scenario # 6 90 100% 14% 20.94% Scheme reasonably

7. Scenario # 7

---

Crore60

Crore _100%

- -

9 % 0

--

26.27%

1—

-

attractiveScheme reasonably

attractive

As depicted above the Internal Rate of Return for Scenario # I and # 6 isreasonably attractive and Scenario # 3 & # 4 is marginally attractive. Scenario 5

is not attractive and Scenario 2 requires further analysis. The major reason for

reduced attractiveness of the options is as listed below:

The uncertain market whereby the price can fluctuate exceptionally andmakes it difficult to predict the future profit margin from the project.he market is very tough and the unit to have 100 % capacity utilization is

a tall order.

Some of the units may find it difficult to reduce the manpower cost and

with existing manpower cost, the cost of production would be higher.t has to be noted that schemes with the present ECU price may become

unviable if the units are unable to reduce their existing manpower cost perTon of Caustic soda & could not achieve 100% capacity utilization.

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7.6ample Calculation for Internal Rate of Return

Units Value

Power Tariff (Existing)

No of Days for Production

Rs/kWhDays

3 .535 0

ProductionJNaO

Production (Chlorine)

TPD

TPD

100

88.00Production (Hydrogen)_____ -TPD 2.20

Cost of NaCl Rs/MT 1000Selling Price of ECU Rs/MT -7200

The calculation shown below for cost benefit is only for the first year of operationof the converted Membrane cell process vis a vis mercury cell operation.

7.6.1.a Mercury Process

Power Consumption (CellHouse) ACPower Consumption (Auxffla!y_

Units

kWh/MTNaOHkWh/MTNaOH_

Vue

_ 3000

25 0Total Power ConsumptionPower Cost

kWh/MT NaOH

Rs/MT NaOH

-25011375

ContractDemand kV A 20500

Cost of ContractDemand Rs/kVA 25 0SpecificCostofContract Demand - Rs/MTNaOH 1757NaCl Consumption MT/MT NaOH 1.6

NaCl Consumpn Cost -s/MT NaOH -1600

Brine Treatment Chemical Cost Rs/MT NaOH 450

Mercury Consumption gm/MT NaOH -

5

Mercury Cost Rs/MT NaOH 30SaaresandWages Rs/MTNaOH 1300MantenanceCost Ri/MTNaOH 1425Marketing _& Re lated _Expenditure Rs/MTNaOH - 429 _88

Sludge Treatment/Disposal Cost

Overheads

Rs/MT NaOH

Rs/MT NaOH

5300

CREP Recommendations Operation &Maintenance Cost

Rs/MT NaOH 150.00

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`fear TRs Crores)

1st Yea r 02 nd Year --- --- ---- 0

-Y—rd Year_- ----- - 1 2. 8 7

4th Yea r____- 13 . 965 th Year 1 5.49

17.72t h Yea r

7th Year 16. 6 2 _

8th YearthY

- - - - - -- _ – --T- 18.98-- _

9t h Yea r -

_20.83

1 0t h Year 1 9 .7 711th Year 20.1312th Year 22.60

13th Year t 2 .211 4th Ye ar 1 . 0 515th Year--_ 0 . 32—16th Y ea r 0.82

17th Year --0.85

18th Yea r- - -

-3. 14 ---19th Year

_ -------^ - --5 . 63 .

2 0th Yea r 8 32

Electrode Coating

Electrode Coating

7.6.2.brofit Loss Analysis (Membrane Cell Process)

Units_ _Val u eCos t of Production Rs /M T NaOH 1 4409.88

Annu al Production Cost Rs Lak hs 5 04 3.46

Annual Production Sales (NaOH ) Rs Lakhs 3850.00Annual Production Sales (Chlorine) Rs (Lakhs) 2156.00Annu al Production Sales (Hydroge  e ) Rs (Lakhs)

Gross Profit ------- - ---._ _ __------------ --- --- — --- Rs (L akh s)-----974 .86

Interest Gr oss Profit B efore Tax

Rs (Lakhs)Rs (Lakhs)

^ __ 0.00974.86

Tax------ --------- ------------- -------

% 3.00iGross Profit after, tax

IRs (Lakhs)_ 633. 66

[Vet Prof it After Conversion

Rs Lakhs t 1287.05

CiimiL•

3 2

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Cash Outflow

Rs Çe!j ITotalInvestment 60OYear 6.01 Year 9 .02_Year 3 .5

3 Year 105!4 Year 10.55 Year 10.56 Year 12.367 Year 10.58 Year 10.59Year 710 Year 5 .3615 Year 1.86

Membrane Replacement

Membrane Replacement & Electrode CoatingMembrane Replacement

Total Investment Rs(Crores)

Years 60

0 Year

lYear

7.2

92 Year 3 .53 Year4 Year

10.

105

5 Year 10.56_Year7 Year

12.3610.5

8 Year 10.59Year 710 Year 5 .3615 Year 1.86

Initial Investment of 10% & Processing &Administration Fees (2(Y o )

Membrane Replacement

Membrane Replacement & Electrode CoatingMembrane Replacement

The IRR for the above project is 231%.

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8.0 RECOMMENDATION

In the long run investing in membrane plant would be very wise decision,considering the higher operational cost and environmental issues associated witha mercury plant. In an ideal case IRR is found to be reasonably attractivesuggesting that the industry can go for conversion. However the actual scenariois different in many cases i.e. in terms of reduced capacity utilization, inability of

the units to reduce manpower cost, fluctuation of product selling price, lowelectricity tariff etc. These factors can make the returns from investment lessattractive.

Though some of the units are in various stages of conversion of technology, mostof the units are hesitating to make a final decision.

nn this scenario an option that can be considered for speeding up theprocess of conversion is to set up a technology up gradation fund/loan tobe given at a lower interest to the unit to facilitate in the conversion. Thiscan be thought about in similar line to the one Govt. of India introduced forTextile & Jute Industries, the salient feature of which are given below

Government of India has introduced the Technology Up gradation FundScheme (TUFS) for Textile and Jute Industries in April 1999, which will bein operation for a period of five years from April 1999 to March 2004. TheScheme is intended to provide induction of state of art or near state of arttechnology in Textile Industry.

Promoter's contribution: Minimum 20% of the cost of the Scheme.

Rupee Loan: Normal applicable rates prevailing at the time ofsanction/execution of loan documents. Ministry of Textiles (MoT),Government of India, has indicated that interest reimbursement of 5% p.a.would be made available to borrowers availing assistance under TUFS.

Foreign Currency Loan: As applicable for normal FC Loan. However,MoT, Gol would provide a cover for actual adverse exchange fluctuationsnot exceeding 5% from the base rate, the base rate being the weighted

average rate covering all disbursements of the loan

Period of loan: To be linked to repaying capacity, normally notexceeding 10 years (inclusive of moratorium).

Security: First charge on fixed assets. Additional security such aspersonal/other guarantees and/or pledge of promoter's shareholdingsmight be stipulated by the lender, if considered necessary.

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• Along wth the interest reimbursement as mentioned above, 100%

depreciation benefits could be provided for the capital goods for the unitsconverted, will further act as an incentive for conversion for profit makingunits. The 100 % depreciation benefit may also be extended to units,which are fully converted to membrane cell technology after the CREPrecommendation implementation date (ie after March 2003)nhe schemes may be available till March 2010 to help maximum numberof units to take its advantage. The units however have to make thefinancial closure for the deal latest by December 2009 to avail thescheme.

Considering the unpredictable market, unit's performance, its financial position etc., it isdifficult to visualize a time frame for the sectoral conversion to membrane technology,purely in terms of the cost economics. However, at present operating costs, most of themercury units are finding it very difficult to survive in the market for long. In the IRRcalculation remediation cost is not considered. If the Hg contamination in ground water,soil and air near to the individual site is monitored regularly and the sources of thecontamination are established, remediation can be insisted from such units within astipulated time frame. Considering the cost involved for remediation, the units areexpected to very seriously consider technology conversion. In order to facilitate earlierconversion, it would be worthwhile to consider providing the financial incentive asmentioned earlier, along with very strict environmental norms for groundwater, soileffluent and air for mercury level.

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Annexure 1

Corporate Responsibility for Environmental Protection

(CREP) Recommendations: Chlor-Alkali Industry

1. Complete recycling of mercury bearing effluent by December 2003.

2. Installation of continuous on-line mercury analyzer by June 2003.

3 . Treatment of cell-room ventilation gas — limit for mercury not to exceed 1gm/t of product by December 2005.

4. De-mercurisation of caustic soda & limit for mercury in caustic soda at0.1 gm/t of product by December 2004.

5eduction of mercury in H2 gas at 0.5 gm/t by December 2004.

6. Installation of common full-fledged salt washery unit at source by Dec.2003.

7. Capping of existing completed disposal sites by June 2004 (Action planto be submitted by June 2003).

8. Installation of mercury distillation units by June 2003

9 . Brine sludge treatment and water leachable mercury content in brinemud at < 0.1 mg/I before disposal in Secured Landfill.

10. Reduction of mercury consumption at < 50 gm/t of product by December2005

11. Total mercury release to environment at < 2.0 gm/t of product byDecember 2005.

12. The mercury cell plants will switch over to membrane cell technology in atime bound manner for which action plan will be prepared by respectiveplants within six months.

13 . Industry to submit action plan covering the pollutional and safety aspectsfor C12 handling to prevent any accident / release of C1 2 , within threemonth.

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Annexure 2

Distribution of the chlorine production processes in West

European countriesMercuryprocess

Diaphragmprocess

Membra eprocessO her processes TOTAL

West Europeancountries

numberof inst

capacity(000'T)

Numberof inst

capacity(000'T)

Numberof inst

capacity(000'T)

Numberof inst

capacity(000'T)

capacity(000'T)

AUSTRIA 1 55 550BELGIUM 5 662 1 120 1 (HCI) 50 832 0

FINLAND 1 40 1 75 1150

FRANCE 7 874 3 560 2 23 2 1 (Na) 20 16860

GERMANY 13 1762 3 1446 4 844 3 (HCI) 23 0 4282 0

GREECE 1 37 370

IRELAND 1 6 60

ITALY 9 812 1 170 9820

NETHERLANDS 1 70 1 140 2 414 6240

NORWAY 1 13 0 2 50 1800

PORTUGAL

SPAIN

SWEDEN

SWITZERLAND

UK

T O T A L

1

9

2

3

^3

55

43

7615

220

1035

856

624

2                                                                                                                                                                 1220

_2496

2

1

1

4

23

46

40

90

105

_2247 5 300_

890

801 5

3100

103 5

1181 0

11284 0

Source: Integrated Pollution Prevention and Control (IPPC) ReferenceDocument on Best Available Techniques in the Chlor-Alkali Manufacturing

industry Dec 2001.

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Annexure 3

Electricity Sales Price in Different Countries

Electricity Sales Price in Different Countries (Cent/kWh)Industry

Country1995 1996 1997 1998 1999 2000

Australia 4.6 6.3 5.6

-

N.A. N.A. N.A.Austria 8.1 8.1 8.1 7.8 N.A. N.A.Bejgum 68 65 5.5 N.A. N.A.N.A.Canada N.A N.A. N.A. N.A. N.A. N.A.Denmark 6.9 7.3 6.4 6.8 6.9 6.5Finland 6.3 6.2 5 .2 5 .0 4.9 4.6FranceGermany

6.010.0

578.6

4.97.2

4.76.7

N.A.N.A.

N.A.

N.A.Greece

6.2 5 .9 5.4 5.0 N.A.N.A.

Irland 6.69318.53.17.5

3.8

6.6 6.3 6.0 6.0 5.6Italy

JapanMexicoNetherlandNewZealandPortugai

101 94 95 95 78

15 .7 14.64.6

N.A.4.3

N.A.4.1

N.A.4.2.8

71

i.4L

6.3 6.2 6.4 6.1

4.0

9.8-

3.5

9.4

3.5

8.5

3.6

8.0228.1

11.2Spain 8.0 6.5 5.9 N.A. N.A.

Sweden 9 4.5 3.4 N.A. N.A. N.A.Switzerland 125 12.0 10.2 10.1 10.2 9.6

Turkey 785 7.7 777.6U.K. 6.8 6.5 6.5 6.5 6.9 N.A.U SAEurope

4.77179

4.6747.4ECD

4.46.56.8

4.06.65 .1

3.6N.A.N.A.

4.0N.A.N.A.

Note. In most of the European countries & USA, the average electricity price is

lower than in India

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Annexure 4a

Regulations that control releases from environmental

sources that contain m ercury with respect to Chlor alkali

sector (CANADA)

The Chlpr-Alkali Mercury Release Regulations under CEPA (1999) limit therelease of mercury into ambient air from mercury cell chlor-alkali plants. Theregulations prescribe the following release limits:

The quantity of mercury that the owner or operator of a plant may releaseinto the ambient air from that plant shall not exceed

a) 5 grams per day per 1,000 kilograms of rated capacity, where the sourceof the mercury is the ventilation gases exhausted from cell rooms;

b) 0.1 gram per day per 1,000 kilograms of rated capacity, where the sourceof the mercury is the hydrogen gas stream originating from denuders,

c) 0.1 gram per day per 1 000 kilograms of rated capacity, where the sourceof the mercury is the ventilation gases exhausted from end boxes; and

d) 0.1 gram per day per 1,000 kilograms of rated capacity, where the sourceof the mercury is the gases exhausted from retorts.

2. No mercury shall be released directly into the ambient air from a tank.

3 . Notwithstanding subsection (1), the total amount of mercury that the owneror operator of a plant may release into the ambient air from the sourcesspecified in subsection (1) shall not exceed 1.68 kilograms per day.

The Chior-Alkali Mercury Liquid Effluent Regulations under the Fisheries Actlimit the level of mercury contained in effluent from Chlor-alkali plants. Theregulations state that mercury deposited in effluent in any day must not exceed0.00250 kilogram per tonne of chlorine times the reference production rate of

the particular plant. The regulations include provisions with respect to sampling,testing and reporting.

SOURCE: UNEP Global Mercury Assessment

(The above regulations are as of November 2002)

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Annexure 4(b)

National Emission Standards for Hazardous Air Pollutants:

Mercury Emissions From Mercury Cell Chlor- Alkali Plants

(Environmental Protection Agency)

Emission LimitationsFor new or reconstructed mercury cell Chior-alkali production facilities, the finalrule prohibits mercury emissions For existing mercury cell Chlor-alkali

production facilities with end box ventilation systems, the final rule requires thataggregate mercury emissions from all by-product hydrogen streams and endbox ventilation system vents not exceed 0.076 g Hg/Mg C12 for any consecutive52-week period For existing mercury cell Chlor-alkali production facilitieswithout end box ventilation systems, the final rule requires that mercuryemissions from all by-product hydrogen streams not exceed 0.033 g Hg/Mg C12for any consecutive 52-week period, For new, reconstructed, or existing

mercury recovery facilities with oven type mercury thermal recovery units, thefinal rule requires that total mercury emissions not exceed 23 mg/dscm fromeach oven type unit vent. For new, reconstructed, or existing mercury recoveryfacilities with non-oven type mercury thermal recovery units, the limit in the finalrule is 4 mg/dscm

Source: Federal Register / Vol. 68, No. 244 / Friday, December 19, 2003 / Rules and

Regulations.

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Annexure 5 (a)

Decommissioned mercury cell Chlor-alkali plants in

Western European Countries

-W ESTERN EU ROPE (1986-200 2)-

DE TAILS OF MERCURY CELL CH LOR-ALKALI PLANT CLO SURES OR CO NVERSION S

(this list is incomplete)

Closure or

conversion

years Last owner

Est. chlorine

Production

capacity (tonnes) Country Location

1986 Akzo Nobel 85,000 Sweden Skoghal

1990-92 Enichem 129,000 Italy Montova

1991 Domsja 35,000 Sweden Domsja

1992 Finnish Chem 45,000 Finland Aetsa

1993 ICI 90,000 UK Fleetwood1993 Soc. Elettrochim 45,000 Italy Tavazzano

1993 Elec Andaiuza 24,000 Spain Ubeda

1994 Octel 75,000 UK Elesmere Port

1994 Nob Forss 13,000 Sweden Koepmanholmen

1994 Enichem 115,000 Italy Gela

1994 Akzo Nobel 58,000 Finland Kuusankoski

1996?? Anaconda 20,000 Italy Saline di Volterra

1996 Borregaard 40,000 Norway Sarpsborg

1997 Caffaro 32,000 Italy Brescia

1998 Micro-Bio Ltd. 6,000 Ireland Fermoy

1998 Solvay 25,000 Portugal Povoa di Sanata ir

1998 Solvay 53,000 Austria Hallein

1998 EC I 65,000 Germany Bitterfeld

1998?? Vestolit 40,000 Germany Luelsdorf

1999 Bayer 300,000 Germany Dormagen

1999 Dow 200,000 Germany Schkopau

1999 Clariant 60,000 Germany Gersthofen

2000 Solvay 146,000 Netherlands Linne Herten

2001 Bayer 130,000 Germany Uerdingen

2002 Wacker 157,000 Germany Burghausen

Note: Due to simultaneous modifications and expansions of other Western European operating mercury

cell chlor-alkali plants (especially in 1994 and 1997), as well as transfers of mercury to other plants for

consumption during routine operartions, the quantities of mercury that reached the international market

were considerably less than the full inventories represented by these closures.

Source: Euro Chlor (1998, 2001 a, 2001 b, 2001 c, 2002a) personal communication with A. Seys, Euro

Chlor.

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Annexure 5 (b)

Decom m issioned m ercury cell Chlor-alkali plants in

United States

UNITED STATES (1989-2002)

DETAILS OF MER CURY CELL CHLO R-ALKA LI PLANT CLOSURES OR CONVER SIONS

Closure orconversion

years L ast owner

Est. chlorine

Productioncapacity (tonnes) City State

1980-1988 LC P 85 ,000 Linden NJ

1984-1987 Olin 109,000 Mcintosh AL

1984-1988 Monsanto 36,500 East St. Louis IL

1980-1988 Pennwalt n.a. Calvert City K Y

1988 OxyChem 51,000 Niagara Falls NY

1988 LCP n.a. Syracuse NY

1989-1994 LCP 96,200 Brunswick GA

1991 Akzo 70,800 Lemoyne AL

1991 LCP 78,900 Moundsville W V

1992 Olin 81,600 Niagara Falls NY

1994 OxyChem 33,600 Mobile AL

1997-99 Georgia Pacific 81,600 Bellingham WA

1998-99 Holtrachem 50,000 Acme NC

2000 Holtrachem 76,000 S. Orrington ME

2002 Westlake 120,000 Calvert City K Y

Note:ome plants have been listed as open in one year and closed in anothernon-consecutive year, leaving one to assume closure or conversion at some pointduring that time period.

Source:Anscombe (2002).

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Annexure 6

Decommissioned mercury cell Chlor-alkali plants in

Canada

Plantocationt a r tloseearsDa tea t ePrince Albert Pulp Saskatoon, Sask 1964 1978 14

Domtar Lebel-sur -Quevillon, Que 1967 1978 1 1

IC I-hawinigan Shawinigan, Que 1938 1979 41

G L Forest Products Dryden, Ont 1962 1975 13

Dow Ch emicals Thunder Bay, Ont 1966 1973 8

American Can Marathon, Ont 1952 1977 25

Dow Chem ical 1 Sarnia, Ont 1948 1973 25

Dow Chem ical 111 Sarnia, Ont 1970 1973 3

IC I-amilton Ham ilton, Ont 1965 1973 8

Alcan Arvida, Que 1947 1976 29

Shawinigan Chemical Shawinigan, Que 1959 1969 10

PPG Inc. Beauharnois, Que 1949 1990 4 1

Con Oxy Ltd. Squamish, BC 1965 1991 26

Canso Chemicals Abercrombie, NS 1970 1992 22

IC I-ornwall Cornwall, Ont 1935 1995 60

IC I-alhousie Dalhousie, NB 1963 Operational

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