The industry federation Euro Chlor distributed its 2009-2010 annual report in April at its chlorine technology conference & exhibition under the title, "The spectre of substitution calls for vigilance." While this holds true for all branches of the chemical industry, the chlorine-alkali sector often finds itself at the center of debate when it comes to issues such as the Restriction on Hazardous Substances (RoHS); many environmental lobby groups have been pushing for a ban on organochlorines, organobromides and PVC for use in electric appliances.

While a plenary vote in the parliament didn't lead to an outright ban under the RoHS Directive, chlorinated chemicals face continued pressure, for example by placing them on various priority lists. Some substances have been placed on the Reach candidate list for Substances of Very High Concern (SVHC) and for example also on the "POP-list"(UNEP Stockholm Convention).

In his foreword in the annual report, Euro Chlor Executive Director Alistair Steel discusses the two paths within the "spectre of substitution."
"The Cefic Policy Center sees substitution being implemented in two dis¬tinctly different ways." The first one, he writes, is via legislation, particularly through Reach. The second one is market-driven substitution.

Steel says that kind of substitution is particularly difficult to tackle, as "it is never obvious just who is driving it in any particular instance." Using PVC - the largest single consumer for chlorine - and the recent ban on use of dichloromethane in paint strippers to illustrate his point, he says that it's clear that environmentalists are the ones active in lobbying for bans and tighter regulations, but downstream users and retailers also play a role. Also, Steel points out that many companies sometimes offer substitutes where testing is not yet complete.

"This is bad practice and will result in splintering our chemical industry as a whole," he writes. "We will look foolish, and worse still our efforts to act from a position of unison and the strength which that brings will be seriously compromised."

One concrete point of substitution of a hazardous chemical used in production the chlor-alkali industry has been working steadily on is the replacement of mercury-based plants with new membrane ones. Membrane technology now accounts for more than 51% of the industry's installed capacity, which is on track for the group's voluntary commitments to have phased out all mercury-based chlor-alkali capacity by 2020.

Mercury, Diaphragm And Membrane

Chlorine is produced by electrolysis using three main technologies: mercury, diaphragm and membrane. Ten years ago, mercury technology accounted for about 60% of European chlorine capacity (including the non Euro Chlor mem¬bers). There is a clear trend of a gradual shift away from mercury cells to the more energy-efficient membrane technology (today: mercury: 31.8 % - membrane: 51.2%). Three mercury cell rooms were converted to membrane technology during 2009, and another was definitively shut down. During 2010, some plants reduced their mercury based capacity.

Market Overview

After being deeply affected by the 2008-2009 downturn, 2010 chlorine production and demand registered the fastest rebounds, albeit remaining well below the pre-crisis levels. With nearly 10 million tons in 2010, European chlorine production was 9.9% higher than in the previous year. The 2010 average capacity utilization rate reached 79.0% compared to 71.1% in 2009.

Germany remained Europe's largest chlorine producer, accounting for 45% of European production, followed by Belgium/The Netherlands with 15.7%, and France with 11.4%. These top three regions accounted together for 72% of total European chlorine manufacture in 2010.
After a drastic drop and, consequently, record high stock levels in 2009, demand for caustic soda - an essential co-product in the making of chlorine - managed to recover although it is still not as robust and stable as before the crisis. Overall average monthly stock levels remained just below the 250,000 tons mark. In May 2011, stocks were down to 234,000 tons.

Conference Highlights

At the 8th International Chlorine Technology Conference & Exhibition in Budapest, industry players and stakeholders discussed a wide-range of topics, from technology to safety, health and environmental protection. Some highlights included:

• Dolf van Wijk, Euro Chlor's director of Science & Regulatory Affairs, discussed the new industrial emissions directive and what implications it has for the chlor-alkali industry. Van Wijk emphasized that the new directive, which went into effect in January, replaces the IPPC and varies in several points from it. Member states have two years to implement it, and its aim is to harmonize plant permitting in order to create a level playing field.
• Philippe Ancery, Solvay, went over the decommissioning of mercury electrolysis units. He said that at the beginning of 2011, there were still 34 chlorine cell rooms using mercury cell technology in Europe, and that mercury-based capacity represents today about 31.8% of the total chlorine production capacity. He used Solvay as an example, which has shutdown three mercury plants between 2006-2001 and has two slated for a partial shutdown in order to convert them in 2012.
• AkzoNobel: The Dutch chemical company's Industrial Chemicals business unit spoke about its mTA, which is used as an anti-caking agent for salt. In the 1950s, the company developed ferrocyanide for this use, but with today's membrane electrolysis in chlorine production, ferrocyanide isn't removed during brine purification, putting it at a cost disadvantage. AkzoNobel's mTA is a substitute for ferrocyanide that matches its performance while addressing the issue of increased energy consumption.
• Ineos Technologies: The UK-based developer and licensor of technologies for the global petrochemical industry discussed technical considerations for membrane cellroom design, touching on the four key aspects that should be considered in design: brine purity and salt selection; cellroom pressure control; stray current management; and shut-down management. They also discussed their Bichlor electrolysers, which are designed to minimize the life time costs of manufacturing chlorine, sodium/potassium hydroxide and hydrogen while maintaining the highest safety standards.
• Uhdenora: The Italy-based joint company of Uhde and Industrie de Nora looked at the major challenges facing the chlor-alkali industry in the near future: the rising cost of energy; the phase-out of mercury; the recycling of chlorine and the transport of liquid chlorine.

A Mercury-Free Future
Executive Director Alistair Steel on Euro Chlor's Activities

CHEManager Europe: The mercury process still is used in 31% of all chlorine processes. What does EuroChlor actively do to phase out the mercury process capacity?

Alistair Steel: In 1999, Euro Chlor negotiated a voluntary agreement with the European Commission in which all Euro Chlor members agreed to convert their mercury-based chlorine plants to membrane by 2020. I am pleased to say that to date, all Euro Chlor member's conversion plans are in line with the voluntary phase-out of mercury technology by 2020. This is how we've been able to reduce the amount of mercury still being used in the industry to 31%.

We are also in continuous dialogue with various member companies to aid them in their discussions with their national regulatory authorities. In fact, some countries have phase-out dates that are well before 2020. We're able to help companies formulate their plans as well as their costs. However, every conversion from mercury to membrane is individual, specific to the site where the conversion is taking place.

The chlorine-alkali industry is an energy intensive industry because of the electricity that is needed as a raw material which cannot be substituted. Does the electricity come only from fuel and gas resources and what alternatives could be used in the future?

Alistair Steel:The chlorine industry primarily purchases from multinational electricity generators, and what fuel they use tends to be a political matter. They have their own policies on where they get their fuel from, ranging from gas and coal to renewable resources, like wind, water and even wave-generated electricity. But as consumers, Euro Chlor members have no influence over what that fuel source ultimately is.

However, in some instances, combined heat and power - the so-called CHP generation scheme - which are used on-site, can offer some flexibility. But CHP schemes have tended to be fueled by gas in recent years, or other waste gases that are available from other processes on the site, particularly if the site is close to an oil cracker. The bottom line is that as a consumer, we have no control over what the alternative fuels are.

Nuclear power plays a role in the chlorine process as well, especially in Asia and the Middle East. Facing the nuclear disaster in Japan, what does Germany's complete pullout from nuclear power by 2022 mean for the industry?

Alistair Steel: As I mentioned before, as consumers, we don't have any control over what kinds of fuel is used in the energy mix. Germany's decision to pull out of nuclear power was entirely political. As far as the chlorine industry is concerned, it does raise concerns over security of supply. I'm sure that from a political point of view, the German authorities will assure that there will be an adequate supply for both industrial and domestic use. So far, there's no real effect on us, but we will continue to monitor the situation carefully in the hope that we can influence a secure supply of electricity well into the future.

How would you describe the relationship between EuroChlor and the European Commission and Parliament?

Alistair Steel: I would say that our relationship is one of healthy respect, which hasn't always been the case. If we go back 25 years when Euro Chlor was just being started up, I would say the respect wasn't there. In fact, it was very adversarial - we were constantly under attack. Over the years, Euro Chlor, through its work with the Commission and the Parliament, has been able to show that it is worthy of trust.

Professor Justin Greenwood of Aberdeen University in concluded in a 2004 benchmark study that Euro Chlor was one of the most trustworthy European trade organizations. This doesn't mean that Euro Chlor gets an easy ride from the European institutions - we are constantly being challenged - but we are respected for our use of sound science, common sense and good use of risk assessment processes. In fact, we were probably one of the first organizations to really use this concept in its argumentation with the European authorities.