Expert witness statement of Mr Edward Joseph Bechberger Expert for Gunns Limited

Transcription

1 Expert witness statement of Mr Edward Joseph Bechberger Expert for Gunns Limited In the matter of the Bell Bay Pulp Mill Project: A project of State Significance Resource Planning and Development Commission inquiry Proponent: Gunns Limited 1 Name and address ERCO Worldwide, A Division of Superior Plus LP 302 The East Mall, Suite 200 Toronto, Ontario, Canada M9B-6C7 EDWARD J BECHBERGER 2 Area of expertise My area of expertise, in so far as it applies to the matters before the Commission, is Chlorine dioxide production processes. My qualifications and experience are detailed in Attachment 1. I am sufficiently expert to make this statement because ERCO Worldwide, A Division of Superior Plus LP ( ERCO ), is one of the first chemical companies and has been operating in Canada since ERCO currently operates seven sodium chlorate, two chlor-alkali facilities and two chlorine dioxide plants for the production of sodium chlorite. Additionally, ERCO has more than 75 years of operating experience in the manufacture of sodium chlorate (Canada, USA and Chile) and approximately 40 years of experience in the operation of chlor-alkali plants in both Canada and the USA. ERCO is one of two companies in the world that over the past 50 years has developed a series of chlorine dioxide processes to meet the changing needs of the industries that use chlorine dioxide. ERCO has supplied over 150 chlorine dioxide processes and has assisted many companies in improving the operation and safety of their plant. For the past 25 years I have worked for ERCO in the field of chlorine dioxide technology, and the marketing of sodium chlorate and process technology. During this period I spent several years as a technical service representative working with customers to trouble shoot operational issues with their chlorine dioxide systems, as well as commission new ERCO Series chlorine dioxide processes. This involved the integration of the chlorine dioxide and co-products into the mills balance, and also liaison with ERCO s and the mill s design teams to determine the process most suited to their particular needs. Expert witness statement of Edward J Bechberger

2 3 Statement Summary The following witness statement was prepared to support and clarify the information supplied by Gunns in the draft IIS with respect to the chemical plant and in particular the chlorine dioxide process described in the base case and option #1 as integrated technology. The draft IIS described the chemical plant in these two cases as consisting of an integrated chlorine dioxide system. The concept of an integrated chlorine dioxide plant has been associated with the pulp and paper industry for many years and is in use at a number of pulp mills around the world. This type of process has been adopted mainly in regions or mills where either the local economics or site remoteness justifies the on-site manufacture of the major bleaching chemicals. The integrated chlorine dioxide process typically consists of a chlor-alkali plant in which caustic (sodium hydroxide) and hydrochloric acid are produced, a sodium chlorate and chlorine dioxide plant. These three plants are linked in that the chlorine dioxide process consumes sodium chlorate and hydrochloric acid in the production of chlorine dioxide (for bleaching), chlorine (recycled to produce hydrochloric acid) and sodium chloride (salt) recycled back to the chlorate plant. The two main raw materials required for this integrated chlorine dioxide plant are salt (for the chlor-alkali production) and electrical energy (for both sodium chlorate and chlor-alkali production). The general description of the chlorine dioxide system in the draft IIS was of a generic nature and only lightly covered the details of the process that result the production of chlorine dioxide solution achieving the low levels of residual elemental chlorine as outlined in the Recommended environmental emission limit guidelines for any new bleached eucalypt kraft pulp mill in Tasmania, Volume 2. The objective of this expert witness statement is to provide a more detailed description of the chlorine dioxide process (section 4), a relevant publication on use of hydrochloric acid in the production of chlorine dioxide (section 3 of Attachment 3), general literature on the chlorine dioxide process (Attachments 4 and 5) and to provide twelve months of operating data (Attachment 2) from a similar system that ERCO operates at its chemical plant in Buckingham, Quebec, Canada. ERCO has operated an integrated chlorine dioxide system at Buckingham since 1987 for the production of sodium chlorite. In 1998 the operation was modified to produce ultra pure sodium chlorite. The modifications involved the use of hydrogen peroxide to convert the residual elemental chlorine in the chlorine dioxide solution to hydrochloric acid. Since 1998 ERCO has consistently operated the chlorine dioxide plant in this manner and has provided a recent twelve months period of operating data from the plant, which demonstrates the residual elemental chlorine in the chlorine dioxide was maintained equivalent to an average of kg chlorine per kg chlorine dioxide in the feed to the chlorite reactor. This data also indicates that during this period the elemental chlorine ranges from to 0.01 kg chlorine per kg chlorine dioxide. The above demonstrated levels of residual elemental chlorine are within the range recommended in the limit guidelines and as described by Beca AMEC as being achievable by chlorine dioxide processes utilizing either methanol or hydrogen peroxide as the reducing agent. Since both the methanol and hydrogen peroxide based systems are considered as Acceptable Modern Technology (AMT) ERCO is representing that the ERCO R5 process is a viable option for Gunns and the information provided is evidence/proof that the process has been in operation for many years and should be regarded as Acceptable Modern Technology. This statement also covers the items related to the chemical plant raised in the conclusions of the Beca AMEC Limited review of the Gunns draft IIS tittled Appendix A Review of Section Bleaching Chemical Preparation of Gunns Draft Integrated Impact statement. Expert witness statement of Edward J Bechberger

3 4 Chemical Production Plant 4.1 Instructions During the preliminary design phase of the pulp mill project, ERCO was requested by Gunns to bid on the supply of the chemical storage and production facility ( chemical island ) for the pulp mill. The request of Gunns set out the scope and other requirements of Gunns and described the chemicals needed for the mill as well as the utilities and raw materials available. During the initial meetings with Gunns, it became evident that the pulp mill would have surplus power available at levels that would support the production of the majority of the bleaching chemicals needed. The scope also identified the need to have low chlorine residual in the chlorine dioxide solution supplied to the fibre line. In order to meet this need, ERCO offered to Gunns a process similar to the one ERCO operates at its chemical plant in Buckingham, Quebec, Canada. The responses arising from the community consultation process indicated to Gunns that an explanation should be provided on the use of a chlorine dioxide system, combined with a sodium chlorate and chlor-alkali plant to produce chlorine dioxide and caustic soda required by the fibre line. ERCO is representing that the ERCO R5 process is a viable option for Gunns and I have been asked to provide evidence/proof that the process has been in operation for many years and should be regarded as Acceptable Modern Technology (AMT). 4.2 Background and Technology Development In 1987 ERCO (then Albright & Wilson Americas, A Division of Tenneco Canada Inc.) began the production of sodium chlorite at its chemical plant in Buckingham, Quebec. The process developed by ERCO integrated an ERCO R5 chlorine dioxide process with the existing merchant sodium chlorate plant at the site. Since the ERCO R5 chlorine dioxide process reacts sodium chlorate with hydrochloric acid under controlled conditions, a significant amount of chlorine is co-produced with the chlorine dioxide. This is typically in the range of 0.85 to 0.90 kg of chlorine per kg of chlorine dioxide. For cost and purity reasons ERCO wanted to lower the residual chlorine in the chlorine dioxide supplied to the sodium chlorite reactor. After a series of meetings between ERCO R&D and Engineering it was determined that the best method to accomplish this was to acidify the absorption water with hydrochloric acid. The published literature in this field suggested that chlorine solubility experienced a minimum of between 0.5 and 0.7 g/l chlorine at between 0.1 and 0.5 N HCl. In order to further reduce the concentration of the dissolved chlorine, ERCO also added a desorption or stripping stage to the process. However, the introduction of air (used to remove the dissolved chlorine) provided only a marginal reduction and increased the potential for chlorine dioxide loss from the absorptive step of the process. The chlorine that exits the top of the absorption tower is sent to a chlorine burner along with hydrogen gas from the chlorate cell line and combined to produce some of the hydrochloric acid for the chlorine dioxide reaction (additional acid is purchased). Since the sodium chlorite produced is sold as a concentrated solution, the chlorine dioxide must be desorbed or stripped from the aqueous solution (chlorine dioxide solution). This is accomplished by heating and then contacting the solution with air in a separate step prior to the chlorine dioxide gas entering into the chlorite reactor, where it is reacted with hydrogen peroxide and caustic soda to produce sodium chlorite solution. ERCO continued to operate the sodium chlorite plant in this manner until 1998, at which time it decided to produce an ultra pure sodium chlorite product. In order to produce this ultra pure product, the residual chlorine in the chlorine dioxide solution had to be lowered even further. Tests involving the application of hydrogen peroxide revealed that the chlorine could be virtually eliminated by its addition to the chlorine dioxide solution prior to stripping, and this was incorporated into the design. To support the effectiveness of the removal of residual chlorine, the operational performance of the process at Buckingham, Quebec ERCO has attached 12 months of operating data, (Attachment 2). Expert witness statement of Edward J Bechberger

4 The operating data consists of daily production of both chlorine dioxide and sodium chlorite. The production of chlorine dioxide is calculated based on the volumetric water inputs to the chlorine dioxide absorption step, and the chlorine dioxide solution concentration measured continuously by a photometric analyser and checked daily by a manual test. The basis of the manual test procedure is the published TAPPI Standard J.14P entitled 'Chlorine Dioxide Plant Analyses'. The neutral and acid potassium iodide titration method is shown for the ClO 2 Solution test, while the air stripping into neutral KI solution is shown for the determination of ClO 2 and Cl 2 in the acidic generator solution (manual test procedure could be attached). The Buckingham data show that the chlorine dioxide and residual chlorine concentrations in the chlorine dioxide solution for the 12 months averaged 9.44 and 0.53 g/l respectively, and ranged from 5.1 to 10.7 g/l and 0.41 to 0.66 g/l respectively. The next step in the process is the addition of hydrogen peroxide to convert the residual chlorine in the chlorine dioxide solution to hydrochloric acid prior to entering a desorber. The reaction between chlorine and hydrogen peroxide has been found to be very effective at reducing the chlorine. The chemical reaction is expressed as: Cl 2 + H 2 O 2 2HCl + O 2 Air is used in the desorber to strip the chlorine dioxide gas from the solution (any remaining chlorine would also be stripped) and transport it to the chlorite reactor, where the chlorine dioxide reacts with peroxide and sodium hydroxide to produce the concentrated sodium chlorite solution. It is important to note that any chlorine gas that enters the chlorite reactor with the chlorine dioxide would also react with the peroxide and caustic to produce sodium chloride via the following overall reaction. Cl 2 + 2NaOH + H 2 O 2 2NaCl + O 2 + 2H 2 O The presence of sodium chloride provides a direct measure of the chlorine remaining after the treatment with hydrogen peroxide described above. At Buckingham, ERCO monitors the sodium chloride in the finished sodium chlorite product and includes it in the certificate of analysis of the sodium chlorite product sent to the customers, and for reference has included the sodium chlorate and sodium chloride analysis associated with every shipment during the twelve month period. The sodium chlorite and sodium chloride test methods are the American Water Works Association standards, in this case ANSI / AWWA B (Attachment 3). The sodium chlorite and sodium chloride concentrations for the same twelve-month period averaged 501 and 3.3 g/l respectively. This is equivalent to an average of kg chlorine per kg chlorine dioxide in the feed to the chlorite reactor. The data ranges from to 0.01 kg chlorine per kg chlorine dioxide. ERCO has not taken into consideration the sodium chloride introduced to the sodium chlorite solution with the sodium hydroxide since the sodium chloride was low (95 ppm). The above Buckingham data provides a demonstrated track record that a low chlorine integrated chlorine dioxide plant is technically effective and economically viable in an industrial mode. Further, based on the guidance provided by the Resource Planning and Development Commission (Recommended environmental emission limit guidelines for any new bleached eucalypt kraft pulp mill in Tasmania, Volume 2) based on Table 4 page 20, the ERCO process merits the description of AMT for bleaching chemical preparation in that it is On-site generation of chlorine dioxide with low contamination of elemental chlorine (methanol or hydrogen peroxide processes). This low elemental chlorine content is further reinforced by Beca AMEC Limited in their Appendix A Review of Section Bleaching Chemical Preparation of Gunns Draft Integrated Impact statement dated Expert witness statement of Edward J Bechberger

5 October 2006, in which they state the elemental chlorine contamination for a methanol or hydrogen peroxide based chlorine dioxide generator is to 0.01 kgcl 2 /kg ClO 2. Therefore the ERCO R5 chlorine dioxide process with post treatment of the chlorine as described at ERCO s Buckingham site falls within this range and therefore should also be considered as AMT based on the low elemental chlorine present in the final chlorine dioxide solution. Bell Bay Plant Gunns required the chlorine dioxide generating system to achieve chlorine concentrations in compliance with the referenced 0.2 g/l residual in the chlorine dioxide solution supplied to the bleaching stages (as indicated in the Recommended environmental emission limit guidelines for any new bleached eucalypt kraft pulp mill in Tasmania Volume 2). Since ERCO is not aware of any pulp mills operating a chlorine dioxide plant at these low levels using hydrochloric acid as the reducing agent, ERCO considered a process that is being used internally for the manufacture of high purity chlorine dioxide for the manufacture of sodium chlorite. The basic concept is to produce the chlorine dioxide in the same reactor design as the other ERCO crystallizing chlorine dioxide plants (ERCO R3, ERCO R8, and ERCO R11) except that the chlorine dioxide would be produced by reacting sodium chlorate with hydrochloric acid. The products from this reaction are chlorine dioxide (gas), chlorine (gas) and sodium chloride (solid). ERCO refers to this process as the ERCO R5 (a basic process description and flow diagram is in attachment 4 & 5 respectively). In the ERCO R5 process there are two conditions under which the reaction of sodium chlorate and hydrochloric acid occurs to be critical. The first is maintaining a constant absolute pressure in the system. This determines the temperature in the reaction liquor and is maintained by means of an indirect heater (reboiler) with low pressure steam. The second condition is the molar ratio of chloride to chlorate in the reaction liquor. The lower the mole ratio the higher the gas purity of the chlorine dioxide produced, indicating that the preferred chlorine dioxide producing reaction is occurring. The two generally accepted reactions that occur in a chloride based chlorine dioxide process are as follows: Preferred Reaction: NaClO HCl ClO Cl 2 + H 2 O +NaCl Undesired Reaction: NaClO HCl 3 Cl H 2 O + NaCl Since ERCO uses a crystallizing process, it is able to control the chloride to chlorate mole ratio in the generator by evaporating more or less water. Because of the solubility differences between sodium chlorate and sodium chloride under these conditions, the sodium chloride preferentially crystallizes and is removed from the chlorine dioxide process and returned to the sodium chlorate cells. In addition the presence of sodium dichromate in the cell liquor influences the preferred reaction slightly, resulting in an improved conversion of the sodium chlorate to chlorine dioxide. Since the ERCO process evaporates the water entering the process, the concentration of dichromate in the reactor can be significantly increased over what is normally supplied by the cell liquor. This provides a benefit in stabilising the process. Flow through or non-crystallizing processes cannot provide the same stability, since the chloride to chlorate ratio is dependent on the incoming cell liquor concentration. The water vapour created from the evaporation/crystallization step is used to dilute and transfer the chlorine and chlorine dioxide produced from the reactor through a cooler and into the absorption tower. Expert witness statement of Edward J Bechberger

6 In order to ensure the chlorine dioxide solution produced is consistently below 0.2 g/l chlorine, the following steps are: 1. The chilled absorption water is acidified with hydrochloric acid to a targeted normality of 0.1N. This is achieved by cascading the hydrochloric acid flow with the chilled water flow. Published data indicated that the solubility of chlorine can be suppressed by the presence of hydrochloric acid, with a minimum solubility near 0.1 to 0.2 N acidity, which then slowly increases once again as the acidity increases. 2. The use of a small stripping (air) section on the bottom of the absorption tower to further reduce the chlorine solubility. 3. The remaining chlorine would then be converted to hydrochloric acid by the addition of hydrogen peroxide to the chlorine dioxide solution as it is pumped to the chlorine dioxide storage tanks. The flow of hydrogen peroxide would be cascaded with the chlorine dioxide production rate. This approach is consistent with the practice at Buckingham except that the chlorine dioxide solution would be used directly by Gunns in the pulp mill. 5 Material Considered In preparing this statement I have reviewed the following documents (insofar as they are relevant to the chemical production plant), in addition to drawing on my own knowledge and experience and that of ERCO: Development of new environmental emission limit guidelines for any new bleached eucalypt kraft pulp mill in Tasmania (2004); Appendix A review of Section Bleaching Chemical Preparation of Gunns Draft Integrated Impact Statement prepared by Beca AMEC Limited; and Section of Volume 1 of the Draft Integrated Impact Statement submitted by Gunns. 6 Response to Beca Amec Limited I have reviewed the Beca AMEC Limited conclusions listed in their report titled Appendix A Review of Section Bleaching Chemical Preparation of Gunns Draft integrated Impact statement dated October 2006 and have the following comments: Conclusion No. 1 I would agree with their general statement that the chlor-alkali process does require that the operators be properly trained and supervised in order to ensure the system is safe and reliable. Expert witness statement of Edward J Bechberger

7 Conclusion No. 2 I agree with Beca AMEC s conclusion on the capability of the integrated chlorine dioxide (IDP) plant to consistently produce chlorine dioxide solution containing low levels of elemental chlorine with only the use of acidified chilled water and the use of stripping air. ERCO observed that in order to significantly reduce the chlorine levels in the chlorine dioxide solution with air, the resulting economic loss of chlorine dioxide (also stripped) does not justify the practice. It was however determined that the addition of hydrogen peroxide to the acidified chlorine dioxide solution is an effective and reliable means to reduce the chlorine content to very low levels as discussed earlier in the statement. This view is supported by the operating from the facility operated at Buckingham, Quebec. Conclusion No. 3 The issue raised in this conclusion is a global issue that is a concern for all pulp mills as they tighten up the liquor cycle and adapt effluent recycle scenarios. The management of non process elements, particularly potassium and chloride becomes problematic and as a result many pulp mills are installing chloride and potassium management (removal systems) that will allow for the selected removal of these elements from the recovery circuit. This is beyond my scope, but I understand that Gunns is planning on installing such a system. The impact on the capital cost would be a function of the precipitator ash or liquor requiring treatment to maintain the desired levels in the circuit. Conclusion No 4 B.1 Emission is 10 mg/nm 3 Cl 2. This is achievable with a caustic scrubber. B.2 Emissions are about 5.6 mg/nm 3 ClO 2 and 4.3 mg/nm 3 Cl 2. This is achievable with peroxide/caustic scrubber as proposed. However flow rate is about 3 times greater than from R-series generator. As such ERCO R-series generator emissions should be 1/3 of stated emissions. B.3 HCl emissions are about ½ the rate stated by an HCl burner supplier and Cl 2 emissions are about double. The lower values will be achieved by the addition of a small caustic scrubber after the standard water scrubber. B.4 No Comment. In summary all the identified gaseous emissions from the chemical plant as stated in the draft IIS will be achieved. Conclusion No 5 C1 Flow of 991 kl/d is a conservative number. Expert witness statement of Edward J Bechberger

8 In the base case, the main liquid effluent will be from the chlor-alkali unit in the form of a sulphate purge from the brine system. This brine purge is estimated at 0.06 m 3 per tonne of sodium hydroxide produced, so if for example the production rate is 60 tonnes per day of sodium hydroxide then the purge volume is estimated at 3.6 m 3 per day. The brine purge stream composition is estimated (based on preliminary salt composition) as 200 to 220 g/l NaCl, 100 to 120 g/l Na 2 SO 4 and less than 15 g/l NaClO 3. The chlor-alkali unit will also produce a solid (sludge) waste from the brine treatment stage. The volume of this sludge is estimated at 0.05 m 3 per tonne of sodium hydroxide produced. It is Gunns intent to slurry this material and send it to the mill effluent system. The estimated composition of this sludge is as follows: CaCO 3, Mg(OH) 2 and other minor insolubles 10 % NaCl, Na 2 SO 4, H 2 O 90 % For the base case there would be no solid waste from the sodium chlorate. Conclusion No.6 Solid waste is produced in the chemical plant as a result of the impurities in the salt and water used to produce the brine for the chlor-alkali plant, and in the case of the merchant sodium chlorate plant from both the brine and mother liquor treatment. In the base case the only solid waste produced is from the brine treatment area. The composition of the solid waste is described in conclusion # 5, and the estimated waste produced is approximately 0.05 m 3 per ton of sodium hydroxide produced. No solid waste is generated from the chlorate plant since there is a closed circuit with respect to salt between the chlorine dioxide generator and the sodium chlorate cells. In the case of the two merchant sodium chlorate plants the estimated total mud produced is expected to be 8 kg/tonne of merchant sodium chlorate produced, based on a merchant capacity of 30,000 tonnes per year this would equate to 240 tonnes per year (this can vary depending on the quality of the salt). The mud is from two sources: first from the salt used to produce the brine needed (this is estimated at 3.6 kg/tonne or 108 tonnes per year) and the second from treatment of the mother liquor in the plant to remove mainly sulphate that builds up in the liquor circuit (estimated at 4.4 kg/tonne or 132 tonnes per year). The brine mud 108 tonnes per year can be separated and handled in a similar manner to the brine sludge from the chlor-alkali plant. The mud produced from the chlorate mother liquor is more complex since it is formed as a result of the build-up of sulphates in the mother liquor. Calcium chloride (CaCl 2 ) is added to the sodium chlorate (NaCl0 3 ) solution to form calcium sulphate (CaSO 4 ). Perchlorates are removed by adding potassium chloride (KCl) to form less soluble potassium perchlorate (KClO 4 ), The mud slurry will be directed into the mud filter press for dewatering and the solid waste transported with the other solid wastes to a licensed Waste Facility. The expected composition of the combined solid wastes from the brine, acid wash, mother liquor treatment and mother liquor filter is given in the table below. Approximately once a month the solid wastes will be transported in a specially fitted and appropriately licensed truck. Expert witness statement of Edward J Bechberger

9 Expected Initial Composition of the Combined Treatment Solids Component A Sodium Chlorate Weight (%) B Calcium Sulphate - CaSO 4 2H 2 O Water - Free - H2O Cellulose Filter Acid 5.80 Sodium Chlorate NaCl Calcium Carbonate CaCO Sodium Chloride NaCl 1.80 Magnesium Hydroxide Mg(OH) Iron (III) Hydroxide - Fe (OH) Calcium Chromate - CaCrO 4 2H 2 O 0.39 A. After 2-5 years of operation, a second treatment process for perchlorate removal from mother liquor will be started and the combined treatment solids will contain about 5% KClO 4 as well. B. The composition may vary significantly with variations in raw materials and the sequencing of the various treatment processes. The composition shown is an approximation based on the other plants. Conclusion No. 7 No comment. Conclusion No. 8 Expert witness statement of Edward J Bechberger

10 Upon reviewing the overall material balance for the mill outlined in Volume 7, Annex IV of the DIIS, my interpretations of the chlorine dioxide usage in the bleach plant as indicated on page 6 of 14 is t/a or 47.8 t/day. A peroxide or methanol based chlorine dioxide plant would produce the equivalent of 51.6 t/d of sodium sulphate (salt cake). The salt cake make-up listed on page 8 of 14 indicates that the recovery boiler requires t/a, or 40.6 t/day, this would result in 11 t/day of sodium sulphate being sent to the effluent treatment plant. Conclusion No. 9 I would suggest that the base case and the proposed Alternative 2A could both be considered just-in-balance options depending on the utilization of chlorine dioxide and hydrogen peroxide in the fibre line. The selection of bleaching chemical requirements are typically determined by the type of fibre to be processed and the final quality or properties of the market pulp required to meet target markets. The chemical plant configuration is determined on the basis of these requirements. In the case of a mill such as Gunns where they are producing power and are remote from low cost sources of caustic and peroxide, the base case would (likely) be favoured. 7 Management and Operations This has two parts: one will be the operator s (Gunns or other party) environmental and safety management processes. The second relates to the design of the plant, and the methods used to identify the risks and design the system to manage the risk. During the process design stage, a hazard and operability study (HAZAN or HAZOP) would be conducted on the plant to identify the potential risk and modify the design or manage the risk and mitigate any impacts. This study would also be used to ensure that all the safety interlocks needed to protect the environment, personnel and equipment are adequate. ERCO is a member of Responsible Care, which is a set of initiatives undertaken by all members of the Canadian Chemical Producers Association (CCPA) to help safeguard employees, the environment and the communities with which we come in touch. 8 Conclusion In conclusion, I consider that a properly designed, maintained and operated integrated chlorine dioxide process can consistently produce chlorine dioxide solution for the intended purpose of bleaching wood pulp in which the residual elemental chlorine content can be equivalent to that of the methanol and hydrogen peroxide based chlorine dioxide process (0.005 to 0.01 kgcl 2 /kgclo 2 ). I trust that my explanation of the operation of the sodium chlorite plant designed and operated by ERCO Worldwide demonstrates that the residual chlorine can be effectively managed in a chloride based chlorine dioxide plant. I have considered the definition of Acceptable Modern Technology (AMT) as defined in the State Policy on Water Quality Management 1997 and Environmental Protection Policy (Air Quality) 2004 as a technology which has a demonstrated capacity to achieve the desired emission concentration Expert witness statement of Edward J Bechberger

11 in a cost-effective manner, takes account of cost-effective engineering and scientific developments and pursues opportunities for waste minimisation in relation to Gunns proposed pulp mill. To the best of my knowledge, I believe that a chemical plant comprised of an onsite chlor-alkali, sodium chlorate plant and a chloride based chlorine dioxide process designed to comply with the low chlorine residuals is within the spirit of the definition above. From the broad perspective Gunns intends to produce surplus electrical power from biomass on the site. The mill location is remote with respect to supply of sodium hydroxide and hydrogen peroxide, but is relatively local to Australian salt supplies. The installation of a modern chlor-alkali plant capable of producing the majority of the sodium hydroxide requirements of the mill from the excess power will provide the mill with stable long-term supply. Combining this with an on-site chlorine dioxide plant and sodium chlorate plant further reinforces the mill s competitiveness by consuming local resources mainly within the mill s control (power). The use of hydrogen peroxide to ensure the production of high purity chlorine dioxide for bleaching and the use of hydrochloric acid in the bleach plant are cost effective methods for waste minimisation, since the sodium sulphate contribution to the mill effluent will be reduced. 9 Provisional opinion The opinions that I have expressed in this report are based on my experience and the experience and advice provided to me by Gunns Limited and the consultants engaged to carry out specialist studies for the Bell Bay Pulp Mill Project. Subject to any limitations and exclusions identified in this statement, my opinions are, to the best of my knowledge, complete and accurate in every material respect. Through my inquiries I am satisfied that the opinions I have expressed are reasonable in regard to Chlorine dioxide production processes. 10 Declaration I have made all the inquiries that I believe are desirable and appropriate and no matters of significance which I regard as relevant have, to my knowledge, been withheld from the Commission. Expert witness statement of Edward J Bechberger

12 Attachment 1 1 Qualifications 1. Education and Development Courses Ryerson University, formerly Ryerson Polytechnical Institute (Toronto, Canada) 1977 to 1980 Diploma in Chemical Technology (Industrial Chemical Option) 1980 to 1986 Bachelor of Technology (Chemical Engineering) Development Program (external) 1991 Advanced Management Course (five-day course at Tenneco Inc. s training office) Strategic Marketing of Technology Products (three day course offered at California Institute of Technology) Account Development Strategies (three day course offered by Learning International) 1994 Managing Sales Force (five day course offered by Learning international) 1994 Winning Through Value-Oriented Marketing (two day course lead by Philip Kotler, Sponsored by The Presidents Association of Canada) Kepner Tregoe: Problem Solving & Decision-Making 1998 Price as a Strategic Weapon (three-day course offered by American Management Association) Intermediate Finance and Accounting for the nonfinancial Executive (three-day course offered by American Management Association) The Management Program: a detailed two-week program offered at the University of Michigan School of Business. This program focused on Finance, accounting, organizational behavior, Marketing and Strategic thinking. Development programs (internal) 1980 to present Quality and Quality Systems Expert witness statement of Edward J Bechberger

13 Leadership Development Process I & II (developed by Procorp Group) Quality Function Deployment House of Quality Statistical Process Control Methods ISO 9000 ISO 9001 Safety training Process Safety Management Risk Identification and Prevention Behavioural Safety Training SafeStart Named as inventor on 14 issued patents relating to chlorine dioxide production. Have presented several papers at Pulp and Paper industry conferences around the world. 2 Professional associations Technical Association Pulp & Paper International (TAPPI), Member 1981 to 2006 Canadian Pulp and Paper Association (CPPA now PAPTECH), Member 1981 to present Publications Tappi Reduction of Saltcake and Production of Caustic from a chlorine dioxide Generator, 1995 Pulping Conference Proceedings In-Plant Solutions for Decreasing effluent Conductivity in Bleached Kraft Pulp Mill; Managing Excess ClO 2 Generator saltcake, 2003 Environmental Conference Proceedings The Use of Hydrochloric Acid For ClO 2 production, 1984 pulping conference (copy below) 3 Relevant publications Publication # 1 THE SOLUBILITY OF CHLORINE IN AQUEOUS SOLUTIONS OF CHLORIDES AND THE FREE ENERGY OF TRICHLORIDE ION By M. S. Sherrill and E. F. Izard Published in May 1931 Publication # 2 (see below) Expert witness statement of Edward J Bechberger

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15 ERCO Worldwide A division of Superior Plus LP Operating Data ERCO Buckingham (12 Months) Page 1 of 9 Time Kg/hr ClO2 operating rate Kg/hr ClO2 Target rate ClO2 MT/day rate Absorber ClO2 (gpl) Absorber Cl2 (gpl) Absorber HCl (N) NaClO2 MT/day production rate Date %NaClO2 gpl NaClO2 gpl NaCl NaClO2 g/l expresse NaCl g/l d as ClO2 expressed g/l as Cl2 g/l Cl2 WT% in ClO2 Calculated g/l Cl2 in a 10 g/l ClO2 sol. 01-Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Oct Oct Oct Oct Oct Oct Oct Oct Oct Oct Oct Oct Oct Oct Oct Oct Oct Oct Oct Oct Oct Oct CONFIDENTIAL

16 ERCO Worldwide A division of Superior Plus LP Operating Data ERCO Buckingham (12 Months) Page 2 of 9 Time Kg/hr ClO2 operating rate Kg/hr ClO2 Target rate ClO2 MT/day rate Absorber ClO2 (gpl) Absorber Cl2 (gpl) Absorber HCl (N) NaClO2 MT/day production rate Date %NaClO2 gpl NaClO2 gpl NaCl NaClO2 g/l expresse NaCl g/l d as ClO2 expressed g/l as Cl2 g/l Cl2 WT% in ClO2 Calculated g/l Cl2 in a 10 g/l ClO2 sol. 18-Oct Oct Oct Oct Oct Oct Oct Oct Oct Oct Oct Oct Oct Oct Oct Oct Oct Oct Nov Nov Nov Nov Nov Nov Nov Nov Nov Nov Nov Nov Nov Nov Nov Nov Nov Nov Nov Nov Nov Nov Nov Nov Nov Nov Nov Nov Nov Nov Nov Nov Nov Nov Dec Dec Dec CONFIDENTIAL

17 ERCO Worldwide A division of Superior Plus LP Operating Data ERCO Buckingham (12 Months) Page 3 of 9 Time Kg/hr ClO2 operating rate Kg/hr ClO2 Target rate ClO2 MT/day rate Absorber ClO2 (gpl) Absorber Cl2 (gpl) Absorber HCl (N) NaClO2 MT/day production rate Date %NaClO2 gpl NaClO2 gpl NaCl NaClO2 g/l expresse NaCl g/l d as ClO2 expressed g/l as Cl2 g/l Cl2 WT% in ClO2 Calculated g/l Cl2 in a 10 g/l ClO2 sol. 04-Dec Dec Dec Dec Dec Dec Dec Dec Dec Dec Dec Dec Dec Dec Dec Dec Dec Dec Dec Dec Dec Dec Dec Dec Dec Dec Dec Dec Dec Dec Jan Jan Jan Jan Jan Jan Jan Jan Jan Jan Jan Jan Jan Jan Jan Jan Jan Jan Jan Jan CONFIDENTIAL

18 ERCO Worldwide A division of Superior Plus LP Operating Data ERCO Buckingham (12 Months) Page 4 of 9 Time Kg/hr ClO2 operating rate Kg/hr ClO2 Target rate ClO2 MT/day rate Absorber ClO2 (gpl) Absorber Cl2 (gpl) Absorber HCl (N) NaClO2 MT/day production rate Date %NaClO2 gpl NaClO2 gpl NaCl NaClO2 g/l expresse NaCl g/l d as ClO2 expressed g/l as Cl2 g/l Cl2 WT% in ClO2 Calculated g/l Cl2 in a 10 g/l ClO2 sol. 20-Jan Jan Jan Jan Jan Jan Jan Jan Jan Jan Jan Jan Jan Jan Feb Feb Feb Feb Feb Feb Feb Feb Feb Feb Feb Feb Feb Feb Feb Feb Feb Feb Feb Feb Feb Feb Feb Feb Feb Feb Feb Feb Feb Mar Mar Mar Mar Mar Mar Mar Mar CONFIDENTIAL

19 ERCO Worldwide A division of Superior Plus LP Operating Data ERCO Buckingham (12 Months) Page 5 of 9 Time Kg/hr ClO2 operating rate Kg/hr ClO2 Target rate ClO2 MT/day rate Absorber ClO2 (gpl) Absorber Cl2 (gpl) Absorber HCl (N) NaClO2 MT/day production rate Date %NaClO2 gpl NaClO2 gpl NaCl NaClO2 g/l expresse NaCl g/l d as ClO2 expressed g/l as Cl2 g/l Cl2 WT% in ClO2 Calculated g/l Cl2 in a 10 g/l ClO2 sol. 08-Mar Mar Mar Mar Mar Mar Mar Mar Mar Mar Mar Mar Mar Mar Mar Mar Mar Mar Mar Mar Mar Mar Mar Mar Mar Mar Mar Mar Apr Apr Apr Apr Apr Apr Apr Apr Apr Apr Apr Apr Apr Apr Apr Apr Apr Apr Apr Apr Apr Apr Apr Apr Apr Apr Apr Apr Apr Apr Apr Apr CONFIDENTIAL

20 ERCO Worldwide A division of Superior Plus LP Operating Data ERCO Buckingham (12 Months) Page 6 of 9 Time Kg/hr ClO2 operating rate Kg/hr ClO2 Target rate ClO2 MT/day rate Absorber ClO2 (gpl) Absorber Cl2 (gpl) Absorber HCl (N) NaClO2 MT/day production rate Date %NaClO2 gpl NaClO2 gpl NaCl NaClO2 g/l expresse NaCl g/l d as ClO2 expressed g/l as Cl2 g/l Cl2 WT% in ClO2 Calculated g/l Cl2 in a 10 g/l ClO2 sol. 24-Apr Apr Apr Apr Apr Apr Apr Apr Apr Apr May May May May May May May May May May May May May May May May May May May May May May May May May May May May May May May May May May May May May May May Jun Jun Jun Jun Jun Jun Jun Jun Jun Jun Jun CONFIDENTIAL

21 ERCO Worldwide A division of Superior Plus LP Operating Data ERCO Buckingham (12 Months) Page 7 of 9 Time Kg/hr ClO2 operating rate Kg/hr ClO2 Target rate ClO2 MT/day rate Absorber ClO2 (gpl) Absorber Cl2 (gpl) Absorber HCl (N) NaClO2 MT/day production rate Date %NaClO2 gpl NaClO2 gpl NaCl NaClO2 g/l expresse NaCl g/l d as ClO2 expressed g/l as Cl2 g/l Cl2 WT% in ClO2 Calculated g/l Cl2 in a 10 g/l ClO2 sol. 10-Jun Jun Jun Jun Jun Jun Jun Jun Jun Jun Jun Jun Jun Jun Jun Jun Jun Jun Jun Jun Jun Jun Jun Jun Jun Jun Jun Jul Jul Jul Jul Jul Jul Jul Jul Jul Jul Jul Jul Jul Jul Jul Jul Jul Jul Jul Jul Jul Jul Jul Jul Jul Jul Jul Jul Jul Jul Jul Jul Jul Jul Jul Jul Jul CONFIDENTIAL

22 ERCO Worldwide A division of Superior Plus LP Operating Data ERCO Buckingham (12 Months) Page 8 of 9 Time Kg/hr ClO2 operating rate Kg/hr ClO2 Target rate ClO2 MT/day rate Absorber ClO2 (gpl) Absorber Cl2 (gpl) Absorber HCl (N) NaClO2 MT/day production rate Date %NaClO2 gpl NaClO2 gpl NaCl NaClO2 g/l expresse NaCl g/l d as ClO2 expressed g/l as Cl2 g/l Cl2 WT% in ClO2 Calculated g/l Cl2 in a 10 g/l ClO2 sol. 27-Jul Jul Jul Jul Jul Jul Aug Aug Aug Aug Aug Aug Aug Aug Aug Aug Aug Aug Aug Aug Aug Aug Aug Aug Aug Aug Aug Aug Aug Aug Aug Aug Aug Aug Aug Aug Aug Aug Aug Aug Aug Aug Aug Aug Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep CONFIDENTIAL

23 ERCO Worldwide A division of Superior Plus LP Operating Data ERCO Buckingham (12 Months) Page 9 of 9 Time Kg/hr ClO2 operating rate Kg/hr ClO2 Target rate ClO2 MT/day rate Absorber ClO2 (gpl) Absorber Cl2 (gpl) Absorber HCl (N) NaClO2 MT/day production rate Date %NaClO2 gpl NaClO2 gpl NaCl NaClO2 g/l expresse NaCl g/l d as ClO2 expressed g/l as Cl2 g/l Cl2 WT% in ClO2 Calculated g/l Cl2 in a 10 g/l ClO2 sol. 12-Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep CONFIDENTIAL

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28 4 Employment history, achievements and projects worked on EDWARD J. BECHBERGER 2. Work History 2005 to present Vice President & General Manager International Operations This position reports to the President with the responsibility for all of ERCO s interests, which includes both product manufacturing and sales of chemicals and technology. June 2003 to 2005 V.P. Sales & Marketing This position reported to the President with the responsibility for the marketing, sales and distribution of all of ERCO s products, both chemical and technology. The chemicals sales responsibility included Sodium Chlorate, chlorine, sodium hydroxide, hydrochloric acid, calcium hypochlorite and sodium chlorite. The technology responsibility included the development, sale, design, procurement, commissioning and ongoing servicing of proprietary technology that converts the sodium chlorate to chlorine dioxide a gas that is used to remove lignin from pulp and sodium chlorite for the water treatment and specialty business to June 2003 Commercial Director Pulp & Paper Strategic Business Unit This position reported to the Vice President (later changed to President) of the Pulp & Paper Business Unit and has two primary responsibilities. The first is the marketing and sale of the business unit s only chemical product: Sodium Chlorate, with a total production capacity of 460,000 tonnes from five plants located across Canada and one in the South Eastern US. The second responsibility for the development, sale, design, procurement, commissioning and ongoing servicing of proprietary technology that converts the sodium chlorate to chlorine dioxide a gas that is used to remove lignin from pulp to 1998 Marketing Director, Pulp & Paper This position reported to the Vice President of Marketing and was responsible for the marketing and sale of sodium chlorate and the company s proprietary technologies. During this period the company expanded its sodium chlorate capacity by 150,000 tonnes as a result of building a Greenfield plant in the southern US and acquiring an existing plant to 1995 Manager Marketing Expert witness statement of Edward J Bechberger

29 This position reported to the Vice President of Marketing with the responsibility for the sale and distribution of sodium chlorate. Reporting to me was the Manager of Technical Services and Customer Services to 1993 Sales & Market Development Manager This position reported to the Director of Technology with the responsibility of selling the company s proprietary technologies, while laying the foundations for new products that were in development. This position had no direct reports but required close working relationships with customers, field reps., engineering and R & D departments to develop products or modification of existing products to meet industries changing needs to 1992 Manager Technical Services This position reported to the Director of Technology with the responsibility of managing and developing the field service personnel, assisting the sales manager and dealing with any customer issues that arose as we completed the contract commitments. During this two-year period the company had a record number (over 30) chlorine dioxide chemical plants to commission due to an environmental concern over dioxins to 1990 Manager Electrochemical Marketing This was a newly created position reporting to the Director of Technology with the responsibility of developing a new product line based on the companies expertise in electrochemistry, and strategic alliances with other companies that could provide value added expertise and equipment to complement our capabilities. I was responsible for establishing a budget and a marketing plan for this new business to 1988 Technical Service Representative This position reported to the Technical Service Manager. The responsibilities included Servicing and handling complaints from the sodium chlorate customers and commissioning the technology sold (chlorine dioxide plants). The activities related to the technology involved the following: training the customers operators and shift supervisors, participating/leading the mechanical and safety checkout of the system, leading the chemical start-up, trouble shooting and resolving any issues, completing the performance tests and ongoing service as required. Since the sale of chlorine dioxide technology was a global business, I was involved in several start-ups overseas, with some projects lasting as long as six months it provided a great learning opportunity to understand operation of chlorine dioxide plant and it s integration in the pulp mill to 1981 Laboratory Technologist This position reported to the Manager of Research and Development, and the duties involved working on assigned projects to support the production of sodium chlorate. Expert witness statement of Edward J Bechberger

30 Attachment 2 Twelve Months of Operating Data from ERCO s Buckingham Plant (This data is listed in the next 9 pages) Expert witness statement of Edward J Bechberger

31 Attachment 3 Test procedure for sodium chlorite and sodium chloride ANSI / AWWA B Reprinted by permission. Copyright 2005, American Water Works Association. No further reproduction of this document may be made without written permission of the publisher. Expert witness statement of Edward J Bechberger

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61 The ERCO TM R5 Process Attachment 4 When by-product salt cake is not required the R5 process can be used, particularly where by-product sodium chloride can be utilized instead. The generating system consists of a Generator and a shell and tube Heat Exchanger. This unit operates at about 70 o C and 190 mm Hg. The Generator liquor is circulated by an axial pump in the line between the Heat Exchanger and the Generator. The sodium chlorate feed is introduced before the Pump while the hydrochloric acid is added at the Heat Exchanger discharge. Steam is supplied to the heat Exchanger and, under vacuum conditions in the Generator, the water introduced into the system is evaporated resulting in crystallization of sodium chloride. The evaporated water acts as the chlorine dioxide gas diluent. The chlorine dioxide gas passes into an Indirect Contact Cooler where the evaporated water is partially condensed, thus increasing the condensation of the chlorine dioxide. This stream of chlorine dioxide, chlorine and water vapour then passes into the Chlorine Dioxide Absorber. The water flow to this tower is adjusted automatically by an on-line photometric analyzer to provide the required chlorine dioxide solution strength. Chlorine leaving the chlorine dioxide absorber is absorbed in a Chlorine Absorption Tower to form the chlorine water or hypochlorite. The Generator, Indirect Contact Cooler, and Tower are maintained under vacuum by a steam jet ejector or vacuum pump. Generator slurry is pumped to a rotary vacuum filter. Here the sodium chloride is continuously removed and the mother liquor and wash water are returned to the Generator. The sodium chloride is fed by gravity into a tank for dissolving or handling as a wet salt depending on end use. Plants can be supplied in modular or for conventional construction. The same basic ERCO R3 Generating Plant is used for production of ClO 2 by the R5 mode of operation. The plant can be readily adapted for any mode of ERCO R SERIES ClO 2 operation. The R5 process is disclosed in Canadian patents No. E and E owned by ERCO Worldwide. Similar patents are owned by Sterling Canada Inc. in many other countries. The R5 Process incorporates technology developed by Dow Chemical Canada Inc. under Dow s U.S. Patent No. 4, 137,296 and Canadian Patent No. 1,223,715. CHEMICAL CONSUMPTION INPUT Kg/kg ClO 2 Sodium Chlorate 1.70 Hydrochloric Acid 1.30 CREDITS Sodium Chloride 1.00 Chlorine 0.70 REFERENCE PLANTS CUSTOMER / LOCATION CPFP Dryden, Ontario, Canada Oulu Oy Oulu, Finland Enzo Gutzeit Imatra, Finland Expert witness statement of Edward J Bechberger

62 Attachment 5 Standard ERCO R5 flow diagram indicating the location of hydrochloric acid and hydrogen peroxide addition to the process for low chlorine content in the chlorine dioxide solution Hydrochloric Acid Air Hydrogen Peroxide Expert witness statement of Edward J Bechberger