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ANALYSIS of ALTERNATIVES Public Version ANALYSIS OF ALTERNATIVES Public Version Legal name of applicant(s): Kemira Chemicals Oy Submitted by: Kemira Chemicals Oy Substance: Sodium dichromate Use title: Use of sodium dichromate as an additive for suppressing parasitic reactions and oxygen evolution, pH buffering and cathode corrosion protection in the electrolytic manufacture of sodium chlorate with or without subsequent production of chlorine dioxide or sodium chlorite. Use number: 1 Disclaimer This report has been prepared by Risk & Policy Analysts Ltd, with reasonable skill, care and diligence under a contract to the client and in accordance with the terms and provisions of the contract. Risk & Policy Analysis Ltd will accept no responsibility towards the client and third parties in respect of any matters outside the scope of the contract. This report has been prepared for the client and we accept no liability for any loss or damage arising out of the provision of the report to third parties. Any such party relies on the report at their own risk. Note This public version of the Analysis of Alternatives includes some redacted text. The letters indicated within each piece of redacted text correspond to the type of justification for confidentiality claims which is included as an Annex (Section 7) in the complete version of the document. Table of contents 1 Summary..............................................................................................................................1 1.1 Use applied for................................................................................................................................1 1.2 Potential alternatives for sodium dichromate................................................................................1 1.3 Suitability of potential alternatives to sodium dichromate............................................................4 1.4 Feasibility and availability of potential alternatives for sodium dichromate .................................6 1.5 Actions needed to improve the suitability and availability of potential alternatives...................10 2 Analysis of substance function ............................................................................................ 13 2.1 The chlorate process.....................................................................................................................13 2.2 Conditions of use and technical feasibility criteria.......................................................................20 2.3 Summary of functionality of sodium dichromate in the “Applied for Use” .................................27 3 Annual tonnage.................................................................................................................. 29 3.1 Tonnage band ...............................................................................................................................29 3.2 Trends in the consumption of sodium dichromate ......................................................................30 3.3 Form and usage of sodium dichromate........................................................................................30 4 Identification of possible alternatives.................................................................................. 31 4.1 List of possible alternatives...........................................................................................................31 4.2 Description of efforts made to identify possible alternatives ......................................................31 4.3 Screening of identified alternatives..............................................................................................61 5 Suitability and availability of possible alternatives............................................................... 83 5.1 Introduction ..................................................................................................................................83 5.2 Chromium(III) chloride..................................................................................................................83 5.3 Sodium molybdate........................................................................................................................93 5.4 Molybdenum-based coatings .....................................................................................................103 5.5 Two-compartment electrolytic systems .....................................................................................109 6 Overall conclusions on suitability and availability of possible alternatives.......................... 117 6.1 Technical feasibility of shortlisted alternatives ..........................................................................117 6.2 Economic feasibility of shortlisted alternatives..........................................................................119 6.3 Reduction of risks from the use of shortlisted alternatives........................................................120 6.4 Availability of shortlisted alternatives ........................................................................................121 6.5 Overall conclusion.......................................................................................................................122 7 Annex – Justifications for confidentiality claims................................................................. 125 8 Appendix 1 – Information sources..................................................................................... 127 9 Appendix 2 – Comparative hazard and risk characterisation of alternatives........................ 131 9.1 Background .................................................................................................................................131 9.2 Reference values for sodium dichromate and alternative substances.......................................131 9.3 Exposure Assessment..................................................................................................................154 9.4 Comparative risk characterisation..............................................................................................159 9.5 References for this Appendix......................................................................................................160 10 Appendix 3 – Economic feasibility ..................................................................................... 163 10.1 Economic feasibility of sodium molybdate.................................................................................163 10.2 Economic feasibility of molybdenum-based coatings ................................................................172 10.3 Economic feasibility of two-compartment electrolytic systems.................................................177 1 Summary 1.1 Use applied for This Analysis of Alternatives (AoA) is part of an Application for the Authorisation (AfA) for the continued use of sodium dichromate (CAS No. 7789-12-0 & 10588-01-9; EINECS No. 234-190-3, hereafter referred to as “SD”) by the applicant, Kemira Chemicals Oy (hereafter referred to as Kemira), in the sodium chlorate (NaClO3) manufacturing process, where it acts as a crucial additive to the process. Generation of sodium chlorate is based on the electrolysis of sodium chloride (NaCl), at a controlled pH range, where the chloride is converted into sodium chlorate while hydrogen evolves as a co-product. SD acts to increase the current efficiency of the conversion process by suppressing unwanted (parasitic cathodic) reactions and thus reducing the use of electrical energy, and acts as a pH buffer to ensure optimal process conditions are maintained. It also has a crucial role in limiting the amount of oxygen generated during the process, the presence of oxygen poses a serious hazard because it will forms explosive atmospheres in the presence of hydrogen. Kemira is using <#B# tonnes of SD out of a total consumption of <40 tonnes consumed in this use by EU-based manufacturers of sodium chlorate. This overall volume represents less than 1% of the entire amount of SD used each year in the EU. This AoA has been prepared by an independent third party working on behalf of Kemira and a further six EU-based users of SD who collectively formed the Sodium Dichromate Authorisation Consortium (hereafter referred to as SDAC). While there is notable overlap in the information presented and the argumentation made in the AoA documents of all seven applicants, each AoA document, including the present one, is tailored to the specific applicant and describes the specific situation for Kemira. It must be noted that each of the company-specific AoA documents may include information which is available only to the applicant and which (a) is confidential, and (b) does not appear in the AoA documents of the remaining SDAC applicants. 1.2 Potential alternatives for sodium dichromate This AoA details an extensive search of literature carried out by the independent third party. In addition, consultation with all seven SDAC members regarding their extensive R&D efforts has been used in conjunction with the publicly available information to ensure all relevant alternatives have been considered. In total, ten alternative substances and technologies were identified and evaluated, and these are summarised in Table 1-1. Table 1-1: Master list of identified potential alternatives for SD in sodium chlorate manufacture No Potential alternative substances 1 Chromium (III) chloride 2 Sodium molybdate 3 Rare Earth Metal (III) salts No Potential alternative cathode coatings
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