Summary of the Final Report “Development of a feasibility study and technical documentation for the establishment of the recycling and disposal system in the fishing industry of the Murmansk oblast for ODS and F-gases” Vasily Tselikov

International Centre for Scientific and Technical Information (ICSTI)

Project “Phase-out of Fluorinated Greenhouse Gases and Ozone-Depleting Substances at Fish and Seafood Processing Enterprises of the Murmansk Oblast (Arctic Zone of the Russian Federation). Phase 2”

Summary of the Final Report

Development of a feasibility study and technical documentation for the establishment of the recycling and disposal system in the fishing industry of the Murmansk oblast for ODS and F-gases. Vasily Tselikov (2022), 126 pages.

The Final report “Development of a feasibility study and technical documentation for the establishment of the recycling and disposal system in the fishing industry of the Murmansk oblast (FI MO) for ozone-depleting substances (ODS) and fluorinated greenhouse gases (F-gases)” includes the following sections:

1. Development of the technical documentation for the establishment of the ODS and F-gases recycling and disposal system in the Murmansk oblast.
2. Development of the feasibility study for the establishment of the ODS and F-gases recycling and disposal system in the Murmansk oblast.
3. Conclusions.
4. Recommendations.

The section “Development of the technical documentation for the establishment of the ODS and F-gases recycling and disposal system in the Murmansk oblast” covers ODS and F-gases destruction technologies approved by the Parties to the Montreal Protocol on Substances that Deplete the Ozone Layer, and permitted by the laws and regulations of the Russian Federation in effect.

The technologies potentially suitable for the destruction of ODSs and F-gases in the Russian Federation are:

• cement kilns;
• gaseous/fume oxidation;
• rotary kiln incineration;
• portable plasma arc;
• superheated steam reactor.

The report shows that no facilities for environmentally sound destruction of ODSs and F-gases are currently available in the Murmansk oblast.

In the Russian Federation, gaseous/fume oxidation facilities are operated by enterprises of OJSC HaloPolymer in Perm and Kirovo-Chepetsk. Designed for in-house application, these are unlikely to be used for disposal of halogen-containing wastes owned by third parties.

Only one domestic manufacturer, NPO Dekanter, LLC (Domodedovo, Moscow oblast), offers rotary drum-type kilns potentially suitable for destruction of ODSs and F-gases. Mobile thermal destruction units offered by company allow treating oil sludge with extremely high content of mechanical impurities, oil-contaminated soils, drilling sludge, oil-contaminated waste from oil and oil-product spills, municipal solid (MSW), and other bulk and paste-like wastes at high temperatures.

Specifications and technologies of these units comply with requirements of the Montreal protocol, however relevant tests are required to confirm compliance with requirements to environmentally sound destruction of ODSs and F-gases. It appears that equipping Thermal Municipal Solid Waste Treatment Plant, AO, Murmansk, with these units would solve the problem of destructing the said substances not only in FI MO but in other sectors of the regional economy.

The report presents a detailed list of equipment for ODS and F-gases recuperation, recycling, and recycling to establish the ODS and F-gases recycling system on the basis of BarentsCool Ltd. The list was prepared with due regard of devices, mechanisms, special tools and materials already available at the company’s facilities, agreed with the company, and may be included in the terms of reference for future bidding.

The report provides a detailed analysis of the laws and regulations of the Russian Federation that control collection, transportation, processing, disposal, decontamination, and placement of wastes of hazard classes I–IV that should include ODSs and F-gases.

According to the Federal Service for Supervision of Natural Resource Usage, collection, transportation, processing, disposal, decontamination, and placement of wastes of hazard classes I–IV does not include the recuperation of ODSs (and F-gases) for recycling or destruction, meaning that BarentsCool Ltd. needs no license to conduct the mentioned activities.

Should the Ministry of Natural Resources and Environment of the Russian Federation attribute ODSs and F-gases to any hazard class from I to IV, BarentsCool Ltd. will have to be licensed, and for that end significant time and material input would be required. To minimize associated risks, a detailed step-by-step instruction to acquire a relevant license and related documents has been prepared.

The report covers in sufficient detail the issues of obtaining permits for the establishment and operation of a specialized ODS and F-gases destruction center on the basis of either an existing or a newly established company engaged in decontamination of MSW and industrial waste.

With the establishment of such an ODS and F-gases destruction center in the Arctic zone of the Russian Federation, transportation of ODSs and F-gases that cannot be reclaimed, to a destruction site would be less expensive and complicated, and prerequisites for its self-sufficiency would be created.

The section “Development of the feasibility study for the establishment of the ODS and F-gases recycling and disposal system in the Murmansk oblast” provides a detailed overview of the international and national legislation on recuperation, recycling, and destruction of ODSs and F-gases.

The section also covers regulatory approach under the Montreal protocol and Code of Good Housekeeping adopted by the Parties to the Montreal Protocol; experience of the US Environmental Protection Agency; references to relevant laws and regulations of the EU, Republic of Kazakhstan, Republic of Belarus, and provisions of the Russian laws and regulations, and interstate and national standards.

The forecast for ODS and F-gases consumption (leakage) in FI MO for 2021–2035 and until 2040 was updated in light of changes in consumption in 2018–2021.

Appropriate measures not taken, the cumulative impact that the fishing and fish-processing industry of the Murmansk oblast would have on the ozone layer and the Earth’s climate in 2021–2035 and until 2043 will reach 19.22 ODP  and 785,469.33 t CO₂-eq, respectively.

The report assesses the resources necessary for the operation of the ODS and F-gases recycling and destruction system in FI MO, analyzes the potential of BarentsCool Ltd., and offers detailed management recommendations to BarentsCool Ltd. in view of the Russian laws and regulations in effect.

The section also includes the ODS and F-gases recycling and destruction schedules for FI MO for 2023–2043 (forecast).

As one of the most sustainable approaches to the management of ODSs and F-gases is the destruction of these substances with persistent organic pollutants (POPs) using the technologies that meet the requirements of the Montreal protocol, the report gives assessment to the opportunities associated with the federal project “Creation of the infrastructure for safe management of wastes of hazard classes I and II” that Rosatom, the state atomic energy corporation, implements under the Ecology national project. As the analysis shows that the created infrastructure and selected technologies will not allow managing and decontaminating POPs (polychlorinated biphenyls (PCBs), pesticides, etc.), ODSs, and F-gases, a new federal project was proposed for the Ecology national project.

The section includes the 2023–2043 cost estimate and sales potential of reclaimed ODSs and F-gases in FI MO.

It is to be noted that the sales potential of reclaimed refrigerants of EUR 6,385,500 is calculated for the entire FI MO while the share attributable to the ODS and F-gases recycling and destruction system to be established on the basis of BarentsCool Ltd. would depend on the company’s market share in this sector.

Five financial arrangements for recuperation and recycling of ODSs and F-gases were proposed to BarentsCool Ltd.

Forecasted annual sales of reclaimed ODSs and F-gases suggest that an enterprise specializing only in refrigerant recuperation and recycling would not be financially viable because of heavy expenses (electricity, transport, rent, wages, etc.), changing (year to year) operating income, and high competition among non-specialized service and repair businesses. Thus, a solution that ensures sustainability and stability of the business during the period under consideration would be the establishment of the FI MO ODS and F-gases recycling and destruction system as a business unit of an enterprise specializing in production, installation, repair, and service of refrigeration and air-conditioning equipment.

To develop a logistic scheme for the FI MO ODS and F-gases recycling and disposal system, the following has been studied:

• special considerations for ODS and F-gases recuperation and recycling in FI MO in terms of environment protection and technology;
• theoretical aspects of logistics related to the provision of ODS and F-gases storage, recuperation, recycling, transportation, and destruction services;
• logistics practice of the provision of ODS and F-gases storage, recuperation, recycling, and transportation services;
• logistics practice of the provision of ODS and F-gases destruction services.

The section covers enhancement recommendations for the logistic component of the ODS and F-gases storage, recuperation, recycling, transportation, and destruction to the management of BarentsCool Ltd.

The third section, Conclusions, contains the following conclusions:

• With the establishment of a center specializing in ODS and F-gases storage, recuperation, recycling, reclamation, transportation, and destruction on the basis of BarentsCool Ltd., a company with considerable experience of more than 20 years in design, supply, installation, commissioning, and servicing of refrigeration and air conditioning equipment, the essential conditions for sustainable operation of FI MO during the entire period of ODS and F-gases phase-out will be created. BarentsCool Ltd. has at its disposal all the documents required by the laws and regulations of the Russian Federation to conduct the activities provided by the company’s articles of association.
• The articles of association of BarentsCool Ltd. provide, inter alia, for other activities not prohibited by the legislation of the Russian Federation in effect, which may include collection, transportation, storage, recuperation, recycling, recycling of ODSs and F-gases.
• Upon supply of the required technological equipment and staff training under the Arctic Council Project, BarentsCool Ltd. will have the resources necessary for the commencement of operation of the FI MO ODS and F-gases recycling and destruction system.
• If complied with, the interstate and national standards in effect allow recuperating, reclaiming, and recycling ODSs and F-gases by means of the ODS and F-gases recycling and destruction system established on the basis of BarentsCool Ltd.
• No licensing for storage, transportation, recuperation, recycling of ODSs and F-gases is provided for the laws and regulations of the Russian Federation in effect. Should the Ministry of Natural Resources and Environment of the Russian Federation identify ODSs and F-gases as substances of any hazard class, the viability of the established FI MO recycling and destruction system will significantly depend on the readiness of BarentsCool Ltd. to urgently submit necessary documents to acquire a license. Non-licensed collection, transportation, processing, and disposal of wastes of hazard classes I–IV constitutes an administrative offense under paragraph 2 of Article 14.1 of the Code of the Russian Federation on Administrative Offenses.
• The Federal Service for Supervision of Natural Resource Usage issues licenses upon submission, inter alia, of a public health and epidemiology certificate of the directorate of the Federal Service for the Oversight of Consumer Protection and Welfare in the Murmansk oblast confirming compliance of buildings, structures, premises, equipment to be used for declared licensed works with sanitary regulations. Acquiring such a certificate and license requires from 4 to 6 months.
• An individual enterprise specializing only in refrigerant recuperation and recycling in FI MO would not be financially viable because of heavy expenses, changing (y/y) operating income, and high competition among servicing and repair businesses offering their services to fish-processing enterprises and fishing vessels.
• Therefore, the preferred option for establishment of the ODS and F-gases destruction center in the Arctic zone of the Russian Federation is retrofit with necessary additional equipment of an existing company in the Murmansk oblast engaged in the treatment of municipal and industrial waste of hazard classes I–IV, and use (even partial) of its existing infrastructure, production and transport capacities and gathered waste treatment experience. With such an approach the project investment cost will reduce significantly. The personnel having the necessary skills in the area of waste management can be involved in the ODS and F-gases destruction operations after appropriate retraining (professional development).
• Establishment of the ODS and F-gases destruction (decontamination) enterprise (center) on the basis of existing regional enterprises engaged in decontamination of municipal and industrial waste of hazard classes I–IV would require re-issuance of the license for collection, transportation, processing, disposal, decontamination and dumping of waste of hazard classes I–IV. The license may be re-issued upon submission of a public health and epidemiology certificate of the directorate of the Federal Service for the Oversight of Consumer Protection and Welfare in the Murmansk oblast confirming compliance of buildings, structures, premises, equipment to be used for declared licensed works with sanitary regulations, and positive findings of the state ecological appraisal upon studying relevant documentation. Obtaining such documents and a license requires from 5 to 7 months.
• With Article 8.2.1 of the Code of Administrative Offenses “Non-compliance with environmental requirements to management of ozone-depleting substances” imposing a considerable administrative penalty or administrative suspension of activities for up to 90 days, FI MO business entities carrying out production activities related to ODS and F-gases management would be sufficiently motivated to cooperate with BarentsCool Ltd. to recuperate ODSs and F-gases contained in products that lost their consumer properties before their disposal or burial at the disposal facilities for production and consumption waste.
• In the fishing and fish-processing industry of the Murmansk oblast, the number of vessels assigned to the port of Murmansk and fish-processing businesses reduced in 2018–2021 due to management, economic and non-economic causes.
• Use of refrigerants containing ODSs and F-gases (except for R-507A) in the refrigeration equipment in FI MO was reduced in 2018–2021. The growth in the use of the blend R-507A is mainly due to the fact that contracts for supply of new equipment containing R-507A were signed before the adoption by the Russian Federation of the Kigali amendment to the Montreal protocol, low public awareness, and other causes (advantageous prices, stricter safety requirements for construction and operation of ammonia refrigerating plants).
• In 2023–2043, the estimated amount of recuperated ODSs and F-gases in FI MO will be 452.52 t, 27.62 ODP t, 921,883.4 t CO₂-eq; the estimated amount of non-recoverable losses of ODSs and F-gases during recuperation will be 21.71 t, 1.34 ODP t, 44,567.9 t CO₂-eq; the estimated amount of reclaimed ODSs and F-gases for reuse in FI MO (net of non-recoverable losses during recuperation and non-reclaimable substances (to be destructed)) 398.0 t, 24.31 ODP t, 810,446.3 t CO₂-eq.
• ODS and F-gases recycling for reuse (net of destruction and non-recoverable losses of substances during recuperation) in FI MO in 2023–2043 is expected to prevent a negative impact on the ozone layer and the Earth’s climate of 24.93 ODP t and 838,573.0 t CO₂-eq. respectively.
• ODS and F-gases destruction in FI MO in 2023–2043 is expected to prevent a negative impact on the ozone layer and the Earth’s climate of 1.96 ODP t and 67,035.9 t CO₂-eq. respectively.
• In 2023–2043 the average share of ODSs and F-gases in FI MO is expected to amount: recuperated 87.9%, destroyed 6.9%, non-recoverable losses 5.2%.
• At the initial stage (until 2024–2025) the FI MO ODS and F-gases recycling and destruction center to be established on the basis of BarentsCool Ltd. would accumulate and store ODSs and F-gases that cannot be reclaimed at its site, so appropriate containers of a total capacity of 3–4.5 t should be provided. After the establishment of facilities for environmentally sound destruction of ODSs and F-gases, these wastes should be transported to the place of destruction.

The section “Recommendations” contains proposals addressed to BarentsCool Ltd., ICSTI, the Ministry of Natural Resources and Environment of the Russian Federation, Federal Service for Supervision of Natural Resource Usage, and other federal executive bodies concerned.

BarentsCool Ltd. is recommended:

• considering the rationale for adding collection, transportation, and treatment of wastes of hazard classes I–IV to the list of the main activities of its articles of association (against the possibility that the Ministry of Natural Resources and Environment of the Russian Federation would classify ODSs and F-gases as wastes of hazard class I–IV);
• developing and approving in-house specifications for reused (recuperated) and reclaimed refrigerants R-12, R-22, R-134a, R-404A, and R-507A in a context of the absence of relevant federal and interstate standards.

ICSTI is recommended:

• developing a provisional form of a certificate confirming recuperation ODSs and F-gases recovered from products that lost their consumer properties before their disposal or burial at the disposal facilities for production and consumption waste, and inform the Ministry of Natural Resources and Environment of the Russian Federation and Federal Service for Supervision of Natural Resource Usage. Issued by BarentsCool Ltd. to FI MO business entities, these certificates may serve as supporting documents during audit of compliance with annual reporting requirements by the Federal Service for Supervision of Natural Resource Usage.

The Federal Agency on Technical Regulating and Metrology is recommended:

• initiating, in accordance with the established procedure, the development of the interstate standard with the proposed title “Equipment for the destruction of ozone-depleting substances and fluorinated greenhouse gases. Operating characteristics.”

The Ministry of Natural Resources and Environment of the Russian Federation is recommended:

• initiating, in accordance with the established procedure, classification of wastes of ODSs, F-gases, and products containing them, as substances of hazard classes I–IV for further inclusion in the Federal Classification Catalog of Waste, Database of wastes and disposal and decontamination technologies for various wastes, and issue of licenses. In that respect, the order of the Ministry of Natural Resources and Environment of the Russian Federation, 04.12.2014, No.536 “On approval of the criteria for attributing waste to hazard classes I–IV by its negative environmental impact” and other laws and regulations may require amending;
• initiating, in pursuance of paragraph 2 of Article 54 of the Federal Law No.7-FZ, 10.01.2002, “On environmental protection,” revision of the regulation of the Government of the Russian Federation No.228, 24.03.2014, “On measures of the state regulation of consumption and circulation of ozone-depleting substances” to specify requirements to ODS use, transportation, storage, recuperation, recycling, recycling, and destruction being the stages of ODS circulation (as in the current version only ODS production requirements are specified at an acceptable level);
• initiating, in accordance with the established procedure and in cooperation with the Ministry of Foreign Affairs of Russian Federation, Federal Agency on Technical Regulating and Metrology, and other federal executive bodies concerned, terminology unification in the area of protection of the ozone layer and the Earth’s climate accepted in the territory of EAEU. The laws and regulations in effect in the EAEU countries use different terms (for example, рекуперация – утилизация; рециркуляция (рециклирование) – рециркулирование – рециклинг; уничтожение – обезвреживание, etc.);
• developing, in accordance with the established procedure, a draft regulation on the annual inventory of technological equipment and devices containing more than 3 kg of ODSs and/or F-gases for legal entities and individual entrepreneurs, for the purpose of obtaining reliable data, at the federal and regional levels, on the actual amount of ODSs and F-gases in operating, back-up, mothballed, dismantled, decommissioned equipment (containing residual ODSs and F-gases), technical devices, and wastes;
• drafting the following documents, in accordance with the established procedure, to unify approaches to ODS and F-gases control in EAEU:
  • procedure for maintaining the national ODS and F-gases register in the Russian Federation;
  • procedure for issuing permits for works related to use of ODSs and F-gases, repair, installation, maintenance of equipment containing ODSs and F-gases, transportation, storage, recuperation, recycling, and destruction of ODSs and F-gases;
  • procedure for management ODSs and F-gases in the Russian Federation.
    Indeed, similar documents (as rules, instructions, codes, etc.) regulating the management of ODSs are already in effect or awaiting approval in the most EAEU member countries;
• considering, in cooperation with the federal executive bodies concerned, the acceptability of adapting certain provisions of the relevant EU regulations and implementing regulations (for details, see paragraph 2.1.1.3 of the report) when developing future amendments and adjustments to the laws and regulations of the Russian Federation in the area of protection of the ozone layer and the Earth’s climate;
• initiating, in accordance with the established procedure and in cooperation with the Federal Agency for Fishery, restrictions on purchase by Russian economic entities of foreign vessels decommissioned in foreign fishing areas and equipped with refrigeration equipment using ODSs and F-gases, for the purpose of significantly accelerating phase-out of these substances at Russian vessels, and facilitating fulfillment of international obligations of the Russian Federation in this area;
• initiating, in accordance with the established procedure and in cooperation with federal executive bodies concerned, development of a draft regulation on the creation of a certification (licensing) system for servicing companies and specialists working with ODSs and F-gases (currently non existing in the country), and organization of a network of training centers and centers for recovery, recuperation, recycling, and environmentally safe destruction of ODSs and F-gases;
• initiating, in accordance with GOST R 56828.27-2017 “Best Available Technologies,” revision of the Reference Document on Best Available Technologies for Waste Management in effect, taking into account a similar EU document in effect since 2018 (No.EUR 29362) that describes technologies acceptable for destruction the of ODSs, F-gases and persistent organic pollutants (POPs);
• considering, in cooperation with the Ministry of Industry and Trade of the Russian Federation and economic entities concerned, the possibility to develop promptly a new federal project on the creation of infrastructure for the environmentally safe destruction of ODSs and F-gases under the Ecology national project.