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Amnesty international and greenpeace netherlands
Chapter 7
Choosing to do caustic washing There were two process by which the coker naphtha could be refined: one was mercaptan oxidation (known as the “Merox process”), and another was caustic washing. As noted in Chapter 2, both processes involve mixing caustic soda with the coker naphtha to capture the mercaptans (which creates a waste by-product). The Merox process includes an important second step, whereby the waste is transformed into stable disulphides through oxidation. This additional step is normally undertaken in a specialized facility. Trafigura carried out caustic washing and not the Merox process. It made this decision despite knowing that:
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Caustic washes are banned by most countries due to the hazardous nature of the waste (mercaptans, phenols, smell) and suppliers of caustic are unwilling to dispose of the waste since there are not many facilities 324 remaining in the market.
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Although there are important differences between caustic washing and Merox, Trafigura has attempted to conflate the two processes. On its website, under the heading “Is the caustic washing/Merox process unusual?” it states: “No. It’s a well-known, legal and effective way of reducing impurities in gasoline blendstocks and has been used in the refining industry for 50 years. In 2006, there were 1,600 Merox units licensed for operation worldwide.”325 Trafigura used none of these 1,600 units because the company did not carry out the – relatively – safer Merox process but decided to do caustic washing. Had Trafigura been carrying out the Merox process, it could indeed have used one of the 1,600 units it says exist worldwide. But, as described in Chapter 3, Trafigura had serious difficulties finding a location on land to do caustic washing, as is clear from an email sent by Trafigura’s London office on 28 December 2005:
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I have approached all our storage terminals with the possibility of caustic washing and only Vopak [at] Fujairah and Tankmed [at] La Skhirra 326 our [sic] willing to entertain the idea…
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The decision to carry out caustic washing at sea As noted above, Trafigura identified two facilities that could undertake caustic washes: one was in the United Arab Emirates (UAE), the other in Tunisia. Reports indicate that Trafigura undertook some caustic washing in UAE, but then moved to Tunisia. However, following an incident at the Tunisia site, the authorities there prohibited further caustic washing because there was not the capacity to deal adequately with the resulting waste. Trafigura then decided to undertake caustic washing on board a ship. There is no known record of such an operation ever being conducted on a ship before this. As a Dutch court later commented, what Trafigura decided to do: “essentially [boiled] down to the moving of an industrial process from land to sea.”327 The matter of dealing with the waste that would be produced on board a ship – and the potential difficulties – was clearly on Trafigura’s radar. Obviously Trafigura was aware of the difficulties of safe management and disposal of the waste on land. In making the decision to carry out caustic washing on board a ship, senior company executives considered various options. An email dated 10 March 2006 noted:
make any sense to take on t/c [time “charter] “ Doesa itvessel that is about to be scrapped … and park somewhere in WAF (West Africa) in order to carry out some of the caustic washings over there? I don’t know how we dispose of the slops and I don’t imply we would dump them, but for sure there must be some way to pay someone to take them. A ship that doesn’t care about it’s (sic) coatings and can re-circulate cargo and strip 328 (emphasis added) tanks would work very well.
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