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You are here: BAILII >> Databases >> England and Wales High Court (Commercial Court) Decisions >> Chenco Chemical Engineering And Consulting GmbH v DO Fluoride Chemicals Co. Ltd [2021] EWHC 1052 (Comm) (26 April 2021) URL: https://www.bailii.org/ew/cases/EWHC/Comm/2021/1052.html Cite as: [2021] EWHC 1052 (Comm) |
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QUEEN'S BENCH DIVISION
COMMERCIAL COURT
Strand, London, WC2A 2LL |
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B e f o r e :
____________________
CHENCO CHEMICAL ENGINEERING AND CONSULTING GMBH |
Claimant |
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- and – |
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DO FLUORIDE CHEMICALS CO. LTD |
Defendant |
____________________
Mr. Lin Wu for the Defendant
Hearing dates: 14 – 16 April 2021
____________________
Crown Copyright ©
Mr Justice Jacobs :
Section A: Introduction
"The extent to which any sums are owed to the Claimant for the period after 23 April 2013 pursuant to paragraph 414 and 417 of the Final Award is to be the subject of a further trial in the Commercial Court, pursuant to the directions attached at Schedule A".
The course of the proceedings
The issues
i) In June 2011, on the commencement of the Arbitration and in the face of uncertainty of the ultimate outcome of the Arbitration, DFD enhanced its efforts and investments on research and technical development work to upgrade its AlF3 production technology. DFD defines this as "the R&D Work".
ii) DFD conducted the R&D Work for the specific purpose of enabling it to get rid of Chenco's Technology, and therefore to avoid the potential adverse consequences of the arbitration.
iii) Following the Award, and with the smooth progress of the R&D Work, DFD was able to stop using Chenco's Technology. The fruit of the R&D Work meant that DFD could use its own upgraded technology which would have the benefit of increasing production capacity whilst decreasing raw material consumption. As a result, DFD stopped all four previous fluid-bed reactors by 16 July 2013 for dismantling, and thereby stopped "in its entirety the use of any Chenco's Technology to the extent described and prohibited by the Award". (I will explain the significance of the "fluid-bed reactors" in Section B below. Each plant had its own fluid-bed reactor. There were therefore 4 reactors in total, but there was no suggestion that there was any material difference in the design of each of them. When referring to the design, I will usually refer to the "reactor" in the singular).
iv) In August and September 2013, DFD dismantled Chenco's Technology from the site of two of its plants (the no.3 and no.4 plants), and installed its own new upgraded plants (referred to in the pleading as the "Two Newly Installed Plants") employing only its own technology. These were said to be newly upgraded plants with the core of new fluid-bed reactors employing "DFD's Upgraded Technology":
v) Thereafter, DFD never used the other two plants. These plants had previously used (on the findings in the Award) Chenco's Technology.
vi) DFD argues that as a result of these changes, DFD has not been using Chenco's Technology in its course of production of AlF3 to any extent whatsoever.
Issue 1: Did DFD in fact design its own "Upgraded Technology" for its own use in or around June 2013?
Issue 2: If so, did DFD actually dismantle the facilities in two of its plants (the previous no.3 and no.4 plant), and install in their place its "DFD's Upgraded Technology", as is alleged, in the period between May 2013 and in or around September 2013?
Issue 3: If so, did that mean that DFD was no longer using Chenco's Technology, in those two plants, or should DFD still be considered to have been doing so?
Issue 4: Did DFD in fact continue to use the other two plants following the Final Award, which it contends were not used, but which it accepts still contained Chenco's Technology; and if so, for how long?
Section B: The Award
"[Respondent] undertakes not to make further use, directly or indirectly, of the designs, proprietary rights, Know-how, technical information, drawings, specifications, manufacturing techniques or manufacturing instructions supplied by [Claimant] or its distributor or in any way acquired from [Claimant] related to the Technology and Know-how, except for the purpose set forth in this Agreement during the term of this Agreement and for a post-contractual term of 10 years after its termination."
"(182) This burden of proof cannot be met only by just showing that a technical principle is known in the public domain. What matters is to show that a piece of specific technical information is in the public domain. Respondent has not met the burden of proof that pages 1-599 006A ("P&I Flow Sheet"), 0-599 014 ("Reactor OD 2600 Internals") and 4-599 014/015 ("Reactor OD 2600") of C-110 are in the public domain.
(183) Such a proof cannot be replaced by allegations of circumstantial means of evidence such as, for example, an alleged lack of R&D facilities. It was not demonstrated that the specific technical information is in the public domain."
"(192) The Arbitral Tribunal accordingly finds that the content of the pages 1-599 014 ("P&I flow sheet"), 0-599 014 ("Reactor OD 2600 Internals") and 4-599 014/015 ("Reactor OD 2600") of C-110 is Claimant's technology ("Claimant's Technology")."
"(213) In 2006 the contractual ALF3 plant was erected and commissioned according to Claimant's Technology. This plant was operated until (at least) 2010."
(214) Respondent admitted that it later built four additional ALF3 plants at its site in Jiaozuo (one in 2007, one in 2009, and two in 2011).
(215) Respondent claims that these additional plants are not copies of Claimant's plant. Rather, they were built by using proprietary know-how developed by Respondent before entering into the Contract with Claimant in 2005.
(216) Respondent submitted three documents which describe the state of Respondent's technology before signing the contract with the Claimant.
- Document R-94 (dated December 2005) is a technical drawing of the concrete structure for housing two ALF3 plants.
- Document R-89 (dated March 2005) is a flow sheet of the core part of the process.
- Document R-138 (dated March 2005) is a technical drawing of the distribution plate with bubble caps at the feed gas entrance into the reactor.
(217) However, most characteristic features of Respondent's earlier technology were not used by Respondent in its later plants. These are, for instance, only two recycles of solid material from the cyclones into the reactor, rotating valves in these recycle lines, a static (not rotating) cooler for the ALF3 product, and bubble caps with cylinder-shaped, straight skirts. Obviously, this technology was abandoned by respondent after signing the contract with Claimant in December 2005.
(218) The four additional plants were built after two years of operation of Claimant's plant. The technology of the four additional plants is disclosed to the Arbitral Tribunal only with respect to flow sheet (R-123 dated November 2009) and reactor design (R-124 dated April 2012). Many technical details of the additional plants (e.g. design and dimensions of Venturi dryer, cyclones, off gas scrubbers, product cooler, etc.) remain unknown.
(219) The flow sheet R-123 is oversimplified as it does not show all essential features of Respondent's process. Nonetheless, together with the printout of the computer screens in the control room (C-46, pp. 11-14, see also CS-16 pp. 61-71) a clear evaluation of Respondent's new process is possible. In the central part (around the reactor) the process has striking similarities with Claimant's process (C-110, drawing 0-599 006A). This manifested by:
- Vaporous AHF feed to the reactor (via item EO301);
- Use of wet Al(OH)3 (via item LO302);
- Circulating fluidized bed reactor (item RO301)
- Three recycles of solid material from the cyclones into the reactor (item XO303-5);
- Cooling of the reaction product AlF3 in a rotating drum (item FO302);
- Temperature control of the reactor by hot air (via item CO302).
(220) Furthermore, there are many additional similarities with Claimant's design in the geometrical design of equipment and piping. The decisive criteria, however, are the specific design and the interaction of these features in the whole process.
(221) By contrast, the existing differences between the Respondent's and Claimant's processes are of minor importance. For instance, the provision of a fourth cyclone and a gravity settling chamber for dust separation from the off gas is due to the rather fine Al(OH)3 feed not forseen in the contract. The same holds for the use of a third scrubber for off gas purification.
(222) The heart of the process is the chemical reactor, which has the circulating fluidized bed. The relevant documents are R-124 (Respondent's drawing of the reactor) and Claimant's drawings in C-110. Of special importance are Claimant's drawings 0-599 014 (reactor lower part) and 1-599 015 (reactor upper part). A comparison of the two reactor designs reveals striking similarities of nearly all design details of the reactors.
- The same material was used (Inconel 600)
- The reactors have exactly the same diameter (2.6m) and approximately the same height (approx. 10m).
- All pipe connections of the reactors have the same positions and dimensions.
- Even the numbering (N1, N2, N3, etc) of the pipe connections is identical.
- The arrangement and shapes of the stiffening plates of the reactor head, of the pipe connections and of the support ring are identical.
- The same holds for the arrangement of the measuring devices (e.g. temperature, pressure).
- In both designs, the distribution plates for the feed gas entry consist of bubble caps. The bubble caps have exactly the same height (300 mm), the same clearance (90 mm), and the same shape (cone-shaped, flared skirt of the caps).
- Respondent's bubble caps, however, have a smaller diameter characterized by the inner diameter of the chimneys (Respondent 4.83 cm, Claimant 7.366 cm). This difference is compensated by a different number of bubble caps on the distribution plate (Respondent 91, Claimant 37). In both cases, the total free area of the chimneys is virtually the same (Respondent 0.1667 m2, Claimant 0.1577 m2). This is important as the pressure drop of the gas, which is a significant operational parameter, is determined by the free area of the distribution plate.
- The design of the bubble caps in Respondent's additional plants differs significantly from Respondent's former design (R-138 dated March 2005), in particular in the height of the bubble caps (old 240 mm, new 300 mm) and in the shape of the caps (old cylinder-shaped, straight skirt; new cone-shaped, flared skirt).
(223) The only obvious difference of the two reactor designs is the provision of a sieve tray in the middle part of the Respondent's reactor. The advantages and disadvantages of the intermediate sieve tray are disputed by the parties. However, the Arbitral Tribunal comes to conclusion that the additional sieve tray is of minor importance for the function of the reactor. The holes in the sieve tray (10 mm diameter) are larger by a factor of 200 than the solid particles (approx. 0.05 mm diameter). Thus, the particles can be easily entrained by the gas and transported from the zone below the sieve tray into the zone above the sieve tray. The sieve tray is equipped with three down comers to enable a down flow of the solid particles from the upper zone into the lower zone of the fluidized bed. In both sections, the superficial velocity of the gas is higher by a factor of approximately 10 than the terminal velocity of the particles. Therefore, the characteristic features of a circulating fluidized bed are maintained in spite of the introduction of an intermediate sieve tray in Respondent's design."
"(224) Therefore, the Arbitral Tribunal comes to the conclusion that the four production lines of Respondent do use Claimant's Technology in the core section of the process, and, to a very high degree, in the specific design of the reactor.
(225) Therefore, the Arbitral Tribunal finds that Respondent was and is in violation of the use restriction."
Section C: Jurisdiction
"3. The extent to which any sums are owed to the Claimant for the period after 23 April 2013 pursuant to paragraph 414 and 417 of the Final Award is to be the subject of a further trial in the Commercial Court, pursuant to the directions attached at Schedule A."
"The parties shall be permitted to serve expert evidence limited to one expert per party relating to the use of Chenco technology by DFD and by when DFD ceased all use of Chenco technology."
"much more sensible for the court to decide it than for a seven- year -old - - I don't even know if the arbitrators are still alive, but they won't have any memory of it, I don't suppose -- much more sensible for it to be decided by the Commercial Court"
"I mean, I don't know whether there's any point, is there, in my giving an opportunity for you - - for you, Mr Dhar and Mr Hughes, to talk about the possibility of having a - - setting aside the order and having a hearing adjudicated by the court on whether you have made unauthorised use of the technology, and I'm quite happy to say since the award, but it seems to me inevitable that you're going to have to say since July 2013, when you made your changes … "
"My Lord, thank you. We've had constructive discussions in part. We've then -- Mr Dhar and I and our respective solicitors have been discussing how to move forward, but we shall then need the opportunity to take proper instructions with our clients in Beijing. So that if I start and then Mr Dhar can follow.
The parties have both agreed in principle that it would be a good idea to - - for the court to address the issue of post-award -- the post-award issue in relation to alleged unauthorised use in relation to the monthly penalty payments as your Lordship suggested."
"We've been having -- holding discussions with our clients over the lunch break.
…
They're in agreement to the – to your Lordship' s proposal that there be a further determination in the Commercial Court of the issue of future or post-award penalty payments …"
"… it is averred that whether, for the period after 23 April 2013 (pursuant to paragraphs (414) – (417) of the Final Award), there was any unauthorised use of Chenco's technology by DFD is a matter of fact before this Court. The Court shall adjudicate the matter afresh upon the parties' statements and evidence in these proceedings without being bound by any observation of the Tribunal …"
"[29]. To the extent that an arbitration has resulted in a final award, the interface between court and arbitration proceedings is very different to that which arises in relation to a prospective or pending arbitration. Not only does a final award render the tribunal functus officio, but enforcement of the award is essentially a matter for national courts rather than arbitral tribunals, so much so that, at least under English law, the award itself gives rise to a cause of action enforceable in court, and the award can be turned into a judgment of the court or enforced as if it were. If an award is entered as a judgment, that generates another cause of action (an action on the judgment) which is itself capable of being sued upon in court. Disputes relating to attempts to enforce the award through national courts are matters for the relevant court, not a dispute to be referred to arbitration.
[30]. As I have noted, an English arbitration award creates a new cause of action – the implied promise to enforce the award – which has long been recognised to give a claim which can be brought before the English court in an action on an award (Purslow v Baily (1704) 2 Ld Raym 1039; Hassneh Insurance Co of Israel v Mew [1993] 2 Lloyd's Rep 243; Associated Electric and Gas Insurance Services Ltd v European Reinsurance Co of Zurich [2003] 1 WLR 1041, [9]). Judgment in such actions is not limited to giving the relief set out in the award, but extends to awarding interest under s.35A of the Senior Courts Act 1981 (Coastal States Trading (UK) Ltd v Mebro Mineraloel-handelsgesellschaft GmbH [1986] 1 Lloyd's Rep 465). It has never, so far as I am aware, been suggested that such claims could be subject to a successful stay argument in favour of arbitration. Equally, it has long been recognised that, in trying an action on an award, it may be necessary for the court to resolve a dispute as to whether the award was settled or varied by subsequent agreement (Smith v Trowsdale (1854) 3 E & B 83).
[31]. If that is the position when an action is brought on an award, what of the position when summary enforcement is sought under s.66? I can see no reason why the court is not able, if it is willing as a matter of discretion to do so, to resolve in the context of a contested s.66 application disputes of a type which might be raised as a defence to an action on an award. […]"
Section D: Issues 1 and 2
"Speaking from my own experience, I have found it essential in cases of fraud, when considering the credibility of witnesses, always to test their veracity by reference to the objective facts proved independently of their testimony, in particular by reference to the documents in the case, and also to pay particular regard to their motives and to the overall probabilities. It is frequently very difficult to tell whether a witness is telling the truth or not; and where there is a conflict of evidence such as there was in the present case, reference to the objective facts and documents, to the witnesses' motives, and to the overall probabilities, can be of very great assistance to a Judge in ascertaining the truth."
"In this regard I would say something about the importance of contemporary documents as a means of getting at the truth, not only of what was going on, but also as to the motivation and state of mind of those concerned. That applies to documents passing between the parties, but with even greater force to a party's internal documents including emails and instant messaging. Those tend to be the documents where a witness's guard is down and their true thoughts are plain to see. Indeed, it has become a commonplace of judgments in commercial cases where there is often extensive disclosure to emphasise the importance of the contemporary documents. Although this cannot be regarded as a rule of law, those documents are generally regarded as far more reliable than the oral evidence of witnesses, still less their demeanour while giving evidence."
"Article 2 Technical Standards (Quality Standards) and Training
Technical standards of equipment (including quality requirements): Party B shall process in strict accordance with national standards, industry standards and drawings finally confirmed by the Parties to meet Part A's technical and operational requirements. Stainless steel is made of Baosteel or TISCO national standard plate, and all materials are provided with material certificates. Within 15 days after signing the contract, Party B shall provide the equipment outline dimension drawings, electrical conditions, equipment weight and basic conditions, among which the as-built drawings shall be a complete set of detailed electronic drawings and two sets of as-built blueprints for each unit. The equipment falling into the category of pressure vessels shall also be provided with pressure vessel qualification certificates, etc.
Before manufacturing, Party B shall notify Party A on a site visit for material confirmation.
Party B shall not limit or obstruct the use of any equipment by setting any operation password or implicitly creating any password for the equipment, or by installing any computer program on the equipment (including but not limited to PRC (Program Route Control)).
During the operation of the equipment, for vulnerable non-standard parts, Party B shall keep the spare parts in Party A's warehouse.
Before delivery, it is required to pickle and passivate inside and outside of the equipment.
Article 5 Acceptance
1.Time of acceptance: the final acceptance shall be carried out after Party B's equipment is installed and debugged, but the final acceptance time shall in no case be later than the time when Party B should make the delivery; otherwise, it shall be deemed as delayed delivery by Party B;
2.Acceptance standards: include but not limited to technical agreements, design drawings, material certificates, equipment operation instructions, equipment certificates, installation and commissioning test reports and other relevant data for acceptance;
3.Acceptance: the acceptance is completed in three progressive stages, namely, preliminary acceptance stage, installation, commissioning and trial run stage, and final acceptance stage;
(1) Preliminary acceptance stage: Party B shall notify Party A in writing to before preliminary acceptance within three days after the arrival of the equipment. The preliminary acceptance period lasts for three days, including inspection of packaging, appearance, specifications, quantity and weight of the equipment and spare parts. Party A shall issue a preliminary acceptance certificate to Party B within 3 days after the preliminary acceptance, which, however, does not mean that the acceptance is completed, and the equipment accepted as qualified.
(2) Installation, commissioning and trial run stage: Party B shall carry out installation and commissioning of the equipment three days after the issuance of the preliminary acceptance certificate. The installation and commissioning process shall be supervised by Party A's personnel onsite. The trial run period shall last for at least three days. During the trial run period, Party B shall record the trial run data every day and sign it for confirmation by Party A.
Installation, commissioning and trial run means equipment power-on and material-carrying operation, which is conducted to show that those equipment are qualified in terms of stable equipment performance, capacity, production and compliance of standard, and compliance of all parameters and indicators with the requirements in technical agreement.
(3) Final acceptance stage: Party B shall notify Party A in writing for final acceptance within three days after installation, commissioning and trial run. The final acceptance period lasts for fifteen days. However, before final acceptance, Party B shall deliver to Party A the original design drawings, material certificates (contracts for purchasing raw materials from a third party and VAT invoices, etc.), equipment certificates, operation instructions, operation guidance, etc., or copies (seals and signatures) approved by Party A, as well as installation, commissioning and trial run records, etc., as prerequisites for final acceptance. In the final acceptance, Party A will compare and test the equipment based on the technical agreement and the data mentioned above. Within three days after the final acceptance, Party A shall issue a final acceptance certificate to Party B, by which the equipment shall be deemed as qualified.
If the equipment has hidden (inherent) quality defects or defects that are unlikely to be found in the final acceptance process, it will still be regarded as unqualified. Party A shall raise a written objection within three days after any flaw or defect is discovered, and Party B shall appoint professional technicians to the site to repair, replace or return the items within forty-eight hours, and all expenses arising therefrom shall be borne by Party B."
May – July 2013: DFD Internal documentation and market announcements
"According to the company's anhydrous aluminium fluoride plants operation status and regarding to the technical improvement of anhydrous aluminium fluoride, the attendees have discussed and concluded as follows:
1. The company's anhydrous aluminium fluoride plants need to be technical upgraded and revamped.
2. Department of Technology have to submit the project proposal before 15 June and finalize the material sourcing, the project will be initial in July, and complete the modification of the existing four plants in September."
"I. Project Background
1. The market of aluminium fluoride was shrink, and the price was in the lower ebb.
2. The tube material of the Anhydrous Hydrofluoric Acid heater in the aluminium fluoride plants facing corrosion alarm, the reliability of the equipment getting low.
3. Hot gas, reaction and wet scrubbing system in the plants are due for maintenance.
II. Undertaking Department
Department of Technology
III. Main Content of the Project
1. Replace the heat exchange tube of the Anhydrous Hydrofluoric Acid heater, increase the reliability of the equipment.
2. Check and maintain the hot gas and reaction system, including the equipment and tube for combustion chamber, fluid-bed and hot gas duct.
3. Clean and maintain of the wet scrubbing system, including the equipment and tube for venture, receiver and waste water tank.
4. Clean the site and surface of the equipment.
5. Process, safety and operation training to the relevant personnel.
IV. Schedule of the Project
1. 16 June to 15 July 2013, material sourcing for the project.
2. 16 July to 31 August 2013, replace the heat exchange tube of the Anhydrous Hydrofluoric Acid heater.
3. 16 July to 31 August 2013, training.
4. 16 July to 31 August 2013, check and maintain hot gas, reaction and off-gas wet scrubbing system. 5. 1 to 15 September 2013, clean the site and surface of the equipment.
V. Project assignment
Item No. | Description | Department | Manager | Remarks |
1 | Source of project material | Project Office | Yu Hehua | Cooperate with the Bid Invitation Office and the Supply Division |
2 | Replace the heat exchange tube | Project Office | Yu Hehua | Cooperate with the Department of Production |
3 | Check and maintain the hot gas and reaction system | Department of Production | Zhou Xiaoping | |
4 | Clean and maintain of the wet scrubbing system | Department of Production | Zhou Xiaoping | |
5 | Training | Department of Production | Zhou Xiaoping | |
6 | Clean the site and surface of the equipment | Department of Production | Zhou Xiaoping |
Department of Technology
June 2013
Drafted by: Yu Hebna (in hand writing)
Reviewed by: Yang Huachun (in hand writing)
Approved by: Hou Hongjun (in hand writing)"
"In view of the continued sluggishness of the aluminium fluoride market, after DFD's research, it was decided to focus on the technical upgrades of the aluminium fluoride production line. The aluminium fluoride production line will be shut down from 16 July 2013 to 15 September 2013. It is expected to reduce production by around 20,000 tons. According to the current market price of aluminium fluoride, the operating income will be reduced by about RMB I 00 million. Investors are advised to pay attention to the investment risk."
The contracts with contractors
The reactor drawings
"12. I would like to note, the original files disclosed in WL2-2 by 10 March 2021 contained working draft, the final confirmed drawing have been printed in hard copies, reviewed and signed by the designers and myself before been stored in archive. The photos collection of the final printed version of WL2-2 is hereby submitted as YH2-1. If there is any discrepancy between the paper signature file and the original WL2-2 file, YH2-1 shall prevail."
"16. Claimant repeatedly raised issue with the date of the Reactor Design and alleged that 'the native CAD file shows that the Alleged Reactor Design was first created by DFD on 23 July 2020 and not in June 2013'. This is absolutely wrong. Defendant has explained this issue in its previous submissions, which is summarized as follows: Document submission errors are inevitable, as the file research conducted between Mr. Wu Lin, Mr. Yu Henua and relevant DFD technical personnel, there were many procedure regarding the files encryption and decryption, zipping and unzipping, translation, submitting and storing. After claimant points out in its skeleton argument paragraph 106 to 119, Defendant realized the wrong version of metadata file with a creation dated 23 July 2020 was mistakenly disclosed within the package of WL2-2. Please notice that exhibit DFD1-5.1 (as well as YH1-14) in PDF format was not converted directly from CAD file, but a scanned copy of the hard copy drawing with the designer and Mr. Yu's signatures on it, the hard copy scanned date is 23 July 2020 to create the PDF file, and then was edited for adding the English translation by the way of comments on 12 November 2020 before disclosed on 13 November 2020. Anyhow, DFD have retrieved the correct version of the CAD file with the creation date 3 June 2013 for the Reactor Design".
"Because according to your description, the steps taken, if you take a hard copy and make a scan to create a PDF file, that should not be able to change the date of a CAD file. At least to my knowledge, I don't think that will affect the date of a CAD file."
"So, indeed, I was also aware of this mistake after a phone call with Mr Wu Lin and he told me why the date of creation was not the right date, so I went to verify with the relevant personnel to check what is wrong. So in July 2020, when the court order with regards to the change -- request first came out, I asked the technical personnel to send me the file so that I can compare the process design between DFD's technology and Chenco's technology, so the technical personnel send me a file. And when we have -- we were requested to disclose some documents and I submitted that file to Mr Wu Lin as our disclosure. So after I heard from Wu Lin that date of creation of that particular file was not the correct date, I went to check with the technical personnel who sent me the file back in July 2020 and I got the answer that he was afraid that I might mistakenly did some changes because I want to make dimensions or I want to measure on the CAD file, so he sent me a copy of the original CAD file. So he created a copy of the original CAD file on the date of the 23 July 2020 and he sent that copied CAD file to me. In the end, I told him to retrieve the original file and send it to me and he did so and I forwarded the original CAD file to Mr Allen Wu."
Section E: The remaining issues
Issue 3
"So it's always the entire process and how you operate it and I would say the technology is the entire bundle consisting of the process flow diagram with the reactor in the centre but also the cyclones around it and so on and how to feed, for instance, the hydrogen fluoride as a gas which has to be evaporated before. And then one very important aspect is you have to fluidise the material in the bed, therefore you need some gas and you need a temperature in the bed, therefore you need the combustion chamber and you have to heat this up before starting the feeding of the HF, yes.
…
You want to have – somewhere must be the reactor and that is always in the core. The other parts are to prepare the reactants for the reactor, and others, other sections of the plant are to separate the product from the residuals, from the byproducts, from the auxiliary materials and so on and then get it out and it's exactly what we have here, yes"
Issue 4
Other issues
Conclusion