For the repeated procedure, the Fund stated an estimated value of €4.72 million excluding VAT.
GOSPIĆ / LIKA · WORKING CONCEPT · AUGUST 2026
Waste is not the end of the flow.
It may be a resource parked in the wrong place.
ECOMULATOR is a concept for a regional centre that would characterize, separate and recover valuable materials from problematic waste streams before the remaining material is sent for specialized final disposal.
This is not an investment project, nor a claim that the origin of the waste has been established. It is a pre-feasibility hypothesis for discussion.
ECOMULATORRECOVER · CONTAIN · RETURNPblead
Sbantimony
PPpolymer
Cucopper
01 · WHY CONSIDER A PLANT AT ALL?
The problem already has a price.
Estimated service value: €400,000 excluding VAT.
The Fund describes a mixture of waste, soil, sand and rubble; a market solution is being sought.
Enquiries to 11 EU hazardous-waste operators and four options for permanent storage in closed salt mines.
CHEMICAL SIGNAL
Antimony repeats. Lead stands out.
Published laboratory reports for buried waste show an antimony signal in the eluate of several samples. Sample 9 measured 3.2 mg/kg Sb in the eluate against the stated criterion of 0.7 mg/kg, while the original sample measured 38,000 mg/kg Pb.
Sb mobilityPb high contentCd monitorCu recover?
One laboratory sample is not the average of the entire mass. Material value must not be calculated from an extreme sample.
HYPOTHESIS, NOT CONCLUSION
Pb + Sb + plastic is an interesting industrial signature.
Lead and antimony have a known history in lead alloys, including battery streams. Polymers may form a separate recoverable stream. But the published analyses do not prove that the waste came from one factory, product or industrial process.
WE DO NOT IDENTIFY THE WASTE SOURCE · WE IDENTIFY MATERIAL FLOWS
02 · ECOMULATOR MODEL
Do not “burn everything”.
Separate value from risk first.
The core idea is modular: the centre must make economic sense even without experimental antimony recovery. Critical materials are an additional value only after characterization confirms them.
01Intake + characterizationsampling · classification · closed flow
→
02Physical separationmetals · polymers · inert · hazardous
→
03Resource recoveryPb · Cu · PP · potential Sb stream
→
04Water controlleachate / process water · polishing
→
05Residualonly what requires specialized disposal
Lead
A high concentration in one sample justifies serious assessment of the metal stream — but only after representative sampling of the entire mass.
Antimony
The EU lists it as a critical raw material. For ECOMULATOR it is a potential recovery stream, not a revenue base until quantity, form and technology are confirmed.
Polymers
A mechanically separated clean fraction may have value; contaminated or flame-retardant plastic requires a separate technical assessment.
Water
Adsorption media may be part of final polishing, but they do not solve the source. Contaminated media become a new solid stream that must be controlled.
03 · PRE-FEASIBILITY v0.1
Can remediation become infrastructure?
The figures below are working scenarios, not supplier quotes or profit forecasts. Their purpose is to test the order of magnitude.
Modular regional centre€12–18 Mworking CAPEX range without a large on-site incinerator
Target capacity15–20k t/yearrequires regional feedstock, not just one location
Decision key7–10 yearsa contracted flow long enough for the infrastructure to make sense
€10 / t
operating contribution
- Service
- €400/t
- Recovery
- €30/t
- OPEX
- €420/t
€160 / t
operating contribution
- Service
- €500/t
- Recovery
- €60/t
- OPEX
- €400/t
€320 / t
operating contribution
- Service
- €600/t
- Recovery
- €100/t
- OPEX
- €380/t
QUICK CALCULATOR
Change the assumptions.
The formula is deliberately simple: (service + recovery − OPEX) × annual tonnage. Payback is CAPEX / annual operating contribution.
It excludes financing, tax, depreciation, permits, ramp-up, contingency and the cost of final disposal when that cost is not included in OPEX.
Operating contribution€3.20 M/year
Simple payback4.7 years
Break-even service for 7 years€447/t
04 · WATER / LIMIT OF THE CLAIM
We do not need to invent a catastrophe to demand good measurement.
GOSPIĆ / LIKAconceptual signal map · not a hydrogeological map
Public monitoring currently shows no threat to the public water supply.
The water institute reports 23 surface-water and 14 groundwater stations in the county during 2026, about 400 samples a year and more than 100 PFAS analyses.
Mrđenovac: not detected.
MRO Centar: all 20 analysed PFAS and their sum were below the quantification limit of <0.0015 µg/L. Tonkovića vrilo: measured concentrations were about 20 times below the prescribed limit.
That is not the same as “the ground beneath the waste is proven clean”.
Assessing the actual contamination plume requires representative piezometers, hydrogeology, groundwater-flow data and repeated measurements immediately beside the site.
05 · GO / NO-GO
GO for a serious pre-feasibility study.
HOLD on construction.
One fact decides almost everything: can at least 15,000–20,000 tonnes of suitable regional waste be contracted each year for 7–10 years?
YESA €12–18 million modular centre may make infrastructural and commercial sense.
NOMobile or modular pre-treatment with existing specialist operators probably makes more sense.
06 · SOURCES AND LIMITS
Verifiable before persuasive.
Remediation and monitoring figures come from publicly available official releases. CAPEX, OPEX and revenue in the feasibility section are working assumptions used to test the model.
FZOEU · Phase 3Market analysis and published laboratory reports for samples 6–15.
MZOZT · 9 July 2026Phase 1 €4.72 M, phase 2 650 t / €400k, chlorine and technical complexity.
MZOZT · 28 July 2026Approximately 35,000 t of buried material and remediation status.
HZJZ / MZOZT · PFASMrđenovac, MRO Centar and Tonkovića vrilo — March 2026 samples.
J.J. Strossmayer Water Institute2024–2026 monitoring network and the number of samples / PFAS analyses.
EU Critical Raw Materials ActAntimony is on the EU list of critical raw materials.
Important: ECOMULATOR is an independent working concept. It is not affiliated with the City of Gospić, the Fund, the Ministry, the laboratory, the citizens’ initiative or any potential contractor. It does not claim that the waste came from batteries. It proposes no technical process without characterization, permits and design by authorized specialists.