Publications archive - Hazardous waste
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Friday 24 November 2000
8.30 am - 4.30 pm
Majura Room, Waldorf on London
Corner London Circuit and Akuna Street, CANBERRA ACT 2600
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Professor Paul Greenfield
Dr Paul Brown
Mr Stephen Moore
Dr Peter Di Marco
Dr Peter Scaife
Mr John Hogan
Dr Peter Brotherton
Ms Fiona Conolly
Dr Geoff Thompson
Dr Greg Rippon
Mr Peter Christoff
Ms Diane Kovacs
Dr Robyn Eckersley
Dr Peter Nadebaum
Mr Ray Evans
Dr Jenny Stauber
1. The Minutes of the 42nd meeting were accepted.
(a) Current list of members
2. Paul Brown amended his phone number.
(b) Replacement of Gordon Reidy
3. The Group endorsed the conclusion reached in the joint meeting with the Policy Reference Group on the previous day.
(a) Permit report for previous twelve months
4. The Group noted the report.
(a) Proposed export of diethylaluminum chloride/heptane mixture
5. The applicants had indicated that they had identified a possible disposal route within Australia, but would not be able to confirm this for another 3-4 weeks. In the meantime, the Department of the Environment and Heritage was still proceeding with amendments to the regulations in case a permit was granted.
(b) Proposed export of tetraethyl lead sludge
6. This issue was briefly discussed at the 29th meeting of the Policy Reference Group and related to two separate export applications. The issue is not new and was previously discussed by the Technical Group in 1996 when an application was made to export tetraethyl lead sludge. At that time, the Group recommended that a permit be granted on the basis that although a company was developing an alternative Australian-based technology to eliminate the need for future exports, this was only at a pre-pilot stage. In the event, the local technology was not further developed and two companies had now again applied for permits for the export of the sludge. Consequently, the Group was asked to consider whether a permit should be granted for the export of lead sludge.
7. Besides the extremely high toxicity of the sludge and other hazards, all of which have relatively standard OH&S operating procedures, the Group acknowledged that the explosiveness of the material presented a high risk. They also noted that the material was being returned to the manufacturer for recovery operations in a purpose-built facility. Retaining the waste in Australia appeared to be less safe, although it was important to ensure that the risks associated with domestic disposal of the waste were not merely transferred offshore.
8. The Group recalled that in 1996 the Australian Institute of Petroleum had provided an inventory of tetraethyl lead sludges in storage and likely decommissioning dates. This was now out of date and the Group requested that the Institute be asked to supply another. They also requested that their previous advice be e-mailed to members for information.
(c) Waste/non-waste status of fuel oil component
9. The Technical Group was asked to advise on the waste/non-waste status of a fuel oil in which waste lubricating oil was blended with a petroleum product (decant oil, or DCO, produced after cracking of the tarry residue of the distillation process). The fuel oil is proposed to be to sent to a power station for use as fuel, replacing a comparable fuel oil made from virgin oil.
10. A major concern was the potential for the waste oil to be contaminated with PCBs. There is always a risk with waste oil that an unscrupulous person might deliberately dispose of PCBs by mixing contaminated oil with other oils. The Group therefore requested more information on the analysis and sampling of the waste oil for PCBs.
11. The Group agreed that the material was not destined for a final disposal operation, but if it was a waste, it was destined for recovery operation R1: use as a fuel (other than in direct incineration) or other means to generate energy.
12. Turning to indicator question 1, the Group agreed that the material had an economic value. For indicator question 2, the Group agreed that the fuel oil was produced intentionally to meet market demand, it met an industry specification, its production was subject to quality control and it was part of the normal commercial cycle. The specification included environmental considerations but these were not complete. For example, the specification required no more than 200 ppm vanadium but there was no limit value for other metals such as lead. In terms of protecting the broader environment, the only relevant specification was a modest limit on sulphur dioxide. On the available information, the Group could not determine whether the blending represented a completed recovery operation, or was merely a dilution of waste oil.
13. On indicator question 3, the Group agreed that the fuel oil could be used in its present form without being subjected to a recovery operation; ie no further processing was required before use. However, Example 16 in Information Paper 2 was relevant and raised the question of whether the waste oil was as good as the oil that would otherwise be blended with the DCO to make a fuel oil suitable for the power station. If dewatered oil was not being used to achieve a particular specification, blending would not convert it to a non-waste.
14. The Group was unable to reach a decision on the available information and decided that it needed answers to the following questions:
15. The Group also noted that the exporting company had stated that it became involved in this issue after a request from the relevant State authorities to assist in finding a re-use for a quantity of used oil, in excess of the State's requirements. The Group asked that information be sought from the relevant State authorities on their involvement and intentions relating to this particular waste.
(d) Proposed export of spent potlinings
16. The Group noted the information in the agenda paper, which described the facility in Italy to which Australia exported spent potlinings.
(e) Proposed export of zinc ash
17. A representative of a South African zinc recycling facility addressed the Technical Group and sought advice on what processes would need to be set in place in order for his company to obtain a permit to import zinc ash from Australia to South Africa. He described the various measures that had already been put in place by his company to achieve environmentally sound management and conveyed his company's willingness and commitment to set in train any other processes or procedures that would ensure environmentally sound management is fully met.
18. The representative stated that since the facility was established 40 years ago, the company has voluntarily developed its own ESM procedures primarily as a means of protecting its workers. An ISO14000 environmental audit of the company was recently undertaken, and the recommendations of this audit are currently being implemented with the aim of becoming ISO14000 compliant within the next 6 months.
19. The company wished to import up to 500 tonnes of zinc ash per month and expressed its willingness to undertake any improvements considered necessary to meet the environmentally sound management criteria set down in the Act. Australian drosses were of particular interest to the company, as it has developed an alternative and effective technology for reclaiming zinc and would ultimately like to export this technology to Australia.
20. The company currently processed about 600 tonnes of zinc dross/ash per month. About a third of the material is sourced from South Africa with two thirds imported from other parts of Africa. The raw material was collected in 44-gallon drums which were stored within the factory. Some material from West Africa was collected in bulka-bags, although drums were preferred. There have been no major spillages and any minor spillages are swept up.
21. Once the material was received at the facility, the fines were separated and the fumes collected in a bag house. The process separated the material into zinc ingots and zinc dross ingots. The zinc dross was sold as pharmaceutical grade zinc to zinc oxide producers who fume the dross to produce zinc oxide.
22. The zinc ingots were processed to a customer specification of 1% lead, which is below the 1.5% limit set by domestic regulation. All ingots containing greater than 1% lead were reprocessed by blending them with low lead materials. It was in the commercial interest of the company to minimise the lead content, as higher prices are obtained for low-lead ingots.
23. Lead was the only significant contaminant and derived from the raw material and the lead that lines the bottom of galvanising baths. Arsenic and cadmium levels were very low in material destined for use as animal feedstock and, while the levels were higher in material used as fertiliser, the material fully met the required specifications.
24. In the past there had been no routine health checks of the company's personnel. Nevertheless, good results were received from blood tests recently carried out as part of the ISO14000 accreditation process. The company indicated that, in future, routine health checks including blood tests would be undertaken at regular 18-month intervals. However, problems in reporting were also highlighted, due to high illiteracy rates amongst the workforce.
25. In terms of meeting other regulatory requirements, earmuffs were required where noise levels exceeded the regulatory limits. More generally, if problems are identified the company is required to submit a report to the South African government. Since no such problems have ever been identified, the company has never had to submit such a report. Adjoining land uses included a meat-processing plant, a general engineering company and an electricity power station.
26. The Group responded to the company's presentation by explaining that there were a number of problems in the information presented. Before a permit can be granted, the Minister must be satisfied that all practicable steps have been taken to ensure that the waste is managed in a manner that will protect human health, and the environment, against the adverse effects that may result from the waste. The Group commended the company for providing some useful documentation on its process and facility, but this information itself indicated that there were problems relating to the exposure of employees to airborne concentrations of zinc, while exposure to lead had not been assessed. Furthermore, it was not sufficient for an overseas facility to upgrade its operations in order to meet Australian export requirements. The facility should already be operating in an environmentally sound manner, irrespective of whether it imported or proposed to import hazardous waste.
27. In any future application for an export permit, evidence would also have to be provided to show that, at a minimum, annual OH&S and environmental reporting requirements were fully met and all other regulatory requirements were satisfied. Detailed answers would be needed to all the questions in the Department of the Environment and Heritage Information Paper No.6. It was likely that third party certification would also be required and the cost of this would have to be met by the company. A consultant selected from a list agreed between the exporter and the Department of the Environment and Heritage would carry out the certification.
(f) Waste/non-waste status of crushed tapped bath
28. The Group was asked to consider whether crushed tapped bath was considered to be a waste. Metallic aluminium is produced by the electrothermal reduction of alumina in molten salt electrolyte, also termed "bath". Bath is formed from cryolite, or sodium aluminium fluoride, and contains aluminium fluoride that is in excess to the stoichoimetric requirement of pure cryolite. Some aluminium smelters produce surplus bath, others have a deficit, depending on their raw materials and process.
29. A smelter that produces surplus bath will tap and cool the surplus bath from time to time. When the bath has solidified it is broken into lumps, the largest of which is about 300 x 300 x 300 mm. This material may then sold to smelters that are bath deficient due to either new capacity start-up requirements, or low sodium inputs, or high losses. The bath is hazardous because of its fluoride content. The question is whether it is also a waste.
30. The Group considered the first diagnostic question and noted that if the material was proposed to be sent to other smelters for use when the bath was in deficit, it would not be destined for final disposal. The answer to the first indicator question was not clear: material was sold and presumably had an economic value, but no information was given on how much it was worth and it had no other uses other than in aluminium smelting.
31. The answers to the second indicator question were mixed. Most cryolite was produced intentionally but the surplus was not. The material was not made in response to market demand. Its production was subjected to quality control because if the chemistry is not carefully monitored and controlled, the cryolite will not function properly as an electrolyte. There was no evidence that the material met appropriate specifications other than size, or that environmental considerations applied. It was not clear whether the material was part of the normal commercial cycle: it was produced as excess material and it was fortuitous that other smelters happened to need it.
32. The answers to the third indicator question suggested that the material was not a waste. It could be used in its present form and a recovery operation or further processing was not required. The answer to the fourth indicator question confirmed this: the material was still suitable for continued use for its originally intended purpose.
33. The Group concluded, therefore, that crushed tapped bath, if sent to an aluminium smelter for use as a molten salt electrolyte in aluminium production, is not a waste. Since cryolite has no other uses, it would be a hazardous waste if sent to any other process.
(a) OECD Second Workshop on Environmentally Sound Management of Wastes Destined for Recovery Operations, 28-29 September 2000, Vienna
(b) OECD Working Group on Waste Management Policy. 51st meeting, 2-4 October 2000, Vienna
(c) Basel Convention Technical Working Group, 9-11 October 2000, Geneva
(d) Basel Convention Legal Working Group, 12-13 October 2000, Geneva
(e) Workshop on environmentally sound management in the Basel Convention ("Dakar II"), Dakar
34. These items had been covered in the joint meeting with the Policy Reference Group on the preceding day and there was no further discussion of them.
(a) History of the Technical Group
(b) Future work program
35. The Group's agreed that there was a need to re-work Information Paper 2 and Paul Brown recommended experimenting with a return to the structure of the OECD guidance document. The Group suggested working in small working groups to cover various issues, and was also interested in what was going on in the Department of the Environment and Heritage more generally.
36. The Group also discussed data collection and analysis to determine flows (ie exports and imports) of hazardous waste, particularly those that are more problematic (ie materials which might be exported without a permit and have a high risk of remaining undetected). Random checks were important to detect these.
(a) New South Wales: Lead Regulations
(b) Victoria: Occupational Health and Safety (Lead Control) Regulations 1988
(c) Western Australia: Occupational Health and Safety Regulations 1996
37. The Group thought the NSW regulations were the most useful for determining cut-off concentrations because they were prescriptive rather than outcome oriented. The definitions were given in the schedules. The Secretariat was asked to write a summary for the next meeting.
(d) 3.4 Water quality guidelines for toxicants
(e) 8.3 Toxicants
(f) 8.3.7 Detailed descriptions of chemicals
38. Information Paper 5 should be revised to take account of the new ecotoxicology-based water quality guidelines for toxicants. Paul Brown and Stephen Moore asked whether an idiot's guide to ecotoxicology could be provided and Geoff Thompson offered to provide one that had been written for lawyers.
39. There was no discussion of these items.