Publications archive - Hazardous waste
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Friday 9 March 2001
8.30 am - 4.30 pm
Ansett Australia: Melbourne Airport. Conference Room C
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Professor Paul Greenfield
Dr Paul Brown
Dr Peter Nadebaum
Dr Robyn Eckersley
Dr Peter Scaife
Mr John Hogan
Dr Neill Stacey
Ms Diane Kovacs
Dr Jenny Stauber
Mr Stephen Moore
Mr Peter Christoff
Ms Sandra Riddell
Dr Geoff Thompson
Dr Greg Rippon
Dr Peter Di Marco
Mr Simon Divecha
Mr Matt Ruchel
1. In para 19 line 1, zinc dross was changed to zinc ash. In para 38 the text was changed to read 'Paul Brown and Stephen Moore'. As amended, the draft Minutes were accepted.
2. Dr Neill Stacey has replaced Dr Gordon Reidy as a member of the Technical Group.
3. The agenda papers for the meetings can now be accessed from a password-protected site on the Department of the Environment and Heritage website.
(a) Permit report for previous twelve months
4. Since the last meeting, two applications to export hazardous waste had been granted and seven applications to import hazardous waste had been granted. Four of the permits to import zinc ashes and residues had previously been refused because a license to process hazardous zinc waste under the new NSW legislation had not yet been issued. This license has now been issued. Six applications were currently outstanding.
(a) Proposed export of diethylaluminum chloride/heptane mixture
5. The applicant indicated that a possible disposal option within Australia had been identified. The Department of the Environment and Heritage will confirm progress on this matter later. The application will expire at the end of March.
(b) Proposed export of tetraethyl lead sludge
6. The Australian Institute of Petroleum had sent the Department of the Environment and Heritage a partially updated inventory of tetraethyl lead sludge in storage: one company was still to submit information. The details of the two export applications received by the Department of the Environment and Heritage, described in the Gazette notices, were consistent with the details in the inventory.
7. The issue of whether there was a suitable alternative to the export of the material had been considered. One applicant had indicated that that the simple re-use of the material in leaded petrol (ie dispersing the material in leaded petrol) was not an option because production of leaded petrol had been phased out, and the production of a lead-replacement petrol had commenced. The company's only leaded petrol storage tank will be used for storage of lead-replacement petrol after repairs and necessary modifications. This was considered satisfactory and a permit had been granted.
8. The other applicant still needed to address the requirements of the competent authority for the United Kingdom before a permit could be granted.
(c) Waste/non-waste status of fuel oil component
9. The company that had requested resolution of the waste/non-waste status of the fuel oil component was waiting on additional information from overseas and the Technical Group could not discuss this issue in detail. The group asked the Secretariat to remind the company about the information requested on the frequency and nature of sampling for PCB contamination by the waste oil collector. This issue will be discussed at the Group's next meeting if the additional information becomes available before then.
10. The Group agreed that when a particular issue, such as this one, was discussed over a number of meetings all the information on the issue should be collated.
(d) Proposed export of spent potlinings
11. Warren Brooks of Tomago attended the meeting to discuss aspects of the company's anticipated application for a export permit. The company had previously been issued a permit to export 34,000 tonnes of this waste but could not export the full amount in the time available. A second permit had been granted for the remaining 18,000 tonnes and 1,300 tonnes of this remained. It was extremely difficult to ship this as a part load direct from Newcastle to the recovery facility in Italy and the company was therefore considering an application to export a full shipload of 8,500 tonnes.
12. The major issues explored by the meeting concerned the global context of the proposed exports, environmental issues arising from the proposed process, and hazards and costs of storing the material.
13. Warren Brooks indicated that all aluminium smelters around the world produced spent potlinings (SPL) but management of them varied. Stockpiling was common and it was better to cover the material to prevent leaching after rainfall. The aluminium industry (and Tomago) did not favour allowing stockpiles to grow large because this increased the risk of environmental damage through accidents. Tomago had already experienced problems when an undetected roof leak resulted in groundwater being contaminated by leachate.
14. Full storage capacity at the site would be reached by late 2003/early 2004. The waste was generated at 6-7,000 tonnes per annum, possibly 8,000 tonne per annum at its maximum, then decreasing to around 5,000 tonne per annum. Increased storage was not a good option as any process that was developed to use the material would be fully occupied with new arisings and was not likely to be able to deal quickly with large backlogs of stored material.
15. The recovery facility had a capacity of about 200,000 tonnes per annum (not 20,000 tonnes as stated in the 1996 report), and it took material from a number of countries including Canada, France, Germany, Holland, Russia and Spain. The economics were favourable because of the economies of scale that were involved and because sources of carbon were more expensive in Europe than in, for example, Australia. Technically, the local steel industry operated its electric arc furnaces in ways that claimed to be leading edge with a much more efficient oxygen enrichment process. The furnaces required carbon to recarbonise of steel and the fluoride replaced fluorspar. In general, the industry was very secretive and it was difficult to obtain detailed information.
16. There was thought to be no particular change in fluoride emissions when SPL was used in place of fluorspar. When the slag was tested, heavy metals were of greater concern then fluoride. It was understood that most slag was used as roadfill after a leachate test was performed and if the slag failed the leachate test then it was landfilled.
17. In Tomago's view, the best option open to it was export for use in steel making. The problem with Australian steel makers that used electric arc furnaces was the low cost of alternative carbon sources, combined with the negative perception of SPL as a hazardous waste because of the cyanide and fluoride content. The difference might lie to some extent in culture because the overseas facilities had started many years ago and were accustomed to dealing with the material. There needed to be some driving force for Australian steel makers to become interested, sufficient to overcome the various hurdles such as workforce and community perceptions and the attitude of regulators.
18. Other countries used various techniques. France, for example, landfills or stockpiles at the back of the facility but is also experimenting with use by the cement industry. Germany is trying to recover cryolite but there are issues with by-products. Canada stabilises the material and then landfills, or exports to Italy. The proposed export was an expensive option once the transport costs had been added to the processing fees charged by the facility and the meeting noted the relevant figures.
19. Of the processes that were being investigated within Australia, and which were reviewed at the 42nd meeting, on 1 September 2000, the most promising appeared to be the use of SPL in cement kilns in Australia. However, there were a number of outstanding issues to be resolved, including community concern about acceptance of hazardous waste as a raw material, the high sodium content (specifications for cement have tight sodium levels) and the potential for fluoride to leach from the clinker. If these issues could be resolved, possibly within 2-3 years, it was likely that this process could dispose of all of Tomago's production of SPL. Changing economic conditions could help because the cement industry faces stiff competition from cheap imports. Community acceptance, however, remains a concern, and the cement industry is looking at a quite a range of cheap alternatives.
20. The meeting identified a number of important issues, including:
21. The Group did not reach a consensus and asked the Department of the Environment and Heritage to prepare a short issues paper for consideration at the next meeting. The Group also requested copies of French Standard NF31210 and the relevant regulations in France and Italy for allowable limits of fluoride in slag from steelworks, and also in leachate from EPA 300 (89). They also asked what sampling procedures were used in generating the leachate data.
(e) Proposed export of aluminium alkyls
22. An application had been received to export aluminium alkyls for final disposal in the Netherlands. The Hazardous Waste Act prohibits exports for final disposal unless there are exceptional circumstances. The applicant had submitted an investigation report into an explosion at their facility which had resulted in the death of one operator. The explosion had also destroyed the equipment used to dispose of this waste. It was not clear whether this would constitute an exceptional circumstance under the Act.
23. The Group was unable to reach a decision on the available information and requested additional information on alternative disposal facilities, the hazards associated with local storage and disposal of the material and the hazards associated with the disposal process at the Rotterdam facility. Members asked that contact be made with Waste Services at Lidcombe, NSW, which has the best facilities in Australia and may be able to treat this type of waste, and Cleanaway in South Australia, to determine whether they are capable of disposing of this waste.
24. Geoff Thompson advised that a similar application had been received from another company almost one year previously (see under item 4(a) above). The applicants had indicated that they were still pursuing a local disposal option, which should be operational soon. This option should also be followed up. The meeting noted that alternative facilities may have operational issues preventing them from taking the waste but if negative responses were received from those facilities, it would provide the Group with firmer grounds on which to base a recommendation.
(f) Import of zinc sulphate heptahydrate
25. Zinc sulphate heptahydrate fertiliser containing extremely high levels of cadmium (up to 11%) had been imported into Australia from China, including Taiwan. Due to the high levels of cadmium, this material was considered a hazardous waste under the Act. An Australian Company, Hardman Australia, had been first to detect these imports and had placed an advertisement in The Land newspaper warning farmers about the contaminated fertiliser. The Department of the Environment and Heritage was working with Customs to detect and prevent these imports
(g) Proposed export of brass dross
26. There was no discussion of this item.
(a) The Basel Convention Regional Training Seminar for Port Enforcement Officers, 4-8 December 2000, Hong Kong
27. Greg Rippon had attended this seminar, which was part of a new Basel Convention project for the Asian Region. He had been particularly impressed by the way that officials from the Netherlands were using a remote video camera and Internet link for inspecting waste shipments. A number of waste streams were of particular concern in the region, including plastic waste and computer scrap.
(b) Workshop on environmentally sound management in the Basel Convention ('Dakar II"), Dakar
28. This item was not discussed.
(a) History of the Technical Group
(b) Future work program
29. These items were not discussed.
(a) Detailed description of chemicals
30. This item was not discussed.
(b) Information Paper No. 5, Second Edition, first draft
31. The Department of the Environment and Heritage had received the report of a police investigation into a suspected illegal export of zinc ash. The exporter had analysed the ash to show that the lead content was less than 1% but did not do a leachate test to demonstrate that it would not leach lead into the environment. The Director of Public Prosecutions decided not to prosecute because while it would be easy to prove negligence if one exported zinc ash without a chemical analysis, it would be difficult to persuade a court that it was negligent to export zinc ash for recycling without doing a leachate test. This outcome confirms the Department of the Environment and Heritage general experience in compliance work. The leachate test is technically sound and very appropriate for landfill management, but it was less suitable for categorising wastes exported for recovery operations. It would be better, at least for compliance and enforcement purposes, to define hazard in terms of percent composition.
32. The Department of the Environment and Heritage proposed, in the short term, to rely on the Worksafe concentration cut-off levels but these should be updated to use the revised values adopted by Worksafe in 1999. These had replaced the 1994 values that were used in the original 1998 edition of Information Paper No.5. This would mean a higher cut-off for arsenic and lower cut-offs for lead, mercury and selenium. It was also necessary to make it clear that diluting a hazardous waste with other materials was not acceptable. In the case under investigation, it had afterwards emerged that the exporter had mixed the zinc ash with sand to get it below 1% lead: the sand was later removed by sieving before the zinc was recovered.
33. In the long term the Department of the Environment and Heritage proposed to revise the Information Paper to review the new water quality guidelines, limits for contaminated sites and so on. At the same time data would be collected on leachate from specific materials such as zinc ash. If it was found, for example, that zinc ash containing specified concentrations of lead generally produced high concentrations of lead in leachate, it might be necessary to revise the concentration cut-offs for that material.
34. The meeting expressed much concern at the decision not to prosecute, because the TCLP was an effective and appropriate way to test whether toxic metals were present in a form that could enter the environment. With the diluted material, a TCLP would have been the best way to determine whether it was in fact hazardous to the environment.
35. The meeting agreed to adopt the new Worksafe cut-off levels immediately. Members asked that the new limits be promulgated in a form other than a second edition of Information Paper No. 5, because that paper needed substantial revision for other reasons.
(c) Questionnaire concerning Hazard Characteristic H10
36. This item was not discussed.
(a) Information Paper No.2, Fourth edition, first draft
(b) Information Paper No.2, Fourth edition, Annex
(c) Information Paper No.2, Third edition
(d) OECD Final guidance document for distinguishing waste from non-waste
37. A first draft of the fourth edition of Information Paper No.2 had been prepared. This edition was restructured to follow the format of the OECD guidance document for distinguishing waste from non-waste.
38. Some members of the Group preferred the use of the indicator questions, as set out in the third edition, because it provided a structure that made it simpler to use the paper. Others preferred the OECD structure because it was less confusing. The meeting agreed to combine elements of both approaches, relying primarily on the OECD structure but introducing references to the indicator questions wherever possible. A number of other comments were made on the text and a revised version would be considered at the next meeting. Members commented that the summary of the examples was an excellent concept.
(a) Draft guidance on Assessment of Environmentally Sound Management of Hazardous Waste Destined for Recovery Operations in OECD Countries
39. This item was not discussed.
(a) Hazardous waste management in Asia
40. Matt Ruchel of Greenpeace Australia and Simon Divecha of the Minerals Policy Institute, and formerly of Greenpeace Australia, gave a presentation on hazardous waste management in Asia. They focussed in particular on the events and issues leading to the adoption of the Basel Ban Amendment.
41. Simon Divecha gave a detailed description of the export of plastic waste to Asia, ostensibly for recycling/recovery operations. Often this waste was contaminated with other wastes and a lot of it did not end up by being recycled. The Indonesian Government had banned the import of plastic waste because companies were sending containers and barrels of other waste, such as zinc and cadmium wastes, mixed up with the plastic waste. Handling this type of material had serious effects on the health of workers and their families. The import of plastics also disrupted the economics of local scavenging and recycling because it substantially depressed the price of plastics for local operators.
42. Matt Ruchel described the export of materials such as used lead-acid batteries and computer scrap to Hong Kong, Indonesia and the Philippines. It was often extremely difficult to track a waste from its origins to its final destination. Both Matt and Simon emphasised that paper evidence could not be trusted with exports to developing countries: statements that looked satisfactory on paper were rarely consistent with reality.
43. This item was not discussed.
44. Robyn Eckersley advised the meeting that work commitments would prevent her attending the next few Technical Group meetings. She had identified a colleague whose expertise and experience made him an appropriate candidate to serve as a co-opted expert in her absence. He was James Johnson, a barrister who was Director of the Environmental Defender's Office in Sydney from 1992-1999. He had had extensive involvement in environmental litigation, legal policy and education. The Group agreed to co-opt Mr Johnson and a copy of his resume would be circulated to the Group.
45. Paul Brown advised the meeting, albeit in colourful language, that he had a similar problem and would endeavour to identify another candidate for co-option as an expert.
(a) Friday 6 April 2001, Melbourne
(b) Friday 11 May 2001
(c) Friday 15 June 2001