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Hazardous Waste Technical Group - 47th meeting

Tuesday 12 June 2001
8.30 am - 3.30 pm
Cleanaway Treatment Plant, 20 George Street, WINGFIELD SA 5013
and Adelaide International Motel, 521 Anzac Highway, GLENELG NORTH SA 5045

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Minutes

Present:

Chair

Professor Paul Greenfield

Members

Dr Peter Di Marco
Dr Peter Scaife
Mr Stephen Moore
Dr Neill Stacey

Co-opted expert

Mr James Johnson

Observers

Ms Wendy Boyce
Dr Peter Brotherton
Mr Geoff Sclare

Secretariat

Mr Cliff Lloyd
Dr Geoff Thompson
Ms Sandra Riddell

Apologies

Dr Paul Brown
Mr John Hogan
Dr Robyn Eckersley
Ms Diane Kovacs
Mr Ray Evans
Dr Peter Nadebaum
Dr Jenny Stauber

Agenda Item 1. Draft Minutes of the 46th meeting

1. Amendments were made to paragraphs 8, 9, 11, 13, 14, 17, 18 and 31. As amended, the draft Minutes were accepted.

Agenda Item 2. Matters arising

2. Robyn Eckersley expected to resume regular attendance at the next meeting. The meeting agreed that James Johnson should continue to serve as a co-opted expert during the absence of Paul Brown.

3. Travel arrangements would change on 1 July 2001 because the Department of the Environment and Heritage had negotiated a larger discount in exchange for renouncing frequent flyer points. Group members could continue to book air travel through the Department of the Environment and Heritage but they would no longer receive frequent flyer points for travel booked in that way.

Agenda Item 3. Progress report on operation of the Hazardous Waste Act

(a) Permit report for previous twelve months

4. Tomago Aluminium Company Pty Ltd had now applied for a permit to export 8,200 tonnes of spent potlinings to Italy.

5. Members of the Group asked how the Department of the Environment and Heritage verified Environmentally Sound Management (ESM) of imported wastes. Geoff Thompson advised that applicants for permits had to describe their proposed processes clearly and the Department of the Environment and Heritage checked that they were authorised under State or Territory law to carry out those processes. This was normally considered sufficient but any uncertainties would trigger further investigation including, if appropriate, referral to the Technical Group.

Agenda Item 4. Technical issues arising from applications and inquiries

(a) Proposed export of diethylaluminum chloride/heptane mixture
(b) Waste/non-waste status of fuel oil component

6. There was nothing to report on these items. The companies had not yet provided the information requested by the Department of the Environment and Heritage.

(c) Proposed export of spent potlinings (SPL)

7. The Department of the Environment and Heritage would assess the export application against regulation 16 of the OECD Decision Regulations, particularly regulation 16.(1)(b) concerning environmentally sound management and regulation 16.(1)(d) concerning authorised facilities. If more information was required to deal with the application it could be requested under regulation 11, but such a request should be comprehensive because it must be made in writing within 40 days after the application was received.

8. The meeting noted that the application involved recovery operation R13 (Accumulation of materials intended for another recovery operation) followed by another recovery operation, probably R1 (Use as a fuel (other than in direct incineration) or other means to generate energy). In accordance with the relevant provisions of OECD Council Decision C(92)39/FINAL, the applicant should be asked to identify each and every recovery facility where recovery operation R1 would occur.

9. The meeting also noted that under Regulation 16 (1)(b), the Minister must not grant a special export permit authorising the export of hazardous waste unless the Minister is satisfied that dealing with the hazardous waste concerned in accordance with the export proposal would be consistent with the environmentally sound management of the waste. The applicant had previously indicated that "Australian electric arc steel mills ... have not shown any real interest to try and recycle this material. Some of the concerns raised have been related to ... the effect of SPL contaminants on their process, in particular sodium and fluoride ... (and to) environmental and emotive issues where there has been a higher level of scrutiny by authorities and communities when accepting waste products for re-use". The meeting agreed that in order to be satisfied about the environmental soundness of the export proposal, specific information was needed on how these concerns and issues were dealt with by the Italian authorities and facilities.

10. The contract with the recovery facility stated that it "will crush, sieve, blend and upgrade the quantities of Total SPL residue ... (and) shall bring the carbonaceous cathodic residue together with other carbonaceous substances to the specifications required for use as additives for fluidisation and deoxidisation in the electric steel production process as specified under Italian and EU Regulations". The meeting agreed that complete copies of these specifications and Regulations should be provided.

11. Details should also be provided on how the recovery facility stored the SPL waste, including the maximum size of any stockpiles, and the measures taken to control dust and particulate emissions from the crushing, sieving and blending process. If any regulations applied to these processes, complete copies of those regulations should be provided.

12. In regard to the electric steel production process, the applicant should be asked to provide complete copies of all regulations governing emissions, particularly of fluoride, to air. The information provided should include details of permitted levels and the levels that were actually achieved in practice.

13. Similarly, the applicant should be asked to provide complete copies of all regulations governing leachate, particularly of fluoride, from slag. The information provided should include details of permitted levels and the levels that are actually achieved in practice.

14. The meeting agreed that it would also be useful, but not essential, if the applicant were to provide details of the other carbonaceous substances which were blended with the carbonaceous cathodic residue.

15. The meeting reviewed correspondence about a proposed alternative method in which leaching with dilute caustic soda solution would be used to remove fluoride and cyanide from SPL. Pilot scale work indicated that the leach residue would contain more carbon (50-60%) than the SPL (25-35%) and less cyanide (from 0.16% to 4.57ppm) and fluoride (from 13.5% to 2.2%). This leach residue could then be sold for use in various furnaces as an alternative fuel. Failing that, it could be landfilled as a non-hazardous waste because it passed the TCLP concentration cut-offs set by NSW EPA.

16. The leach solution contains fluoride and cyanide. This is oxidised, precipitated and filtered to produce an immobilised calcium/magnesium fluoride which passes the TCLP concentration cut-offs set by NSW EPA and may be landfilled.

17. The meeting made a number of comments on the proposed method. The proposed timescale envisaged commercial processing on a long-term basis within 2 years and this was very optimistic. The proposal assumed that steel mills, smelters or cement kilns would be willing to take a material that contained 2.2% fluoride. This would certainly not be possible at Rooty Hill and the meeting asked whether the proponent had discussed the fluoride content with the operators of potential facilities. The technology could be considered inferior to the Ausmelt process because it did not produce useable fluoride, but it appeared to be less expensive.

18. Concerns were also expressed about which TCLP had been used and whether the aluminium carbides would present a problem. The real issue, however, was whether the upgraded carbon product could actually be used in steelmaking processes. The meeting asked the Secretariat to draft a letter to the proponent raising the various issues and to clear the draft with the Group before despatch.

19. The meeting noted that the advice on the export of spent potlinings, agreed at its previous meeting, had been discussed by the Policy Reference Group on 4 June 2001.

20. In the context of acting at a high level to encourage cooperation between the steel and aluminium industries in disposal of SPL, the meeting noted that the Department of the Environment and Heritage proposed to pursue this through the Light Metals Action Agenda, a whole-of-government initiative administered by the Department of Industry, Science and Resources.

(d) Proposed export of aluminium alkyls

21. The meeting discussed the outcomes of the site visit to the Cleanaway Technical Services incinerator. This was suitable for the treatment of various wastes including hydrocarbon solvents, paints, alcohols, inks, flammable sludges, security documents, out of specification products and quarantine confiscated goods. However, its main use was to dispose of medical wastes. The fluidised bed incinerator destroyed wastes thermally, producing an inert ash and clean flue gas. The system employed was unique as it allowed the destruction of solid wastes, such as medical wastes, at the same time as the incineration of liquid solvents. The incinerator currently ran for three shifts, five days a week. The site was continuously monitored in relation to emission levels prescribed by the SA EPA as conditions of the site licence. Stack emission tests were also required for a broad range of chemicals on an annual basis.

22. In theory, the incinerator could use a separate handling system to introduce the aluminium alkyl waste. However, the company had had experience of such a process with another waste, an off-specification herbicide consisting almost entirely of acrolein and known as "Magnacide". Treating this had necessitated a shutdown of the normal incinerator process, connection to the different handling system, and operation over the weekend and on overtime. It was an expensive, intrusive and time-consuming process which required emission monitoring, a methanol purge and rinse, quench tanks and a gas detection capacity.

23. Cleanaway had cited the reactivity of the aluminium alkyls as the main reason for not accepting them. They resembled the Magnacide in that handling them would raise issues related to occupational health and safety, operational procedures, the skills of the current workforce, the cost of extra training and the need for EPA approval. The decision not to accept them was not totally cost driven but the facility was not in a position to take on the disposal of the aluminium alkyls. Although a niche market presented an opportunity, there was a need to balance this with maintaining mainstream operations.

24. One question that had not been considered was whether dilution of the waste with non-aqueous solvents could reduce the hazards to a level where no special handling was required before incineration.

25. At its previous meeting, the Technical Group had requested some additional information from the applicant for an export permit. A response had been received on 1 June 2001 and was tabled at the meeting. The Group considered this response and requested further information on the following points:

(a) Figures on the quantity of aluminium alkyl waste generated each year since 1994, so that an accurate picture of production in relation to storage capacity was available.

(b) The waste was stored at 10% dilution in the containers in which the aluminium alkyls were originally supplied. Since this suggests that at least 90% of the material is consumed in the process there is a question whether the alkyls be properly considered to be catalysts or reagents.

(c) Whether the importing company is the sole user of the dedicated unloading unit, and at what point its responsibility for the waste ends.

(d) The applicant considered that storage of this material was currently an issue with both sites reaching their Dangerous Goods maximums, and they had not yet been successful at locating an off-site storage facility that was able to store the material. This raised questions about the legal requirements for inspection, as opposed to the manufacturer's recommendations. What were the licensed maximums for storage and what was the process for increasing them?

(e) What was the magnitude of dilution with solvents that would be required to reduce the hazard posed by the waste so that it could be treated in an incinerator such as Cleanaway's as a solvent?

26. The meeting also requested the Department of the Environment and Heritage, where appropriate, to seek this information from State and Territory authorities and Cleanaway.

27. Paul Greenfield summed up by noting that, notwithstanding the information still being sought on possible dilution of the waste, the general view was that neither the Lidcombe nor Cleanaway facilities were suitable for disposal of the waste. More information was desirable on safe storage of the waste but, in view of the small quantities generated and the likelihood that the excisting process would eventually be replaced by others, it appeared unlikely that a local disposal option would ever be developed in Australia. This was in marked contrast to the spent potlinings from aluminium smelting, which were produced in such large and continuing quantities that it was essential to develop local solutions.

(e) Application for transfrontier movement of brass dross

28. The Department of the Environment and Heritage had received a new application to export brass dross to the United Kingdom. The meeting examined this and concluded that the advice given at its 45th meeting still stood: the hazardous waste could be disposed of safely and efficiently, and in an environmentally sound manner, at a facility in Australia.

Agenda Item 5. Reports of international meetings

(a) Basel Convention Technical Working Group, 18th session, 18-20 June 2001 , Geneva

(i). Annotated provisional agenda

(ii). Review of adjustment of the lists of wastes contained in Annex VIII or IX: additional information on bituminous materials and waste edible fats and oils

(iii). Review of adjustment of the lists of wastes contained in Annex VIII or IX: application by India on PVC coated cable scrap

(iv). Information paper on the purpose of Annex IX

(v). Consideration of the development of the work on hazard characteristic H6.2 (Infectious Substances)

(vi). Development of the ecotoxicological criteria for the characterisation of hazardous wastes

(b) Basel Convention Legal Working Group, 3rd session, 21-22 June 2001 , Geneva

(i) Annotated provisional agenda

29. Geoff Thompson will be attending these meetings. There was no discussion of the agenda items.

(c) Workshop on environmentally sound management in the Basel Convention ("Dakar II"), Dakar

30. There was nothing to report on this item.

Agenda Item 6. Work Program of the Technical Group

(a) History of the Technical Group
(b) Future work program

Agenda Item 7. Criteria for separating hazardous from non-hazardous wastes

31. There was nothing to report on these items.

Agenda Item 8. Criteria for separating wastes from non-wastes

(a) Information Paper No.2, Fourth edition, third draft

32. This paper was tabled at the last meeting of the Policy Reference Group. The PRG recommended some minor changes to Figure 1 in the paper. The Group agreed with these changes and suggested some additional changes to Figure 1. As amended, the Group agreed that the paper is ready to be published.

Agenda Item 9. Defining environmentally sound management

(a) Assessment of Environmentally Sound Management: An Example

33. A draft paper had been prepared by the Department of the Environment and Heritage to help applicants for a Basel export permit to understand the requirements for environmentally sound management. The paper followed the format of the 'Assessment of Environmentally Sound Management' prepared for the export of paragoethite to South Africa.

34. The meeting agreed that the draft paper should be turned into an example of the kind of document that an applicant should submit. Examples of information, addressing the eight ESM questions, should be included to show what was acceptable and what was not. Examples of comments that might be made by the Technical Groups should also be inserted, perhaps in italics.. It was also suggested that the document be restructured using the ESM questions as sub-headings.

35. The Department of the Environment and Heritage intended to prepare a revised document within the next two weeks for the Group to comment on out-of-session.

Agenda Item 10. Regional Centres

Agenda Item 11. Avoidance, minimisation and treatment of hazardous wastes

Agenda Item 12. Other Business

36. There was no discussion under these items.

Agenda Item 13. Dates of next meetings

(a) Friday 13 July 2001, Brisbane (depends on progress with application to export aluminium alkyls: members to be advised by Thursday 5 July 2001)

(b) Friday 17 August 2001, Sydney

(c) Friday 21 September 2001

Document tabled at meeting

Response to the Department of the Environment and Heritage Questions: e-mail of 1 June 2001.