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Hazardous Waste Technical Group - 56th meeting

Friday 23 August 2002, 8.30 am - 4.30 pm, Bellarine Room, Hilton Melbourne Airport

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Minutes

Present:

Chair
Professor Paul Greenfield

Members
Dr Peter Di Marco
Mr Stephen Moore
Mr John Hogan
Dr Peter Scaife
Ms Diane Kovacs
Dr Neill Stacey
Dr Paul Brown
Dr Jennifer Stauber

Secretariat
Mr Andrew Inglis
Dr Geoff Thompson
Dr Greg Rippon

Apologies
Dr Peter Brotherton (Observer)
Mr James Johnson
Dr Robyn Eckersley
Dr Peter Nadebaum

Agenda Item 1. Draft Minutes of the 55th meeting

1. The meeting requested that in the first two lines of paragraph 6, the perfect and present tenses should be used. A note should be added before paragraph 18 to record that the meeting agreed to defer any new work on items 7(b) and (c) until work on 7(a) was completed.

Agenda Item 2. Matters arising

2. There were no matters arising.

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

(a) Permit report for previous twelve months

3. The permit listed for HydroMet to export precious metal concentrates to Norway was questioned. The permit listed for Exide to export lead-acid battery waste to New Zealand was for 15,000 tonnes, not 1,500 tonnes.

4. The application from Tredi to export nickel-cadmium batteries to France would probably be refused because the necessary financial guarantee had not been given and the French authorities had not consented to the proposed import.

5. The zinc ferrite proposed for export to the United Kingdom could not be treated at Pasminco's Cockle Creek smelter because although it had the technical capacity to process the material, it was operating at full capacity and could not accept an additional 3,000 tonnes at present.

Agenda Item 4. Technical issues arising from applications and inquiries

(a) Proposed export of spent potlinings

6. Representatives of Regain Technologies Pty Ltd gave a detailed briefing on their strategic approach to transforming aluminium smelter by-products such as spent potlinings (SPL) into mineral products for industrial use. SPL is hazardous because it contains soluble cyanide and fluorides, which may leach and create an environmental hazard. It also contains compounds that react with water to give off gases such as ammonia, acetylene, hydrogen and methane, which may create environmental and explosion hazards.

7. The Regain process changes the hazardous nature of SPL in three processes:

(a) heating in a rotary kiln to destroy soluble cyanide;

(b) treating with calcium sulphate to reduce soluble fluorides to levels that are safe under the Dangerous Goods Code; and

(c) crushing to a small size and reacting with water and air so that hazardous gases are driven off under controlled conditions over a 28-day curing period.

8. The processed SPL is blended with other chemicals and minerals to meet product specifications. It is particularly useful as a feed for the cement industry because it contains carbon as a source of energy to heat the kiln, alumina, iron and silica minerals, which are required in the raw material, and fluorides that can act as mineralisers in cement manufacture. Fluoride has unique mineraliser properties that allow cement active ingredients to form at lower temperatures, typically 1,300C instead of 1,450C, and which produce cement with superior strength characteristics. In the highly alkaline environment of a cement kiln, fluorine reacts quickly to form insoluble calcium fluoride that is either locked into the structure of the cement or present as insoluble calcium fluoride in the kiln dust.

9. Regain is working with Tomago Aluminium on a trial program for processing 2,000 tonnes of SPL. The objective of the trial is to establish that SPL can be used in the manufacture of mineral products that have a genuine industrial use. Two products are being produced, one based on the carbon fraction and one on the refractory fraction. The demonstration thermal plant is establishing that the process works on Tomago Aluminium SPL at a design rate of 3 tonnes per hour and the testing program is showing that the hazards of soluble cyanide, soluble fluorides and gas emission are being managed as planned. The company is in the process of obtaining the necessary State approvals and licences to develop the pilot project into a fully commercial operation and to obtain a ruling that the process results in a non-hazardous material being produced for the commercial market.

10. Development of the process on a full commercial scale is now limited by the lack of available space on the Tomago site. Regain plans to move to commercial contracts for 5,000 to 10,000 tonnes each, but needs sufficient space to hold the material during the 28 day curing period and to build up a stockpile that is large enough to guarantee security of supply to customers. There are two suitable sheds, numbers 5 and 6, on site but shed 6 is already full of SPL. Shed 5 is used to deline pots and also contains more than 10,000 tonnes of SPL. Regain wants to take control of shed 5, including the delining, so that SPL is no longer produced in its current form. Shed 5 would provide the space that is needed, but only if 10,000 tonnes of SPL are removed first.

11. Regain therefore supports Tomago's current application to export 10,200 tonnes of SPL to Italy. If the SPL was exported quickly, it would remove the current constraints on full-scale commercial operation by making space available. Regain would have preferred to retain the material for use in Australia but at present, moving to full-scale operation quickly is more important.

12. The option of constructing another shed had been considered but rejected because the process of getting approval followed by construction would take at least twelve months. By the time the shed had been built, the opportunity for moving to full-scale commercial operation quickly would have passed.

13. The meeting noted that the process was an elegant market-driven solution to the problem of dealing with SPL. The proponents had a clear business vision and were well-organised. In addition to the other environmental benefits, use of the material contributed to greenhouse targets by offering a saving of about 10% in fuel use by allowing operation at a lower temperature.

14. Two previous permits for the export of SPL to Italy were granted at a time when there were no domestic recovery options available for the waste and it was argued that there was no real alternative to export. Circumstances had changed, and it was now argued that in the short term, export was the best way to facilitate the rapid commercial development of a local beneficial use.

(b) Possible import of POPs wastes

15. There was no report under this standing item.

(c) Possible import of Flue-gas Desulphurisation Gypsum to rehabilitate land

16. The secretariat had yet to finalise its letter to Professor Rudolph.

(d) Proposed import of industrial waste water treatment sludge

17. The secretariat tabled a copy of the 'Statutory Order from the Ministry of Environment and Energy No.823 of September 16, 1996, on Application of Waste Products for Agricultural Purposes', from the Danish Environmental Protection Agency. This sets out prescriptive rules on how to use such wastes. A decision on the application to import industrial waste water treatment sludge must be made by 10 September 2002.

(e) Proposed export of used lead-acid batteries to New Zealand

18. The meeting discussed Annex C to the Statement of Decision, the comments by Commonwealth Departments on the Statement of Advice prepared by the Technical Group. Paragraphs 13 and 14 of Annex C were not strictly correct and reflected an incomplete understanding of the process. The issues raised in paragraph 13 had been considered in considerable detail, as described in paragraphs 28-35 of the Technical Group's advice. All relevant provisions of the Basel Convention had been considered and the comments about Article 4.9 overlooked the fact that this Article was neutral in the context of the present application. The Technical Group did not agree that the effects on the recycling industries in Melbourne were irrelevant to our international obligations under the Basel Convention: these effects were critical in estimating whether transboundary movements would in fact be reduced to a minimum.

19. The meeting also disagreed with the suggestion in paragraph 39 that their recommendations appeared to be based on promoting the commercial interests of ARA ahead of Exide's interests. This suggestion was wrong: the recommendations were based upon the Technical Group's best assessment of Australia's international obligations under the Basel Convention.

(f) Proposed lead-acid battery stripping operation

20. The meeting discussed the proposed operation and noted that the process appeared to be technically feasible. However, more technical information was required to support the company's argument that the materials produced at the end of the process would be non-wastes. In particular:

(a) What process would be used to clean the high grade lead grids?

(b) Too little information was provided to determine whether the conversion of lead sulphate paste to lead carbonate would produce a non-waste, as described in Information Paper No. 2.

(c) What was the detailed composition of the potassium sulphate or ammonium sulphate, produced as a by-product for marketing to the agricultural industry as a fertiliser? This was a critical element of the whole proposal.

21. As described, the proposal had potential environmental benefits, notably the recycling of the acid and a reduction in the amount of slag produced. However, critical questions remained on whether the grids and the lead carbonates were hazardous wastes or not, and on whether the economics of the proposal were commercially feasible.

Agenda Item 5. Reports of international meetings

(a) Report of the twentieth session of the Basel Convention Technical Working group, Geneva, 23-24 May 2002

22. The meeting noted the report.

(b) Draft technical guidelines on the environmentally sound recycling/reclamation of metals and metal compounds

23. The meeting noted that a note for Table 4, headed "LD50 Toxicity", was inappropriate: common salt was not more toxic than thallium.

Agenda Item 6. Work Program of the Technical Group

24. The meeting:-

(a) Expressed concern that we still didn't know how much hazardous waste is generated in Australia.

(b) Wanted to have our treatment capabilities described more clearly. For example, spent potlinings were now being processed in a technically advanced but expensive process at Portland while a more commercially focussed process was being developed at Tomago.

(c) Welcomed the proposal that the Group discuss issues relating to the management of hazardous waste with officers of the Department of the Environment and Heritage Sustainable Industries Branch at its next meeting.

(d) Was concerned to foster cleaner production and sustainable industries as a way forward for the management of hazardous waste.

(e) Thought it would be useful to have another look at the Basel Convention Strategic Plan, at what happened in countries that imported Australian hazardous waste, and at the management of hazardous waste in Australia.

(f) Recommended that consideration be given to engaging a technical editor or writer to assist in the preparation of technical papers.

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

(a) Guidance on whether wastes containing metals or metal compounds are controlled under the Hazardous Waste Act

25. The meeting agreed that we could not continue to use guidelines that did not take ecotoxicological data into account. However, this would be a significant regulatory change and government policy required that the Department of the Environment and Heritage undertake a consultation process on the implications of such a change. The meeting therefore agreed to finalise an interim paper whose prime purpose was to make the requirement for a leachate test enforceable. At the same time, the Department of the Environment and Heritage would begin the consultation process for ecotoxicology based guidelines.

26. The meeting made a number of amendments to the draft paper. In particular, a statement was inserted to the effect that advice on correct sampling procedures and dealing with variability of results should be sought from the Department of the Environment and Heritage. The meeting also agreed to use a drinking water value of 3 g/L for thallium, based on a Provisional Remediation Goal developed by Region 9 US EPA. The paper was adopted, subject to circulation of the amended draft to members out of session.

(b) Hazard assessment of Y22 copper compounds

(c) Hazard assessment of Y23 zinc compounds

27. There was no discussion of these items.

(d) Hazard status of PVC

28. At the 20th session of the Technical Working Group to the Basel Convention, India had proposed placing PVC coated cables in Annex IX. The session did not come to a conclusion on the proposal but in the course of the debate, reference was made to the fact that PVC generally contained lead stabilisers at concentrations greater than 0.5 %. This raised the question of whether PVC wastes should be regulated under the Hazardous Waste Act because they contained more than 0.5 % lead, irrespective of other considerations.

29. Under the OECD control system, polymers of vinyl chloride are green tier wastes (GH013) and are not controlled unless they are contaminated by other materials. The status of polymers of vinyl chloride has not been decided under the Basel Convention because the Parties have not reached agreement on whether they are hazardous.

30. The meeting noted that although there was disagreement about the hazard status of PVC wastes, the lead content is only one of the issues. Members asked the secretariat to obtain further information on the quantities of PVC wastes that were exported and imported and the countries that were involved, on the lead content, and on typical ways of recycling. They asked the secretariat to contact the Plastics and Chemicals Industries Association for more information, and to obtain copies of the CSIRO report on PVC.

31. The meeting also discussed whether the lead content of PVC coated cable should be determined as a proportion of the PVC component alone, or as a proportion of the PVC and the copper wire combined. No conclusion was reached.

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

Agenda Item 9. Defining environmentally sound management

Agenda Item 10. Regional Centres

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

(a) Scoping study for the National Environment Protection Council National Management of Clinical and Related Wastes

Agenda Item 12. Other Business

32. There was no discussion of these items.

Agenda Item 13. Dates of next meetings

(a) Friday 11 October 2002, Canberra

(b) Friday 22 November 2002