(BAT) Reference Document for the Production of Chlor-alkali ...

Chapter 4
Deposit to be built for long-term deposition as long as geological conditions are
unchanged
Transportation to the landfill with minimised risk of mercury loss
Measures to monitor possible leaks
Marked with appropriate signs describing the content
Designed to blend into its surroundings
Secure against trespassers
Programme of monitoring and maintenance routines
{Requirements for landfills are outside the scope of this BREF.}
Costs for cleaning the old plant and depositing of contaminated waste:
{Text and table were shortened and moved upwards.}
Reference literature
[ 1, Ullmann's 2006 ], [ 57, EIPPCB 2011 ], [ 59, Euro Chlor 2010 ], [ 87, Euro Chlor 2006 ],
[ 91, Euro Chlor 2011 ], [ 92, Gluszcz et al. 2007 ], [ 94, Euro Chlor 2009 ], [ 166, CEN 2001 ],
[ 167, CEN 2005 ], [ 168, ISO 2004 ], [ 175, CEN 2007 ], [ 177, CEN 2002 ], [ 178, CEN
2002 ], [ 184, Euro Chlor 2008 ], [ 222, Euro Chlor 2007 ], [ 227, de Flon 1998 ], [ 271, CEN
2006 ], [ 274, Ancery 2011 ], [ 275, ANE 2010 ], [ 276, French Ministry 2010 ] [de Flon, 1998],
[Euro Chlor Env. Prot.3, 1999], [Italian report, 1997], [Lindley, 1997]
4.1.3.2 Mercury-containing wastes
Large amounts of mercury-containing wastes are generated during decommissioning. Mercury
is classified as very toxic [ 76, Regulation EC/1272/2008 2008 ] and waste containing very toxic
substances at concentrations [ 0.1 % is classified as hazardous [ 145, Decision 2000/532/EC
2000 ]. General techniques for the treatment of mercury-containing wastes are described in
Section 4.1.3.1 and in the Waste Treatments Industries BREF [ 268, COM 2006 ].
Most of the mercury incurred during decommissioning is in its elemental form (see
Section 3.5.11). Metallic mercury no longer used in the chlor-alkali industry is considered waste
[ 279, Regulation EC/1102/2008 2008 ]. The storage of metallic mercury that is considered as
waste for up to one year is subject to the permit requirements of the Waste Framework Directive
[ 269, Waste Framework Directive 98/EC 2008 ]. If the storage time exceeds one year, the
provisions of the Landfill Directive apply [ 281, Directive 1999/31/EC 1999 ]. In addition, the
provisions of the Seveso II Directive apply if the quantities of stored mercury exceed the
threshold values in Annex I, Part 2 to that Directive [ 280, Seveso II Directive (96/82/EC)
1996 ]. In 2011, however, the Landfill Directive did not contain specific criteria for the
temporary storage of metallic mercury considered waste. To this effect, a proposal for a
Directive was submitted to the Council in May 2011. The proposal does not include criteria for
the permanent storage of metallic mercury because additional assessments were deemed
necessary. Furthermore, the proposal takes note of the research activities on safe disposal
options including solidification of metallic mercury but deems that it is premature to decide on
WORKING DRAFT IN PROGRESS
the large scale viability of such option [ 282, COM 2011 ]. An overview of available options for
the storage of metallic mercury with or without solidification can be found in [ 283, BiPRO
2010 ] and [ 284, Krehenwinkel 2011 ].
170 December 2011 TB/EIPPCB/CAK_Draft_1