|Friday, 23 September 2011 15:26|
The raw materials such as lime, coal and oil that are used for cement production usually contain trace concentrations of mercury. In addition, solid residues from other sectors such as fly ash and gypsum often used as raw materials for cement production contain mercury as well. Also the waste that is sometimes used as fuel in cement manufacturing may significantly increase the total input of mercury to cement production.
Sometimes the use of materials with low concentrations of mercury could lead to significantly high releases of mercury into the atmosphere if the consumption of these materials is in very large quantities.
Emissions from cement production amount to 9.8% of the global mercury emissions to air.
Relevant legislation and NGO policy work
In the EU
The Integrated Pollution Prevention and Control (IPPC) Directive (96/61/EC), has been in place since 1996 and also refers to the Cement production sector. The Commission has undertaken a 2 year review to examine how the legislation on industrial emissions could be improved.
As a result, the Commission adopted on 21 December 2007 a Proposal for a Directive on industrial emissions recasting seven existing Directives (the IPPC Directive and six sectoral Directives) into a single legislative instrument.Following the co-decision process on this Proposal, the Industrial Emissions Directive 2010/75/EU (IED) has been adopted on 24 November 2010 and published in the Official Journal on 17 December 2010. It has entered into force on 6 January 2011 and has to be transposed into national legislation by Member States by 7 January 2013. IPPC and now IED sets out the main principles for the permitting and control of installations based on an integrated approach and the application of best available techniques (BAT) which are the most effective techniques to achieve a high level of environmental protection, taking into account the costs and benefits. For more information on the directive please visit the EC website.
The benchmarks or criteria on which BAT relies are described in the BAT Reference Documents (BREFs). The Cement, Lime and Magnesium Oxide Manufacturing Industries BREF document has been recently updated and published at EU level in May 2010.
Through the implementation of the IED, the role of the BREFs will be strengthened. After a BREF is completed, it should be subject to BAT conclusions that are adopted through a comitology decision (implementing act). The right of initiative however rests with the Commission. BAT conclusions contain parts of the BREF, their description, information on applicability, including BAT Associated Emission Levels (BATAELs) for different pollutants (meaning emission levels that can be achieved for a pollutant if the industry is implementing BAT) as well as associated consumption levels and monitoring. It may also include site remediation measures “where appropriate”. Within 4 years after publication of the comitology decision on the relevant BAT conclusions, local authorities should review and update all the permits to the respective industries in order to make sure the industrial activity operates according to the requirements set out in the BAT conclusions. The provision in the IED requires that Emission Limit Values (ELVs) for pollutants set out in the permit should not exceed the relevant BATAEL. However the permit writer may derogate in specific cases and set higher ELVs under certain conditions. An assessment needs to demonstrate that the application of the BATAEL would lead to disproportionate higher costs compared to the benefits due to the local conditions (technical characteristics of the plants, or geographical location or local environmental conditions). In any case no significant pollution may be caused and a high level of protection of the environment as a whole is achieved. Environmental Quality Standards also need to be respected. These derogations are subject to public participation and scrutiny by the public concerned, which includes NGOs.
The Cement BREF includes references on mercury which could be indeed adopted under BAT conclusions - this however is still take place since the Cement BREF was finalised right before the IED directive so further discussion is going on as to how this is going to happen. (March 2011)
In the US , on August 9, 2010, EPA issued a final rule to limit emissions of mercury and other toxics from Portland cement plants. This rule was published in the Federal Register on September 9, 2010. The rule adds or revises, as applicable, emission limits for mercury, total hydrocarbons (THC), and particulate matter (PM) from new and existing kilns located at major and area sources, and for hydrochloric acid (HCl) from new and existing kilns located at major sources. The standards for new kilns apply to facilities that commence construction, modification, or reconstruction after May 6, 2009.
See also http://www.epa.gov/hg/regs.htm#regs