Information describing the spERC’s scope

Criterion 5: the spERC’s coverage is unambiguous and understandable to all relevant actors;

main and auxiliary processes are identified, not covered processes are explicitly excluded.

Criterion 6: Information describing the spERCs coverage is clearly separated from justifications and background data.

Table 25: Descriptive sections; Eurometaux 5.v1.1 spERC ‘‘Industrial use of metals in metallic coating’’

Section New / changed content in Eurometaux 5.1.v2.1 Assessment of changed / new content Possible improvement

Scope Revised

Limitations of coverage compared to ERC relate to:

User groups: Industrial use of metals and metal compounds in plating, galvanising.

Substance groups or functions: Release defaults are derived from measured emissions. Metal representativeness of background data: (Figure showing shares of data from zinc, nickel and tin processing).

Metal (compound) is defined here in a broad sense. The definition includes alkali metals, alkaline earth metals, transition metals, post-transition metals, metalloids and their compounds but excludes non-metals, halogens, noble gases and metallo-organic compounds.

SpERC valid for metals with solid water partition coefficient for suspended matter between 25,000 L/kg and 400,000 L/kg.

Types of products: Metal and/or metal compounds

Geographical and Time: Release defaults are derived from measured emissions from various EU member states and between 1998-2009. (Figure showing the Member States and the years of data collection)

In the first version of the factsheet, the section “Scope”

only provided the information which metals form the data basis from which the default values are derived.

The new version is more specific and therefore improves the understandability of what is covered by the spERC.

Metals and compounds are explicitly included or excluded; a range of the water partitioning coefficient further limits the scope.

It is not specified whether or not auxiliary and cleaning processes are included.

The section on the scope mixes information directly pertaining to the scope (description of what is covered) and the justification for the spERC. This may be confusing, e.g. because the data basis is derived from only three metals, whereas the scope covers more substances. It would be better to include the information on the background data as annex

Include information that spERCs integrate the full process (currently part of narrative description and operational conditions).

Remove information on background data and include as Annex to the spERC It may be useful to include the Title of ERC5, because the limitations are provided in comparison to the ERC

User Group New

Main User Group: SU14

SU14 (manufacture of metals and metal compounds) is not consistent, as the title specifies a use rather than the manufacture of the metal (compounds).

Select SU3. Potentially the SU 15 may also be applicable.

Environmental Release Category

New

Environmental Release Category: ERC 5

The ERC5 (industrial use with inclusion into/onto a matrix) is consistent with the spERC’s coverage.

Process Category

New

Process Categories: PROC1, PROC2, PROC3, PROC4, PROC8a, PROC8b, PROC9, PROC13, PROC26

The listing of PROC1 to PROC4 (manufacturing and formulation processes) is confusing, as they don’t relate to plating and galvanising (except potentially the mixing of the formulations for use in plating as preparatory process). PROCs 8a/b, 9 and 26 relate to transfer and handling processes, which is consistent.

The most relevant core PROC is PROC 13 (plating and galvanizing).

PROC 13 could be highlighted, as it is the core process, PROC 1-4 should be removed, as they are not consistent with the scope; explanation that mixing of galvanising / plating mixtures on-site is covered in the narrative and coverage would be clearer.

Section New / changed content in Eurometaux 5.1.v2.1 Assessment of changed / new content Possible improvement Product

Category Product Categories : Not included PC14 could be added

Narrative

description Revised

Since metal spERCs are based on measured data at end-of-pipe on-site, all indicated PROCs are integrated in the release fractions from raw materials handling to cleaning and maintenance.

A distinction can be made between hot dip batch process, continuous hot dip process and continuous electroplating process. Electroplating is a plating process that uses electrical current to reduce cations of a desired material from a solution and coat a conductive object with a thin layer of the material, such as a metal.

Mechanical milling to remove oxide layers. Pickling. Chemical treatment or blasting of internal tube surfaces. Cleaning and stain removal. Polishing. Pre-patination. Raw materials handling and storing of produced substances are also included in this spERC.

Hazardous wastes from on-site risk management measures and solid or liquid wastes from production, use and cleaning processes should be disposed of separately to hazardous waste incineration plants or hazardous waste landfills as hazardous waste.

The description is consistent with the scope and use descriptors and adds useful explanation, in particular by listing the auxiliary and cleaning processes, which are covered by the spERC. This fills the gaps of the information in the scope and list of use descriptors and allows the user to unambiguously decide, if the spERC is applicable.

The information on waste classification and treatment options is useful, also.

Scaling New

If a site does not comply with the conditions stipulated in the spERC, it is recommended to monitor the air and water releases and apply the Metals DU scaling tool in order to perform a site-specific assessment. Each site can evaluate whether he works inside the boundaries set by the ES through scaling. The Metal EUSES calculator for DUs is freely available to metal industry DUs and can be downloaded from http://www.archeconsulting.be/Metal-CSA-toolbox/du-scaling-tool.

The section provides general advice on scaling and refers to the sector specific scaling tool prepared by the association⁴⁰. This corresponds to the requirement of short and concise information that is useful to the spERC users.

Appendix New (relates to CHESAR implementation)

The included spERC determinants only relate to the risk management measures The spERC determinants are not complete, as the

operational conditions and processing information is Add further determinants to the Annex;

also as this information is

40 The tool is provided only to members of the association according to Arche Consulting.

Section New / changed content in Eurometaux 5.1.v2.1 Assessment of changed / new content Possible improvement for wastewater and waste air. Here, information from BREFs is quoted in the

description of values; for import to CHESAR the names of the techniques are specified; the efficiencies, which are provided in the factsheet are not included.

missing. The content of the RMMs corresponds to that provide in the factsheet, hence the information is consistent.

recommended for inclusion in the CSR and is necessary to check plausibility.

The revised description of the spERCs is significantly improved and gives a clear picture of the coverage. From the list of PROCs it can be deduced that auxiliary processes (transfer or substances / mixtures) are covered. The narrative description clarifies that also cleaning processes are covered and lists the auxiliary activities which are in the remit of the spERC.

The SU und some of the PROCs refer to manufacturing and formulation processes (in closed system), which is not consistent with the title and scope. Although to the low exposures from these PROCs they are likely to be factually covered, it may confuse the users of the spERC that they are listed.