Reflection on the spERC factsheet by ECMA

The ECMA spERC factsheet resembles the Eurometaux factsheet and seems to partly build upon a similar database. However, there are also some differences and a rough overall evaluation of the factsheet “Manufacture of metal-containing catalysts” is provided in the following⁴². The title section of the spERC factsheet is even more concrete in limiting the scope by listing distinct metals for which the spERC is applicable. The database upon which the spERC is built consists of data from all of the listed metals, with Nickel slightly dominating. The covered tasks are listed in the section “scope” providing for a very clear picture of the applicability of the spERC. It is further specified that the spERC is applicable only to operations where wastewater is discharged to an on-site treatment plant. In conclusion the information provided in the first sections of the factsheet is concise, clear and sufficiently detailed to allow the users to identify whether or not the spERC is relevant to them (criteria 5 and 6).

The listed use descriptors are consistent with the coverage specified in the former sections listing manufacturing, formulating and transfer processes as being covered⁴³.

The specification of operational conditions includes basic information relevant for

environmental emissions (indoor use, water based, product application in aqueous process

42 A detailed assessment was not foreseen due to resource constraints.

43 There is a “PROC 0” as last item in the list of PROCs; such PROC is not contained in the ECHA guidance on use descriptors and can hence not be assigned.

solution, discharge to wastewater, assumption of occupational hygiene being implemented).

However, in the section “other operational conditions” also dry processes are mentioned and should rather be included in the main section on operational conditions; this is in conflict with the existence of discharges to wastewater (criteria 6, 7 and 9).

The information provided on where emissions could occur as well as the “free text background” should be moved to the section “narrative description” (criterion 6).

The section obligatory RMMs lists the types of measures recommended for air and water emissions without specifying any technical conditions. The reported efficiency of measures is provided in addition (criterion 10).

In particular for the water RMMs it is not clear why the 50^th percentile of the reported efficiencies (99%) is highlighted and not a different one, e.g. the 90^th percentile, as implemented by Eurometaux. The section is not clear as to which efficiency of RMMs is

required in the spERC, because the reported efficiencies are highlighted but no clear statement is made on whether or not they are obligatory. One easy way of providing clarification would be to separate the required efficiencies (if any) from the justification with a respective heading (criteria 9 and 13).

In contrast to the Eurometaux factsheet a substance use rated is calculated (90^th percentile of company reports). The number of emission days (280) is provided without justification. As both intermittent and continuous releases are possible for the process, it could be useful to clarify if a different value applies to the two production situations.

The integrated release factors (after on-site RMM) provided are almost a factor 10 lower than those in the Eurometaux factsheet (0.025% vs. 0.2% (air) and 0.067% vs. 0.5% (water)), which can be explained by the type of process (manufacturing vs. use).

The release factors are derived from reported emission data from catalyst manufacturers in various EU Member States between 2008 – 2010. They represent the 90^th percentile of site-specific release factors from 19 sites. As for Eurometaux, neither the data basis nor the method for data collection and deriving site-specific release factors is available for plausibility checking in the factsheet (criteria 8, 9 and 13).

The (incomplete) justification and description of the base data is spread over various sections of the factsheet. It is recommended to compile all information in one annex or separate

document that relates to the information basis and methodology for deriving release factors.

No specific optional RMMs are provided (criterion 11).

The narrative description is comparably short and it is suggested to move information from the sections scope and operational conditions to this section in order to better differentiate

between spERC information and explanation / justification.

The scaling tool of the metals industry is referenced in the respective section. In addition, the values of the “use rate”, the “emission days” and the “RFs” are listed as parameters for scaling.

It should be considered whether scaling the release factors is consistent with the idea of spERCs as this would make the justification invalid. This is particularly true for the metals spERCs, as the release factors integrate the release from the process and the RMM efficiency.

The adaptation of the emission days is not relevant, as it may not be used to calculate a daily use amount from the annual use amount (vice versa is possible, however). Hence, the

modification does not affect the result, except emissions occur on less than 12 days per year and can hence be regarded as “intermittent” according to the ECHA guidance R.16.2.3 (PNECwater may be increased by factor 10).

Table 31 summarizes the assessment results. As criterion 13 applies to several aspects of the fact sheet it is not included separately but is integrated in the other criteria.

Table 31: Assessment overview --- ECMA spERC

# Criterion Assessment

1 CEFIC factsheet format Yes

2 Unique code Yes

3 Old and new version on the web n.a.

4 spERC is consistent; no unnecessary doublings Yes

5 Coverage is clear and unambiguous; inclusion of auxiliary/cleaning processes clear; potential exclusion

of processes Yes

6 Information on coverage clearly separated from background data No

7 Undefined terms not used Few

8 Release factors to water, air and soil exist Yes

9 Assumptions and methods for deriving release factors are sufficiently documented No

9.1 Relation between RF and OC is clear No

9.2 Information sources are provided or referenced and related to spERC conditions No

9.3 Differentiation according to substance properties No

10 RF and RMM efficiency are described separately; clear which RMMs are obligatory Yes

11 Efficiencies of optional RMMs are provided n.a.

12 RF to waste is provided Yes