Potential amendment E11 – Preparation of scrap metal

Potential amendment E11 – Preparation of scrap metal

1. Issue

2. Current Practice

1. 
   Short description of the scrap preparation sector
   

Both production scrap and post consumer scrap are treated in scrap metal preparation installations. The processes and installations used for processing of these products into scrap metal for remelting depend on the composition of the metal products. In general, post consumer scrap needs a pre-treatment consisting of a dismantling and/or depollution operation. After pre-treatment the larger metallic fraction is cut, pressed or shredded. Production scrap is treated by scrap metal preparation plants, without prior dismantling. The preparation involves cutting, pressing or shredding, depending on the shape and degree of contamination of the metal. Scrap metal preparation installations produce cleaned scrap for steel works, foundries and non-ferrous smelters. Besides they generate important side streams (e.g. shredder residue, fluff) that are further processed or landfilled (see below).

2. 
   Installation types
   

• 
  Scrap dealers – scrap yards
  

The environmental impact is assumed to be limited. The handled and stored scrap (original format or smaller parts after size reduction) can produce diffuse dust emissions, but to a lesser extent than the fine material (fluff) leaving shredder installations. Possible BAT measures could be applied for the reduction of water and soil pollution from the storage and handling of scrap. The use of an impermeable base combined with the collection and primary treatment of waste water is considered to be BAT in some countries¹.

The scrap dealers will not be discussed further in this fact sheet, as their size and environmental impact is limited.

• 
  Dismantling and depollution installations for WEEE and ELV
  

A number of shredder facilities that exclusively process WEEE are in operation in the EU-25. These facilities typically process small WEEE, either as whole products (directly into the shredder) or with selective dismantling prior to shredding to remove hazardous components for example cathode ray tubes (CRT’s) in monitors and TVs. Similar to the ELV shredders, a number of separation steps are performed on the shredder residue in order to separate various metal and plastic streams.²

• 
  Integrated scrap treatment installations
  

Size reduction may involve a variety of manual activities such as grinding, cutting, sawing. Most integrated sites operate a large-scale scrap shear, scrap press and a shredder. Scrap is processed by either of these units depending on its size, type and degree of mixing with other materials. Shredders are used for the size reduction of complex mixed scraps.

Shredders process metal-dominated products such as vehicles (ELVs), complex scrap and white goods. The primary route for large household appliances (white goods) has been traditionally through these large-scale installations. A typical example lay-out of a large-scale shredder plant is given in Annex I. After shredding, the material flow is sorted. The shredder produces ferrous and non-ferrous metals fraction, a heavy residue (often referred to as ASR, automotive shredder residue) and a fluff fraction (i.e. the light and fine non-metallic fraction). Increasingly shredder plants experiment with and invest in further sorting of the residue and fluff fractions.

Because the shredder is the largest installation on the site, the integrated scrap treatment installations are often referred to as shredder installations. Most ‘shredder installations’ also have other techniques available. Shredding is not the only activity on the site. On the other hand, the treatment activities of integrated scrap treatment plants may be limited to cutting and/or pressing. A shredder is not always part of these large scale scrap treatment plants. Historically, they often started as storage and handling plants for scrap metal. This may still be an important activity.

Production scrap and post consumer scrap goes to scrap treatment installations. Post consumer scrap in general follows the route: collection – dismantling/depollution – scrap treatment.

Dismantling/depollution is often performed at the scrap treatment installation. Scrap treatment involves sorting, separation and size reduction through cutting, pressing and shredding.
In this study, both dismantling/depollution and scrap metal preparation will be discussed. Scrap collection is left out of the scope as these are operations that are small-sized or linked to larger waste collection installations.

3. 
   Size of the sector
   

• 
  Production and total number of scrap treatment installations
  

• 
  Total consumption scrap (including own arisings) by European Steelworks: 100.6 Mtonnes
  
• 
  Total purchases scrap (including imports) by European Steelworks: 73 Mtonnes
  
• 
  Export of scrap out of the EU-25: 8.9 Mtonnes
  
• 
  Import of scrap in the EU-25: 7.4 Mtonnes
  

In the EU, electro-scrap is the fastest growing waste stream, growing at 3-5% per year, which is three times faster than average waste source. Each EU citizen currently produces around 17-20 kg of e-waste per year.⁵ This would amount up to 8.4 – 9.9 Mtonnes WEEE per year. Another study shows that the estimated amounts vary and cites 7 Mtonnes as a good estimate.⁶ A relatively large part of WEEE is non-metallic. According to a UK study⁷ from 2007, the average composition of small mixed WEEE is: 55% metals, 36% plastics, 2% printed circuit board and 7% other materials. The average composition of large WEEE is: 66% metals, 13,5% plastics, 21% other materials and 0,1% printed circuit boards.

The total amount of ELV waste is estimated at 10 Mtonnes per year for the EU (data for 2005). This volume is projected to increase to 14 million tonnes by 2015 as the number and average weight of vehicles increases.⁸

According to the EFR and EUROMETREC (European Federation for non Ferrous Recovery and Recycling), more than 7 000 companies are active in the collection, sorting and processing of ferrous and non-ferrous metals. The majority of these companies are micro-enterprises with less than 10 people employed, working in scrap collection and sorting. About 10 of them are multi-national companies, treating on the average more than 1 Mtonne scrap per year. These multi-national companies operate numerous installations in different countries in Europe and the rest of the world. As a result, the total number of installations is much higher than 7 000.

No detailed data are given in literature on the number of dismantling and depollution installations. Data from our own questionnaire are very fragmented. For dismantling operations, the respondents report a total of 290 scrap procesing installations for mixed scrap or WEEE. An extrapolation based on the population of the respondent MSs allows to estimate the total number of WEEE dismantling and mixed scrap processing units in the EU-27 at 1300 installations. This does not include the dedicated ELV processing installations.

A general overview of the number of authorised treatment facilities (ATF) for ELV depollution gives a total of nearly 8000 ATFs in the EU-27, with an average capacity of 9 tonnes per day (see also Annex II). This should be considered an estimate, as not all MSs have an efficient monitoring in place. Additionally, the unregistered ELV processing still has an important market share. The share varies between MS. Illegal car dismantling facilities are estimated to have between <10% and 80% of the market. ⁸

Also according to EFR, there are 220 shredder installations in the EU-25. These are large-scale shredders. It can be assumed that most of these are integrated scrap treatment installations. The same figure is used by the BIR to quantify the number of ELV shredder installations. In a recent European study on the implementation of the ELV Directive, a detailed inventory is made of the number of ELV treatment units in the EU-25. The result is 232 ELV shredders.⁸

Data from Belgium show that the number of employees for shredder installations varies between 5 and 66 (based on data for 9 installations)¹.

According to BIR (Bureau of International Recycling) ELV shredders produce about 8 Mtonnes of ferrous scrap. Assuming that 68% of the mixed scrap is ferrous metal⁵, this indicates that shredders process 16% of the total scrap production (75.5Mtonnes). From EFR scrap trading figures, it can be seen that 20% of imported and exported scrap is shredded material. This could imply that shredders process about 20% of the total scrap production. A multinational company, operating shredders in north and eastern Europe ertimates⁹ that about 40-50% of all recycled ferrous scrap passes through a shredder in MS with high labour costs. In MS with low labour costs, such as Poland, about 20-30% of the ferrous scrap passes a shredder.

For large scale integrated scrap treatment installations, calculations on basis of Belgian plant capacity data, show a relative share of 38% for shredders, compared to 62% for cutting and pressing. Data include installations that have no shredder activities, only cutting and/or pressing (3 out of 10 installations).

All these data show that it is difficult to have a clear picture of the relative share of shredders in the total scrap processing over the EU-27, but an average of 35% can be assumed.

• 
  Treatment capacity
  

The data from the questionnaire are very fragmented and give only a partial view of the sector in the EU-27. Nevertheless, the data can be used to present the relative shares and capacities of the different installations. More specifically, it can be estimated which share of the plants has a capacity above 50 tonnes per day. This is presented in Table 1.

Table 1: results of questionnaire, inventory for 9 MSs

For installations dedicated to WEEE processing, 91% of the reported installations has a capcacity below 50 tonnes/day.

For ELV dismantling and depollution, the data on the number of installations per MS are not consistent between the questionnaire and the BIO-GHK study. This is probably due to the different wording used in the questionnaire. The BIO-data show that the average capacity of the ATFs (i.e. ELV depollution installations) is well below 50 tonnes/day, at 9 tonnes/day. The average capacity for the ELV shredders is 131 tonnes/day, based on the amount of processed ELVs only. The actual average capacity is higher, since ELVs respresent only part of the shredder input.

For the shredder installations, EFR states that 8 Mtonnes of ferrous metal scrap are produced. Based on the assumption that 68% of the processed mixed scrap is recovered as ferrous scrap, the total input for shredder installations is 11.8 Mt.

Other large scale activities are cutting and pressing. Based on an average share of shredders in total scrap treatment capacity of 35% and starting from the estimated input of 11.8 Mtonnes mixed scrap for shredding, the total treatment capacity for large scale scrap treatment in the EU-25 is estimated at 34 Mtonnes per year.

Summary of key capacity issues for the sector

The scrap treatment sector includes more than 7000 installations active in collection, sorting and processing of metals, the majority of which are SME’s. The total consumption of purchased scrap by the European steelworks is 73.3Mtonnes/year. Europe is a net exporter of scrap.

Dedicated dismantling and depollution installations typically have a capacity below 50 tonnes/day. The number of dismantling installations for WEEE and other mixed scrap can be estimated at 1300 for the EU-27. Depollution of ELVs is performed in 8000 authorised treatment facilities.

The 232 shredder installations in the EU-25 produce 8 Mtonnes ferrous metal per year. It is estimated that shredders represent a share of 35% of the scrap treatment capacity at integrated scrap treatment plants. The total treatment capacity of integrated plants is estimated at 34 Mtonnes/year.

4. 
   Environmental Impacts
   

Most installations covered by this fact sheet are ELV or/and WEEE treatment installations falling within the scope of the ELV and WEEE Directives. The ELV and WEEE Directives set requirements for the protection of soil and water (ELV: Annex I, WEEE: Annex III, both are given in Annex III to this fact sheet). They specify soil protection measures and require waste water treatment for all treatment installations of ELV and WEEE. This includes integrated shredder installations that process ELVs. Nevertheless, the measures to be taken are very general and no specific techniques are indicated. The annexes refer to ‘appropriate’ means and measures for storage and ‘equipment for the treatment of waste water’, without indicating a level of environmental protection that can be reached. Furthermore, other environmental issues such as emisisons to air, energy efficiency, noise and odour are not mentioned in the Directives.

• 
  Environmental impacts for shredder installations
  

• 
  the process: emissions from shredding the scrap (both diffuse and conducted emissions)
  

• 
  dust
  
• 
  dioxins
  
• 
  (dioxin-like) PCBs
  

• 
  material handling: emissions from storage and handling of (treated) scrap
  

• 
  dust emissions
  
• 
  evaporation of organic components from stockpiles
  

• 
  transport: emissions from (internal and external) transport (exhaust gasses, road dust,…)
  

From these, emissions from stockpiles and transport emissions are of secondary importance, so focus is on emissions of dust by the process and material handling, and on dioxin emissions from the shredder installation.

• 
  Dust emissions
  

Materials are classified according to their susceptibility to be dispersed and the possibility to prevent this dispersion by wetting (for non-reactive materials). Emission factors from storage increase with the ability to drift of the material. Wetting the materials reduces by a factor 10 the emission of dust from storage.

However, this method has several restrictions such as the limited amount of test result on which it is based.

This method considers the handling of the materials as the only relevant activity for dust emissions, so without taking account of the process itself.

Table 2: Emission factors associated to the handling and crushing of materials

Class of material	Drift sensitivity	Wettable	Example of material	Emission factor of the dry material (g/kg)
S1	High	No		1
S2	High	Yes	shredder dust (fines+fluff)	1 (0.1)
S3	Moderate	No		0.1
S4	Moderate	Yes	Ferrous metal, non-ferrous metal, waste, ASR	0.1(0.01)
S5	Slight	No		0.01
Figure in parenthesis is the emission factor of the wet material

Estimation of emissions
Based on the TNO-method and the size of the sector the diffuse dust emissions from shredder installations can be estimated.
The total amount of ferrous metal output from shredders in EU25 is estimated at 8 Mtonnes. Taking into account that only 68% of the output of a shredder is ferrous metal, the total input is 11,8 Mtonnes. About 18% of the input (2,1 Mtonnes) becomes shredder dust (fines + fluff).

For shredders the input scrap is classified S4; the output materials belong to class S4, except for shredder dust that is categorized S2.

According to this methodology, the quantity of PM10 emitted into the air by shredding scrap amounts to 4250 tonnes per year. By wetting the materials, this could be reduced to 425 tonnes per year.

• 
  Dioxin emissions
  

As mentioned earlier, through the combination of high temperatures and PCB- containing materials shredding of scrap metal causes both diffuse and stack emissions of dioxins.

Table 4 summarizes the available information on dioxin stack emissions from shredders.

Table 4: Dioxin emission factors for shredders

• 
  (Dioxin-like) PCB emissions
  

The Flemish environmental inspectorate performed a study concerning emissions and dispersion of dioxins and (dioxin-like) PCBs from shredder installations.¹⁴

The emission concentrations of dioxins at different installations are in the range 0,0004 - 0,37 ng I-TEQ/Nm³ and mostly stay below the level of 0,1 ng I-TEQ/Nm³. The latter value is used as a limit value in several sectors. The emitted concentrations of dioxin-like PCBs from shredders are in the range 0,012 - 3,0 ng I-TEQ/Nm³. There seemed to be no correlation between the emission of both dioxins and PCBs, which may indicate that different factors are governing the emissions of both compounds.

Calculated total emissions for the whole Flemish Region (7 installations) were around 60 mg I-TEQ/year for PCDD/PCDF and around 715 mg I-TEQ/year for dioxin-like PCBs. This shows that the emissions of dioxin-like PCBs are several times higher than dioxins and they are of great relevance when compared to emissions from other sectors. Furthermore deposition measurements by the Flemish Environment Agency have shown that increased depositions of dioxin-like PCBs are found in the vicinity of scrap metal treatment and shredder installations.

• 
  Environmental impacts for large installations for scrap metal preparation
  

• 
  Dust emissions
  

The previous paragraph dealt specifically with shredder installations. With the TNO-method for estimation of total fugitive dust emissions, an estimation of these emissions from the large installations for scrap metal preparation can be made.

The estimation of the total dust emissions of the large scale scrap treatment installations amounts to 8110 tonnes per year. Wetting of the treated materials, in combination with other dust reduction measures could reduce the dust emissions with 90 %.

• 
  Waste water
  

• 
  Comparison with other sectors
  

• 
  Dust
  

As shown in this table, shredders emit 53 and 4,3 times more PM₁₀ into air than the sector disposal or recovery of hazardous waste and the sector for the disposal of non-hazardous waste, respectively. For the large scale scrap treatment installations the respective numbers are 101 and 8,1 times more. The dust emissions from shredders and integrated scrap treatment are at a level of 1.5 and 3 %, respectively, compared to the total industrial dust emissions reported by EPER. This estimation therefore shows that scrap metal treatment is a very important source of diffuse dust emissions.

• 
  Dioxins
  

The key environmental issues for integrated scrap treatment plants are diffuse dust emissions, dioxin and dioxin-like PCB emissions. Estimations based on the TNO-method show a total emission of 4250 tonnes PM10 by shredders, for a total of 8110 tonnes from the integrated plants. Dioxin emissions from shredders are estimated at 0.7-8 giTEQ/year. Both levels can be considered relevant as compared to disposal operations for non-hazardous waste. Data from Flanders indicate that dioxin-like PCB emissions typically are more than 10 times higher than dioxin emissions.

• 
  Emission reduction and prevention techniques – Best Available Techniques
  

Measures to reduce the environmental impact from scrap processing installations are available. In Belgium (Flemish Region), a BAT-study for the sector is in final draft stage.¹ It presents a range of environmental friendly techniques and provides a BAT evaluation. The techniques include:

• 
  For diffuse emission of dust:
  

• 
  Storage: wetting of the material in case of dry and windy weather or storage in a building
  
• 
  Moving belts: use of covered or closed belts or installation of wind screens for some specific locations in the shredder unit (due to explosion risk).
  

• 
  Dioxin and dioxin-like PCB emissions (only for shredders):
  

• 
  A stricter acceptance policy, including training of the personnel to detect and refuse polluted material
  
• 
  No end-of-pipe treatment techniques for selective reduction of dioxin emissions are available
  
• 
  Dust emission reduction using a combination of cyclones and wet scrubbing or a bag filter, to reach a dust emission level of 20 mg/Nm³. Economic data on wet scrubbers are given in Annex IV.
  

• 
  Protection of soil and discharges to water
  

For the protection of soil and minimisation of discharges to water, the Flemish study also provides BAT conclusions. These conclusions are more detailed than the requirements given in the ELV and WEEE Directives. If the conditions of the sectoral directives are interpreted in a strict way, they will result in a similar level of environmental protection as the BAT measures. Some Flemish BAT measures are:

• 
  Separate collection system for process water, contaminated and non-contaminated rain water
  
• 
  Apply primary waste water treatment, through the use of a oil-water separator and a settling basin
  
• 
  Apply biological waste water treatment for flotation units
  
• 
  The application of biological or physico-chemical waste water treatment is not BAT at sector level, the technical and economical availability needs to be assessed at the installation level and depends e.g. on the lay-out of the site, the type of receiving water (sewage or surface water) and the contamination level of the run-off water.
  

• 
  Storage BREF
  

According to the BREF it is BAT to prevent dust dispersion due to loading and unloading activities in the open air by scheduling the transfer as much as possible when the wind speed is low. Slag and ashes are classified in dispersiveness class S4. This means that transfer activities would need to be suspended if the wind speed exceeds 20 m/s (wind force 8).

It is BAT is to make transport distances as short as possible and to apply, wherever possible, continuous transport modes. When using a mechanical shovel emissions can be minimised by reducing the drop height and to choose the best position during discharging into a truck. When the speed of the vehicles on-site is adjusted the dust being swirled up can be avoided or minimised. Applying hard surfaces to the roads that are used by trucks and cars, and cleaning them, avoids dust being swirled up. Also the cleaning of vehicle tyres reduces the emissions of dust. For drift sensitive, wettable products (classes S2 and S4) it is BAT to moisten the product when it do not compromises the product quality, the plant safety and water resources. For instance, this BAT might not be applicable when there is risk of freezing of the product, risk of slippery situations because of ice forming or wet product on the road or in case of water shortage. During loading and unloading activities it is BAT to minimise the speed of descent and the free fall height of the product. Several techniques are considered BAT for this purpose. Because it is not likely that these techniques are used during the handling of slag and ashes we do not go into further detail.

When a grab is applied the crane driver can take measures to prevent the accumulation of dust. Dust emissions are also reduced by leaving the grab in the hopper for a sufficient time after material discharge. For new grabs properties are defined so the grab is considered BAT (see § 5.4.2 BREF storage).

For moderately drift sensitive, wettable products (S4, such as slag and ashes) it is BAT to apply an open belt conveyor and additionally, depending on the local circumstances, one or a proper combination of the following techniques:

- lateral wind protection,

- spraying water and jet spraying at the transfer points,

- belt cleaning.

5. 
   Economic and social issues
   

Medium and large collectors normally concentrate on industrial producers and also buy scrap metal from small and local dealers, who collect the scrap from smaller undertakings or consumers. Given that the local dealers generally do not have access to the infrastructure that would enable them to trade on a wider basis, the unprocessed scrap is delivered by local dealers within relatively short distances to middle and top tier dealers for processing. The relevant geographic markets for the sale and purchase of unprocessed scrap are therefore smaller than for the sale of processed ferrous scrap, and could be national or local. The market for processed scrap is word-wide.

The markets for the smallest companies is limited to the local area. The scrap is collected from the local area and the processed scrap is sold to local companies. The large companies are oriented to different markets. The can buy scrap from local players, but also from other companies. They sell on a larger market than the local market from the small companies. Shredder plants are generally large companies, or make part of multi-nationals. They trade on the international market.

6. 
   Current Legislation
   

• 
  European Legislation
  

• 
  ELV Directive
  

The ELV Directive sets minimum standards for installations that de-pollute and dismantle ELVs. The storage and treatment of end-of-life vehicles is also subject to strict control, in accordance with the requirements of Directive 2006/12/EC and those of Annex I to the Directive (see Annex III to this fact sheet). Establishments or undertakings carrying out treatment operations must strip end-of-life vehicles before treatment and recover all environmentally hazardous components.

• 
  WEEE Directive
  

Concerning treatment of waste EEE, producers of electrical and electronic equipment must apply the best available treatment, recovery and recycling techniques. Such treatment is to include the removal of fluids and selective treatment in accordance with Annex II to the Directive. Waste treatment and storage must be in conformity with Annex III to the Directive. This Annex specifies measures for soil protection, storage and water treatment (see Annex III to this fact sheet).

• 
  End of waste project
  

• 
  National Legislation
  

One MS mentions in the questionnaire that scrap yards and ELV and WEEE processing centres pose little environmental impact. They are/can be regulated by means of straightforward fixed licenses that reflect the low environmental risks. The WEEE and ELV treatment installations have to comply with the standards set in the Directive. Treatment of other scrap metal and de-polluted ELV (and recently also WEEE) fall under the exemption of the licence system.

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