european commission,...

European Commission, Brussels

Requirements for facilities and acceptance criteria for the disposal of metallic mercury

07.0307/2009/530302

Final report

16 April 2010

BiPRO Beratungsgesellschaft für integrierte Problemlösungen

DISCLAIMER:

This document is distributed as prepared by BiPRO GmbH, and is the result of the scientific work carried out by its authors. Any subjective information contained therein should be perceived as expressing the views of its authors rather than those of the European Commission.

Reference number 07.0307/2009/530302/ETU/G.2.2 ii

European Commission Final report Requirements for facilities and acceptance criteria for the disposal of metallic mercury

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Content

1 Background and objectives ..................................................................................12

1.1 General background.................................................................................................12

1.2 Legal background.....................................................................................................15

1.3 Objectives of the project ...........................................................................................18

1.4 References ...............................................................................................................20

2 Methodology ...........................................................................................................22

2.1 Overall methodological approach.............................................................................22

2.2 Detailed methodology for the identification of options and the review of the state of the art; approach for information gathering..................................................25

2.2.1 Overview of information gathering............................................................................25

2.2.2 Literature search ......................................................................................................25

2.2.3 Questionnaire ...........................................................................................................27

2.2.4 Expert interviews and site visits................................................................................28

2.2.5 Data base search .....................................................................................................29

2.3 Detailed description of the screening analysis and the selection of options including the elaboration of basic acceptance criteria ..............................................31

2.4 Detailed description of the assessment methodology including the elaboration of fine tuned acceptance criteria and the recommendation list ................................34

2.5 References ...............................................................................................................35

3 Identification of options.........................................................................................36

4 Review of the hazardous characteristics of metallic mercury ...........................41

4.1 Specific properties of liquid mercury related to storage............................................41

4.1.1 Occurrence of mercury .............................................................................................41

4.1.2 Basic physico-chemical properties ...........................................................................41

4.1.3 Toxic effects .............................................................................................................48

4.1.4 Classification ............................................................................................................49

4.1.5 Occupational exposure limit values..........................................................................50

4.2 Hazardous properties related to the environment ....................................................50

4.2.1 Transformation and transport of mercury .................................................................50

4.2.2 Overview of the behaviour in the environment .........................................................54

4.2.3 Environmental limit values related to mercury..........................................................55

4.3 Conclusions..............................................................................................................57

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4.4 References ...............................................................................................................58

5 Review of legislation, policy and best practice...................................................62

5.1 International agreements..........................................................................................62

5.2 European legislation.................................................................................................66

5.2.1 Legal requirements for all storage facilities ..............................................................69

5.2.2 Legal requirements for above-ground storage facilities............................................80

5.2.3 Legal requirements for underground disposal ..........................................................83

5.2.4 Additional considerations for salt mines ...................................................................87

5.2.5 Additional considerations for hard rock ....................................................................89

5.3 Legislation at Member State level ............................................................................91

5.3.1 National legislation on mercury and mercury-containing waste ...............................91

5.3.2 National legislation on leachate limit values of mercury ...........................................92

5.3.3 Germany...................................................................................................................94

5.3.4 Sweden ....................................................................................................................98

5.3.5 UK ............................................................................................................................98

5.4 Legislation of non-EU countries................................................................................99

5.4.1 Norway .....................................................................................................................99

5.4.2 USA ..........................................................................................................................99

5.5 Policy Initiatives......................................................................................................102

5.5.1 UNEP Mercury Programme....................................................................................102

5.5.2 WHO.......................................................................................................................103

5.5.3 International Conference on Mercury .....................................................................104

5.5.4 HELCOM ................................................................................................................104

5.5.5 PARCOM / OSPAR ................................................................................................104

5.6 References .............................................................................................................106

6 Review of the state of the art of storage and disposal options .......................110

6.1 General considerations ..........................................................................................110

6.2 Review of underground disposal operations ..........................................................114

6.2.1 Potential host rocks ................................................................................................116

6.2.2 Salt rock .................................................................................................................118

6.2.3 Hard rock formations ..............................................................................................127

6.2.4 Radioactive waste ..................................................................................................136

6.3 Review of above-ground storage............................................................................141

6.3.1 Europe....................................................................................................................142

6.3.2 USA ........................................................................................................................143

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6.4 Review of containment ...........................................................................................146

6.4.1 Container systems currently in use ........................................................................146

6.4.2 Environmental and safety aspects..........................................................................151

6.4.3 Container material ..................................................................................................155

6.4.4 Conclusions............................................................................................................159

6.5 References .............................................................................................................161

7 Review of immobilization, solidification and other appropriate technologies for metallic mercury waste...........................................................167

7.1 Sulphur stabilization ...............................................................................................170

7.1.1 Technical background: ...........................................................................................171

7.1.2 Economic information.............................................................................................172

7.1.3 Environmental information......................................................................................172

7.1.4 Use of the technology.............................................................................................172

7.1.5 Overview of patents................................................................................................174

7.1.6 Further details concerning the realization of the process.......................................176

7.2 Sulphur Polymer Stabilisation/Solidification SPSS.................................................180

7.2.1 Technical background ............................................................................................181

7.2.2 Economic information.............................................................................................182

7.2.3 Environmental information......................................................................................182



7.2.6 Further details concerning realization of the process.............................................185

7.3 Amalgamation ........................................................................................................189


7.3.2 Economic background............................................................................................190

7.3.3 Environmental background.....................................................................................190



7.4 Phosphate ceramic/glass stabilization: Chemical bonded phosphate ceramic (CBPC) ...................................................................................................................192




7.4.4 Use of technology...................................................................................................194


7.5 Solidification/encapsulation ....................................................................................195

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7.6 Encapsulation of stabilized mercury with cement ........................................................197





7.6.5 Further details concerning realization of the process.............................................198

7.7 Conclusion..............................................................................................................201

7.8 References .............................................................................................................206

8 Screening analysis of options.............................................................................211

8.1 Identification of minimum requirements for storage options ...................................212

8.2 Feasibility of options...............................................................................................214

8.3 Acceptance criteria for metallic mercury and appropriate containment, procedure for the acceptance at the storage facility...............................................215

8.3.1 Acceptance criteria for metallic mercury.................................................................215

8.3.2 Appropriate containment ........................................................................................217

8.3.3 Acceptance procedure ...........................................................................................217

8.4 Option 1l: permanent storage of liquid mercury in salt mines.................................220

8.4.1 Technical minimum requirements...........................................................................220

8.4.2 Environmental minimum requirements ...................................................................223

8.4.3 Economic minimum requirements ..........................................................................225

8.4.4 Feasibility of implementation ..................................................................................225

8.4.5 Summary: option 1l ................................................................................................227

8.5 Option 2l: temporary storage of liquid mercury in salt mines..................................228





8.5.5 Summary: Option 2l................................................................................................232

8.6 Option 3l: permanent storage of liquid mercury in deep underground hard rock formations...............................................................................................................232


8.6.2 Summary: option 3l ................................................................................................234

8.7 Option 4l: temporary storage of liquid mercury in deep underground hard rock formations...............................................................................................................234



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8.7.5 Summary: option 4l ................................................................................................238

8.8 Option 5l: temporary storage of liquid mercury in above-ground facilities..............238





8.8.5 Summary: option 5l ................................................................................................243

8.9 Option 6: Pre-treatment ..........................................................................................244

8.9.1 Technical, environmental and economic minimum requirements...........................245




8.9.5 Assessment of pre-treatment technologies ............................................................247

8.9.6 Technology overview of Option 6 ...........................................................................250

8.9.7 Feasibility of immobilization techniques .................................................................252

8.9.8 Minimum acceptance criteria for stabilised mercury...............................................253

8.9.9 Feasibility of permanent storage of pre-treated elemental mercury .......................254

8.9.10 Summary Option 6l and its permanent storage......................................................258

8.10 Summary of the screening analysis........................................................................259

8.11 References .............................................................................................................262

9 Summary of acceptance criteria and additional facility related requirements.........................................................................................................263

9.1 Proposed acceptance criteria for metallic mercury and additional facility related requirements ..............................................................................................264

9.2 Proposed acceptance criteria for stabilized mercury and additional facility related requirements ..............................................................................................268

10 Assessment of options........................................................................................269

10.1 Economic assessment of the options.....................................................................270

10.2 Environmental assessment of the options..............................................................274

10.3 Overview on the result of the assessment..............................................................279

11 Conclusions and Recommendations .................................................................280

12 Annexes ................................................................................................................282

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12.1 Annex 1: Questionnaire..........................................................................................282

12.2 Annex 2: Literature overview..................................................................................285

12.3 Annex 3: Data base research - results ...................................................................304

12.4 Annex 4: Physico-chemical properties of metallic mercury and products resulting from different immobilisation technologies...............................................313

12.5 Annex 5: Summary of technologies available in large-scale application ................315

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Index of tables

Table 1-1: Sources of mercury supply in 2005 [UNEP 2006]...........................................13

Table 1-2: EU mercury consumption estimates in 2007 (tonnes) [MEMO 08-808_EN] ..........................................................................................................13

Table 1-3: Overview of chlor-alkali plants still using mercury, September 2009 (source: Euro Chlor)........................................................................................14

Table 1-4: Estimated amount of excess mercury that has to be safely stored.................18

Table 2-1: Overview of important studies relevant for the project ....................................26

Table 4-1: Solubility of Hg and Hg compounds in water ..................................................43

Table 4-2: Change of solubility (in ppm) against the temperature [Mersade 2007A] .......47

Table 4-3: Risk phrases and classification of mercury .....................................................49

Table 4-4: Hazard class, category codes and hazard statement codes of mercury.........49

Table 4-5: Environmental Quality Standards (EQS) set for mercury in Directive 2008/105/EC ...................................................................................................56

Table 5-1: Requirements for all types of mercury storage facilities according to Directive N° EC 1102/2008 .............................................................................69

Table 5-2: General requirements for all classes of landfills according to Directive 1999/31/EC, Annex I .......................................................................................71

Table 5-3: Control and monitoring procedures for all classes of landfills according to Directive 1999/31/EC, Annex III ......................................................................73

Table 5-4: Control and monitoring procedures for all classes of landfills according to Directive 1999/31/EC, Annex III ......................................................................74

Table 5-5: Procedures for the acceptance of waste according to Decision 2003/33/EC, Annex .........................................................................................75

Table 5-6: Mercury leaching limit values for different landfill types and standards according to Decision 2003/33/EC..................................................................77

Table 5-7: Requirements for above ground mercury storage according to Regulation (EC) N° 1102/2008........................................................................81

Table 5-8: Requirements for mercury storage in above-ground disposal facilities according to Directive 1996/82/EC..................................................................82

Table 5-9: Site specific risk assessment for underground disposal according to Decision 2003/33/EC, Appendix A ..................................................................85

Table 5-10: Requirements for mercury storage in salt mines according to Directive N° EC 1102/2008 ............................................................................................87

Table 5-11: Requirements for salt mines according to Decision 2003/33/EC ....................88

Table 5-12: Requirements for mercury storage in hard rock formations according to Directive N° EC 1102/2008 .............................................................................89

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Table 5-13: Requirements for deep storage in hard rocks according to Decision 2003/33/EC .....................................................................................................90

Table 5-14: Overview of Member State legislation concerning mercury and mercury-containing waste .............................................................................................91

Table 5-15: Member States mercury leaching limit values for landfills (more stringent or additional to Decision 2003/33/EC).............................................................93

Table 5-16: Requirements for deep storage in salt mines according to German legislation ........................................................................................................95

Table 6-1: Overview of literature related to the storage of liquid mercury......................115

Table 6-2: Overview of properties of salt rock................................................................118

Table 6-3: Overview of properties of crystalline rock .....................................................127

Table 6-4: Overview of properties of Argillaceous rock, Clay / claystone ......................129

Table 6-5: Summary of Estimates of Total Storage Costs (US Dollars) for 40 Years [USEPA 2007a] .............................................................................................146

Table 6-6: Tested equipment [Muñoz, 2009], presentation: Mr. Ramos ........................156

Table 7-1: Sulphur stabilization: overview of the relevant literature ...............................170

Table 7-2: Sulphur Polymer Stabilisation/Solidification: overview of the relevant literature ........................................................................................................180

Table 7-3: Amalgamation: overview of the relevant literature ........................................189

Table 7-4: Phosphate ceramic/glass stabilization: overview of the relevant literature ...192

Table 7-5: Cement solidification: overview of the relevant literature ..............................197

Table 7-6: Overview on existing pre-treatment technologies for liquid mercury.............205

Table 8-1: Summary of the assessment of used pre-treatment technologies against minimum requirements..................................................................................249

Table 8-2: Summary of the assessment of pre-treatment technologies.........................250

Table 8-3: Assessment of feasibility requirements.........................................................253

Table 8-4: Results of the evaluation of the options for storage of liquid mercury...........259

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Index of figures

Figure 1-1: Legal background............................................................................................17

Figure 2-1: Overview of the methodological approach ......................................................22

Figure 2-2: Overview of possible options to be assessed .................................................23

Figure 2-3: Systematic data collection...............................................................................25

Figure 3-1: Overview of options.........................................................................................38

Figure 4-1: Relative solubility of elemental mercury in different salt water concentrations (NaCl and KCl) [GRS 2008A] .................................................44

Figure 4-2: Diagram of the biogeochemical mercury cycle ...............................................55

Figure 6-1: Illustration of possible releases of mercury related to the temporary or permanent storage of mercury ......................................................................110

Figure 6-2: Protection layers for the storage of mercury .................................................112

Figure 6-3: Metallic mercury storage at the Defense National Stockpile Center (source: DNSC).............................................................................................144

Figure 6-4: Examples of standard mercury steel containers used by Mayasa (source: Mayasa) ..........................................................................................147

Figure 6-5: typical mercury storage flask [DNSC 2007] ..................................................149

Figure 6-6: Overpacking concept of mercury containing flask [DNSC 2007] ..................150

Figure 6-7: Packaging instruction for liquid mercury according to ADR ..........................152

Figure 7-1: Overview of immobilisation technologies for metallic mercury......................169

Figure 7-2: Leaching behaviour of stabilized waste with different Hg loads and at different pH values. .......................................................................................194

Figure 8-1: Decision scheme for the selection of suitable pre-treatment processes .......245

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List of Abbreviations:

ADR Agreement on Dangerous Goods by Road

AISI American Iron and Steel Institute

ASTM American Society for Testing and Materials

BFS Blast furnace slag

CBPC Chemically bonded phosphate ceramic

DNSC Defense National Stockpile Center

EPA Environmental protection agency

Hg-Regulation Regulation (EC) N° 1102/2008

IATA International Air Transport Association

IMO International Maritime Organisation

MERSADE Mercury Safety Deposit

MM EIS Mercury Management Environmental Impact Statement

OPC Ordinary Portland cement

RID Regulations concerning the International Transport of Dangerous Goods by Rail

RCRA Resource Conservation and Recovery Act, US

SPC Sulphur polymer cement

SPSS Sulphur polymer stabilization/solidification

TCLP Toxicity characteristic leaching procedure

UNEP United Nations Environment Programme

WAC Waste acceptance criteria

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1 Background and objectives

1.1 General background

Metallic mercury as well as most of its compounds are highly toxic to humans and the environment.

High doses can be fatal to humans, but even relatively low doses can have serious adverse health

effects, e.g. on the reproductive system.

Mercury is considered a global persistent pollutant; once entering in the environment it cannot be

broken down to any harmless form. Mercury can be found in almost all environmental

compartments, such as the atmosphere, soil or water systems all over the world. Current

environmental concentrations are a result of anthropogenic and natural sources. Mercury is the only

metallic chemical element being liquid at standard conditions of temperature and pressure. In

particular in its gaseous form mercury is transported globally via the atmosphere. Due to its bio-

accumulation through the food chain, the consumption of fish is by far the most significant source of

mercury exposure in humans.

Due to its high toxicity to humans, ecosystems and wildlife, especially if chemically converted to

methyl mercury, there is now a world-wide common effort to reduce both demand and supply of

mercury. In 2009, the UN Environment Programme Governing Council agreed to take steps towards a

comprehensive legally binding international agreement on mercury. The Council of the European

Union had already supported this approach towards an international agreement by adopting

Conclusions on the specific issue in December 2008 [EU Council 2008].

Mercury emissions

In 2005 the global atmospheric emissions of mercury from natural sources were estimated to be

400–1,300 tonnes per year from oceans and 500–1,000 tonnes per year from land. The global

atmospheric emissions of mercury from human activities were estimated in the same range between

1,220–2,900 tonnes [UNEP 2009].

The major sources of anthropogenic mercury emissions worldwide are from fossil fuel combustion

for power and heating (878 tonnes), artisanal and small-scale gold production (350 tonnes), metal

production (ferrous and non-ferrous, excluding gold) (200 tonnes), cement production (189 tonnes),

waste incineration, waste and others (125 tonnes) [UNEP 2009].

Sources of elemental mercury

At present Kyrgyzstan is the only country mining mercury for export, China’s mercury mining is for

domestic consumption only [UNEP 2009].

Before 2003 Europe was a major exporter of mercury (around 25% of the total supply) [MEMO 08-

808_EN]. The main production site in Europe was the mine in Almadén in Spain where primary

production of metallic mercury came from cinnabar extraction. In 2003 the production of virgin

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mercury in Almadén stopped and the export of mercury from Europe declined significantly. Mercury

mining in Slovenia (Idrija mine) and Italy (Monte Amiata) ceased several years ago (1995 in Slovenia

and 1976 in Italy).

Apart from primary production from cinnabar ore, mercury can also be obtained as a secondary

product along with the production of other materials e.g. zinc or tin. Nowadays, the recovery of

mercury from waste materials containing mercury e.g. thermometers, measuring devices, etc is also

a source of elemental mercury.

The estimated average global supply (and demand) of metallic mercury is around 3,000 (2008)

tonnes per year. Based on [UNEP 2006], the main sources of mercury on the global market are

summarized in the following table:

Table 1-1: Sources of mercury supply in 2005 [UNEP 2006]

Sector Mercury supply (metric tonnes) range

Primary mercury mining 1,350-1,600

By-product 450-600

Recycled mercury from chlor-alkali

wastes

90-140

Recycled mercury – others 450-520

Mercury from chlor-alkali cells

(decommissioning)

600-800

(Stocked) 0-200

Total 3,000-3,800

Use of mercury

In 2007 the demand for mercury was estimated at more than 320 t in the 27 EU Member States. The

following table gives an overview of the most important uses of metallic mercury in Europe:

Table 1-2: EU mercury consumption estimates in 2007 (tonnes) [MEMO 08-808_EN]

sector Mercury demand (metric tonnes) range

Chlor-alkali plants 160-190

Batteries 7-25

Dental amalgam 90-110

Measuring and control equipment 7-17

Switches and electrical control 0-1

Lighting (energy-efficient lamps) 11-15

Chemicals 28-59

Other uses 15-114

Total 320-530



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In general the use of mercury is declining at both global and EU levels [EU COM 2005]. One reason is

the increased availability of mercury-free alternatives e.g. mercury-free production of chlorine or

mercury-free thermometers. On the other hand the use of mercury is increasingly being banned or

restricted by legal provisions such as restrictions for batteries (Directive 91/157/EEC1).

In Europe the most important industry related to the use of mercury is the chemical industry with its

sub-sector chlorine production. In the so called “mercury cell process” mercury is essential for the

production process of chlorine2. Currently the European chlorine industry – represented by Euro

Chlor, the European association of the chlor-alkali industry – has an agreement with the state-owned

Miñas de Almadén and y Arrayanes (MAYASA) in Spain. According to the agreement MAYASA

receives all excess mercury from western European chlorine producers and places it on the market

instead of virgin mercury. As a consequence MAYASA ceased mercury mining in 2003.

Phase out of mercury

The European chlorine industry committed itself to voluntarily phasing out the mercury-based

chlorine plants or conversion to non-mercury technologies (e.g. membrane technology) by 2020. As a

consequence, an amount of around 8,000-9,000 t of metallic mercury is expected to arise from the

decommissioned plants of the chlor-alkali industry within the next decade [Euro Chlor 2009].

Table 1-3: Overview of chlor-alkali plants still using mercury, September 2009 (source: Euro Chlor)

Country N° of plants Country N° of plants

Belgium 3 Poland 1

Czech Rep. 2 Romania 1

Finland 1 Slovak Rep. 1

France 6 Spain 7

Germany 4* Sweden 1

Greece 1 Switzerland 1

Hungary 1 UK 1

Italy 2 TOTAL 33

* In Germany, a total of 6 plants use mercury cell technology; however 2 plants are excepted from the voluntary phase out as they are not

chlor-alkali plants and have a different product range.

The ongoing substitution process of mercury in products and in particular the decommissioning of

1 Council Directive 91/157/EEC of 18 March 1991 on batteries and accumulators containing certain dangerous

substances, OJ L 078, 26.3.91 2 http://www.eurochlor.org/makingchlorine

http://www.eurochlor.org/makingchlorine

http://www.eurochlor.org/makingchlorine



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mercury cell plants has led to a situation in which increasing amounts of mercury are available on the

market. Therefore efforts have to be made to phase out surplus mercury; withdraw it from

circulation and find solutions for a permanent and safe final storage.

1.2 Legal background

Community Mercury Strategy

On 28 January 2005 the “Community Strategy Concerning Mercury” [EU COM 2005] was published

formulating the key objective to reduce mercury levels in the environment and human exposure as

mercury poses a threat within the Community and globally. The “mercury strategy” lists 20 actions

which should support the overall objectives. Among others, the following two actions have been

included in this strategy:

Action 5: As a pro-active contribution to a proposed globally organised effort to phase out primary

production of mercury and to stop surpluses re-entering the market as described in section 10, the

Commission intends to propose an amendment to Regulation (EC) No. 304/2003 to phase out the

export of mercury from the Community by 2011.

Action 9: The Commission will take action to pursue the storage of mercury from the chlor-alkali

industry, according to a timetable consistent with the intended phase out of mercury exports by 2011.

In the first instance the Commission will explore the scope for an agreement with the industry.

Mercury Regulation

To implement the above stated actions, the Council and European Parliament adopted on 22.10.2008

the Regulation on the banning of exports and the safe storage of metallic mercury (Regulation (EC)

No 1102/2008, OJ L304 of 14/11/08, p.75).

The export ban starts on 15 March 2011 and affects metallic mercury, cinnabar ore, mercury (I)

chloride, mercury (II) oxide and mixtures of metallic mercury with other substances including alloys

of mercury, with a concentration of at least 95 wt % Hg.

Furthermore, the Regulation lays down that from 15 March 2011 metallic mercury from the

following sources should be considered as waste (Article 2, Regulation (EC) No 1102/2008):

• Metallic mercury that is no longer used in the chlor-alkali industry

• Metallic mercury gained from the cleaning of natural gas

• Metallic mercury gained from non-ferrous mining and smelting operations

• Metallic mercury extracted from cinnabar ore in the Community as from 15 March 2011

In order to provide for possibilities of a safe storage of the above mentioned metallic mercury waste

within the Community, Article 3 of Regulation (EC) No 1102/2008 constitutes suitable options both

for permanent and temporary storage in appropriate containments (by derogation from Article 5



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(3)(a) of Directive 1999/313):

• temporary storage for more than one year or permanent storage in

o salt mines adapted for the disposal of metallic mercury, or

o in deep underground, hard rock formations providing a level of safety and

confinement equivalent to that of those salt mines; or

• temporary storage for more than one year in above-ground facilities dedicated to and

equipped for the temporary storage of metallic mercury (In this case, the criteria set out in

section 2.4 of the Annex to Decision 2003/33/EC4 shall not apply).

Article 3 (1) also sets out that all other provisions (except Article 5 (3)(a)) of Directive 1999/31/EC and

Decision 2003/33/EC shall apply to the above described storage options for liquid mercury. In

addition, in case of a temporary above ground storage Directive 96/82/EC5 (Seveso Directive, see also

chapter 5) applies to the storage facility and the corresponding requirements (e.g. establishment of a

safety management system) have to be fulfilled.

Article 4 of Regulation (EC) No 1102/2008 stipulates that the safety assessment which is required for

a safe underground storage under Decision 2003/33/EC should be complemented by specific

requirements to address the particular risks specific to the storage of metallic mercury. Furthermore,

acceptance criteria should be developed for metallic mercury either temporarily or permanently

stored in appropriate underground or above-ground facilities.

3 Council directive 1999/31/EC of 26 April 1999 on the landfill of waste (OJ L14, 20.1.2009, p.10) 4 Council Decision of 19 December 2002 establishing criteria and procedures for the acceptance of waste at

landfills pursuant to Article 16 of and Annex II to Directive 1999/31/EC 5 Council Directive 96/82/EC of 9 December 1996 on the control of major-accident hazards involving dangerous

substances (OJ L 10, 14.1.1997, p. 13–33) as amended by Directive 2003/105/EC; also referred to as the ‘Seveso II Directive’.



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Figure 1-1: Legal background

Against this background the Commission is requested, in order to ensure the proper application and

enforcement of the Regulation (EC) No 1102/2008, to propose requirements for the three specific

types of storage facilities (salt mine, hard rock, above ground) as well as acceptance criteria for

metallic mercury going to such facilities by amending annexes I, II and III of Directive 1999/31/EC.

Consequences of the Regulation

As a consequence of the Regulation large amounts of metallic mercury – which are currently

considered as raw material – will become waste, and adequate safe storage or disposal options have

to be identified. The following amounts of metallic mercury are expected to be stored/disposed of in

the next few years:

Regulation 1102/2008

- Export ban of metallic mercury

- Metallic mercury from specific sources has to be considered as waste

Underground storage permanent or temporary (>1 year)

Above-ground storage temporary (>1 year)

Amending of Annex I, II, III of Directive 1999/31/EC

Annex I: General requirements for all classes of landfills

Annex II: Waste acceptance criteria and procedures

Annex III: Control and Monitoring procedures in operation and after-care phase

Decision 2003/33/EC+

Derogation from Article 5(3)(a) of Directive 1999/31/EC

- Criteria for above ground storage - Criteria for underground storage - Site specific safety assessment (Annex A)

Definition of requirements for storage facilities and acceptance criteria for metallic mercury



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Table 1-4: Estimated amount of excess mercury that has to be safely stored

Activity Estimated amount of excess mercury which has

to be safely stored

Metallic mercury that is no longer used in the

chlor-alkali industry

~8,000 t – 9,000 t (~ 700 m³) by 2020 [Euro Chlor

2009]

Metallic mercury gained from the cleaning of

natural gas

~26t/a [Concorde 2006]

Metallic mercury gained from non-ferrous

smelting operations

~53t/a [Concorde 2006]

Metallic mercury extracted from cinnabar ore

in the Community as from 15 March 2011

No mining activities currently or anticipated

[COWI 2008] estimates that quantities of mercury in non-ferrous ores and in natural gas gives a total

of 350-410 tonnes of mercury per year potentially recoverable as a by-product from these sources, of

which 65-90 tonnes are already being recovered.

A possible extension of storage obligation to metallic mercury from other sources will be based on

the outcome of an information exchange organized by the Commission (Article 8 of the Mercury

Regulation).

In December 2008 Euro Chlor announced a voluntary agreement to ensure the safe storage of

surplus mercury from the European chlor-alkali industry, once a ban on mercury exports from the

European Union takes effect in 2011. This voluntary commitment was formally acknowledged by an

EC Recommendation on 22 December 2008 (C (2008) 8422).

According to the Regulation, no final disposal operations for metallic mercury should be permitted

until the special requirements and acceptance criteria for the storage or disposal of metallic mercury

are adopted.

1.3 Objectives of the project

The overall objective of the study is to provide the Commission with a solid knowledge base for

fulfilling the tasks resulting from Article 4 (3) of the Regulation (EC) N° 1102/2008. The Regulation

requires that for the storage options as defined in Article 3(1)(a) and (b) requirements for the

different types of storage facilities as well as acceptance criteria for metallic mercury going to such

facilities are established by amending the annexes I, II and III of Directive 1999/31/EC.

The study will provide:

• an overview of treatment techniques for metallic mercury before storage (solidification and

others), assessing the stage of development already reached (concept, laboratory phase,

pilot phase or proven large-scale application; costs),

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:32009H0039:EN:NOT



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• an overview of feasible storage options (permanent or temporary) for metallic mercury as

well as treated (solidified/stabilized) mercury

Based on the outcome of the overview

• a set of draft requirements and draft acceptance criteria for metallic mercury

• a set of draft requirements and draft acceptance criteria for stabilized mercury

will be elaborated for the different types of permanent and temporary storage.

For the elaboration of these draft requirements and acceptance criteria the following principles – as

stated in the Mercury Regulation – will be taken into consideration:

• The storage conditions in a salt mine or in deep underground, hard rock formations, adapted

for the disposal of metallic mercury, should notably meet the principles of

o protection of groundwater against mercury

o prevention of vapour emissions of mercury

o impermeability to gas and liquids of the surroundings and

o in case of permanent storage — of firmly encapsulating the wastes at the end of the

mines' deformation process.

• The safety assessment required for underground storage under Decision 2003/33/EC will be

complemented by specific requirements and will be made applicable to non-underground

storage to ensure storage that is safe for human health and the environment.

• The above-ground storage conditions should notably meet

o the principles of reversibility of storage,

o protection of mercury against meteoric water,

o impermeability towards soils and

o prevention of vapour emissions of mercury.

• The above-ground storage of metallic mercury should be considered as a temporary solution.

To achieve the overall objective, all feasible options will be assessed and compared in order to

provide the Commission with a recommendation of how to best fulfill the tasks resulting from Article

4(3) of the Regulation (EC) N° 1102/2008.



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1.4 References

[Concorde 2004] Concorde EastWest Spr., Mercury flows in Europe and the world: the impact of decommissioned chlor-alkali plants, February 2004 http://ec.europa.eu/environment/chemicals/mercury/pdf/report.pdf [Concorde 2006] Concorde EastWest Spr., Mercury flows and safe storage of surplus mercury, 2006 http://ec.europa.eu/environment/chemicals/mercury/pdf/hg_flows_safe_storage.pdf [Concorde 2009] Concorde sprl, Assessment of excess mercury in Asia, 2010-2050, May 2009 http://www.chem.unep.ch/mercury/storage/Asian%20Hg%20storage_ZMWG%20Final_26May2009.pdf [COWI 2007] COWI, Follow-up study on the implementation of Directive 1999/31/EC on, June 2007 the landfill of waste in EU-25, Final Report - Findings of the Study http://web.rec.org/documents/ECENA/training_programmes/2008_06_budapest/session1/7-implementation_eu_25_2007_cowi_report.pdf [COWI 2008] COWI A/S and Concorde East/West Sprl, Options for reducing mercury use in products and applications, and the fate of mercury already circulating in society, December 2008 http://ec.europa.eu/environment/chemicals/mercury/pdf/study_report2008.pdf [EIA EU 2005] Communication from the Commission to the Council and the European Parliament on Community Strategy Concerning Mercury, EXTENDED IMPACT ASSESSMENT, 2005 http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=COM:2005:0020:FIN:EN:PDF [EU COM 2001] European Commission, Integrated Pollution Prevention and Control (IPPC) - Reference Document on Best Available Techniques in the Chlor-Alkali Manufacturing industry -, http://ec.europa.eu/comm/environment/ippc/brefs/cak_bref_1201.pdf [EU COM 2002] Report from the Commission to the Council concerning mercury from the Chlor-alkali industry, COM (2002) 489 final, http://eur-lex.europa.eu/smartapi/cgi/sga_doc?smartapi!celexplus!prod!DocNumber&lg=en&type_doc=COMfinal&an_doc=2002&nu_doc=489 [EU COM 2005] Communication from the Commission to the Council and the European Parliament,

http://ec.europa.eu/environment/chemicals/mercury/pdf/report.pdf

http://ec.europa.eu/environment/chemicals/mercury/pdf/hg_flows_safe_storage.pdf

http://www.chem.unep.ch/mercury/storage/Asian Hg storage_ZMWG Final_26May2009.pdf


http://web.rec.org/documents/ECENA/training_programmes/2008_06_budapest/session1/7-implementation_eu_25_2007_cowi_report.pdf


http://ec.europa.eu/environment/chemicals/mercury/pdf/study_report2008.pdf

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=COM:2005:0020:FIN:EN:PDF

http://ec.europa.eu/comm/environment/ippc/brefs/cak_bref_1201.pdf

http://eur-lex.europa.eu/smartapi/cgi/sga_doc?smartapi!celexplus!prod!DocNumber&lg=en&type_doc=COMfinal&an_doc=2002&nu_doc=489





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Community Strategy Concerning Mercury, COM (2005) 20 final, 28 January 2005, Brussels http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=COM:2005:0020:FIN:EN:PDF [EU COM 2005A] Commission staff working paper, Annex to the Communication from the Commission to the Council and the European Parliament, Community Strategy Concerning Mercury, Extended Impact Assessment, SEC(2005) 101, 28 January 2005, Brussels, http://ec.europa.eu/environment/chemicals/mercury/pdf/extended_impact_assessment.pdf [EU COM 2006] European Commission, Report on the International Mercury Conference - How to reduce mercury supply and demand, Brussels 26-27 October 2006, 2006 http://ec.europa.eu/environment/chemicals/mercury/conference.htm [EU COM 2006A] European Commission, Integrated Pollution Prevention and Control Reference Document on Best Available Techniques for the Waste Treatments Industries, August 2006 ftp://ftp.jrc.es/pub/eippcb/doc/wt_bref_0806.pdf [MEMO-08-808_EN] Questions & Answers on the EU Mercury Strategy, MEMO/08/808 Brussels, 22 December 2008 http://europa.eu/rapid/pressReleasesAction.do?reference=MEMO/08/808&format=HTML&aged=0&language=EN&guiLanguage=en [UNEP 2007] Draft technical guidelines on the environmentally sound management of mercury wastes, 2007, http://www.basel.int/techmatters/mercury/guidelines/240707.pdf [UNEP 2009] UNEP, Draft technical guidelines on the environmentally sound management of mercury wastes, 4th Draft, April 2009, http://www.basel.int/techmatters/mercury/guidelines/040409.doc


http://ec.europa.eu/environment/chemicals/mercury/pdf/extended_impact_assessment.pdf


http://ec.europa.eu/environment/chemicals/mercury/conference.htm

ftp://ftp.jrc.es/pub/eippcb/doc/wt_bref_0806.pdf

http://europa.eu/rapid/pressReleasesAction.do?reference=MEMO/08/808&format=HTML&aged=0&language=EN&guiLanguage=en


http://www.basel.int/techmatters/mercury/guidelines/240707.pdf

http://www.basel.int/techmatters/mercury/guidelines/040409.doc



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2 Methodology

2.1 Overall methodological approach

Against the described background and objectives, the methodological approach of the project is visualized in the following figure: Figure 2-1: Overview of the methodological approach

For the first step of this methodology (Identification of options against the legal background) a

review of the existing pre-treatment technologies, disposal facilities for temporary and permanent

storage and of different types of containment has been carried out. With regard to disposal facilities,

apart from existing hazardous waste landfills (above ground and underground), experience from

radioactive waste disposal is also included in the review. An overview of the current status of

knowledge explains the hazardous properties and characteristics of metallic mercury with a special

focus on its behaviour in the environment. An overview of existing legal requirements, policies and

best practice related to the disposal of mercury waste in Europe as well as on an international level is

provided. With this investigation a “pool” of options is generated. The various options of the pool can

also be combined (e.g. temporary storage + pre-treatment + permanent storage) and in this way

form a broad basis for all potential solutions related to the problem of the disposal of liquid mercury.

The objective of this initial work is to acquire a current and updated status on the scientific and

technical knowledge related to the storage or disposal of mercury. The results provide various

options that all comply with the legal requirements. This outcome can be roughly characterized as



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follows and forms the basis for the further assessments, identification of necessary acceptance

criteria and combinations of options (see steps 2 and 3 of the overall methodology, Figure 2-1).

Figure 2-2: Overview of possible options to be assessed

Data and information sources for step 1 have been:

• extensive literature research

• patent analyses

• expert interviews

• site visits

• questionnaire survey

All these information sources have been used by the project team to generate the pool of options

(for more details see section 2.2.1).

Metallic mercury waste

Pre-treatment options

No pre-treatment

Options: underground storage in salt mines

Options: storage in deep underground, hard rock

formations

Options: above ground storage

Various storage possibilities according to

Directive 1999/31/EC

Solidified mercury (non metallic mercury)

Permanent Temporary Permanent Temporary Temporary

Under-ground

Above ground



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The second step of the methodology foresees a screening analysis (see Figure 2-1). One target of this

screening analysis is to exclude options from further investigation if there is no reasonable possibility

to realize them in compliance with minimum technical, environmental and economic criteria. A

second target of this step is to identify basic acceptance criteria that need to be linked to the options

(or to combinations of options) to fulfill the minimum criteria. Within the screening analysis, the

feasibility of options related to their implementation under time constraints and required resources

for realization are also investigated. The screening analysis results in a short list of feasible options

which will be further assessed.

Option Currently feasibly

I Permanent storage of liquid mercury in salt rock No / YES / ?

II Permanent storage of liquid mercury in deep underground hard

rock formations

No / YES /?

III …

For further details see section 2.3.

The third step of the methodology covers the assessment of options or combinations of options (and

corresponding acceptance criteria) that remain after the screening analysis on a short list.

Environmental and economic targets will be used to basically evaluate the options within the

assessment. After the basic evaluation, potential combinations of options and fine tuning of

corresponding acceptance criteria take place and the evaluation is repeated for a final overview on

the appropriateness of options which then found their way to the list of recommendations. Options

that are best in all or in selected criteria then find their way into the list of recommendations. The list

of recommendations will also cover the required amendments of annexes I, II and III of Directive

1999/31/EC.

The findings of the study were presented in a workshop in November 2009 and discussed with

interested stakeholders. All received comments were taken into consideration for this report.



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2.2 Detailed methodology for the identification of options and the review of the state of the art; approach for information gathering

2.2.1 Overview of information gathering

The review of the state of the art and state of the development is based on information provided by

the relevant experts on relevant studies and other systematically identified documents or

publications.

Figure 2-3: Systematic data collection

All options that could be identified with these information sources have been collected and

characterized in a “pool of options”. The results are documented in chapters 3, 4, 5 and 7 of this

report.

2.2.2 Literature search

At the beginning of the study an intensive literature search was carried out to identify relevant

information. Studies already carried out on the topic of the disposal and storage of metallic mercury

have been investigated in detail and the bibliographic references thereof were evaluated in order to

Questionnaire; expert interviews, site visits

Data base search

MS and international authorities

Industrial and scientific experts

NGOs

Patent data bases

Scientific data bases

- Environmental data bases - Technical data bases - Health data bases

Systematic data collection

Literature search

Review of important studies

Web search

Libraries



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identify further relevant literature sources and contact details of relevant experts. The following

studies provided an important input to the project:

Table 2-1: Overview of important studies relevant for the project

Reference Short description of the content

[Env Canada 2001]

National Office of Pollution prevention,

Environment Canada, The Development of

retirement and long term storage options of

mercury, Draft final report, Ontario, June 2001

Environmental Canada has published a draft report

(prepared by the Consultants SENSE) on the

development of retirement and long-term storage

options for mercury. The study evaluated 67

technologies – including disposal options in mines –

using the Kepner-Tregoe ranking technique and

reviewed a further 9 technologies but did not rank

them because there was insufficient information.

[Env Canada 2004]

Environment Canada, Mercury and the

environment, Internet document:

http://www.ec.gc.ca/MERCURY/EH/EN/eh-

i.cfm, last update 2004-02-04, accessed on 29

June 2009

This homepage provides an overview of the current

state of knowledge related to the properties of

liquid mercury.

[DNSC 2004B]

Defense National Stockpile Center, Final

Mercury Management Environmental Impact

Statement, Volume I, 2004

The Defense Logistics Agency (DLA), USA, prepared

a Mercury Management Environmental Impact

Statement (MMEIS). In 2003/2004 a Mercury

Management Environmental Impact Assessment

(MM EIS) was carried out to find the most

appropriate way of how to deal with the stored

mercury in future.

[SOU 2008A]

Statens offentliga Utredningar (SOU) 2008: 19:

Att slutförvara långlivat farligt avfall i

undermarksdeponi i berg – Permanent storage

of long-lived hazardous waste in underground

deep bedrock depositories, SOU 2008: 10 April

2008

This study – commissioned by the Swedish

government –analysed the permanent storage of

mercury in deep bedrock and salt mines. The

report provides an account of permanent storage

options for mercury-containing waste, and the

requirements and risks attendant to the permanent

storage of liquid mercury.

A summary on the key findings of the study is

available in English [SOU 2008]

[UNEP 2009]

UNEP, Draft technical guidelines on the

environmentally sound management of

These draft technical guidelines provide a broad

overview of the current state of knowledge related

to the properties of mercury and its compounds, its

behaviour in the environment but also information



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Apart from the above-mentioned studies, the world wide web has also been used for individual

searches for specific information by using specific key word combinations according to individual

search purposes. The identified documents have been evaluated related to their relevance and an

evaluation of the bibliographic references was carried out to identify further documents.

2.2.3 Questionnaire

Relevant experts of Member States authorities as well as non-EU country authorities, industrial and

scientific experts and international NGOs dealing with this topic were contacted within the scope of a

questionnaire survey in June 2009 (for a list of contacted experts, see separate excel file6). The

experts were asked to provide information on relevant research / scientific activities related to pre-

treatment techniques and disposal options of metallic mercury waste as well as on relevant contact

persons.

6 A separate excel file including the contacted institutions and experts has been provided to the European

Commission. Due to reasons of confidentiality, this list is not included as an annex to this report.

mercury wastes, 4th Draft, April 2009 on the storage of liquid mercury.

[USEPA 2002c]

Preliminary analysis of alternatives for the long

term management of excess mercury,

EPA/600/R-03/048 AUGUST 2002

This study describes a systematic method for

comparing options for the long-term management

of surplus elemental mercury in the US, using the

analytic hierarchy process. A limited scope multi-

criteria decision analysis was performed. Alternatives were evaluated against criteria that

included costs, environmental performance,

compliance with current regulations,

implementation considerations, technology

maturity, potential risks to the public and workers,

and public perception.

[DOE 2009]

U.S. Department of Energy, Interim Guidance

on Packaging, Transportation, Receipt,

Management, and Long-Term Storage of

Elemental Mercury, U.S. Department of Energy

Office of Environmental Management

Washington, D.C., November 13, 2009

This document is intended to provide general

guidance on standards and illustrative procedures

that are current, consistent, and best suited for

supporting the DOE program for the receipt,

management, and long-term storage of mercury

generated in the United States. As such, this

interim guidance provides a framework for the

standards and procedures associated with a DOE-

designated elemental mercury storage facility with

a focus on the RCRA permitting of such a facility

and planning for that storage facility’s needs.



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In total, the questionnaire (see Annex 1) was sent to 43 institutions. In total 26 questionnaires have

been sent back. The feedback on the questionnaire was quite diverse and it varied from very

extensive answers including links, documents and experts for further investigations, to very short

answers due to lack of information or no relevance of the topic.

2.2.4 Expert interviews and site visits

Received information was evaluated with respect to its content. Key persons were contacted with

the intention of obtaining specific additional information. In this way the most relevant information

sources could be systematically identified and an information exchange with selected experts was

initiated.

Expert interviews were carried out with various concerned stakeholders such as

• Treatment technology providers / developers

• Operators of underground disposal facilities

• Operators of above ground storage facilities (not landfills) for liquid mercury

• Member States’ experts on landfill and mercury

• European Associations (e.g. Euro Chlor)

In addition, site visits at an underground disposal site and treatment technology provider took place

to receive more detailed information on the disposal process and treatment technology.

This approach turned out to be the most efficient way of targeted data collection. It was additionally

supplemented by a systematic literature search in selected data bases.

Another valuable input for the project was a workshop initiated by IKIMP7. The workshop “Safe

storage and disposal of redundant mercury” (13 & 14 October, 2009) offered a good platform for

information exchange and discussion of technologies and storage options with experts.

7 IKIMP: Integrating Knowledge to Inform Mercury Policy, http://www.mercurynetwork.org.uk/

http://www.mercurynetwork.org.uk/

http://www.mercurynetwork.org.uk/



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2.2.5 Data base search

An intensive data base search was carried out to identify relevant scientific literature. The search

covered patent data bases as well as environmental, technical and health related data bases. The

data bases were scanned using appropriate key words such as “mercury and immobilization” and

“mercury and stabilization”. The identified results were evaluated based on the available abstracts

for their relevance to the project. Relevant persons and companies cited in the patents were

contacted with the intention of obtaining specific additional information.

A detailed overview of the data base search results is attached as Annex 3 to this report.

Patent data bases

With regard to relevant patents, the following data bases were used for the search:

• German patent information system (DEPATIS8) provided by the German Patent and Trade

Mark Office. It enables online searches in patent publications from around the world stored

in the database of DEPATIS, the in-house patent information system of the German Patent

and Trade Mark Office.

• Europe's network of patent data bases (esp@cenet9). Its interface is available in most

European languages. It contains over 60 million patent documents from all over the world.

These patent data bases have been searched using the following search terms and their

combinations: “mercury”, “stabilization”, “solidification”, “immobilization”. The patents resulting

from the search, preceding patents and patents that are cited in the search results have been

evaluated for their usefulness to the review of the state of the art. Relevant persons and companies

cited in the patents where contacted with the intention of obtaining specific additional information.

Scientific data bases

With regard to scientific publications, the following data bases were used for the literature search:

• Dialog© Dissertation Abstracts Online (35),

• Dialog© Enviroline (40)

• Dialog© WasteInfo (110)

• Federal Research in Progress (FEDRIP) (File 266)

• UFORDAT10: (Data base of the German EPA on research projects)

• ULIDAT11 (Data base of the German EPA on environmental literature)

8http://depatisnet.dpma.de/DepatisNet/depatisnet?window=1&space=unknown&content=index&action=inde

x&session=c23b66f330d8b2a5ae5f763b40288513d8ee58f67400&stamp=83152 9 http://ep.espacenet.com/?locale=en_EP 10 http://doku.uba.de/cgi-bin/g2kadis?WEB=JA&ADISDB=VH&SATZNR=83198 11 http://doku.uba.de/cgi-bin/g2kadis?WEB=JA&ADISDB=VH&SATZNR=83198

http://depatisnet.dpma.de/DepatisNet/depatisnet?window=1&space=unknown&content=index&action=index&session=c23b66f330d8b2a5ae5f763b40288513d8ee58f67400&stamp=83152

http://depatisnet.dpma.de/DepatisNet/depatisnet?window=1&space=unknown&content=index&action=index&session=c23b66f330d8b2a5ae5f763b40288513d8ee58f67400&stamp=83152

http://ep.espacenet.com/?locale=en_EP

http://doku.uba.de/cgi-bin/g2kadis?WEB=JA&ADISDB=VH&SATZNR=83198





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These data bases have been systematically searched for relevant literature by using appropriate key

words (e.g. mercury, stabilization) and key word combinations (see Annex 3). Search results were

screened for their relevance for the project objectives. Relevant studies were evaluated with respect

to their content and their bibliographic references. Selected authors of key studies have been

contacted with the intention of obtaining specific additional information. The identified documents

have been evaluated based on the available abstracts.

At the end of each section the section specific references are listed. Annex 2 includes a compilation

of all identified relevant literature for this study.



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2.3 Detailed description of the screening analysis and the selection of options including the elaboration of basic acceptance criteria

The following flow chart describes the methodology for the first phase of the screening analysis:

Pool of options resulting from step 1

Acceptance criteria to be combined with

options

Technical minimum

requirements

Options that have to be excluded as they do not fulfill the minimum requirements/ acceptance criteria

Options + acceptance criteria for further investigation


options

Environmental minimum

requirements




options

Economic minimum

requirements



Candidates (options + corresponding acceptance criteria) for further

investigation



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In the first step, technical minimum requirements are established that are basically justified by the

requirements for safe and sustainable solutions.

Examples of such minimum requirements are:

- Protection of groundwater against mercury in cases of permanent underground storage

- Impermeability to gas and liquids of the surroundings (permanent underground storage)

- Large scale application or pilot plant available (applicable for pre-treatment technologies)

In relation to an option, these criteria find themselves translated into facility related requirements

and acceptance criteria for the waste, which need to be fulfilled to make the option a real solution.

Facility related requirements directly address the disposal facility or the pre-treatment technology,

such as

• Effectiveness of the geological barrier in terms of migration time for mercury to the

biosphere (permanent storage) >1 million years

• Installation of a permanent mercury vapour monitoring system

Acceptance criteria directly address the waste and its properties, the waste container or the handling

of the waste, such as

• Acceptance only of certified containers

• Purity of the mercury to be accepted: >99.9% per weight

If the defined additional acceptance criteria cannot be fulfilled by an option, the corresponding

option has to be excluded from further investigations.

The same procedure as described for the minimum technical criteria is carried out for minimum

environmental/health and minimum economic criteria. Environmental and health related minimum

criteria are for example the compliance with existing occupational exposure limits. A corresponding

facility related requirement might be the installation of a permanent monitoring system with a

certain level of sensitivity.

The following flow chart describes the methodology for the second phase of the screening analysis.

For this second phase, only options and combinations of options are considered that have not been

excluded in the first phase:



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The first criterion that is checked concerns the feasibility under the given framework of time. Feasible

solutions need to be available – together with fulfilled acceptance criteria – at the latest by 15 March

2011 for large scale applications. If options for permanent solutions cannot fulfill this feasibility

criterion they need to be combined with temporary storage options to bridge the period up to the

implementation of the option.

The second criterion covers the costs that are required to enable a large scale application. Currently,

there are some uncertainties on the quantities of liquid mercury that need to be disposed of in the

years after 2011. Feasibility under economic conditions is granted, if – with reasonable costs – a

flexibility related to the required annual capacity is provided.

Candidates as outcome of first phase of screening analysis

Option not regarded as feasible

Feasibility related to time frame

requirements for large scale

implementation

OK

Option not regarded as feasible

Feasibility related to costs required

for large scale implementation

failed

failed

OK

Feasible option + acceptance criteria for

comparative assessment

Pool of options resulting from step 1



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2.4 Detailed description of the assessment methodology including the elaboration of fine tuned acceptance criteria and the recommendation list

The screening analysis was followed by an assessment of remaining options or combinations of

options on their strengths and weaknesses. Within this assessment environmental and economic

targets have been used to basically evaluate the options. After the basic evaluation, potential

combinations of options and fine tuning of corresponding acceptance criteria took place and the

evaluation was repeated for a final overview on the appropriateness of options which then found

their way to the list of recommendations.

If an option or a combination of options fulfills all acceptance criteria, in principle it can be chosen by

industry. So the question might come up why an assessment and a following recommendation list

are necessary at all.

The answer on such questions and correspondingly the justification of the final assessment is to offer

industry an information and decision basis where they can see the advantages of options under

different criteria. This might lead to a preference of solutions that provide environmental advantages

against other options with equal costs. Also a preference might be generated for less expensive

solutions with the same level of environmental safeness.

For the assessment direct environmental and economic target criteria are set up such as:

• Hg-Emissions and corresponding risks for human health or the environment

• Risk for accidents or handling problems

• Overall costs

• Required investment costs

• Costs of temporary storage of liquid mercury prior to treatment

The final result is then summarized in the recommendation list including a written justification.



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2.5 References

[DNSC 2004B] Defense National Stockpile Center, Final Mercury Management Environmental Impact Statement, Volume I, 2004 [DOE 2009] U.S. Department of Energy, Interim Guidance on Packaging, Transportation, Receipt, Management, and Long-Term Storage of Elemental Mercury, U.S. Department of Energy Office of Environmental Management Washington, D.C., November 13, 2009, http://www.em.doe.gov/pdfs/Elementalmercurystorage%20Interim%20Guidance_11_13_2009.pdf [Env Canada 2001] National Office of Pollution prevention, Environment Canada, The Development of retirement and long term storage options of mercury, Draft final report, Ontario, June 2001 [Env Canada 2004] Environment Canada, Mercury and the environment, Internet document: http://www.ec.gc.ca/MERCURY/EH/EN/eh-i.cfm, last update 2004-02-04, accessed on 29 June 2009 [SOU 2008A] Miljödepartementet, Att slutförvara långlivat farligt avfall i undermarksdeponi i berg, ISBN 978-91-38-22922-4, 2008 [UNEP 2009] UNEP, Draft technical guidelines on the environmentally sound management of mercury wastes, 4th Draft, April 2009, http://www.basel.int/techmatters/mercury/guidelines/040409.doc [USEPA 2002c] Hugh W. McKinnon, Preliminary analysis of alternatives for the long term management of excess mercury, EPA/600/R-03/048, 2002, http://www.epa.gov/nrmrl/pubs/600r03048/600R03048.pdf

http://www.em.doe.gov/pdfs/Elementalmercurystorage Interim Guidance_11_13_2009.pdf


http://www.epa.gov/nrmrl/pubs/600r03048/600R03048.pdf



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3 Identification of options Article 3 (1) Regulation (EC) N° 1102/2008 prescribes possible storage options for liquid mercury

“By way of derogation from Article 5(3)(a) of Directive 1999/31/EC, metallic mercury that is

considered as waste may, in appropriate containment, be

a. temporarily stored for more than one year or permanently stored (disposal operations D 15 or

D 12 respectively, as defined in Annex II A of Directive 2006/12/EC)

• in salt mines adapted for the disposal of metallic mercury, or

• in deep underground, hard rock formations providing a level of safety and confinement

equivalent to that of those salt mines; or

b. temporarily stored (disposal operation D 15, as defined in Annex II A of Directive 2006/12/EC)

for more than one year in above-ground facilities dedicated to and equipped for the

temporary storage of metallic mercury. In this case, the criteria set out in section 2.4 of the

Annex to Decision 2003/33/EC shall not apply.

The other provisions of Directive 1999/31/EC and Decision 2003/33/EC shall apply to points (a) and

(b).”

The term “temporarily” is not clearly defined in the Regulation. It is simply stated that temporary

means more than one year but no upper limit is defined.

The term “stored” is defined via the reference to Annex II A (Disposal operations) of the waste

directive 2006/12/EC:

D12: Permanent storage (e.g. emplacement of containers in a mine, etc.)

D15: Storage pending any of the operations numbered D1 to D14 (excluding temporary storage,

pending collection, on the site where it is produced)

The expression “adapted for the disposal of metallic mercury” implies that, in order to fulfil the

requirements especially established in Regulation 1102/2008, in particular the recitals (11) and (12)

on a storage that is safe for human health and the environment , not only the mercury waste has to

fulfil requirements and acceptance criteria, but also the potential storage facilities.

The term “appropriate containment” refers to the aspect that various types of containment might be

required, depending on the storage time and facility.

Against the above-described background, the following 5 options for the storage of liquid mercury

(options are marked with an “l”) have been derived:



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Option 1l: Permanent storage of liquid mercury in salt mines

Option 2l: Temporary storage of liquid mercury in salt mines

Option 3l: Permanent storage of liquid mercury in deep underground hard rock formations

Option 4l: Temporary storage of liquid mercury in deep underground hard rock formations

Option 5l: Temporary storage of liquid mercury in above ground facilities

Apart from the storage/disposal of liquid mercury, the possibility of pre-treating liquid mercury has

also to be taken into consideration. Article 8 (2) Regulation 1102/2008 requires that the Commission

“shall keep under review ongoing research activities on safe disposal options, including solidification

of metallic mercury”. Therefore, in addition to the above-stated options, the following option shall

also be taken into consideration:

Option 6l: Pre-treatment of liquid mercury

After the pre-treatment process a stabilised and solid (waste) product is the result, with quite

different properties compared to liquid mercury. The resulting product is no longer “metallic”

mercury and thus the storage provisions laid down in Regulation (EC) N° 1108/2008 will no longer

apply. Therefore, depending on its properties, various storage options are possible following existing

legal requirements. The storage options referring to pre-treated or stabilised mercury are marked

with an “s”:

Option 1s: Permanent storage of pre-treated mercury in salt mines

Option 3s: Permanent storage of pre-treated mercury in deep underground hard rock

formations

Option 7s: Permanent storage of pre-treated mercury in above ground facilities

Another temporary storage (options 2s, 4s, 5s) after the pre-treatment does not provide the

requested type of a solution. Therefore for the pre-treated (stabilised) product only permanent

storage options are considered further.

The following diagram presents an overview of all relevant options related to the storage of metallic

mercury which will be investigated within this study:



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Figure 3-1: Overview of options

Option 1l: Permanent storage of metallic mercury in salt mines

This option covers the permanent storage of metallic mercury in salt mines. It must be determined

which minimum requirements salt mines have to fulfil for safe permanent storage of metallic

mercury.

Option 2l: Temporary storage of metallic mercury in salt mines

The temporary storage (>1 year) of metallic mercury in salt mines requires partly different

requirements compared to permanent storage. In cases of temporary storage, the retrievability of

the metallic mercury has to be taken into consideration. In addition, other criteria related to the

containment apply, in comparison with permanent storage.

Option 3l: Permanent storage of metallic mercury in deep underground hard rock formations

Storage in deep underground hard rock formations is only possible – according to Regulation

Metallic mercury waste

Underground storage in salt mines

Storage in deep underground, hard

rock formations

Temporary above ground

storage

Permanent Temporary Permanent Temporary

Option 1l Option 2l Option 3l Option 4l

Option 6l

Option 5l

Pre-treatmentoptions

Solidified mercury (nonmetallic mercury)

Permanent underground storage

in salt mines

Permanent storage in deep underground, hard rock

formations

Permanent above ground

storage

Option 1s Option 3s Option 7s

No pre-treatment



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1102/2008 – in case the level of safety and confinement is equal to those of salt mines.

Option 4l: Temporary storage of metallic mercury in deep underground hard rock formations

This option considers the temporary underground storage in deep hard rock formation. The same

requirements apply as for salt mines.

According to Decision 2003/33/EC, deep storage in hard rock is defined here as an underground

storage at a depth of several hundred metres, where hard rock includes various igneous rocks, e.g.

granite or gneiss, it may also include sedimentary rocks, e.g. limestone and sandstone.

Option 5l: Temporary storage of liquid mercury in above-ground facilities

The storage of liquid mercury above ground is only foreseen as a temporary form of storage. In cases

of above ground storage, the facility has to fulfil the criteria of reversibility of the storage. Above-

ground facilities have to comply with the requirements of Directive 1996/82/EC (Seveso Directive,

see chapter 5).

Option 6l: Pre-treatment of mercury

Option 6 differs from the other options as it does not investigate the storage or disposal of metallic

mercury but investigates the available solidification possibilities for liquid mercury.

This option includes several sub-options using various pre-treatment technologies. In chapter 7

techniques currently under development or already available have been introduced. By means of a

screening analysis, the most promising pre-treatment technologies will be selected for further

investigation. Relevant sub-options will then be defined.

After pre-treatment of the mercury a suitable permanent storage option has to be identified for the

stabilised mercury. Further temporary storage following pre-treatment does not provide the

required adequate solution therefore, after pre-treatment only permanent storage options are

considered further.

Option 1s: Permanent storage of pre-treated mercury in salt mines

This option covers the permanent storage of pre-treated mercury in salt mines. It must be

determined which minimum requirements salt mines have to fulfil for a safe permanent storage of

pre-treated mercury. In addition, the criteria (e.g. leaching rate) which pre-treated mercury has to

fulfil to be accepted for permanent storage in underground salt mines, will be examined.

Option 3s: Permanent storage of pre-treated mercury in deep underground hard rock formations

Option 3s investigates the permanent storage of pre-treated metallic mercury in deep underground

hard rock formations. The minimum requirements which hard rock formations have to fulfil for safe

permanent storage of pre-treated mercury, will be examined. In addition, the criteria (e.g. leaching

rate) which pre-treated mercury has to fulfil to be accepted for permanent storage in underground

hard rock formations, will be examined.



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Option 7s: Permanent storage of pre-treated mercury in above-ground facilities

Regulation (EC) N° 1102/2008 prescribes the temporary or permanent storage options for metallic

mercury only. Following pre-treatment (stabilisation / solidification), mercury is no longer metallic

(liquid). Therefore, permanent above-ground storage of the resulting product (stabilised/solidified

mercury) might also be an option. Consequently, option 7s is introduced as permanent storage above

ground.



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4 Review of the hazardous characteristics of metallic mercury

Mercury is particularly related to specific risks due to its persistent, bio-accumulative and toxic

characteristics. This section is dedicated to providing a brief review of metallic mercury's hazardous

properties in view of defining appropriate acceptance criteria for its temporary and long term

disposal.

The brief overview of the hazardous characteristics is to a large extent based on information that has

been generated by Environment Canada ([Env Canada 2004]12], the information is available at the

web site “Mercury and the Environment”), [WHO 2003] and [UNEP 2009]. Additional information

used within this section is specifically cited.

4.1 Specific properties of liquid mercury related to storage

4.1.1 Occurrence of mercury

In nature, mercury has three possible oxidation states. “Elemental” or “metallic” mercury (Hg0) has

no electric charge. Mercury is also found in two positively charged, or cationic, states, Hg2+ (mercuric)

and Hg1+ (mercurous). The mercuric cation is more stable and is generally associated with inorganic

molecules, such as sulphur (in the mineral cinnabar), chlorine (mercuric chloride), oxygen and

hydroxyl ions. Hg2+ and Hg1+ are also found in organic (carbon based) substances such as

dimethylmercury (Me2Hg)13 or methylmercury (MeHg)14 which are far more toxic than inorganic

forms of mercury and bioaccumulate in the tissues of living organisms. Since mercury can be

adsorbed easily into small particles of matter, some scientists use the notation Hg(p) to represent

elemental mercury attached to or absorbed onto a particle.

Mercury is a persistent chemical and once released to the environment, it will stay there in one of its

forms. It is converted into its various forms through a range of abiotic and biogeochemical

transformations and during atmospheric transportation.

The most common natural occurrence of mercury is cinnabar (HgS), with large deposits in Spain

(Almadén) and Slovenia (Idrija).

4.1.2 Basic physico-chemical properties

The list of physico-chemical parameters in Annex 4 is mainly restricted to those parameters that

enable an assessment of the mobilisation and transport mechanisms of the relevant substances.

12 http://www.ec.gc.ca/MERCURY/EH/EN/eh-i.cfm 13 Structural formula: (CH3)2Hg 14 Structural formula: CH3Hg

http://www.ec.gc.ca/MERCURY/EH/EN/eh-i.cfm



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With regard to mobilisation and transport from stored substances, these parameters were selected

in order to assess possible risks of releases.

Relevant substances are elemental mercury and all mercury compounds that will potentially be

stored (temporarily or permanently). Organic mercury compounds (e.g. methyl mercury) will not be

stored or disposed of. However, it should be noted once again that mercury compounds that are

released can be easily transformed under environmental conditions into organic compounds and

may cause severe environmental and health risks.

Mercury is a naturally occurring element. Its atomic number is 80, its atomic mass is 200.59 grams

per mole and its specific density is 13.534 g/cm3 at 25°C. Mercury has a melting point of -38.9°C and

a boiling point of 357°C. It is the only metal to remain in liquid form at room temperature. Droplets

of liquid mercury are shiny and silver-white with a high surface tension, appearing rounded when on

flat surfaces. The liquid is highly mobile and droplets combine easily due to low viscosity. The metal is

a fair conductor of electricity, but a poor conductor of heat. Under high pressure (1.2 GPa, 12,000

bar) and at room temperature, mercury becomes solid [Funtikov 2009], [Mercury 65GPa 1993].

According to a report from the Fraunhofer Institut Bauphysik (building construction physics)

[Fraunhofer 273], at a pressure of 200 bar, mercury is capable of penetrating into micropores with a

radius of 3.7 nm.

Solubility ([g/l], [g/kg], [mol/l] or [mol/kg])

Solubility is the quantity of a particular substance that can dissolve in a particular solvent (yielding a

saturated solution). It is a measure indicating how easily a substance may dissolve and mobilise from

a stored material and is transported via a water pathway.

The solubility of elemental mercury in naturally occurring water depends on various parameters such

as the composition of the solution or pH. The solubility of metallic mercury in distilled water is

indicated in literature with ~0.3µmol/L (~60µg/l) at 25°C [Hagelberg 2006]. In [USEPA 2007], the

solubility of mercury in water is indicated as 0.28µmol/l (56µg/l) at 25°C.

In 2006 a study was published which investigated the solubility of elemental mercury in three

different liquid matrices (L1: 1 mmolL-1 NaCl and 1 mmol NaHCO3, L2: as L1 with 1.8 mmol conc.

H2SO4 and L3: leachate of crunched concrete) and at three different mercury/solution ratios

[Hagelberg 2006]. Due to the very small number of repetitions with equal parameters, lack of

equilibrium conditions, improper equipment materials (PTFE tubes instead of glass), among some

other inconsistencies, the test results are only of limited value.

In comparison to elemental mercury the solubility of mercury compounds is very different:



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Table 4-1: Solubility of Hg and Hg compounds in water

Mercury compound Solubility of Hg in water Hg Hg = 1.6*10-4 mmol/l (2.9 *10-5 g/l) [GRS 2008] HgS HgS = 7*10-21 mmol/l (1.40*10-27 g/l) [SPC 2009] HgO HgO = 8.9mmol/l (1.5 g/l) [GRS 2008A] HgCl2 HgCl2 = 6,000mmol/l (1,200 g/l) [GRS 2008A]

While pure mercury sulphide has a significantly lower solubility compared to elemental mercury, the

presence of HgO or HgCl2 – which might be due to impurities (< 1%) in mercury sulphide – increases

the solubility of HgS.

In 2003 a laboratory study was conducted [Sakar 2003] to investigate the solubility of mercury in the

presence of amphoteric oxides of iron, an electron acceptor. Investigations were performed with and

without chloride in solution, a rather ubiquitous component of mercury wastes. Mercury solubility

decreased in the presence of iron oxides, suggesting adsorption of mercury ions at the oxide-water

interface. There was indirect evidence of formation of ionic mercury due to oxidation of elemental

mercury in the presence of free iron in solution. Mercury solubility generally increased in the

presence of chloride in solution because of the formation of weakly adsorbing mercury-chloro

complexes.

Information related to the influence of salt and salt solutions to solubility of mercury is very limited.

In the presentation [GRS 2008A], first results have been presented on solubility of mercury at

different concentrations of NaCl and KCl. It can be seen that the solubility of mercury in pure water is

0.3 µmol/l, whereas in a saturated NaCl (~6mol/l) solution the solubility is reduced to 0.16 µmol/l.

This relationship is nearly linear but flattens with increasing NaCl concentrations. In the case of KCl,

fewer solubility values are available (5 different concentrations) at lower concentration levels (< 1

mol/l), but it can be predicted that the Hg solubility in KCl solutions is similar to that in NaCl

solutions. Some salts have a reverse effect on the solubility of mercury. NaSCN and (CH3)4NBr for

example are salts which increase the solubility of mercury with increasing salt concentration.

The solubility of pure mercury in salt solutions is illustrated in the diagram below.



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Figure 4-1: Relative solubility of elemental mercury in different salt water concentrations (NaCl and KCl) [GRS 2008A]

These data coincide with the results of other studies such as “Effects of salts on the solubility of

elemental mercury in water” [Sanemasa 1981] and “The solubility of elemental mercury vapor in

water” [Sanemasa 1975]. The main result of the studies is that there is a linear decrease – at least

until a 1 molar solution is reached – of the solubility of mercury in saturated potassium or sodium

solutions. The solubility is significantly lower (half) compared to distilled water. Tests have also been

made to demonstrate the temperature dependency of mercury vapour in pure water and sea water.

It can be seen that the solubility increases exponentially with the temperature starting with

0.1 µmol/l (19.2 µg/l) at 5°C and up to 9 µmol/l (1,800 µg/l) at 100°C. The solubility in sea water is

about 20% less than that in pure water [Sanemasa 1975].

Solubility product ((mol/l)n)

With the mean value of the solubility product (Ksp), it is possible to determine the dissolved

concentration of a solid’s constituents in solution assuming it has reached equilibrium. The solubility

product constant is the simplified equilibrium constant (Ksp) defined for equilibrium between a solid

and its respective ions in a solution. Its value indicates the degree to which a compound dissociates

in water. The higher the solubility product constant, the more soluble is the compound.

As elemental mercury only consists of one element, the solubility product is not relevant. But in the

case of pre-treatment to immobilize or solidify mercury, the solubility product of the resulting solid

form is important. The solubility products of relevant pre-treated mercury compounds (e.g. HgS) are

included in Annex 4.



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Leachability (mg/l or mg/kg)

Leachability is a specific measure to assess how a pollutant that is contained in a stored material

contributes to possible groundwater contamination if water seeps into and through the stored

material. It indicates to what extent the mercury compounds are mobilised in the waste matrix and

transported out of the stored material. The leachability of waste is often used for the classification of

a waste. Depending on the leaching behaviour, the waste is allocated to different landfill categories

(WAC Decision 2003/33/EC).

The leachability is of particular interest for pre-treated (solidified) mercury. It is linked to the

conditions of the pre-treatment process and the stability and homogeneity of the solidified mercury

thus attained. Therefore general statements are not possible. Product-specific leaching values are

included in Annex 4.

Volatility (mg/kg) or vapour pressure (Pa)

Volatility is a measure indicating how easily a substance may be evaporated and mobilised from a

stored material and transported via an atmospheric pathway.

Mercury has a relatively high vapour pressure of 0.3 Pa at 25°C [WHO 2003] and the highest volatility

of any metal. The vapour pressure increases with temperature. The vapour is colour- and odourless

and due to its high molar mass heavier than air and therefore mercury concentration is higher at

ground level.

Reactivity of mercury with other substances

Reactivity indicates under which conditions the stored substance may react and be transformed to

other substances that may be more easily mobilised and/or transported.

Mercury can be elemental, monovalent or bivalent. Monovalent bonds are always bimolecular: Hg2X2

and bivalent bonds are always monomolecular: HgX2. Mercury has a positive redox potential which

makes it noble and therefore does not tend to oxidise. [Ho Wi 1995]

A reaction with oxygen takes place above ~300°C in air and decomposes again at 400 °C. Pure

mercury does not interact with ambient air but in the case of contaminated mercury an oxide layer is

formed on the surface of the mercury [Ho Wi 1995]. Formation of HgO should be avoided due to its

higher solubility compared to elemental mercury. [GRS 2008A]

Mercury can react with halogens and more easily with sulphur but not with phosphorus, nitrate,

hydrogen or carbon. [Ho Wi 1995]

Reaction with chlorine can result in Hg2Cl2 (low water solubility) or in HgCl2 (very high water

solubility). The formation of HgCl2 should be avoided due to its very high water solubility. In general it

can be stated that Hg(I) molecules are more stable and therefore less soluble than Hg(II) molecules.

Both kinds of chlorides can be generated by sublimation. [Ho Wi 1995]



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Mercury has a very high affinity to sulphur resulting in very stable mercury(II)sulphide (HgS). This is

the reason why natural sources of mercury are mostly HgS (cinnabar) reservoirs.

Elemental mercury cannot be attacked by dilute HCl or H2SO4 solutions, and then only slowly in the

case of dilute HNO3. [Ho Wi 1995]

Mercury combines with other metals such as copper, gold, zinc, aluminium, nickel, tin, silver or

selenium and forms mercury alloys known as amalgams. Amalgams are semi-solid solutions obtained

by dissolution of mercury in the solid metal [Mersade 2007A]. Mercury destroys the passivation layer

of aluminium which normally protects aluminium from oxidation. Blank aluminium can be oxidised

again and the corrosion process is ongoing. Therefore, aluminium is not a suitable material for the

storage of mercury. [Aluminium 2004]

Iron on the other hand does not dissolve in elemental mercury and can therefore be used as

container material. [Ho Wi 1995]

Elemental mercury does not react with glass or ceramic products. An interaction of elemental

mercury with certain plastic material is possible. [Hagelberg 2006] reported an adsorption of

elemental mercury at plastic tubes.

Within the scope of the Life project MERSADE (see chapter 6.4.1.1) a literature review has been

carried out concerning corrosion problems in mercury [Mersade 2007A]. It was concluded that

literature referring to corrosion problems on metal containment used for the storage of liquid

mercury is practically nil.

In the following, the main findings of the review are described (the information is based on

[MERSADE 2007A]):

According to the document, at low temperature and static conditions, liquid metal corrosion is not an

important factor. Therefore, steel and ceramic materials are appropriate for the storage of liquid

mercury.

Plain carbon steel is virtually unattached by mercury under non flowing conditions or isothermal

conditions. Working temperatures up to 540°C are possible. The addition of Titanium (10 ppm) might

increase the operating temperatures up to 650°C, but in this case elements with a higher affinity for

oxygen than titanium, such as Na or Mg, are required to prevent oxidation of the titanium and loss of

its inhibitive action.

On the contrary, the presence of either a temperature gradient or liquid flow might lead to a drastic

attack of the containment. It is stated that the solubility of metals (e.g. iron, nickel) in mercury

increases with temperature.



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Table 4-2: Change of solubility (in ppm) against the temperature [Mersade 2007A]

260°C 538°C

Iron 0.001 0.4

Nickel 7.0 80.0

Chromium 0,02 8.2

As a consequence, low solubility of metals in mercury results in a low corrosion rate. Although the

addition of elements such as chromium, titanium, silicon and molybdenum, alone or in combination,

show high resistance up to 600°C, other alloying elements might have a contrary effect. For example,

Nickel tends to have adverse effects on iron-based and cobalt-based alloys as it tends to form

intermetallic compounds with mercury, lead and bismuth.

In addition, experiences related to the use of liquid mercury as a target for a proton beam in a

Spallation Neutron Source (SNS) facility have been included in the report. Tests have been carried out

with various alloys, flow rates and temperatures. Due to contradicting results in the corrosion

investigations, an extrapolation to static or different dynamic conditions, other temperatures or a

long-term mercury storage condition is not recommended.

Within the scope of the Mersade project, practical investigation also took place. Storage containers

and pipe systems which have been in use for several years for the storage of liquid mercury at the

storage facility at Almadén were analysed for potential attack by the stored mercury [Muñoz, 2009].

Another important information source related to potential corrosive effects of metallic mercury with

containers are the investigations carried out by the Oak Ridge National Laboratory (ORNL), USA. The

ORNL analysed storage containers which have been used for almost 40 years for the storage of

metallic mercury.

Detailed information on the outcome and conclusions of both projects are included in sections

6.4.3.1 and 6.4.3.2.

Adsorption of mercury

Ionic forms of mercury are strongly adsorbed by soils and sediments and are desorbed slowly. Clay

minerals optimally adsorb mercury ions at pH 6. Iron oxides also adsorb mercury ions in neutral soils.

Most mercury ions are adsorbed by organic matter (mainly fulvic and humic acids) in acidic soils.

When organic matter is not present, mercury becomes relatively more mobile in acid soils and can

evaporate to the atmosphere or leach to groundwater (Ref. 1.5). [US EPA 2007]

Octanol/water partition coefficient (Kow)

The octanol/water partition coefficient is a measure to indicate the hydrophobicity of a substance. It

can give an indication of how easily a compound might be taken up in groundwater to pollute

waterways. In the field of hydrogeology it is used to predict and model the migration of dissolved



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hydrophobic organic compounds in soil and groundwater. Several studies have been carried out

concerning the 1-Octanol/Water partition coefficient of mercury.

The 1-octanol/water partition coefficient of metallic mercury was measured as a useful parameter

for predicting the environmental behaviour and fate of mercury. The partition coefficient obtained

was 4.15 ± 0.20 at 298 K [Okouchi 1985] and is indirectly proportional to the temperature, having a

value of 3.80 at 35°C. Mercury is therefore a lipophile element, which has a higher solubility in

octanol instead of water. The coefficient depends on the temperature and it decreases with an

increase in temperature. The partition coefficient of metallic mercury is very low in comparison to

non-polar organic compounds such as benzene, tetrachloromethane or PCBs. Therefore, it was

concluded that metallic mercury has a tendency for further concentration in the atmosphere.

[OKOUCHI 1985]

4.1.3 Toxic effects

The severity of mercury's toxic effects depends on the form and concentration of mercury and the

route of exposure.

Exposure to elemental mercury can result in effects on the nervous system, including tremors,

memory loss and headaches. Other symptoms include bronchitis, weight loss, fatigue, gastro-

intestinal problems, gingivitis, excitability, thyroid enlargement, unstable pulse, and toxicity to the

kidneys.

Adverse effects to human health from exposure to elemental mercury are summarised in the draft

technical guidelines on the environmentally sound management of mercury wastes (see [UNEP

2009], section 1.3.2).

Exposure to inorganic mercury can affect the kidneys, causing immune-mediated kidney toxicity.

Effects may also include tremors, loss of co-ordination, slower physical and mental responses, gastric

pain, vomiting, bloody diarrhoea and gingivitis.

Adverse effects to human health from exposure to inorganic mercury compounds are summarised in

the draft technical guidelines on the environmentally sound management of mercury wastes (see

[UNEP 2009], section 1.3.3).

Symptoms of methylmercury toxicity, also known as Minamata disease, range from tingling of the

skin, numbness, lack of muscle coordination, tremors, tunnel vision, loss of hearing, slurred speech,

skin rashes, abnormal behaviour (such as fits of laughter), intellectual impairment, to cerebral palsy,

coma and death, depending on the level of exposure. In addition, methylmercury has been classified

as a possible human carcinogen by the U.S. Environmental Protection Agency. More recently,

additional findings have described adverse cardiovascular and immune system effects at very low

exposure levels.

Prenatal exposure to organic mercury, even at levels that do not appear to affect the mother, may



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depress the development of the central nervous system and may cause psychomotor retardation for

affected children. Mild neurological and developmental delays may occur in infants ingesting

methylmercury in breast milk. Affected children may exhibit reduced coordination and growth, lower

intelligence, poor hearing and verbal development, cerebral palsy and behavioural problems.

Adverse effects to human health from exposure to inorganic mercury compounds are summarised in

the draft technical guidelines on the environmentally sound management of mercury wastes (see

[UNEP 2009], section 1.3.1).

4.1.4 Classification

The classification of mercury (EC 231-106-7; CAS 7439-97-6) according to Directive 67/548/EEC15 is as

follows:

Table 4-3: Risk phrases and classification of mercury

Classification Risk phrases

Repr. Cat. 2; R61 R61: May cause harm to the unborn child.

T+; R26 R26: Very toxic by inhalation.

T; R48/23 R48/23: Toxic: danger of serious damage to health by prolonged exposure through inhalation.

N; R50-53. R50/53: Very toxic to aquatic organisms, may cause long-term adverse effects in the aquatic environment.

The preliminary classification of mercury according to Regulation (EC) N° 1272/200816 is as follows:

Table 4-4: Hazard class, category codes and hazard statement codes of mercury

Hazard Class and Category Code(s)

Hazard statement Code(s)

Acute Tox. 3 * H331: Toxic if inhaled

STOT RE 2 * H373: May cause damage to organs through prolonged or repeated exposure

Aquatic Acute 1 H400: Very toxic to aquatic life

Aquatic Chronic 1 H410: Very toxic to aquatic life with long lasting effects

15 Council Directive 67/548/EEC of 27 June 1967 on the approximation of laws, regulations and administrative

provisions relating to the classification, packaging and labelling of dangerous substances, OJ 196, 16.8.1967 16 Regulation (EC) No 1272/2008 of the European Parliament and of the Council of 16 December 2008 on

classification, labelling and packaging of substances and mixtures, amending and repealing Directives 67/548/EEC and 1999/45/EC, and amending Regulation (EC) No 1907/2006 (Text with EEA relevance), OJ L 353, 31.12.2008, p. 1–1355



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4.1.5 Occupational exposure limit values

Acute exposure (>0.1 mg⋅mercury/m3) to mercury vapour causes adverse effects to human health

[UNEP 2009].

Therefore, many EU Member States implemented occupational exposure limit (OEL, eight hour

average) values for “mercury and its inorganic divalent compounds (as Hg)” ranging from 0.03 mg/m³

in Lithuania, Sweden, Slovakia to 0.1 mg/m³ in Germany [EU OSHA 2007, GESTIS 2009, TRGS 900].

Currently, Poland is the only country with an OEL (eight hour average) for metallic vapour of mercury

with a value of 0.025 mg/m³ [GESTIS 2009].

On the European level no corresponding indicative value is available but [SCOEL 2007] recommended

an 8-hour TWA of 0.02 mg mercury/m³ for “elemental mercury and inorganic divalent mercury

compounds”. A biological limit value (BLV) of 10 µg Hg/l blood and 30 µg Hg/g creatinine in urine is

also recommended by [SCOEL 2007].

The UNEP recommended health-based exposure limit value for metallic mercury is 0.025 mg⋅Hg/m³

for long-term exposure as the time weighted average (TWA). This means the time weighted average

concentration for a normal 8-hour day and 40-hour workweek, to which nearly all workers can be

repeatedly exposed without adverse effect [UNEP 2009]. However, recent studies suggest that

mercury may have no threshold below which adverse effects do not occur [UNEP 2009].

In the USA 0.1 mg/m3 is also declared as the ceiling limit value for mercury vapour (concentration

cannot exceed this value at any time) [OSHA 2009]. Threshold limit values (TLV) are available for

elemental mercury being 0.025 mg/m³ and 0.01 mg/m3 for organic mercury [US EP 2007]. Referring

to [NIOSH 2005] the Time Weighted Average (TWA) for an 8-hour day should not exceed 0.05 mg/m3.

4.2 Hazardous properties related to the environment

4.2.1 Transformation and transport of mercury

Natural transformations and environmental pathways of mercury are very complex and are greatly

affected by local conditions. The environmental fate and the impacts of anthropogenic mercury

emissions depend on a range of biogeochemical interactions affecting mercury in its various physical

states and chemical forms.

There are two main types of reactions in the mercury cycle that convert mercury through its various

forms: oxidation-reduction and methylation-demethylation. In oxidation-reduction reactions,

mercury is either oxidized to a higher valence state (e.g. from relatively inert Hg0 to the more

reactive Hg2+) or reduced (e.g. from Hg2+ to Hg0).

Most relevant environmental pathways are short or long range atmospheric transport mechanisms



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and transport in water/sediment systems (e.g. river or marine systems).

In general, the form of mercury in the environment varies with the season, with changes in organic

matter, nutrient and oxygen levels and hydrological interactions within an ecosystem. In addition,

the quantity and forms of mercury are, to a large extent, a function of emission sources and

transportation processes. All of these variables in turn affect the global mercury budget.

Mercury oxidation

The oxidation of elemental mercury (Hg0) in the atmosphere is an important mechanism involved in

the deposition of mercury on land and water. Hg0 can volatilize relatively easily and be emitted into

the atmosphere, where it may be transported on wind currents for a year or more and be re-

deposited in the environment for further cycling. In contrast, Hg2+ has an atmospheric residence time

of less than two weeks due to its solubility in water, low volatility and reactive properties. Hence,

when (Hg0) is converted to Hg2+, it can be rapidly taken up in rain water, snow, or adsorbed onto

small particles, and be subsequently deposited in the environment through "wet" or "dry" deposition

[Selin 2009].

In the Arctic, the conversion of Hg0 to Hg2+ in the atmosphere occurs very rapidly in a phenomenon

known as "mercury depletion" at the end of dark polar winters. When the sun rises in the spring,

atmospheric Hg0 is converted photochemically to Hg2+ in the presence of reactive chemicals released

from sea salt (for example, bromine and chlorine ions) and mercury levels in the atmosphere are

"depleted" as the Hg2+ is then deposited on snow and ice surfaces. As a consequence, a pulse of

reactive mercury enters the Arctic environment when the short lived growing season is beginning. It

remains a research question as to what fraction of this reactive mercury is converted to toxic

methylmercury and taken up by animals and plants.

Mercury Methylation

In an aquatic environment under suitable conditions, mercury is bioconverted to methylmercury, by

a chemical process called Methylation [Wood 1974].

In the Methylation process, mercury is transformed into methylmercury when the oxidized, or

mercuric species (Hg2+), gains a methyl group (CH3). The methylation of Hg2+ is primarily a biological

process resulting in the production of highly toxic and bioaccumulative methylmercury compounds

(MeHg+) that build up in living tissue and increase in concentration up the food chain, from micro-

organisms like plankton, to small fish, then to fish eating-species such as otters and loons, and

humans.

The formation of methylmercury is critically important due to its highly toxic, bioaccumulative and

persistent nature. A variety of micro-organisms, particularly methanogenic (methane producing) and

sulphate-dependant bacteria are thought to be involved in the conversion of Hg2+ to MeHg under

anaerobic (oxygen poor) conditions found, for example, in wetlands and river sediments, as well as in

certain soils. Methylation occurs primarily in aquatic, low pH (acidic) environments with high

concentrations of organic matter.



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Rates of bio-methylation are a function of environmental variables affecting mercuric ion availability

as well as the population sizes of methylating microbes. Alkalinity, or pH, plays a strong role in

regulating the process because it is affected by, and in turn affects, the adsorption of various forms

of mercury on soil, clay and organic matter particles, thus influencing mercuric ion availability. Acid

rain may increase biomethylation as more MeHg is formed under acidic conditions. [Env Canada

2004].

In several reports it is stated that bioavailability of mercury for methylation is increased in the

presence of neutral dissolved Hg complexes HgS0(aq) [Benoit 1999], [Drott 2007]. It is also described

that high dissolved sulphide concentration favour the creation of disulfide complexes, primarily

HgHS2-, which reduces the bioavailability of mercury for methylation. [Hammerschmidt 2008]

[Benoit 1999]. Tests showed that not dissolved Hg or mercury sulphide gave no significant

relationship with the specific methylation rate constant. [Drott 2007] [Benoit 2001].

Some substances have been identified to have an inhibiting effect on the methylation process as iron

sulphides. This is probably due to the decrease of neutral Hg(II)-sulphide complexes via formation of

charged Hg(II)polysulfides [[Liu 2009].

However, sulphate may stimulate growth of certain methylating microbes. Organic matter can

stimulate microbial populations, reduce oxygen levels, and therefore increase bio-methylation. Bio-

methylation increases in warmer temperatures when biological productivity is high, and decreases

during the winter.

Atmospheric long range transport

Mercury in the atmosphere is broadly divided into gas form and particulate form. Most of the

mercury in the general atmosphere is in gas form (95% or more). Gaseous mercury includes mercury

vapour, inorganic compounds (chlorides and oxides), and alkyl mercury (primarily methylmercury

[JPHA 2001].

The volatility of elemental mercury (Hg0) enables mercury to travel in a multi-step sequence of

emission to the atmosphere, transportation, deposition and re-emission. As a result, mercury from

point source emissions may remain localized in the environment, or may be transported regionally

and even globally.

Atmospheric transport is likely the primary mechanism by which Hg0 is distributed throughout the

environment, unlike many pollutants that follow erosion or leaching pathways. Mercury can enter

the atmosphere as a gas or bound to other airborne particles and circulates until removal. Removal

occurs primarily through the "wet" deposition of Hg2+ in rainfall, however it can also occur in the

presence of snow, fog, or through direct, or "dry", deposition.

Approximately 98% of the estimated 5000 tonnes of mercury in the atmosphere is Hg0 vapour,

emitted from human activities, contaminated soils and water, as well as natural sources [Env Canada

2004]. This gas is readily transported and has a mean atmospheric residence time of about one year

to one and a half years [Selin 2009]. The transformation of insoluble Hg0 to its more reactive and



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water-soluble form, Hg2+, is thought to provide the mechanism for the deposition of Hg0 emissions to

land and water. Hg0 oxidation may also be affected by concentrations of other atmospheric

pollutants such as ozone, sulphur dioxide and soot. Additional research is needed in order to predict

corresponding mercury deposition rates.

Mercury Deposition

Following release to the atmosphere and depending on its physical/chemical form, mercury can be

either deposited in the vicinity of the emission source, or subjected to long-range atmospheric

transport via air masses. Because the uptake of Hg0 in cloud water is relatively slow, this process may

be responsible for the deposition of mercury far from its source and may be important when

considering global mercury pollution. Gaseous Hg+2 and particulate mercury (Hg(p), mercury

adsorbed onto other particulate matter) emissions generally undergo direct wet or dry deposition to

the earth's surface locally. These species have relatively short residence times in the atmosphere

ranging from hours to months. Gaseous Hg+2 has a residence time of 5 to 14 days in the atmosphere,

and may travel tens to hundreds of kilometres. Particulate forms of mercury (Hg(p)) tend to fall out

closer to the source of emissions, with larger particles falling out faster than smaller ones. The site-

specific deposition of mercury is variable, and is affected by conditions such as meteorology,

temperature and humidity, solar radiation and emission characteristics (speciation, source, stack

height, etc.).

Atmospheric Circulation

Atmospheric circulation processes may play an important role in determining where airborne

mercury is eventually deposited. Mercury, like other semi-volatile compounds such as PCBs, is

thought to participate in a global distillation phenomenon that transfers chemical emissions from

equatorial, subtropical and temperate regions to the polar regions via the "grasshopper effect".

When this phenomenon takes place, an emitted compound re-enters the atmosphere by volatilizing

after initial deposition, and continues over time to "hop" through the environment in the direction of

the prevailing winds, favouring accumulation in the colder regions of the planet. During the summer

months, major air currents in the northern hemisphere lead to the Arctic, and once there, a

contaminant can no longer gain enough heat energy for another "hop" out of the Arctic. The net

result is a concentration of contaminants in the Arctic at odds with the relative sparsity of emissions

sources in the region.

Other pathways (other than atmospheric long range transport)

In addition to atmospheric pathways, mercury can be transported through river systems in their

sediment loads, or in aqueous solution. The transport distance may be long or short. Where mercury

is carried on particles, the distance is limited by sedimentation. Transport of contaminants via

particles tends to halt at riverine lakes or reservoirs since heavy sedimentation can occur there.

Transport also occurs along ocean currents.

Transport of mercury underground depends particularly on the pH conditions in the hydrogeological

and geochemical conditions. Deep groundwater is generally neutral to alkaline, under which



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conditions Hg tends to be immobilised due to adsorption to mineral surfaces. Deep environments

tend to be reducing, under which conditions mercury tends to be immobilised due to precipitation as

sulphur compounds. The adsorption of mercury compounds is positively correlated with the cation

exchange capacity of the geo-environment. The mercury is adsorbed by certain clays (e.g. naturally

occurring clays or montmorillonite/bentonite). [Heath 2006]

The oceans are considered the ultimate sink for mercury because Hg2+ deposited from the

atmosphere can settle to oceanic depths where it is reduced and precipitates as insoluble mercuric

sulphide. It is thought that approximately one third of the total current mercury emissions cycle

between the oceans and the atmosphere, and that 20 to 30% of oceanic emissions, are re-emitted

from prior anthropogenic sources.

4.2.2 Overview of the behaviour in the environment

Mercury is a persistent, mobile and bioaccumulative element in the environment and is retained in

organisms. Mercury in the aquatic environment is changed to various forms, mainly methylmercury,

methylated from mercury. As a consequence mercury permanently exists in the environment and its

chemical form availability to living organism change over time depending on the environmental

conditions.

Figure 4-2 shows the main chemical reactions and pathways of mercury in the atmosphere, water,

soil, and in sediments and the effect of bioaccumulation.



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Figure 4-2: Diagram of the biogeochemical mercury cycle

Figure 4-2 illustrates the main chemical reactions and pathways of mercury in the atmosphere,

water, soil, and in sediments. Pathways include leaching and runoff, emission from natural and

anthropogenic sources, volatilization, deposition from the atmosphere, and sedimentation-

resuspension. Methylation-demethylation, oxidation-reduction, and complexation are the chemical

reactions shown. The diagram also illustrates bioaccumulation of mercury in a fish food chain.

(Source: Env Canada 2004)

4.2.3 Environmental limit values related to mercury

Water

Within the European Community, Directive 2008/105/EC17 on environmental quality standards in the

field of water policy establishes Environmental Quality Standards (EQS) for mercury and its

compounds.

17 Directive 2008/105/EC on environmental quality standards in the field of water policy, amending and subsequently, repealing Council Directives 82/176/EEC, 83/513/EEC, 84/156/EEC, 84/491/EEC, 86/280/EEC and amending Directive 2000/60/EC of the European Parliament and of the Council, 16 December 2008 (OJ L 348, 24.12.2008, p. 84–97)



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Table 4-5: Environmental Quality Standards (EQS) set for mercury in Directive 2008/105/EC

AA-EQS Inland surface waters (3)

AA-EQS Other surface waters

MAC-EQS Inland surface waters (3)

MAC-EQS Other surface waters

Mercury and its compounds

0.05 (9) 0.05 (9) 0.07 0.07

AA: annual average; MAC: maximum allowable concentration, Unit: [μg/l] In addition, in article 3(2)(a) an EQS for biota is set for mercury and its compounds of 20 µg/kg based

on prey tissue (wet weight), choosing the most appropriate indicator from fish, molluscs, crustaceans

and other biota. In cases where Member States do not apply the EQS for biota they shall introduce

stricter EQS for water in order to achieve the same level of protection.

On the international level [WHO 2004] is proposing a limit value of 1 μg/litre for total mercury in

water.

Air

Within the European Community no common limit value for mercury concentration is set. Directive

2004/107/EC18 establishing target values for the concentration of arsenic, cadmium, mercury, nickel

and polycyclic aromatic hydrocarbons in ambient air does not introduce specific target values for

mercury, while for the other substances such targets are introduced (Annex I of the Directive).

On the international level, the WHO prescribes an air quality guideline value of 1 μg Hg0/m3 as an

annual average concentration and 0.2 μg/m3 for long-term inhalation exposure to elemental mercury

vapour [WHO 2007]. [UNEP 2009] also describes exposure levels (RELs) for Hg0 established for the

general non-occupational population, based on US American and Canadian limits:

• 0.3 μg/m3 from the US EPA (chronic reference air concentration)

• 0.2 μg/m3 from the US Agency for Toxic Substances and Disease Registry (minimal risk level

for chronic inhalation exposure)

• 0.09 μg/m3 from the California Environmental Protection Agency (inhalation reference

exposure)

• 0.06 μg/m3 from Health Canada (chronic tolerable air concentration)

18 Directive 2004/107/EC of the European Parliament and of the Council of 15 December 2004 relating to

arsenic, cadmium, mercury, nickel and polycyclic aromatic hydrocarbons in ambient air, 16. December 2008 (OJ L 23, 26.1.2005, p. 3–16)



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4.3 Conclusions

Mercury is a persistent, mobile and bioaccumulative element in the environment and is retained in

organisms [Env Canada 2004].

In particular the methylation - transformation of mercury compounds to the highly toxic form

methylmecury – has to be taken into consideration for the storage of liquid mercury but also for

mercury compounds. Methylation occurs primarily in aquatic, low pH environments with high

concentration of organic matter but also other parameters might influence the formation of

methylmecury [Env Canada 2004], [Wood 1974]. Therefore in case of the storage of mercury a

special focus should be laid on the potential formation of methylmercury.

Metallic mercury has specific properties which have to be taken into consideration for the

assessment of possible storage options. In particular its high vapour pressure and its liquid state at

room temperature might entail problems in handling and long term storage.

Information on leaching values for mercury and mercury compounds are available in literature and

are summarized in Annex 4.

Although information is available related to the solubility of mercury and mercury compounds in

water [Hagelberg 2006], [USEPA 2007], information to the influence of salt and salt solutions to

solubility of mercury is still very limited. Results from available investigations ([GRS 2008A],

[Sanemasa 1981]) give first indications of a decreased solubility of mercury in salt solutions. But

further research is required to verify these results [GRS 2008A].

Information on the reactivity of mercury with other substances is described in chemical literature [Ho

Wi 1995]. With reference to the corrosiveness of mercury with possible container material only very

limited literature has been found [Mersade 2007A]. Most important information is available from

two projects carried out by ONRL (Oak Ridge National Laboratory), USA and within the Life Project

MERSADE19 (detailed results see 6.4.3).

Acute exposure to mercury vapour causes adverse effects to human health. Therefore occupational

exposure limit values are established in many countries [EU OSAH 2007], [GESTIS 2009]. On European

level a limit value of 0.02 mg Hg/m³ (TWA, 8 h) for elemental mercury and inorganic divalent mercury

compounds is recommended by [SCOEL 2007]. Environmental limit values are available on EU level

for water20. On international level also air quality guideline values are established [WHO 2007].

19 LIFE is the EU’s financial instrument supporting environmental and nature conservation projects throughout

the EU, as well as in some candidate, acceding and neighbouring countries, for further information see http://ec.europa.eu/environment/life/

20 Directive 2008/105/EC

http://ec.europa.eu/environment/life/



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4.4 References

[Aluminium 2004] Corrosion of Aluminium, Christian Vargel, ISBN: 0 08 044495 4, 2004 [ATSDR 1999] U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES, Public Health Service, Agency for Toxic Substances and Disease Registry, TOXICOLOGICAL PROFILE FOR MERCURY, 1999; http://www.atsdr.cdc.gov/toxfaqs/TF.asp?id=115&tid=24 [Benoit 1999] Benoit, J.M., Mason, R.P., Gilmour, C.C., Estimation of mercury-sulfide speciation in sediment pore waters using octanol-water partitioning and implications for availability to methylating bacteria, Environmental Toxicology and Chemistry, Vol. 18, No. 10, pp. 2138-2141, 1999 http://www.serc.si.edu/labs/microbial/pubs/Benoit%20et%20al%20ET&C%201999.pdf [Benoit 2001] Benoit, J.M., Gilmour, C.C., Mason, R.P., The influence of sulphide on solid-phase mercury bioavailability for methylation by pure cultures of Desulfobulbus propionicus, (2001), Environmental Science and Technology, 35 (1), pp. 127-132, 2001 [CCOHS 1998] Canadian Centre for Occupational Health & Safety, Chemical profile mercury, preparation date 1998, copyright 2007 http://www.ccohs.ca/oshanswers/chemicals/chem_profiles/mercury/ [Drott 2007] Drott, a., Lambertsson, L., Björn, E., Skyllberg, U., Importance of dissolved neutral mercury sulfides for methyl mercury production in contaminated sediments, Environmental Science and Technology, 41 (7), pp. 2270-2276, 2007 [Env Canada 2004] Environment Canada, Mercury and the environment, Internet document: http://www.ec.gc.ca/MERCURY/EH/EN/eh-i.cfm, last update 2004-02-04, accessed on 29 June 2009 [EU OSHA 2007] Exploratory Survey of Occupational Exposure Limits for Carcinogens, Mutagens and Reprotoxic substances at EU Member States Level, European Agency for Safety and Health at Work, European Risk Observatory Report http://osha.europa.eu/en/publications/reports/548OELs [Euro Chlor 2009] Euro Chlor, Metallic mercury (Hg0) The biological effects of long-time, low to moderate exposures, Science dossier 13, February 2009 [Fraunhofer 273] M. Krus, H.M. Künzel, Das Wasseraufnahmeverhalten von Betonbaustoffen, IBP-Mitteilung 273, Fraunhofer Institut für Bauphysik http://www.ibp.fraunhofer.de/HT/pub/ibpmitt/ibp273.pdf

http://www.atsdr.cdc.gov/toxfaqs/TF.asp?id=115&tid=24

http://www.serc.si.edu/labs/microbial/pubs/Benoit et al ET&C 1999.pdf

http://www.ccohs.ca/oshanswers/chemicals/chem_profiles/mercury/

http://www.ec.gc.ca/MERCURY/EH/EN/eh-i.cfm

http://osha.europa.eu/en/publications/reports/548OELs

http://www.ibp.fraunhofer.de/HT/pub/ibpmitt/ibp273.pdf



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[Funtikov 2009] High Temperature 2009, Vol. 47, No. 2, pp201-205, A. I. FUTNIKOV, Shock Adiabat, Phase Diagram, and Viscosity of Mercury at a Pressure up to 50 GPa. [Gestis 2009] http://www.dguv.de/bgia/de/gestis/stoffdb/index.jsp# [GRS 2008A] Gesellschaft für Anlagen- und Reaktorsicherheit (GRS) mbH, Solubility of metallic mercury and mercury compounds in saline solutions, presentation by Horst-Jürgen Herbert and Sven Hagemann GRS, Braunschweig, 2008, Germany [Hagelberg 2006] Hagelberg, Erik, Örebro University, Institutionen för naturvetenskap, Department of Natural Sciences, The matrix dependent solubility and speciation of mercury, 2006, http://oru.diva-portal.org/smash/record.jsf?pid=diva2:137047 [Hammerschmidt 2008] Hammerschmidt Chad R., Fitzgerald William F., Balcom Prentiss H., Visscher Pieter T., Organic matter and sulfide inhibit methylmercury production in sediments of New York/New Jersey Habor, Marine Chemistry 109 (2008) 165-182 [Heath 2006] Mike Heath, Health environmental and safety questions related to the underground storage/disposal of mercury over time, Presentation at the EEB Conference on EU Mercury surplus management and mercury-use restrictions in measuring and control equipment, Brussels, 19 June 2006; http://www.zeromercury.org/EU_developments/HEATH-storage.pdf [Ho Wi 1995] Lehrbuch der Anorganischen Chemie 101. Auflage Hollemann Wiberg, 1995 [JPHA 2001] Japan Public Health Association: Preventive Measures against Environmental Mercury Pollution and Its Health Effects, Japan, 2001 http://www.chem.unep.ch/Mercury/2003-gov-sub/Japan-complete-report.pdf [Liu 2009] Liu, J., Valsaraj, K.T., Delaune, “Inhibition of mercury methylation by iron sulfides in an anoxic sediment”, Environmental Engineering Science, 26 (4), pp. 833-840, 2009 [Mercury 65GPa] Rapid communication, Physical Review B, Volume 48, Number 18, 14009-14012, 1 November 1993-II, Olaf Schulte and Wilfried B. Holzapfel, Phase Diagram for mercury up to 65 GPa and 500 K [OKOUCHI 1985] Okouchi S., Sasaki, S., The 1-octanol/water partition coefficient of mercury, Bulletin of the Chemical Society of Japan, Vol.58 , No.11(1985)pp.3401-3402, http://www.journalarchive.jst.go.jp/jnlpdf.php?cdjournal=bcsj1926&cdvol=58&noissue=11&startpage=3401&lang=en&from=jnlabstract

http://www.dguv.de/bgia/de/gestis/stoffdb/index.jsp

http://oru.diva-portal.org/smash/record.jsf?pid=diva2:137047


http://www.zeromercury.org/EU_developments/HEATH-storage.pdf

http://www.chem.unep.ch/Mercury/2003-gov-sub/Japan-complete-report.pdf


http://www.journalarchive.jst.go.jp/jnlpdf.php?cdjournal=bcsj1926&cdvol=58&noissue=11&startpage=3401&lang=en&from=jnlabstract




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[Sakar 2003] Sarkar, Dibyendu, Preliminary studies on mercury solubility in the presence of iron oxide phases using static headspace analysis, Environmental Geosciences; December 2003; v. 10; no. 4; p. 151-155; DOI: 10.1306/eg.08220303015 http://eg.geoscienceworld.org/cgi/content/abstract/10/4/151 [Sanemasa 1975] Isao Sanemasa, The solubility of elemental mercury vapor in water, Bulletin of the chemical society of Japan, Vol 48(6), 1975 http://www.journalarchive.jst.go.jp/jnlpdf.php?cdjournal=bcsj1926&cdvol=48&noissue=6&startpage=1795&lang=en&from=jnlabstract [Sanemasa 1981] Isao Sanemasa, Effects of salts on the solubility of elemental mercury vapor in water, Bulletin of the chemical society of Japan, Vol 54(4), 1981 http://www.journalarchive.jst.go.jp/jnlpdf.php?cdjournal=bcsj1926&cdvol=54&noissue=4&startpage=1040&lang=en&from=jnlabstract [SCOEL 2007] SCOEL, Recommendation from the Scientific Committee on Occupational Exposure Limits for elemental mercury and inorganic divalent mercury compounds“, SCOEL/SUM/84, May 2007, http://ec.europa.eu/social/BlobServlet?docId=3852&langId=en [Selin 2009] Selin, Noelle E., Global Biogeochemical Cycling of Mercury: A Review, Department of Earth, Atmospheric, and Planetary Sciences, Massachusetts Institute of Technology, Cambridge, Massachusetts 02139-4307; Annu. Rev. Environ. Resour. 2009. 34:43–63, DOI 10.1146/annurev.environ.051308.084314 http://globalchange.mit.edu/files/document/MITJPSPGC_Reprint_09-15.pdf [SPC 2009] http://www.ktf-split.hr/periodni/en/abc/kpt.html [TRGS 900] Technische Regeln für Gefahrstoffe. Arbeitsplatzgrenzwerte. Ausgabe: Januar 2006, zuletzt geändert und ergänzt: GMBl Nr. 28 S. 605 (v. 2.7.2009), http://www.baua.de/nn_16806/de/Themen-von-A-Z/Gefahrstoffe/TRGS/pdf/TRGS-900.pdf [UNEP 2002] UNEP, Global mercury assessment, 2002, http://www.chem.unep.ch/mercury/Report/Final%20Assessment%20report.htm [UNEP 2009] UNEP, Draft technical guidelines on the environmentally sound management of mercury wastes, 4th Draft, April 2009, http://www.basel.int/techmatters/mercury/guidelines/040409.doc [USEPA 2007] U.S. Environmental Protection Agency, Treatment Technologies For Mercury in Soil, Waste, and Water, EPA-542-R-07-003, 2007, 2007 http://www.epa.gov/tio/download/remed/542r07003.pdf

http://eg.geoscienceworld.org/cgi/content/abstract/10/4/151





http://ec.europa.eu/social/BlobServlet?docId=3852&langId=en

http://globalchange.mit.edu/files/document/MITJPSPGC_Reprint_09-15.pdf

http://www.ktf-split.hr/periodni/en/abc/kpt.html

http://www.baua.de/nn_16806/de/Themen-von-A-Z/Gefahrstoffe/TRGS/pdf/TRGS-900.pdf


http://www.chem.unep.ch/mercury/Report/Final Assessment report.htm

http://www.epa.gov/tio/download/remed/542r07003.pdf



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[WHO 2004] Guidelines for Drinking-water quality 3rd edition. Geneva, World Health Organization, http://www.who.int/water_sanitation_health/dwq/fulltext.pdf [WHO 2005] World Health Organisation, Mercury in Drinking-water, Background document for development of WHO Guidelines for Drinking-water Quality, 2005, http://www.who.int/water_sanitation_health/dwq/chemicals/mercuryfinal.pdf [WHO 2006] World Health Organisation, Guidelines for drinking-water quality incorporating first addendum. Vol. 1, Recommendations. – 3rd ed.Electronic version for the Web, 2006, http://www.who.int/water_sanitation_health/dwq/gdwq3rev/en/ [WHO 2007] World Health Organisation, Preventing disease through healthy environments exposure to mercury, A major public health concerns, Geneve 2007, http://www.who.int/phe/news/Mercury-flyer.pdf [Wood 1974] Wood, J.M.: Biological Cycles for Toxic Elements in the Environment, Science, 15, 1043-1048, 1974 [ZERO Hg 2006] Zero Mercury working group, EU Mercury Surplus Management and Mercury-Use Restrictions in Measuring and Control Equipment, Report from the EEB Conference, October 2006, http://www.zeromercury.org/EU_developments/0606_EEB_Mercury_Conference_ReportFINAL.pdf

http://www.who.int/water_sanitation_health/dwq/fulltext.pdf

http://www.who.int/phe/news/Mercury-flyer.pdf

http://www.zeromercury.org/EU_developments/0606_EEB_Mercury_Conference_ReportFINAL.pdf



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5 Review of legislation, policy and best practice

5.1 International agreements

UNEP

The United Nations Environment Programme established the UNEP Mercury Programme with the

aim of delivering activities on mercury and to support negotiations of an international instrument for

the control of mercury (for more information about the UNEP Mercury Programme, see chapter 5.5

[UNEP 2009B].

In order to strengthen the UNEP Mercury Programme, a series of Governing Council (GC) Decisions

have been established since 2001:

• GC Decision 21/5 Mercury assessment (2001),

• GC Decision 22/4 V Chemicals; Mercury Programme (2003),

• GC Decision 23/9 IV Chemicals management; Mercury Programme (2005),

• GC Decision 24/3 IV Chemicals management; Mercury (2007),

• GC Decision 25/5 III Chemicals management, including mercury; Mercury (2009).

Decision GC 21/5 from 2001 focused on the assessment of available information and the provision of

a summary description of existing scientific and technical information, needs and data gaps referring

to information like the global nature and anthropogenic source of mercury, the long-range transport,

pathways and deposition, source of releases and production patterns of mercury as well as

prevention and control technologies and practice.

As regards mercury waste, one aim of the Decision GC 21/5 was to describe ongoing actions and to

compile information about future plans at national, sub-regional and regional levels for controlling

releases and limiting use and exposures, including waste management practice.

Decision GC 22/4 from 2003 announced the Mercury Programme and promoted first actions to

reduce the risks of mercury. It proposed again the improvement of the scientific basis on mercury

and mercury components. The decision requested to enhance risk communication on mercury, to

reduce anthropogenic releases and the demand for and the uses of mercury, to identify subsidisation

of mercury mining and to cooperate with other international organisations.

With regard to mercury waste, the decision proposed a reduction of releases from waste streams

and to improve collection and exchange of information on disposal.

GC Decision 23/9 from 2005 included the management on other chemicals, in particular lead and

http://www.chem.unep.ch/mercury/mandate-2001.htm



http://www.chem.unep.ch/mercury/Decision 24-3.pdf



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cadmium. The decision concentrated on the cooperation between UNEP and other multilateral

environmental organisations and agreements. With regard to mercury, it repeated the requests of

the previous decision promoting national, regional and global actions, both immediate and long-

term, to reduce and eliminate the use of mercury. It firstly included specific provisions on processes

(the chlor-alkali process) and products containing mercury (batteries containing mercury) to be

phased out.

With regard to mercury waste, the decision promoted more precisely the development of

environmentally sound disposal and remediation practices.

GC Decision 24/3 firstly established a strategic approach to international chemicals management in

2007. The reduction in mercury supply was identified as a global priority. The aim was to establish a

legally binding instrument on mercury at international level.

With regard to mercury waste, the decision urged governments to gather information on the options

and solutions for the management of waste containing mercury and mercury components as well as

for the long-term storage of mercury instead of allowing this mercury to be sold on the global

marketplace. In consequence, the ‘Draft technical guidelines on the environmentally sound

management of mercury wastes’ were prepared in 2007 [UNEP 2007] containing information on:

• the application for mercury waste prevention and minimisation;

• guidance on environmentally sound management (EMS) criteria and practice of mercury

waste;

• the chemical analysis of mercury in waste;

• treatment of mercury waste and recovery of mercury; long-term storage and disposal of

mercury waste.

In February 2009, the UNEP Governing Council Decision 25/5 considered further work required on

mercury, and agreed to a number of activities, in particular:

• the elaboration of a legally binding instrument on mercury, including provisions to be

considered by the intergovernmental negotiating committee;

• a study on various types of mercury emitting sources;

• interim activities to reduce risks to human health and the environment; an update of the

2008 report on Global Atmospheric Mercury Assessment; Sources, Emissions and Transport.

The reduction of the supply of mercury and the enhancement of capacity for its environmentally

sound storage is set out as a further priority. Furthermore, the ‘Draft technical guidelines on the

environmentally sound management of mercury wastes’ was further elaborated [UNEP 2009].



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Basel Convention

The Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their

Disposal is the most comprehensive global environmental agreement on hazardous and other

wastes. The Secretariat of the Basel Convention is administered by UNEP. The Convention came into

force in 1992 and has 172 Parties. It aims at the protection of human health and the environment

against the adverse effects resulting from the generation, management, transboundary movements

and disposal of hazardous and other wastes by stipulating that any transboundary movement of

wastes (export, import, transit) is permitted only when the movement itself and the disposal of the

wastes are environmentally sound [Basel 2010].

The parties of the Basel Convention have the right to prohibit the import of hazardous wastes or

other wastes for disposal. In this case they have to inform the other Parties of their decision (Article 4

of the Basel Convention). Article 4 (2) contains the major general provisions for the Parties of the

Basel Convention including the obligation to take appropriate measures to:

• Reduce the generation of hazardous and other wastes

• Ensure the availability of adequate disposal facilities

• Prevent pollution while handling and managing the waste

• Reduce transboundary movements to a minimum

• Not allow export of wastes to countries where the import of the waste is prohibited

• Ensure that information about the transboundary movement is provided to other states

• Prevent the import of waste if environmental sound management cannot be assured

• Co-operate

Mercury and mercury compounds are included as entry Y29 in Annex I, which lists hazardous wastes

that shall be controlled. In case of transboundary movements of such wastes a notification document

is required which has to be forwarded to the competent authorities of the involved countries (Art. 6

of the Basel Convention).

Additionally mercury containing wastes are listed in Annex VIII of the Basel convention as A1010

(metal wastes and wastes consisting of different alloys, amongst mercury) and A1030 (waste having

as constitutes or contaminants mercury and mercury compounds).

Also in other entries wastes are listed which may contain mercury, in particular A 1180 (mercury-

switches), A1170 (batteries), A 2030 (waste catalysts), A2060 (fly-ashes), A3170 (wastes from

production of aliphatic halogenated hydrocarbons), A4010 (wastes from production of

pharmaceutical products), A4020 (clinical wastes), A4080 (explosive wastes) and A 4160 (spent

activated carbon) [UNEP 2009].



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The Basel Convention not only aims at a controlled transboundary movement but also at the

environmentally sound disposal of the wastes. Disposal means any operation specified in Annex IV to

the Basel Convention (Article 2 (4) of the Basel Convention). Annex IV includes the whole list of

operations which do not lead to the possibility of resource recovery, recycling, reclamation, direct re-

use or alternative uses (D operations, as similar listed in the Waste Framework Directive) and

operations which may lead to such that possibility (R operations, as similar listed in the Waste

Framework Directive) . However environmental sound management (ESM) is only generally

described within Article 2 (8) of the Basel Convention as “taking all practicable steps to ensure that

hazardous wastes or other wastes are managed in a manner which will protect human health and the

environment against the adverse effects which may result from such wastes”.

CLRTAP

Since 1979 the Convention on Long-range Transboundary Air Pollution (CLRTAP) has addressed major

environmental problems of the UNECE21 region through scientific collaboration and policy

negotiation. The aim of the Convention is to limit and, as far as possible, gradually reduce and

prevent air pollution including long-range transboundary air pollution. Parties develop policies and

strategies to combat the discharge of air pollutants through exchanges of information, consultation,

research and monitoring.

The Convention has been extended by eight protocols that identify specific measures to be taken by

Parties to cut their emissions of air pollutants, amongst them the Protocol on Heavy Metals22 which

was adopted by the Executive Body (EB) on 24 June 1998 entering into force in 2003. It targets the

three particularly harmful metals cadmium, lead and mercury. One of the main obligations is the

reduction of emissions from these metals by aiming at the cut of emissions from industrial sources

(iron and steel industry, non-ferrous metal industry), combustion processes (power generation, road

transport) and waste incineration. Therefore, it lays down stringent limit values for emissions from

stationary sources and suggests best available techniques (BAT) for these sources, such as special

filters or scrubbers for combustion sources or mercury-free processes. The Protocol also requires

Parties to phase out leaded petrol and reduce emissions from other products (e.g. mercury in

batteries, electrical components (thermostats, switches), measuring devices (thermometers,

manometers, barometers), fluorescent lamps, dental amalgam, pesticides and paint.

Each party shall reduce its total annual emissions into the atmosphere for mercury to the level of the

emissions in the reference year 1990, or an alternative year from 1985 to 1995.

21 United Nations Economic Commission for Europe with currently 56 Member States from the European

continent 22 The 1998 Protocol on Heavy Metals to the 1979 Convention on long-range transboundary air pollution, 24

June 1998 in Aarhus (Denmark)

http://www.unece.org/env/lrtap/ExecutiveBody/welcome.html

http://www.unece.org/env/lrtap/status/lrtap_s.htm



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5.2 European legislation

Elemental mercury

At present, mercury is not seen as waste on the European Community level, but considered as raw

material. Excess mercury from the decommissioning of chlor-alkali plants as well as liquid mercury

gained from e.g. recycling processes of products is sold to mercury dealing companies (e.g. Mayasa)

and re-sold as raw material for various applications. Large amounts are also exported to non-EU

countries. Therefore specific requirements related to the disposal of liquid mercury have not been

needed so far.

The situation changed with the publication of Regulation (EC) No 1102/200823 on the banning of

exports and the safe storage of metallic mercury. Safe storage options for metallic mercury are

needed for the near future within the Community as the ban starts from 15 March 2011 and affects

metallic mercury, cinnabar ore, mercury (I) chloride, mercury (II) oxide and mixtures of metallic

mercury with other substances including alloys of mercury, with a concentration of at least 95 wt %

Hg (recital 5 of Regulation (EC) No 1102/2008).

In order to provide possibilities for a safe storage of the above-mentioned metallic mercury waste

within the Community, Article 3 of Regulation (EC) No 1102/2008 constitutes suitable options, both

for permanent and temporary storage in appropriate containments:

• temporary storage for more than one year or permanent storage in salt mines adapted for

the disposal of metallic mercury,

• temporary storage for more than one year or permanent storage in deep underground, hard

rock formations providing a level of safety and confinement equivalent to that of those salt

mines,

• temporary storage for more than one year in above-ground facilities dedicated to and

equipped for the temporary storage of metallic mercury.

For this purpose Article 5 (3)(a) of Directive 1999/3124 shall be derogated. In addition, Article 4 of

Regulation (EC) No 1102/2008 stipulates that the safety assessment which is required for a safe

underground storage under Decision 2003/33/EC25 should be complemented by specific

requirements resulting from the specific risk of the storage of metallic mercury. Furthermore,

acceptance criteria should be developed for metallic mercury either temporarily or permanently 23 Regulation (EC) No 1102/2008 of the European Parliament and of the Council of 22 October 2008 on the banning of exports of metallic mercury and certain mercury compounds and mixtures and the safe storage of metallic mercury (OJ L304 of 14/11/08, p.75-79), also referred to as the ‘Mercury Regulation‘. 24 Council Directive 1999/31/EC of 26 April 1999 on the landfill of waste (OJ L 182, 16.7.1999, p. 1–19), also

referred to as the ‘Landfill Directive‘. 25 Council Decision of 19 December 2002 establishing criteria and procedures for the acceptance of waste at

landfills pursuant to Article 16 of and Annex II to Directive 1999/31/EC (OJ L 11, 16.1.2003, p. 27–49), also referred to as the ‘WAC Decision‘.



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stored in appropriate underground or above-ground facilities.

So far no waste code exists for elemental mercury on the European level.

With regard to transport of liquid mercury, the containers and transport operations have to fulfil the

specific requirements set for the different types of transports inter alia stated in the European

Agreement Concerning the International Carriage of Dangerous Goods by Road (ADR), Regulations

concerning the Transport of Dangerous Goods by Rail (RID), International Maritime Organisation

(IMO) or International Air Transport Association (IATA).

“Waste containing mercury”

For waste containing mercury (not liquid), requirements concerning disposal exist at the European as

well as at Member State levels. Directive 1999/31/EC together with Decision 2003/33/EC in particular

lay down which requirements storage facilities (landfills) in general have to fulfil and which

acceptance criteria in particular have to be fulfilled for a certain type of landfill. This includes

technical standards, acceptance procedures, limit values, monitoring and control activities.

More stringent protective measures at Member States level are possible.

Several waste codes for waste containing mercury exist, depending on its source of origin listed in

the European Waste Catalogue with the following EWC numbers:

• 05 07 01* wastes containing mercury from natural gas purification,

• 06 04 04* wastes containing mercury from inorganic chemical processes,

• 06 07 03* barium sulphate sludge containing mercury,

• 10 14 01* waste from gas cleaning containing mercury,

• 16 01 08* components containing mercury,

• 16 06 03* mercury-containing batteries,

• 17 09 01* construction and demolition wastes containing mercury,

• 20 01 21* fluorescent tubes and other mercury-containing waste.

Apart from the specifically addressed mercury-containing waste other types of waste may also

contain mercury or mercury compounds such as waste types specified as ‘containing heavy metals’

or ‘containing hazardous substances’ (Directive 2000/532/EC26 ).

26 Commission Decision of 3 May 2000 replaces Decision 94/3/EC establishing a list of wastes pursuant to

Article 1(a) of Council Directive 75/442/EEC on waste and Council Decision 94/904/EC establishing a list of hazardous waste pursuant to Article 1(4) of Council Directive 91/689/EEC on hazardous waste (notified under document number C(2000) 1147) (OJ L 226, 6.9.2000, p. 3–24).



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Apart from Regulation (EC) N° 1102/2008, the following legal documents at the European level have

to be considered for evaluating the storage requirements of metallic mercury and mercury

containing waste as they are referred to in Regulation (EC) N° 1102/2008:

• Directive 2006/12/EC27 and Directive 2008/98/EC28 (‘Waste Framework Directives’)

• Directive 1999/31/EC (‘Landfill Directive‘),

• Decision 2003/33/EC (‘WAC Decision’),

• Directive 1996/82/EC 29 (‘Seveso II Directive’),

• Regulation (EC) N° 1013/2006 30 (‘Waste Shipment Regulation’),

• Directive 2004/35/CE 31 (‘Environmental Liability Directive’).

Directive 85/337/EEC32 (‘Environmental Impact Assessment Directive’) was also taken into account,

though not mentioned in the Mercury Regulation, as certain storage facilities need to comply with

this Directive.

These documents are evaluated in the following chapter with regard to possible storage facilities for

metallic mercury and mercury containing waste including above ground and underground facilities

such as salt mines and deep underground hard rock formation.

The evaluation focuses on the extraction of requirements for the various storage types laid down in

the above-mentioned legislation. However, issues such as transport and handling of mercury and

mercury waste will also be tackled within the following chapters.

Further national legislation have been screened for additional requirements for mercury disposal and

disposal of hazardous waste e.g. in underground facilities.

27 Directive 2006/12/EC of the European Parliament and of the Council of 5 April 2006 on waste (OJ L 114,

27.4.2006, p. 9–21), also referred as ‘Waste Framework Directive‘. 28 Directive 2008/98/EC of the European Parliament and of the Council of 19 November 2008 on waste

and repealing certain Directives(OJ L 312, 22.11.2008, p. 3–29), also referred as ‘new Waste Framework Directive‘.

29 Council Directive 96/82/EC of 9 December 1996 on the control of major-accident hazards involving dangerous substances (OJ L 10, 14.1.1997, p. 13–33) as amended by Directive 2003/105/EC; also referred to as the ‘Seveso II Directive’.

30 Regulation No 1013/2006 of the European Parliament and of the Council of 14 June 2006 on shipments of waste (OJ L 190, 12.07.2006, p.1-98), also referred to as the ‘Waste Shipment Regulation‘.

31 Directive 2004/35/CE of the European Parliament and of the Council of 21 April 2004 on environmental liability with regard to the prevention and remedying of environmental damage (OJ L 143, 30.4.2004, p. 56–75), also referred to as ‘Environmental Liability Directive’.

32 Council Directive 85/337/EEC of 27 June 1985 on the assessment of the effects of certain public and private projects on the environment (OJ L 175, 5.7.1985, p. 40–48) with last amendment from 25 June 2003 , also referred as ‘Environmental Impact Assessment Directive‘.



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5.2.1 Legal requirements for all storage facilities

Regulation (EC) N° 1102/2008 (‘Mercury Regulation’)

The Mercury Regulation sets specific requirements for the disposal of metallic mercury. In general,

the provisions from the Landfill Directive and the WAC Decision are applicable with few exemptions

for specific types of landfills. The requirements listed in Table 5-1are applicable for all types of

mercury disposal facilities, while some specifications are made for above-ground facilities and for

storage in salt-mines and deep underground hard rock formations (see chapters 5.2.2 to 5.2.5).

Table 5-1: Requirements for all types of mercury storage facilities according to Directive N° EC 1102/2008

Requirements for all types of mercury storage facilities according to Regulation EC N°1102/2008

Requirement / source Specification

Objective

[Regulation 1102/2008, Recital 6]

• Safe storage should be ensured

Provisions

[Regulation 1102/2008, Recital 8 and Article 3(1)]

• All provisions of Directive 1999/31/EC shall apply; except Article 5(3)(a) (= not accepting liquid waste at landfills)

• Assuring financial security (provision in Article 8(a)(iv) of Landfill Directive) including period of closure and after care

• Directive 2004/35/CE on environmental liability applies to mercury storage facilities

Containment

[Regulation 1102/2008, Article 3 (1)]

• Storage of metallic mercury in appropriate containment

Safety assessment

[Regulation 1102/2008, Article 4(1)]

• Safety assessment for all mercury storage facilities • Covering particular risks of metallic mercury and its containment

arising from natural and long-term properties

Visual inspection

[Regulation 1102/2008, Article 4(2)]

• Permit for storage according to Landfill Directive shall include requirements for regular visual inspections of the containers,

• Installation of appropriate vapour detection equipment to detect leak

Directive 2006/12/EC and Directive 2008/98/EC (‘Waste Framework Directives’)

The new Waste Framework Directive (Directive 2008/98/EC), which has to transposed into national

law by the Member States by 12 December 2010 is repealing the old Waste Framework Directive

(Directive 2006/12/EC) and incorporating and repealing the Hazardous Waste Directive33 and the

Waste Oil Directive34.

33 Council Directive 91/689/EEC of 12 December 1991 on hazardous waste (OJ L 337, 31.12.1991, 20–27)

with last amendment from 19 November 2008, also referred as ‘Hazardous Waste Directive‘.

34 Council Directive 75/439/689/EEC of 16 June 1975 on the disposal of waste oils (OJ L 194, 25.7.1975, p. 23–25) as ‘Waste Oil Directive‘.



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The new Framework Directive requires more stringent waste reduction and waste prevention efforts.

Member States must ensure that waste is recovered or disposed of without endangering human

health and the environment and that the waste amount disposed of is reduced to a minimum by kind

of measures and effective tools to minimise waste generation.

Amongst other issues, the new WFD provides a further clarification and differentiation of the waste

hierarchy, modifies definitions as regards e.g. the end-of-waste status, by-products and classification

of treatment operations and changes requirements for the preparation of waste management plans.

The Directive emphasizes new waste management targets, encourages waste reduction and gives a

new dimension to prevention as Member States are obliged to draw up and implement waste

prevention programmes not later than 2013.

Also the producer responsibility is extended in order to strengthen the re-use, prevention as well as

recycling and other recovery of waste. The New Waste Framework Directive also sets new recycling

targets which have to be achieved by 2020. In addition, the Directive sets out more stringent

provisions for authorisation and registration.

With the new Waste Framework Directive, the Hazardous Waste Directive is repealed with effect

from 12 December 2010. No reference in Mercury Regulation is therefore made to the Hazardous

Waste Directive. However some parts of the Hazardous Waste Directive were incorporated into

Directive 2008/98/EC, especially Annex III, describing properties of waste (which are classified as

hazardous). Annexes I (describing categories or generic types of waste which are classified as

hazardous) and Annex II (listing constitutes of waste which are classified as hazardous) are not

incorporated in the new Waste Framework Directive.

Directive 1999/31/EC (‘Landfill Directive’)

The Landfill Directive defines the relevant terms (e.g. waste, treatment options, and technical terms),

sets the scope and the landfill classes, specifies the waste and treatment options acceptable and not

acceptable at different landfill classes and explains the requirements for a permit, waste acceptance

and the control and monitoring as well as the closure and after-care procedures.

The focus of this report is only on the provisions being of relevance for the issue of mercury storage

and the deviation of specific criteria for mercury storage.

According to Directive 1999/31/EC, ‘landfill’ means a waste disposal site for the deposit of waste

onto or into land (i.e. underground), including […] a permanent site (i.e. more than one year) which is

used for temporary storage of waste (Article 2 (g)) but excluding

• Facilities where waste is unloaded in order to permit its preparation for further transport for

recovery, treatment or disposal elsewhere, and

• Storage of waste prior to recovery or treatment for a period of less than three years as a

general rule, or



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• Storage of waste prior to disposal for a period of less than one year.

According to Article 7 of Directive 1999/31/EC a landfill needs a permit, which contains information

about the identity of the applicant and the operator, the description of the types and total quantity

of waste, the proposed capacity, a description of the site, the proposed methods for pollution

prevention and control and the proposed plan for the closure and after-care procedures.

Furthermore an impact assessment following Council Directive 85/337/EEC might be required and

has to be added to the permit.

The provisions that all types of landfill have to fulfil are set out in Annex I of Directive 1999/31/EC

and summarised in Table 5-2.

Table 5-2: General requirements for all classes of landfills according to Directive 1999/31/EC, Annex I

Requirements for all classes of landfills according to Directive 1999/31/EC, Annex I


Location

[Directive 1999/31/EC,

Annex I, section 1]

Location of landfill must take into consideration requirements related to:

• Distance to residential and recreational areas, waterways, water bodies,

agricultural and urban sites

• Existence of groundwater, coastal water or nature protection zones

• Geological and hydrological conditions

• Risk of flooding, subsidence, landslides or avalanches

• Protection of nature or cultural patrimony

Landfill can only be authorised if requirements or measures indicate, that they do

not pose a serious risk.

Water and leachate

management


Annex I, section 2]

Measures (possible exceptions for inert landfills):

• Control water from precipitations entering into the landfill

• Prevent surface water and/or groundwater from entering

• Collect contaminated water and leachate (exception possible)

• Treat contaminated water and leachate

Protection of soil and

water


Annex I, section 3]

Measures (possible exceptions for inert landfills):

• Landfill must be situated to prevent pollution to soil, groundwater, surface

water and to ensure efficient collection of leachate

• Combination of geological barrier and bottom liner during passive phase/post-

closure

• Combination of geological barrier and top liner during operational/active

phase

• Geological barrier determined by geological and hydro-geological conditions

below and in the vicinity of a landfill providing sufficient attenuation capacity

to prevent a potential risk



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Requirements for all classes of landfills according to Directive 1999/31/EC, Annex I


• Landfill base and sites consist of mineral layer (specified for each class;

artificial layer possible)

• Leachate collection and sealing system including artificial sealing liner and

drainage layer (exception possible for inert waste)

• Surface sealing layer dependent on landfill class

Gas control


Annex I, section 4]

• Control the accumulation and migration of landfill gas

• Collection and treatment of landfill gas (for landfills receiving biodegradable

waste)

Nuisances and hazards


Annex I, section 6]

Measures to minimise nuisance and hazards through emissions of odours and

dust; wind-blown materials; noise and traffic; birds, vermin and insects;

formation of aerosols; fires

Stability


Annex I, section 6]

• Stability of the mass of waste and associated structures; avoid slippages

• Where artificial barrier, geological substratum stable to prevent settlement

that causes damage to barrier

Barriers


Annex I, section 7]

• Secured to prevent free access

• Gates shall be closed outside operating hours

• System to detect and discourage illegal dumping

Annex II of Directive 1999/31/EC prescribes general waste acceptance criteria proposing the

following three-level hierarchy [Directive 1999/31/EC, Annex II, section 3]:

• Basic characterisation (each type of waste, exemption for waste types where impractical)

o determination according to standardised analysis and behaviour-testing methods,

o short and long-term leaching behaviour,

o characteristic properties of the waste.

• Compliance testing (at regular intervals, at least once a year)

o periodical testing by simpler standardised analysis and behaviour-testing methods,

o determine whether a waste complies with permit conditions and/or specific

reference criteria,

o focus on key variables and behaviour identified by basic characterisation.

• On-site verification (each load of waste)



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o rapid test methods to confirm that each shipment/load of waste is the same as in the

basic characterisation and described in accompanying documents,

o visual inspection of each load of waste before and after unloading at the landfill site.

The acceptance procedures shall as far as possible be based on standardised waste analysing

methods. Furthermore, they shall respect corresponding limit values for the properties of waste to

be accepted. Therefore, Member States shall establish a national list of waste to be accepted or

refused at each class of landfills. These lists shall be used to establish site specific lists [Directive

1999/31/EC, Annex II, section 2].

The general waste acceptance procedure is concretised by Decision 2003/33/EC, Annex including

information on the function of each level of testing, the fundamental requirements, the testing

methods and the limit values to be fulfilled.

A first guideline to define what kind of waste should be accepted at each landfill class is given in the

Landfill Directive [Directive 1999/31/EC, Annex II, section 4], summarised as follows:

Table 5-3: Control and monitoring procedures for all classes of landfills according to Directive 1999/31/EC, Annex III

Preliminary criteria for waste acceptance according to Directive 1999/31/EC, Annex II

Landfill class Waste to be generally accepted

Inert waste landfills

• Only inert waste as defined in Article 2(e) accepted

(=not undergoing significant physical, chemical or biological transformations, not

dissolving, burning, physically or chemically reacting, biodegrading, adversely

affecting, no rise in environmental pollution or harm to human health,

leachability and ecotoxicity of leachate insignificant)

Non-hazardous waste

landfills • Only waste type not covered by Directive 91/689/EEC35

Hazardous waste landfills • Covered by Directive 91/689/EEC (preliminary list)

• Prior treatment required if contents or leachability is high enough to

constitute short term occupational and environmental risk

Additionally, the acceptance of waste at each landfill type depends on the leaching properties of the

waste. Leaching limit values are defined for each class of landfills in the Annex of the WAC Decision

(see description below).

Wastes which contain mercury and mercury compounds are defined as hazardous waste as they are

listed in entry C16 in Annex II of the Hazardous Waste Directive (when they fulfil the properties

described in Annex III of the same Directive). The Hazardous Waste Directive will be incorporated 35 Council Directive 91/689/EEC of 12 December 1991 on hazardous waste (OJ L 337, 31.12.1991, p. 20) with

last amendment from 19 November 2008, also referred as ‘Hazardous Waste Directive’



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and repealed by the new Waste Framework Directive (Directive 2008/98/EC) by 12 December 2010.

The new Waste Framework Directive does not adopt the list of constitutes of the wastes. However, it

adopts also in its Annex III the list of properties of waste which render it hazardous. In consequence

following the new Waste Framework Directive wastes containing mercury and mercury compounds

are defined as hazardous if fulfilling the properties listed in Annex III of Directive 2008/98/EC.

In case of stable and non-reactive waste provision 2.3 of the Annex of Decision 2003/33/EC allows

the disposal of hazardous wastes in landfills for non-hazardous waste if such wastes have been

rendered stable and non-reactive. Stable, non-reactive means that the leaching behaviour of the

waste will not change adversely in the long-term, under landfill design conditions or foreseeable

accidents (Provision 2.3 of Annex of Decision 2003/33/EC):

• In the waste alone (for example, by biodegradation),

• Under the impact of long-term ambient conditions (for example, water, air, temperature,

mechanical constraints),

• By the impact of other wastes (including waste products such as leachate and gas).

Annex III of the Landfill Directive lays down control and monitoring procedures during operation as

well as for the after-care phase of a landfill. The purpose of these procedures is to check that:

• the waste has been accepted to disposal in accordance with the criteria set for the category

of landfill in question,

• the processes within the landfill proceed as desired,

• the environmental protection systems are functioning fully as intended,

• the permit conditions for the landfill are fulfilled [Annex III, point 1 of Directive 1999/31/EC].

The control and monitoring programmes have to cover the following areas:

Table 5-4: Control and monitoring procedures for all classes of landfills according to Directive 1999/31/EC, Annex III

Control and monitoring procedures for all classes of landfills according to Directive 1999/31/EC, Annex III


Meteorological data


Annex III, section 2]

• MS decide how to collect data (in situ, national, etc.)

• If required for evaluating leachate behaviour data of precipitation,

temperature, wind, evaporation and atmospheric humidity data have to be

collected according to given schedule

Emission data



Data on water, leachate and gas control including:

• collection of leachate and surface water if present (volume and composition)

at representative points according to guidelines



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Control and monitoring procedures for all classes of landfills according to Directive 1999/31/EC, Annex III


• collection of surface water down- and up-stream

• gas monitoring representative for each section of landfill according to given

frequency and analysis and according to permit

Protection of

groundwater



• Sampling at measuring points for groundwater at inflow and outflow region

according to Sampling Guideline

• Monitoring based on parameters according to local conditions and level of

groundwater according to given schedule

• Determination of trigger level for change of groundwater composition in

permit

Topography



Data according to given schedule on:

• structure and composition of landfill

• setting behaviour of the landfill body

Decision 2003/33/EC (‘WAC Decision’)

Decision 2003/33/EC lays down specific requirements which have to be fulfilled by storage facilities

(landfills). Furthermore, the decision determines waste acceptance criteria for each type of waste to

be accepted at a certain type of landfill. More stringent protective measures at Member States level

are possible. This could be of particular relevance with reference to the limit values for cadmium and

mercury (see introduction to Annex of Decision 2003/33/EC).

The WAC Decision specifies in its Annex the procedure for waste acceptance at landfills as laid down

in Annex II, section 3 of the Landfill Directive. The procedures are generally applicable for all types of

landfills.

The following procedures are specified:

Table 5-5: Procedures for the acceptance of waste according to Decision 2003/33/EC, Annex

Procedures for the acceptance of waste according to Decision 2003/33/EC, Annex

Requirement / Source Specification

Function of the basic

characterisation

[Decision 2003/33/EC,

Annex, section 1.1.1]

(a) Basic information on the waste ( type and origin, composition, consistency,

leachability and where necessary and available other characteristic properties)

(b) Basic information for understanding the behaviour of waste in landfills and

options for treatment as laid out in Article 6(a) of the Landfill Directive

(c) Assessing waste against limit values

(d) Detection of key variables (critical parameters) for compliance testing and

options for simplification of compliance testing (leading to a significant decrease

of constituents to be measured, but only after demonstration of relevant



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Procedures for the acceptance of waste according to Decision 2003/33/EC, Annex

Requirement / Source Specification

information). Characterisation may deliver ratios between basic characterisation

and results of simplified test procedures as well as frequency for compliance

testing.

Fundamental

requirements for basic

characterisation


Annex, section 1.1.2]

Necessary data:

(a) Source and origin of waste

(b) Information on process producing waste (description, characteristics of raw

materials and products)

(c) Description of pre-treatment applied, or statement why no treatment

(d) Data on composition of waste and leaching behaviour, where relevant

(e) Appearance of waste (smell, colour, physical form)

(f) Code according to the European waste list36 (Commission Decision 2001/118/EC)

(1)

(g) Relevant hazard properties ( Annex III to Hazardous Waste Directive) for mirror

entries

(h) Information to prove that the waste does not fall under the exclusions of Article

5(3) of the Landfill Directive (liquid, explosive, corrosive etc.)

(i) Landfill class at which the waste maybe accepted

(j) If necessary, additional precautions to be taken at landfill

(k) Check if waste can be recycled or recovered

Compliance testing


Annex, section 1.2]

• Parameters, scope and frequency of testing determined in basic characterisation

(key variables)

• Same testing method as in basic characterisation

• Keeping of records

On-site verification


Annex, section 1.3]

• Visual inspection of waste before and after unloading at the landfill

• Same waste as described in accompanying documents / same as basic

characterisation

The extent of laboratory testing between basic characterisation and compliance testing is dependent

on the type of waste and if the waste is regularly generated within the same process or not. For

waste regularly generated, information on compositional range, variability of properties and key

variables are also necessary. Waste does not need testing if it is produced within the same process in

the same installation or within a defined and already tested process. There is also no testing

required, if the necessary information is well known and duly justified [Annex, Section 1.3 (a) and (b),

Decision 2003/33/EC].

36 Decision 2001/118/EC amending Decision 2000/532/EC as regards the list of wastes, 16 January 2001 (OJL

47, 16.02.2001, p. 1-31)



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In addition, short lists with EWC codes according to the European waste list are established by the

WAC Decision for wastes acceptable without testing. The acceptances of all other wastes primarily

depend on their leaching properties, which are laid down in the Annex to the WAC Decision [Section

2.1 to 2.4.]. The storage options of mercury containing waste depend mainly on the leaching limit

values for Hg as summarized for each landfill type in the following table:

Table 5-6: Mercury leaching limit values for different landfill types and standards according to Decision 2003/33/EC

Mercury leaching limit values for different landfill types according to Decision 2003/33/EC, Annex

Landfill type L/S =2 l/kg

mg/kg dry substance

L/S =10 l/kg mg/kg dry substance

C0 (percolating test) mg/l

Criteria for landfills for inert waste 0.003 0.01 0.002 Criteria for granular non-hazardous waste accepted in the same cell as stable non-reactive hazardous waste 0.05 0.2 0.03

Criteria for hazardous waste acceptable at landfills for non-hazardous waste

0.05 0.2 0.03

Criteria for waste acceptable for landfills for hazardous waste 0.5 2 0.3

Member States have the possibility to determine more stringent requirements (such as more

stringent leaching limit values, see chapter 5.3). In general, the limit values given are valid for all

kinds of storage facilities. However, in the case of hazardous waste disposed of in underground

disposal facilities, the leaching limit values are not valid. In such cases the waste has to be compliant

with the site specific safety assessment [Annex, point 2.5 of Decision 2003/33/EC].

The sampling and test methods which have to be used to determine the leachability are set in

Section 3 of the Annex to the Decision 2003/33/EC. Leaching tests have to be made in accordance

with EN 12457/1-4 ‘Leaching-Compliance test for leaching of granular waste materials and sludges.’

(Part 1: L/S=2 l/kg particle size <4mm; Part 2: L/S=10 l/kg particle size < 4mm; Part 3: L/S=2 and 8 l/kg

particle size <4mm and Part 4: L/S=2 l/kg particle size <10mm).

The WAC Decision foresees that Member States have to set criteria for monolithic waste to provide

the same level of environmental protection as for granular waste. In many Member States the

crunched monolithic waste has to fulfil the same leaching limit values as the granular waste.

The percolating test has to be carried out in accordance with prEN 14405 (CEN/TS 14405:2004)

‘Leaching behaviour test – Up flow percolation test for inorganic constituents’. Each of the Member

States has to decide which of the leaching tests shall be used.

Mercury containing waste which exceeds the indicated limit value set for a specific type of landfill

has to be treated again to reduce the content of mercury or to be stabilised to reduce the



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leachability.

Apart from the general requirements, the WAC Decision contains specific requirements for

underground disposal facilities (see chapter 5.2.3) and for salt mines (see chapter 5.2.4) and hard

rock formation (see chapter 5.2.5).

Regulation (EC) N° 1013/2006 (‘Waste Shipment Regulation’)

“If only a few storage sites for metallic mercury within the European Union would be in operation,

mercury has to be transported throughout Europe. For such waste transports the Waste Shipment

Regulation has to be complied with. It states that shipments of waste destined for disposal operation

shall be subject to prior written notification and consent procedure [Article 3(1)(a) of Regulation (EC)

N° 1013/2006]. Recital 10 of the Mercury Regulation makes it clear that the Mercury Regulation

should be without prejudice to the Waste Shipment Regulation.

This means that transboundary transports of mercury destined for disposal within the European

Union have to follow the notification procedures. The notifier has to submit the notification

document to the competent authority in the country of dispatch – the country from which the

shipment is planned to be initiated [Article 4 of Regulation (EC) N° 1013/2006]. Then the competent

authorities at the point of dispatch and destination and in the case of transit, the competent

authority/authorities of the transit countries, have to agree to the shipment (consent) or not agree

to the shipment (objection).

In general, one reason for objection – for a shipment of waste destined for disposal – which can be

raised by the authorities of dispatch and destination is laid down in Article 11(1)(a) of the Waste

Shipment Regulation. The Article refers to:

• the principles of proximity,

• priority for recovery and

• the principle of self-sufficiency

as defined in Directive 2006/12/EC37. If one of the authorities believes that one or more of the

principles is not being complied with it can make a reasoned objection. The principles are alike

defined in Directive 2008/98/EC (new Waste Framework Directive) which repeals Directive

2006/12/EC and which has to be transposed into national legislation by the Member States by 12

December 2010.

In the case of a disposal of mercury, Recital 10 of the Mercury Regulation now encourages the

authorities of dispatch and destination to avoid raising such reasoned objections based on the listed

37 Directive 2006/12/EC of the European Parliament and of the Council of 5 April 2006 on waste (OJ L

114, 27.4.2006, p. 9–21), also referred as ‘Waste Framework Directive‘.



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principles outlined in Article 11(1)(a) of the Waste Shipment Regulation. The article is not applicable

for shipments of metallic mercury and certain mercury compounds destined for disposal in another

EU Member State. As a justification, the Mercury Regulation refers to Article 11(3) of the Waste

Shipment Regulation stating that where the production of wastes in very small quantities and the

setting up of a new specialised installation is uneconomic, Article 11(1)(a) will not apply.

However, reasoned objections by the competent authority of dispatch might be based on Article

11(1)(b) − interference with national legislation related to environmental protection, public order,

public safety or health protection of the country − or Article 11(1) (e) − right of Member States

pursuant to Article 4(1) of the Basel Convention to prohibit import of hazardous waste or of waste

listed in Annex II (household residues, residues from incineration of household wastes).

In consequence, all procedures and requirements of the Waste Shipment Regulation are applicable

for the shipment of mercury and mercury-containing waste but reasoned objections based on Article

11(1)(a) cannot be made by the authorities.

Directive 2004/35/EC 38 (‘Environmental Liability Directive’)

The objective of the Directive on environmental liability with regard to the prevention and remedying

of environmental damage is to establish a common framework for the prevention and remedying of

environmental damage at a reasonable cost to society.

It applies to occupational activities which present a risk for environmental damage (land, water,

protected species and natural habitats), or human health [Recital 8 and 9 as well as Article 2 (1) of

Directive 2004/35/EC]. As laid down in the Mercury Regulation, it applies also to all storage facilities

for metallic mercury [Recital 8 of Regulation EC No 1102/2008]. The criteria for measuring damage

are laid down in Annex I of the Directive.

By implementing the ‘polluter pays’ principle, an operator causing environmental damage or creating

an imminent threat of such damage shall, in principle, bear the cost of the necessary preventive or

remedial measures. In cases where a competent authority acts by itself or through a third party (in

the place of an operator) the authority shall ensure that the cost incurred is recovered from the

operator [Recital 18 and Article 8(1) of Directive 2004/35/EC].

For such purposes the competent authority may require the operator to provide information on any

imminent threat or suspicion of threat of environmental damage and to take necessary preventive

measures. Additionally, the authority may give to the operator instructions to be followed on a

necessary preventive measure or to take the measure itself [Article 5 (3) of Directive 2004/35/EC].

Annex II of the Directive lays down the framework to choose the appropriate remediation measure.

Member States shall establish financial security instruments and financial guarantees enabling the

38 Directive 2004/35/EC of the European Parliament and of the Council of 21 April 2004 on environmental

liability with regard to the prevention and remedying of environmental damage (OJ L 143, 30.4.2004, p. 56–75), also referred as ‘Environmental Liability Directive ‘.



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operators to cover their responsibilities under the Directive [Article 14 of Directive 2004/35/EC].

Directive 85/337/EEC (‘Environmental Impact Assessment Directive’)

The Directive on Environmental Impact Assessment (EIA) was introduced in 1985 and was amended

in 1997. Member States had to transpose the amended EIA Directive by 14 March 1999 at the latest.

The EIA procedure ensures that environmental consequences of projects are identified and assessed

before authorisation is given. The public can give its opinion and all results are taken into account in

the authorisation procedure of the project.

The EIA Directive outlines which project categories shall be made subject to an EIA, which procedure

shall be followed and the content of the assessment. In terms of waste disposal, Annex I, 9 and 10

lays down, that the following facilities require an EIA:

• Waste disposal installations for the incineration, chemical treatment as defined in Annex IIA

to Directive 75/442/EEC39 under heading D9, or landfill of hazardous waste (i.e. waste to

which Directive 91/689/EEC39 applies).

• Waste disposal installations for the incineration or chemical treatment as defined in Annex

IIA to Directive 75/442/EEC39 under heading D9 of nonhazardous waste with a capacity

exceeding 100 tonnes per day.

That means, that landfill for hazardous waste do require an EIA. Also installations for incineration or

chemical treatment (operation D9) for hazardous waste and for non-hazardous waste if exceeding

the capacity of 100 t/day do require an EIA.

For operations listed in Annex II Member States shall determine though a case-by-case examination

or/and the setting of thresholds or criteria which projects listed shall be subject to an EIA. Criteria

which could be used are listed as a proposal in Annex III. Article 5 in connection with Annex VI

includes the information to be provided by the developer of the project.

5.2.2 Legal requirements for above-ground storage facilities


Metallic mercury may be temporarily stored for more than one year in above-ground facilities

[Article 3(1)(b) of Regulation (EC) N° 1102/2008]. The above-ground storage of metallic mercury shall

be considered as a temporary solution [Recital 12 of Regulation (EC) N° 1102/2008]

Requirements to be applied for all mercury storage facilities are listed in Table 5-7.

39 References to repealed Directives shall be construed as references to new Directives in accordance with the

correlations table, thus meaning Directive 2006/12/EC Annex IIA and Directive 2008/98/EC Annex I.



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Table 5-7: Requirements for above ground mercury storage according to Regulation (EC) N° 1102/2008

Requirements for above ground mercury storage according to Regulation (EC) N°1102/2008


Provisions


• All provisions of Directive 1999/31/EC shall apply; except

Article 5(3)(a) = not accepting liquid waste at landfills

• All provisions of Decision 2003/33/EC shall apply, except

criteria set out in section 2.4 of the Annex (criteria for waste

acceptable at landfills for hazardous waste)

Seveso II Directive

[Regulation 1102/2008, Recital 9 and

Article 3 (1)]

• Above-ground storage for more than one year in facilities

dedicated to and equipped for this purpose

• Council Directive 96/82/EC of 9 December 1996 on the control

of major-accident hazards involving dangerous substances

should apply

Equipment


• Dedicated and equipped for the temporary storage of mercury

Safety assessment


• Safety assessment required under WAC Decision for

underground storage applicable also for above ground storage

• Complemented by specific requirements

• No final disposal operation permitted until special

requirements and acceptance criteria are adopted

Principles


• Principle of reversibility of storage

• Protection of mercury against meteoric water

• Impermeability towards soils

• Prevention of vapour emissions of mercury

Containment


• Temporary storage in above-ground facilities in appropriate

containment

Reversibility

[Regulation 1102/2008, Article 3 (1)(b)]

• Facility has to be dedicated to and equipped for temporary

storage of metallic mercury

Directive 1999/31/EC (‘Landfill Directive’) / Decision 2003/33/EC (‘WAC Decision’)

Neither the Landfill Directive nor the WAC Decision provide specifications on disposal exclusively for

above ground storage. The defined requirements are valid for all types of storage, including above

and underground storage.

For the deposit of liquid mercury, an exemption is made for Article 5 (3) (a) of the Landfill Directive in

which liquid waste is not to be accepted at landfills. Additionally, Section 2.4 of the Annex to the

WAC Decision, setting out the criteria for waste acceptable at landfills for hazardous waste, will not

apply for temporary storage of mercury in above ground facilities [Recital 7 and Article 3(1)(b) of

Regulation (EC) N° 1102/2008].

Furthermore, Recital 11 of the Mercury Regulation states that the safety assessment laid down in the



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WAC Decision required for underground storage (see Table 5-9) shall also be applicable to non-

underground mercury disposal.

Directive 1996/82/EC (‘Seveso II Directive’)

Recital 9 and Article 3(1) of Regulation (EC) N° 1102/2008 states that for temporary storage of

metallic mercury for more than one year in above-ground facilities, Council Directive 96/82/EC on

the control of major-accident hazards involving dangerous substances shall apply.

The Seveso II Directive aims at the prevention of major accidents that involve dangerous substances

and the limitation of their negative consequences for humans and the environment [Article 1 of

Directive 96/82/EC] by requiring the operator of facilities and establishments where dangerous

substances are involved, to notify the establishment to a competent authority. The notification

includes information on the location of the facility, the responsible person, dangerous substances or

category of substances involved, etc. [Article 6 of Directive 96/82/EC].

Additionally, the operator has to prepare the following documents:

• A major-accident prevention policy laid down in a safety report (including information on the

safety management system, the major hazards arising from the operation, operational

control and maintenance measures, planning for emergencies, monitoring performance, etc.)

[Article 7 and 9 and Annex III of Directive 96/82/EC];

• An emergency plan (including internal emergency plans made known to the staff of the

facility and external plans to be made known to the general public) [Article 11 and Annex IV

of Directive 96/82/EC].

The safety report has to be reviewed at least every five years or earlier where justified by new facts;

development of new technical knowledge etc. [Article 9(5) of Directive 96/82/EC]. Guidance on the

preparation of such safety reports is available, e.g. at [Seveso Guidance 2005].

For the disposal of mercury in above ground storage, the requirements listed in Table 5-8 are of

relevance for the planning of the facility.

Table 5-8: Requirements for mercury storage in above-ground disposal facilities according to Directive 1996/82/EC

Requirements for mercury storage in above-ground disposal facilities according to Directive 1996/82/EC


Adaptation of site


Recital 17 and Article 9]

By means of a safety report it shall be demonstrated that:

• a major-accident prevention policy and a safety management system for

implementing have been put into effect in accordance with the information

set out in Annex III;

• major-accident hazards have been identified and the necessary measures

have been taken to prevent such accidents and to limit their consequences for

man and the environment;



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Requirements for mercury storage in above-ground disposal facilities according to Directive 1996/82/EC


• adequate safety and reliability have been incorporated into the design,

construction, operation and maintenance of any installation, storage facility,

equipment and infrastructure connected with its operation which are linked

to major-accident

• hazards inside the establishment;

• internal emergency plans have been drawn up and information has been

supplied to enable the external plan to be drawn up in order to take the

necessary measures in the event of a major accident;

In addition the safety report shall provide sufficient information to the

competent authorities to enable decisions to be made in terms of the siting of

new activities or developments around existing establishments.

Domino effect


Recital 18]

In order to reduce the risk of domino effects, where establishments are sited so

close together

• so as to increase the probability and possibility of major accidents, or

• aggravate their consequences,

there should be provision for the exchange of appropriate information and

cooperation on public information

Location


Recital 22]

Suitable distance between areas of: • substantial public use

• areas of particular natural interest or sensitivity

Taking account of additional technical measures so that the risk to individuals is not increased.

5.2.3 Legal requirements for underground disposal


Another possibility for the storage of metallic mercury is the storage in a hazardous underground

facility permitted for the disposal of mercury containing waste. For such facilities, the requirements

for all mercury storage facilities (see Table 5-1) have to be applied. The safety assessment as

described in Decision 2003/33/EC for underground storage is applicable for the underground storage

of mercury. There are no further specifications for disposal in underground facilities. A few

specifications however are made for underground disposal in salt mines (see chapter 5.2.4) and in

hard rock formations (see chapter 5.2.5).


The Landfill Directive defines ‘underground storage’ as permanent waste storage facilities in a deep

geological cavity such as a salt or potassium mine [Article 2 (g)]. It is also defined that ‘landfill’ as

disposal onto or into land includes underground storage [Article 2 (f) of Directive 1999/31/EC].

Therefore, in general, the provisions of the Landfill Directive apply also to underground disposal.

However, Member States can declare for underground storage exemptions regarding the following



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provisions [Article 3 (5) of Directive 1999/31/EC]:

• Monitoring and analysing of landfill gas (provision in Article 13(d), Annex I, point 4 and Annex

III, point 3),

• Water control and leachate management (provision in Article 13(d), Annex I, point 2 and

Annex III, point 3),

• Measures to protect soil, groundwater or surface water and collection of leachate (Annex I,

point 3 and Annex III, point 4),

• Measures to minimise nuisance and hazards (Annex I, point 5),

• Reporting of meteorological data (Annex III, point 2),

• Data on the structure and composition of the landfill body and settling behaviour (provision

of Annex III, point 5).

The control of water from precipitations entering into the landfill body has to be performed for

underground disposal as well, because the first indent of Article 13 (d) is excluded from the

exemption.

Article 16 and Annex II, point 1 of the Landfill Directive proposes that the development of specific

criteria, test methods and associated limit values shall be set for each landfill class, including specific

landfill types such as underground storage. These specifications are set out in the WAC Decision.


For underground storage facilities no leaching limits are established in Decision 2003/33/EC.

The acceptance of waste though in underground storage facilities depends on a site-specific safety

assessment which is obligatory for each underground storage facility. Waste may be only accepted if

it is compatible with the assessment. For the underground storage of inert waste and non-hazardous

waste, the same leaching limit values as for other landfills apply. In case of storage of hazardous

waste in underground storage, such leaching limit values do not apply. Only the compliance with the

site-specific safety assessment is of relevance. The acceptance procedures however are the same as

for other landfill types [Annex, point 2.5].

The procedure for carrying out a site-specific safety assessment is defined in Appendix A of Decision

2003/33/EC. It includes:

2. Safety philosophy for underground storage: all types,

3. Acceptance criteria for underground storage: all sites,

4. Additional considerations: salt mines,



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5. Additional considerations: hard rock.

The safety philosophy chapter covers the importance of the geological barrier and demands the

permanent isolation of wastes from the biosphere by such a barrier. To demonstrate the long-term

safety of the installation and prevent the discharge of pollutants into the groundwater, a site-specific

risk assessment has to be carried out. The specifications to the risk assessment analysis set out in

Appendix A, section 1 of Directive 2003/33/EC are highlighted and described in Table 5-9.

Table 5-9: Site specific risk assessment for underground disposal according to Decision 2003/33/EC, Appendix A

Site-specific risk assessment for underground disposal according to Decision 2003/33/EC, Appendix A


Identification

[Decision 2003/33/EC, Appendix A,

point 1.2, para 1]

• The deposited waste (‘the hazard’)

• The biosphere and possibly groundwater (‘the receptor’)

• The pathway by which the substances may reach the biosphere,

and

• The assessment of impact of substances that may reach the

biosphere

Analysis of host rock


point 1.2, para 2]

• Analysis of host rock

• Taking into account conditions stated in Annex I, point 1, 6, 7 of

Directive 1999/31/EC referring to location, stability and barriers

• Demonstration of suitability of strata for establishing storage

Acceptance criteria


point 1.2, para 3]

• Referring to local conditions

• Taking into account overall system of waste, engineered structures

and cavities and host rock body

Time and measures


point 1.2, para 4]

• Assessment for operational and post-operational phase

• Development of control and safety measures and waste acceptance

criteria

Geological assessment


point 1.2.1]

Investigation of:

• rocks, soils, topography

• location, frequency and structure of faults and fractures in

surrounding geological strata

• Seismic activity

• Alternative location

Geomechanical assessment


point 1.2.2]

Demonstrate that:

• no risk of major deformation that could impair the operability

• no risk of major deformation that could provide a pathway to the

biosphere

• no risk of collapse during operation

• deposited material has necessary stability compatible with the

properties of the host rock

Hydrogeological assessment


point 1.2.3]

Investigation of:

• Hydraulic properties and groundwater flow patterns

• hydraulic conductivity of the rock mass

• fractures



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Site-specific risk assessment for underground disposal according to Decision 2003/33/EC, Appendix A


• hydraulic gradients

Geochemical assessment


point 1.2.4]

Investigation of:

• present groundwater composition and potential evolution over

time

• nature and abundance of fracture-filling mineral

• rock composition

Biosphere impact assessment


point 1.2.5]

• Baseline studies to define local natural background levels of

relevant substances

Assessment operational of phase


point 1.2.6]

Demonstrate that there is/are:

• stable cavities

• no unacceptable risk of pathways between waste and biosphere

• no unacceptable risk affecting the operation of the facility

• no reaction with rock in any physical or chemical way, which could

impair strength and tightness of rock

Identification of:

• waste inventory, facility management, scheme of operation

• accidents leading to pathway to biosphere

• operational risks

Development of:

• contingency measures

Long-term assessment


point 1.2.7]

Investigation of:

• barriers, e.g. waste quality, engineered structures, back filling,

sealing

• performance of host rock

• surrounding strata and overburden

• groundwater flow, barrier efficiency, natural attenuation, leaching

of waste

• changes over geological time

• scenarios of consequences on release of waste reflecting long-term

evolution of biosphere, geosphere and underground storage (not

taking into account containers/lining due to limited lifetime)

Assessment of the surface

reception facilities

[Decision 2003/33/EC, 1.2.8]

Reception facilities must be designed and operated to:

• prevent harm to human health

• prevent harm to the local environment

• fulfil same requirements as other waste reception facilities

Assessment of other risks


point 1.2.9]

• separation of waste disposal from other mining activities

• no acceptance of hazardous substances which harm human health

(e.g. pathogenic germs)

Section 2 of Appendix A of the WAC Decision includes an overview of waste types which are excluded

from underground storage and considerations related to the acceptance of waste for underground



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storage. Wastes that may undergo undesired physical, chemical or biological transformation after it

has been deposited are generally excluded from underground storage. Liquid waste is in general also

excluded from storage in underground disposal (Appendix A, 2.1 of Decision 2003/33/EC with

reference to Article 5(3) of Directive 1999/31/EC).

Wastes not excluded by this list are suitable for underground storage including inert wastes, non-

hazardous and hazardous wastes. In general, the acceptance of waste is based on the site-specific

risk assessment demonstrating the level of isolation from the biosphere (see table: Table 5-9).

Member States may also establish a list of wastes which are acceptable at underground storage

facilities [Appendix A, 2.2 of Decision 2003/33/EC].

Sections 3 and 4 include some further considerations related to the safety of underground storage in

salt mines and hard rock, described in more detail in chapter 5.2.4 and 5.2.5.

5.2.4 Additional considerations for salt mines


Another possibility for the storage of metallic mercury is the storage in salt mines, as salt is

considered to provide total containment.

For a salt mine, permitted for the storage of mercury, the requirements for all mercury storage

facilities (see Table 5-1) have to be applied. Additionally, some further requirements are made, listed

in Table 5-10.

Table 5-10: Requirements for mercury storage in salt mines according to Directive N° EC 1102/2008

Requirements for mercury storage in salt mines according to Regulation EC N°1102/2008


Safety assessment


• Safety assessment required under WAC Decision for

underground storage also for salt mines

• Adapted for the disposal of metallic mercury

• Meet principle of protection of groundwater against mercury


• Impermeability to gas and liquids of the surroundings

• Firmly encapsulating the waste at the end of the mine’s

deformation process (for permanent storage)

Reversibility

[Regulation 1102/2008, Article 3 (1)(a)]

• Facility has to be adapted for storage of metallic mercury



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Apart from the definition in Article 2 of Directive 1999/31/EC stating that salt mines may be used as

underground storage facilities, the Landfill Directive does not provide specifications on disposal in

salt mines.


In addition to the requirements set in Appendix A of Decision 2003/33/EC, section 1 and 2 referring

to the safety assessment and the acceptance criteria (see chapter 5.2.3), section 3 refers especially to

disposal in salt mines including the requirements specified in Table 5-11.

Table 5-11: Requirements for salt mines according to Decision 2003/33/EC

Requirements for salt mines according to Decision 2003/33/EC, Appendix A


Encapsulation


3.1, para 1]

• Rock surrounding the waste acts as ‘host rock’ in which waste is

encapsulated

Geological barrier


3.1, bullett 2]

• The storage site must be located between overlying and

underlying impermeable rock strata to prevent groundwater

from entering and liquids and gases from escaping

• Shafts and boreholes must be sealed during operation

• Shafts and boreholes must be hermetically closed after

operation

• Disposal area must be sealed with a hydraulically impermeable

dam (according to calculated hydraulically operative pressure

corresponding to depth) when mineral extraction still ongoing

Failure scenarios


3.1, bullet 3]

• Salt is considered to provide total containment

• Cases of accidents where waste can come into contact with the

biosphere have to be assessed

• Events in geological time (earth movements, erosion e.g.

associated with sea-level rise) have to be assessed

Long-term assessment


3.2, para 1]

• Designation of the salt rock as barrier rock for the long term

assessment

Stability and Integrity


3.2, para 2]

• Stability of the host rock has to be assured during the operation

phase

• The integrity of the geological barrier has to be assured over

unlimited time

• Subsidence of the overburden or other defects are acceptable

only if rupture-free transformation will occur



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5.2.5 Additional considerations for hard rock


For the disposal of mercury in hard rock formations, the requirements for all mercury storage

facilities (see Table 5-1) have to be applied. Some additional requirements are outlined in the

Mercury Regulation listed in Table 5-12.

Table 5-12: Requirements for mercury storage in hard rock formations according to Directive N° EC 1102/2008

Requirements for mercury storage in hard rock formations according to Regulation EC N°1102/2008


Safety assessment


• Safety assessment required under the WAC Decision for

underground storage also for deep underground hard rock

formations

• Adapted for the disposal of metallic mercury

• Meet principle of protection of groundwater against mercury


• Impermeability to gas and liquids of the surroundings

• Firmly encapsulating the waste at the end of the mine’s

deformation process (for permanent storage)

Containment


• Storage in deep underground hard rock formations in

appropriate containment

Reversibility

[Regulation 1102/2008, Article 3 (1)(a)]

• Providing a level of safety and confinement equivalent to salt

mines


The Landfill Directive does not provide specifications on disposal in hard rock formations.


According to Decision 2003/33/EC ‘deep storage in hard rocks’ is defined as an underground storage

at several hundred metres depth, where hard rock includes various igneous rocks, e.g. granite or

gneiss or also sedimentary rocks, e.g. limestone and sandstone.

In addition to the requirements set out in Appendix A of Decision 2003/33/EC, section 1 and 2

referring to the safety assessment and the acceptance criteria (see chapter 5.2.3), section 4 refers

especially to the disposal in hard rock formations including the requirements specified in Table 5-13.



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Table 5-13: Requirements for deep storage in hard rocks according to Decision 2003/33/EC

Requirement for deep storage in hard rock according to Decision 2003/33/EC, Appendix A


Definition

[Decision 2003/33/EC, Appendix A, 4] • Site must be located in hard rock several hundred metres in

depth

• Composed of hard rock including igneous rocks and sedimentary

rocks

Construction

[Decision 2003/33/EC, Appendix A, 4.1

para 1]

• To be passive with no need for maintenance

• Allows recovery of waste and future corrective measures

• No negative environmental effects or liabilities should fall upon

future generations

Safety philosophy


para 2]

• Isolation of the waste from biosphere, natural attenuation of

any pollutants leaking from the waste

• Extended periods of time (several thousands of years)

• Former mines where mining activity has come to an end

• New storage facilities

Safety philosophy


para 3]

• The storage site has to be constructed so that natural

attenuation of the surrounding strata mediates the effect of

pollutants to the extent that they have no irreversible negative

effects on the environment

Groundwater


para 4]

• The storage site must be located below the groundwater table

• No direct discharge of pollutants into the groundwater

• Prevent deterioration of the status of all bodies of groundwater

• Assessment of paths to and in the biosphere and impact of

variability on the geohydraulic system

Gas formation


para 5]

• Gas formation must be considered



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5.3 Legislation at Member State level

5.3.1 National legislation on mercury and mercury-containing waste

A good overview of existing national legislation related to mercury and mercury containing waste

exceeding EU legislation is provided by [COWI 2008] (section 5). The legislation about mercury waste

requirements in the Member States concentrates on the following issues:

• Requirements on treatment methods of mercury-containing waste, e.g. lamps, equipment or

amalgam residues (AT);

• Restriction of the concentration of mercury in certain products and materials, e.g. engine oils

and compost (AT);

• Classification of mercury-containing products as hazardous waste, e.g. thermometers,

electrical equipment, batteries etc. (AT);

• Restriction of incineration and co-incineration of waste containing mercury (AT, BE, FR);

• Prohibition of mixing mercury-containing wastes with other wastes for preparation of a mix

principally used as a fuel or other means to generate energy (NL);

• Emission limit values for mercury from crematoria (BE);

• Requirements for the handling and treatment of dental amalgam (AT, BE, UK);

• Restriction of export of waste containing mercury (NL, SE, UK, FI, SE).

Additionally, some Member States have set specific requirements for the treatment, landfilling and

storage of mercury and mercury-containing waste, which are listed in more detail in Table 5-14.

Table 5-14: Overview of Member State legislation concerning mercury and mercury-containing waste

Description of Member State legislation for mercury and mercury-containing waste

Scope MS Description Legislation

Ban on landfilling of

mercury BE • Landfilling of mercury is prohibited (in Flanders) [VLAREM 1995]

Ban on landfilling of

mercury- containing

waste

NL

• Ban on mercury-containing waste, by-products,

measuring and control equipment, e.g. thermometers

and batteries containing mercury

[COWI 2008]

AT

• Mercury limit value for landfilling is 1- 20 mg/kg TS

depending on landfill class

• Exception: mercury as sulphide: 3,000 mg/kg TS

• Waste exceeding limit values has to be

decontaminated or stored in underground landfills

[DeponieVO

2008]

Restriction of landfilling

of mercury- containing

waste

BE • Mercury limit value for landfilling is 0.5% of organic or

inorganic compounds (in Flanders)

• Exception: mercury as sulphide

[VLAREM 1995]



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Description of Member State legislation for mercury and mercury-containing waste

Scope MS Description Legislation

• In practice, threshold value of 100 mg/kg (also limit for

toxic waste in BE)

FI

• Mercury limit value for industrial waste deposit area is

< 40 ppm

• Waste above limit value must be deposited in landfills

or hazardous landfills (special permission)

• Supplementary requirements for solubility of mercury

from wastes in landfills

[COWI 2008]

SE

• Mercury containing waste that exceeds 0,1 % by

weight shall be finally disposed in underground

storage.

• The rules mentioned above do not apply for mercury

waste that is covered by the Regulation (EC)

1102/2008.

• From the 1 of January 2010 it is possible to grant an

exemption from the rules of underground storage.

[personal

information Mr.

Carl Mikael

Strauss,

Swedish EPA]

FI • Mercury-containing waste is neutralised or treated in

well-controlled sulphidation reactor before landfilling [COWI 2008]

FR

• Stabilisation using hydraulic binders is required on the

leachable fraction for storage in landfills.

• Stabilisation/solidification – landfilling of hazardous

waste

[COWI 2008],

[FNADE/ADEME

2006]

Treatment of mercury-

containing waste going

to landfills

NL

• ‘Lowest’ standard for permitting waste treatment

installations is separating mercury and recovering

other fractions e.g. metals, glass

[COWI 2008]



to salt mines

FR • Solidification is required for storage in salt mines [COWI 2008]



to bedrock

SE

• Specific requirements for pre-treatment are under

development, including solidification and stabilisation

as mercury sulphide

[COWI 2008]

5.3.2 National legislation on leachate limit values of mercury

Directive 1999/31/EC together with the WAC Decision lay down which requirements storage facilities

(landfills) in general have to fulfil and which acceptance criteria waste has to fulfil to be accepted at a

certain type of landfill. More stringent protective measures at Member States level are possible and

are mentioned in particular in the Annex of Decision 2003/33/EC (introduction):

‘In accordance with Article 176 of the Treaty, Member States are not prevented from

maintaining or introducing more stringent protective measures than those established in

this Annex, provided that such measures are compatible with the Treaty. Such measures



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shall be notified to the Commission. This could be of particular relevance with reference

to the limit values for cadmium and mercury in section 2.’

Most of the EU Member States adopted the limit values set in the WAC Decision, while only a few

countries implemented more stringent and additional leaching limit values for mercury. Those

stricter values are summarised in Table 5-15.

Table 5-15: Member States mercury leaching limit values for landfills (more stringent or additional to Decision 2003/33/EC)

Member States mercury leaching limit values for landfills (stricter or additional to Decision 2003/33/EC)

Landfill type L/S =2 l/kg

mg/kg dry

substance

L/S =10 l/kg

mg/kg dry

substance

C0 (percolating

test)

mg/l dry

EU criteria for landfills for inert waste 0.003 0.01 0.002

Luxembourg [Legislation36 2006] 0.001

EU criteria for landfills for non-hazardous waste - - -

Austria (residual waste, e.g. incineration

residues) [DeponieVO 2008] 0.1

Denmark (non-hazardous landfills in a non-

coastal location)[Miljøministeriet 2009] 0.012 0.05 0.0063

Germany (non-hazardous waste with low organic

compounds)[DepVereinfachV 2009] 0.05*

Italy [Decreto 2003] 0.05*


EU criteria for hazardous waste acceptable at

landfills for non-hazardous waste 0.05 0.2 0.03

UK / Northern Ireland [Schedule10 2007] 0.02

EU criteria for waste acceptable for landfills for

hazardous waste 0.5 2 0.3

Austria [DeponieVO 2008] 0.5

Denmark (hazardous landfills in a non-coastal

location)[Miljøministeriet 2009] 0.012 0.051 0.0064

Italy [Decreto 2003] 0.5*


UK / Northern Ireland [Schedule10 2007] 0.4 *Unit [mg/l] is used instead of [mg/kg]; values have been converted

In the following, the legal situation of some selected countries with underground disposal facilities is

described in more detail.



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5.3.3 Germany

Due to the lack of appropriate storage facilities, many EU Member States export Hg-containing waste

to other EU countries. Germany is the main importing country of mercury containing waste. On the

basis of information by [COWI 2008], Germany is also the only country importing mercury containing

waste for permanent storage (D12). Due to its hazardous and leaching properties Hg-containing

waste is typically disposed of in hazardous underground facilities (salt mines). Leaching requirements

for above-ground facilities are typically not met. Waste exceeding the limit values for above ground

landfills can be stored in underground facilities (no limit values related to mercury concentration, for

example) if it fulfils the site-specific waste acceptance criteria for the underground disposal site.

In Germany hazardous waste is only allowed to be deposited in salt rock due to the lack of hard rock

formations fulfilling the requirements of safe long-term storage. Therefore, in the new legislation

(see below) only requirements for underground disposals in salt rock are defined.

On 16 July 2009 the ordinance on the simplification of waste disposal regulations40 came into force.

This regulation has already taken into consideration Regulation (EC) No 1102/2008 as regards the

long-term storage of mercury. Following the regulation, the long-term storage of metallic mercury is

possible in landfill class III (above ground) and landfill class IV (underground storage). The class IV

landfills have been recently introduced for the purpose of mercury storage in Germany.

Liquid wastes are forbidden in long-term storage. An exception is made for the long-term storage of

liquid mercury (§ 23, para 2 of the Simplification Ordinance). The exception adopts the provisions set

down in Article 3 of Regulation (EC) No 1102/2008 [Kabinett 2008, questionnaire survey]. With

regard to above-ground storage (landfill class III), the landfill has to be dedicated for the storage of

mercury and needs to be operationally and technically equipped for this purpose. In the case of

underground storage (landfill class IV) the landfill has to be adapted for the purpose of disposing of

metallic mercury and this has to be taken into particular consideration in the site-specific safety

assessment. Wastes accepted into long-term storage facilities need to have a written certification

granting the planned recovery or disposal operation (§ 23, para 3 of the Simplification Ordinance).

The requirements referring to the site specific risk assessment set out in the WAC Decision, Appendix

A have been specified so far in German legislation in the Technical Instruction on Waste41. With the

Simplification Ordinance, the Technical Instruction on Waste is no longer in place since 2009. The

requirements are now set down in the Ordinance on Landfills42 which is included in the Simplification

Ordinance.

40 Verordnung zur Vereinfachung des Deponierechts vom 27. April 2009 (Bundesgesetzblatt Jahrgang 2009 Teil I

Nr. 22, ausgegeben zu Bonn am 29. April 2009), also referred to as the ‘Simplification Ordinance‘ 41 Zweite allgemeine Verwaltungsvorschrift zum Abfallgesetz (TA Abfall) vom 12. März 1991 (GMBl. Nr. 8 S. 139) last amendment on 21. März 1991. 42 Verordnung über Deponien und Langzeitlager (Deponieverordnung - DepV) vom 27. April 2009 (BGBl. I S.

900), also referred to as the ‘Landfill Ordinance‘.



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In order to obtain permission for the disposal of hazardous waste in salt rock in class IV landfills, a

long-term safety record is necessary in Germany. This concerns in particular site-specific

circumstances, including scheduled and non-scheduled (hypothetical) incidents. The long-term safety

record is essentially based on the results of the other two individual records, the:

• record of geotechnical stability, and

• safety record for the operational phase.

The record of geotechnical stability in particular plays a key role in evaluating the long-term

effectiveness and integrity of the salt barrier. If the complete enclosure has been verified by the

record of geotechnical stability, there is no need for any model calculations of unplanned incidents

and no need for a long-term safety record for model calculations on pollutant dissemination [Annex

2, 2.1.1]. The geotechnical stability has to be proven by a report from an expert in rock mechanics

requiring very detailed information about rock behaviour and rock mechanics based on geotechnical

laboratory experiments, on-site measurements and computational rock-mechanical modelling

[Annex 2, 2.1.4].

The long-time safety record summarises the information on the entire system ‘waste/underground

structure/rock body’. The record requires comprehensive information – for example about the

natural barriers of the host rock, the technical barriers and events that could endanger the whole

encapsulation (earthquakes, volcanism, leaks in boreholes etc.)

Annex 2 of the Simplification Ordinance includes instructions on the maintenance of long-term safety

records within the context of site-related safety assessments for mines in salt rock and applied in

practice. Most of the requirements have been laid down since 2002 and are already included in the

old Ordinance of Landfills43. Recently implemented are the requirements laid down in Annex 2, point

3 and 4 of the Waste Ordinance, addressing the closure of the deep underground disposal facility in

salt mines and the documentation of access to the mines after closure (including for example the

filling of pillars, introduction of a safety zone and documentation of waste filled). Table 5-16includes

the provisions for salt mines that complement the requirements of European legislation.

Table 5-16: Requirements for deep storage in salt mines according to German legislation

Requirement for deep storage in salt mines according to German Landfill Ordinance


Location / geological barriers

[Landfill Ordinance, Annex 2, point 1]

The salt barrier rock must have / must be:

• impermeable against gas and liquids

• adequate spatial spread

• adequate unworked salt thickness, being sufficiently large

that the barrier function is not impaired in the long term

• gradually enclosing the waste by its convergence behaviour,

43 Verordnung über Deponien und Langzeitlager (Deponieverordnung - DepV) vom 24. Juli 2002 (BGBl. I S.

2807), mit Änderungen vom 13.Dezember 2006.



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and at the end of the deformation process, of encapsulating

it solidly

• stable cavities at least during the operational and closing

phase of the landfill

• storage is prohibited in regional areas where the earth

movement intensity of the value 8 according to the MSK-

scale44 is above 99%

Geotechnical stability

[Landfill Ordinance, Annex point 2, 2 and

2.1.4]

• In addition to the provisions set out in the WAC Decision

regarding the site-specific safety assessment (Appendix A),

the record of geotechnical stability is required (see above)

Geological properties

[Landfill Ordinance, Annex 2, point

2.1.2.1]

In addition to the provisions set out in the WAC Decision

regarding the geological assessment, the following

concretisations are made:

• Geological barrier; vertical distance from salt roof zone to

nearest upper underground, excavations; distances of

horizontal cavities from salt rock edges and vertical distance

from the footwall; thickness of the entire salt deposit or salt

rock body

• Degree of exploration of deposit

• Exploratory bore holes from above and below ground

• Stratigraphy in mining territory (including thicknesses, rock

face transitions)

• Material composition of salt deposit with ratio of salt rock to

potash rock, clays, anhydrites, carbonate rock

• Salt deposit structure/interior construction, structural

development including movements of the salt deposit and

its environment, convergence, bearings and underlays of

deposit, edge formation, transformations at surface of salt

deposit, position and formation of potential alkali

• Degree of tectonic stress on the salt structure, predominant

fault directions

• Geological cross-sections through the drifts

• Geothermal depth level

• Regional seismic activity in past and present

• Subrosion, formation of earth subsidence on surface

• Halokinesis

44 The Medvedev-Sponheuer-Karnik scale, also known as the MSK or MSK-64, is a macro seismic intensity scale

used to evaluate the severity of ground shaking on the basis of observed effects in an area of the earthquake occurrence. The scale ranges from 1 to 12. 8 denotes “damaging” (Many people find it difficult to stand, even outdoors. Furniture may be overturned. Waves may be seen on very soft ground. Older structures partially collapse or sustain considerable damage. Large cracks and fissures opening up, rock falls). See e.g. http://en.wikipedia.org/wiki/Medvedev-Sponheuer-Karnik_scale

http://en.wikipedia.org/wiki/Medvedev-Sponheuer-Karnik_scale

http://en.wikipedia.org/wiki/Medvedev-Sponheuer-Karnik_scale



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Drifts


2.1.2.2]


regarding the site-specific safety assessment (Appendix A),

information about drifts is required, including:

• Layout (depth of drifts, cavity volume, drift cross-sections,

shafts, staple-pits, spiral, chutes and ramps, horizontal

spread of drifts, location and deepness of all shafts in drifts,

area and location of levels and sub-levels, distance between

levels and sub-levels, levels connected to a filling station on

air shaft, location and size of planned storage cavities)

• Safety (stability of shafts, drifts, staple-pits and working

areas; roof subsidence, flaking due to impact and footwall

risers in vicinity of mining territory; solution inflows, cause

and origin, gas release/risk; petroleum/natural gas

occurrences; safety pillars to overburden/edges/base

/solution cavities/bore holes/shafts/neighbouring mines;

existing exploratory bore holes from above and below

ground; insulated parts of drift and those that need to be

insulated)

Hydrological Assessment


2.1.2.3]


regarding the hydrological assessment, the following

concretisations are made:

• Stratigraphy, petrography, tectonics, thickness and storage

conditions of layers in the overburden and adjacent rock

• Details of the structure of aquifers and details of

groundwater movement

• Permeability and flow speeds

• Mineralisation of groundwater, groundwater chemism,

location of saltwater / freshwater boundary

• Use of groundwater, designated and planned drinking water

and healing water conservation areas and priority areas

Location, formation and properties of overground watercourses

and stagnant waterbodies and those in water-filled

underground caverns

Waste Information


2.1.2.4]


(Appendix A), information about waste is required (e.g. waste

types, quantities and properties, geomechanical behaviour of

waste, reaction behaviour).

Waste Information

[Landfill Ordinance, Annex 2, 2.1.2.4]


(Appendix A), information about waste is required (e.g. waste

types, quantities and properties, geomechanical behaviour of

waste, reaction behaviour).

The old Ordinance on Landfills from 2002 included a leaching limit value for mercury in landfill class



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IV –disposal in rock other than salt rock - being 0,001 mg/l Hg. However, this limit value was not

transposed into the revised Landfill Ordinance (2009). Under the amended Landfill Ordinance only

salt mines are covered by the landfill class IV. Since in salt mines total containment and permanent

isolation from the biosphere is assumed, leaching limit values are not required.

Furthermore, the Federal Mining Act45 includes requirements for underground storage. Nevertheless,

it is not relevant to the storage of hazardous waste, as underground storage is defined as storage of

gas, liquid and solid materials without containment.

5.3.4 Sweden

Sweden is recognised as having the most far-reaching approach to mercury waste.

Sweden has a national environmental goal and legislation stating that the use of mercury shall be

phased out. In addition, mercury waste shall be deposited in final storage underground to eliminate

emissions and to isolate mercury from the biosphere.

Since 1 August 2005 Sweden implemented an ordinance regarding mercury in waste (Waste

Ordinance 2001:1063) which states: Waste that contains at least 0.1 percent by weight mercury and

is not in a permanent landfill shall be placed in deep underground disposal by 1 January 2015 at the

latest. It is not allowed to dispose of mercury waste before 1 January 2015 in a way that prevents

terminal storage in bedrock. [COWI 2008, questionnaire survey]

The Swedish ordinance regarding mercury in waste (Waste ordinance 2001:1063) states: Waste that

contains at least 0,1 % by weight mercury and is not in a permanent landfill shall be placed in deep

underground disposal. The rules mentioned above do not apply for mercury waste that is covered by

the Regulation (EC) 1102/2008. [personal information Mr. Carl Mikael Strauss, Swedish EPA]

The characteristics of deep underground disposal must however be viewed in the light of other

barriers such as containment, and if the waste is stabilised or not. Both salt mines and underground

hard rock formations can fulfil the requirements [Questionnaire survey, SE].

5.3.5 UK

The Environmental Permitting System of England and Wales of Regulation 200746 gives effect to the permitting requirements of Articles 9 & 10 of the EU Waste Framework Directive to ensure that waste is recovered or disposed of without endangering human health or the environment. The EU

45 Bundesberggesetz vom 13. August 1980 (BGBl. I S. 1310), mit Änderungen vom 31. Juli 2009 (BGBl. I S. 2585) 46 Environmental Permitting (England and Wales) Regulations 2007



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Landfill Directive and the WAC Decision are both implemented by Regulation 2007, Schedule 1047 for England and Wales. The provisions of both documents have been taken over with minor differences regarding the acceptance and limit values laid down in § 6 to 8 in Schedule 10. The provisions set for disposal facilities are unaffected. The same is valid for Northern Ireland48 and Scotland49.

5.4 Legislation of non-EU countries

5.4.1 Norway

Since January 2008, the Norwegian Pollution Control Authority banned the use of mercury in all

products within the country (Norwegian Product Regulation, Produktforskriften). In addition, the

importing, exporting and selling of products containing mercury or mercury compounds is forbidden.

There are limited exemptions for some areas of use until December 2010. At the moment, it is very

uncertain if elemental mercury will be allowed for export from Norway, it depends on whether the

authorities will regard elemental mercury as a product or not [Kystverket 2008].

In Norway, there is a need to store mercury containing waste from zinc-production (one site).

Mercury containing waste from zinc-production is treated for final disposal. The mercury-residue

from zinc-production is cemented in sarcophagi and placed in a bedrock hall at the production site

[NO 2005, COWI 2008]. There are no emissions of mercury reported from this activity [COWI 2008].

In the future, there might be a need to store unexpected mercury-waste, as in 2003 a submarine-

wreck from the World War II was discovered, containing large amounts of mercury. Historic

documents state that the submarine contains 65 tons of metallic mercury which is stored in steel

ampoules. The area surrounding the submarine is monitored, but so far no decision has been made

about bringing the mercury cargo up from the ocean floor.

Following the statement of [NO 2005], Norway prefers a terminal disposal in a safe manner that

meets standards for long-term environmentally sound management.

5.4.2 USA

The US approach relating to governmental as well as non-governmental surplus metallic mercury is

long-term storage (>40 years) in appropriate above ground facilities.

In 2008 the US Congress adopted the ‘Mercury Export Ban Act of 2008’ [US ban 2008]. This Act

47 Schedule 10: Provision in relation to landfill to the Environmental Permitting (England and Wales) Regulations 2007, 48 Schedule 2 (General requirements for landfills) of the Landfill Regulations (Northern Ireland) 2003 with amendments from 2004 and 2007 49 The Environment Act 1995, The Criteria And Procedures For The Acceptance Of Waste At Landfills (Scotland)

Direction 2005 [Scotland Directive 2005]

http://www.sft.no/artikkel____39927.aspx?cid=29292



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prohibits on the one hand the sale, distribution, or transfer of elemental mercury by federal agencies

and on the other hand, it bans the export of elemental mercury from the United States effective

from 1 January 2013. In addition, the Act directs the DOE (Department of Energy) to provide storage

facilities by 2013 to accept and store excess mercury sent to it from commercial mercury recyclers,

gold mines generating mercury as a by-product, and chlor-alkali plants. By 1 January 2010 the DOE

has to designate one or more facilities for the purpose of long-term management and storage of

elemental mercury generated in the USA. Currently, seven sites are in discussion as possible future

storage facilities for metallic mercury. The DOE is carrying out an Environmental Impact Statement

(EIS) to identify the most appropriate storage facilities. The relevant facility(ies) – constructed,

existing or modified facilities – must comply with the corresponding requirements of section 5 (d) of

the Act Management Standards for Facilities, including the requirements of the Solid Waste Disposal

Act, as amended by the Resource Conservation and Recovery Act (RCRA).

The DOE already stores about 1,200 tons of state-owned mercury at the Y-12 National Security

complex in Oak Ridge, Tennessee. The Environmental Protection Agency (EPA) estimates that 7,500

to 10,000 metric tons of elemental mercury from private sources would be eligible for storage over

the next 40 years.

In November 2009 the DOE published “Interim Guidance on Packaging, Transport, Receipt,

Management, and Long-Term Storage of Elemental Mercury [DOE 2009]. These interim guidelines a

framework for the standards and procedures associated with a DOE-designated elemental mercury

storage facility with a focus on the RCRA permitting of such a facility and planning for that storage

facility’s needs.

Apart from the above mentioned 1,200 metric tons currently stored by the DOE, the Department of

Defense (DOD) has stored approximately 4,436 metric tons of government-owned elemental

mercury in three above ground locations for more than 40 years. Until 1994 this governmental

owned mercury was sold as a commodity. After the environmental and health risks related to

mercury became more and more obvious, the DOD halted the selling of elemental mercury.

In 2003/2004 a Mercury Management Environmental Impact Assessment (MM EIS) was carried out

to find the most appropriate way of dealing with the stored mercury in future.

The MM EIS considered the following options:

• Maintaining all the sites,

• Consolidating the mercury for storage at one site.

• Selling the elemental mercury on the market.

The addressed storage period was 40 years. The MM EIS evaluated consolidated storages in

warehouses as well as in igloos designed for the storage of army materials.

As a result of the MM EIS the preferred alternative was the consolidation of mercury storage at one



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site. The selected warehouse (Hawthorne Army Depot) was not one of the existing mercury storage

sites. This decision was based on a combination of environmental, economic and technical factors,

policy considerations and public and stakeholder comments [DNSC 2004]:

• Consolidating the DNSC mercury inventory at one site results in negligible-to-minor

environmental impacts at that site and improves environmental conditions at sites from

which the mercury would be removed;

• Human health risks to the public are negligible for normal operations and negligible-to-low

for facility and transportation accidents;

• Ecological risks are negligible for normal operations and negligible-to-low for facility and

transportation accidents with dry deposition. Ecological risks are negligible-to-moderate for

facility and transportation accidents – if it is raining during an accident which results in a

release of mercury and a fire;

• Consolidating the mercury inventory simplifies storage operations and results in economies

of scale (i.e., fewer resources required to manage the mercury inventory);

• Consolidating the excess mercury inventory facilitates DNSC’s long-term closure strategy at

the sites from which the mercury is removed;

• Removing DNSC’s excess mercury inventory is consistent with the national security mission

of Y-12; and

• The stored DNSC commodity-grade elemental mercury will be available for future use.

The environmental impact of the temporary storage itself could be expected to be negligible. Both of

the storage alternatives were assessed as having negligible human health and ecological risks,

considering both routine operations and the risk of facility accidents. The consolidated storage

option was seen as presenting slightly higher (but still low and short term) risk, connected with

transporting the mercury. A concern with temporary storage is that there is a possibility that the

storage facilities might be neglected or damaged in the future. However, the DLA assessed the risks

over a 40 year period, from a variety of accident scenarios such as fires, earthquakes, vehicle and

aircraft crashes, etc., to be negligible.

The MM EIS also took into consideration underground storage as well as pre-treatment options

(stabilisation of the waste). These possibilities have not been further evaluated due to the following

reasons:

• Below-ground facilities such as bunkers and mines were considered but not evaluated as

bunkers would be similar to the evaluated igloos at Hawthorn. Due to the limited availability

of existing mines, inspection considerations, additional material handling, and regulatory

issues, the storage in mines was not considered to be a reasonable alternative.



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• A pre-treatment of the metallic mercury to a stabilised, less toxic form before storage was

also eliminated from a detailed analysis. According to the DNSC, treatment and storage

would result in additional environmental impacts and costs, without significant benefits as in

their opinion metallic mercury can be safely stored and it is the preferred form in most

industrial processes requiring mercury.

• Based on the immaturity of the bulk mercury treatment technologies and the lack of a way

forward approved by the EPA for treatment and disposal of elemental mercury, the disposal

in a qualified landfill after pre-treatment was not evaluated in detail in the MM EIS.

5.5 Policy Initiatives

5.5.1 UNEP Mercury Programme

Under the UNEP Mercury Programme (see chapter 5.1) the UNEP Global Mercury Partnership is the

main mechanism for the delivery of immediate actions related to mercury. Its overall objective is to

protect human health and the global environment from the release of mercury and its compounds by

minimizing and, where feasible, ultimately eliminating global, anthropogenic mercury releases to air,

water and land [UNEP 2009B]. The partnership working areas currently identified include:

• Mercury Management in Artisanal and Small-Scale Gold Mining,

• Mercury Control from Coal Combustion,

• Mercury Reduction in the Chlor-alkali Sector,

• Mercury Reduction in Products,

• Mercury Air Transport and Fate Research,

• Mercury Waste Management,

• Mercury Supply and Storage.

The objective of the Mercury Waste Management partnership is to minimise and, where feasible,

eliminate unintentional mercury releases to air, water and land from mercury wastes. Activities

within the waste partnership area are:

• to support the Basel Convention on the Control of Transboundary Movements of Hazardous

Wastes and their Disposal,

• to draft Technical Guidelines on EMS of Mercury Waste,

http://www.chem.unep.ch/mercury/Sector-Specific-Information/Artisanal-small-scale-mining.htm

http://www.chem.unep.ch/mercury/Sector-Specific-Information/Coal_combustion.htm

http://www.chem.unep.ch/mercury/Sector-Specific-Information/Chlor-alkali_sector.htm

http://www.chem.unep.ch/mercury/Sector-Specific-Information/Mercury-in-products.htm

http://www.chem.unep.ch/mercury/Sector-Specific-Information/Fate_and_Transport.htm

http://www.chem.unep.ch/mercury/Sector-Specific-Information/Waste_management.htm

http://www.chem.unep.ch/mercury/Sector-Specific-Information/supply_and_storage.htm

http://www.basel.int/

http://www.basel.int/



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• to execute the Mercury waste management project,

• to add requirements on the technical and economic assessment of mercury-containing

tailings.

As a consequence of the Mercury Supply and Storage partnership the project ‘Reduce Mercury

Supply and Investigate Mercury Storage Solutions’ has been initiated in two regions within the:

• Asian mercury storage project,

• Latin America and the Caribbean mercury storage project.

After the establishment of regional advisory groups – formed by interested organisations and

governments – assessment reports on excess mercury supply in Asia [Concorde 2009] and Latin

America [UNEP 2009 A] for the period 2010-2050 have been prepared as a basis for further activities.

During inception workshops in Bangkok (Thailand, 4-5 March 200950) and Montevideo (Uruguay, 22-

23 April 200951) these assessment reports have been discussed and possible long-term storage

options have been presented. The regional advisory group will now explore and analyse the

presented options. In exploring options, the range of factors needed to establish a safe long-term

storage or repository facilities will be explored, including criteria (e.g. costs and benefits, social and

political acceptability, technical and environmental factors, infrastructure and regulatory

requirements) for site selection. Following the development of the options, a feasibility study which

further explores the suitability of a proposed site will be undertaken. Country selection for a mercury

storage site will be dependent on the results of the analysis and site suitability. Furthermore, it will

be based on an agreement within the region.

These mercury storage projects complement a mercury waste project (funded by Norway) that aims

to improve the technical guidelines on the environmentally sound management of mercury waste

done in coordination with the Secretariat of Basel Convention (SBC). Long-term storage is critical in

the ESM of mercury waste. The mercury waste project is underway to being implemented in two

countries in Asia, being managed by UNEP Chemicals, and in two countries in Latin America, being

managed by the SBC.

5.5.2 WHO

The World Health Organisation has been dealing with the issue of mercury, mercury exposure and

the risks to human health and the environment and for many years focusing on topics as follows:

• Exposure to mercury and effects on human health and health risks from food intake [WHO

2008];

50 Workshop documents are available at:

http://www.chem.unep.ch/mercury/storage/Inception_workshop.htm 51 Workshop documents are available at:

http://www.chem.unep.ch/mercury/storage/Inception_workshop_LatinAmerica.htm

http://www.chem.unep.ch/mercury/Sector-Specific-Information/Waste_management_project.htm

http://www.chem.unep.ch/mercury/storage/Inception_workshop.htm





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• Risks from long-range transboundary air pollution of heavy metals and mercury content in

environmental compartments (soil, air, water) [WHO 2007a];

• Setting of exposure limit values for mercury, e.g. for air and water exposure [WHO 2007];

• Estimating the environmental burden on diseases based on mercury exposure [WHO 2008];

• Elaborating policy papers for mercury issues, e.g. [WHO 2005a].

The WHO is organizing workshops with policy makers on the issue of mercury and mercury exposure.

The organisation is also proposing strategic actions to eliminate mercury-related diseases including

the [WHO 2007]:

• The use of mercury-free alternatives, e.g. for manometers and thermometers,

• The development of mercury clean-up and waste-handling, storage and safe-handling

procedures,

• The promotion of environmentally sound management of health-related waste containing

mercury (as set out in the UN Basel Convention on the Control of Trans-boundary

Movements of Hazardous Wastes and their Disposal).

5.5.3 International Conference on Mercury

The International Conferences on Mercury as a Global Pollutant (ICMGP) have been held periodically

since the 1990s and are the major international forum for formal presentation and discussion of

scientific advances concerning environmental mercury.

The most recent conference was held in China in May 2009 (see: http://www.mercury2009.org).

5.5.4 HELCOM

The Helsinki Commission for the Convention ‘Protection of the Marine Environment of the Baltic Sea

Area’ (HELCOM) focuses on environmental issues relevant for the protection of the Baltic Sea area.

The contamination with heavy metals and mercury in particular has been one of the concerns for

some years. HELCOM is regularly estimating and reporting data, for example about the atmospheric

emissions of mercury and mercury emissions from anthropogenic sources for neighbouring European

countries.

5.5.5 PARCOM / OSPAR

15 Governments of the western coasts and catchments of Europe are members of the Commission

for the Protection of the marine Environment of the North-East Atlantic. OSPAR investigated mercury

as hazardous substance of concern as early as the 1980s, e.g. [PARCOM 1981, 1982] and elaborated

http://www.mercury2009.org/



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for example recommendations on land-based sources of mercury pollution and also addressed

specific industrial sectors such as the chlor-alkali industry [PARCOM, 1981a and 1982a, 1985].

More recent agreements from OSPAR focus on the management of contaminated, dredged material

[OSPAR 2009] and the realisation of coordinated monitoring programmes [OSPAR 2008].



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5.6 References

[Basel 2010] http://www.basel.int/ Concorde 2009] Concorde sprl, Assessment of excess mercury in Asia, 2010-2050, May 2009, http://www.chem.unep.ch/mercury/storage/Asian%20Hg%20storage_ZMWG%20Final_26May2009.pdf [COWI 2008] COWI A/S and Concorde East/West Sprl, Options for reducing mercury use in products and applications, and the fate of mercury already circulating in society, December 2008 http://ec.europa.eu/environment/chemicals/mercury/pdf/study_report2008.pdf [Decreto 2003] Criteri di ammissibilità dei rifiuti in discarica. Ministero dell'ambiente e della tutela del territorio, 13 marzo 2003, Italy http://www.reteambiente.it/normativa/4355/dm-ambiente-13-marzo-2003/ [Deponieverordnung 2008] 39. Verordnung des Bundesministers für Land- und Forstwirtschaft, Umwelt und Wasserwirtschaft über Deponien, Januar 2008, Germany [DepVereinfachV 2009] Verordnung zur Vereinfachung des Deponierechts, Germany 27. April 2009, http://www.bmu.de/files/pdfs/allgemein/application/pdf/depvereinfv.pdf [DOE 2009] U.S. Department of Energy, Interim Guidance on Packaging, Transportation, Receipt, Management, and Long-Term Storage of Elemental Mercury, U.S. Department of Energy Office of Environmental Management Washington, D.C., November 13, 2009, http://www.mercurystorageeis.com/Elementalmercurystorage%20Interim%20Guidance%20(dated%202009-11-13).pdf [DNSC 2004] Defense National Stockpile Center, Record of Decision for the Mercury Management EIS, April 2004 [FNADE/ADEME 2006] Feedback on the French system, stabilisation/solidification-landfilling of hazardous waste, FNADE/ADEME, 2006 [IKIMP 2009] Briefing note for participants for "Workshop on Safe Storage and Disposal of Redundant Mercury", St Anne’s College, Oxford (UK), 13th & 14th October, 2009,




http://www.reteambiente.it/normativa/4355/dm-ambiente-13-marzo-2003/

http://www.bmu.de/files/pdfs/allgemein/application/pdf/depvereinfv.pdf

http://www.mercurystorageeis.com/Elementalmercurystorage Interim Guidance (dated 2009-11-13).pdf




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http://www.mercurynetwork.org.uk/wp-content/uploads/2009/09/IKIMP_storage-disposal_briefing_r1.pdf [Kabinett 2008] Begründung Verordnung zur Vereinfachung des Deponierechts (Stand – Kabinettbeschluss am 24.9.2008) http://www.bmu.de/files/pdfs/allgemein/application/pdf/depvereinfv_begr.pdf [Kystverket 2008] Det Norske Veritas AS, Kystverket Norwegian Coastal Administration - Salvage of U-864 - Supplementary studies - disposal, report NO. 23916-6, Revision N° 01, 2008 http://www.kystverket.no/arch/_img/9818145.pdf [Legisation36 2006] Recueil de Legislation No 36 Mise en décharge des déchets (Legislation 36), 2 mars 2006, Luxembourg [Miljøministeriet 2009] 252 af 31/03 2009. Bek. om deponeringsanlæg, 31. marts 2009, Denmark [NO 2005] Stakeholder meeting in Brussels 8 September 2005. Additional questions, Answers from the Norwegian authorities http://ec.europa.eu/environment/chemicals/mercury/doc/norway_2.doc [OSPAR 2008] OSPAR Coordinated Environmental Monitoring Programme (CEMP) (This agreement replaces agreement 2007-01), Brest 2008 [PARCOM 1981] PARCOM Recommendation 81/1 on Other Land-Based Sources of Mercury Pollution (Thermometers, Batteries, Dental Filters), Brussels 1981 [PARCOM 1981b] PARCOM Decision 81/2 on Limit Values for Existing Brine Recirculation Chlor-Alkali Plants (exit of the factory site), Brussels 1981 [PARCOM 1982] PARCOM Recommendation 82/1 on Other Land-Based Sources of Mercury Pollution, Copenhagen 1982 [PARCOM 1982a] PARCOM Decision 82/1 on New Chlor-Alkali Plants Using Mercury Cells, Copenhagen 1982

http://www.mercurynetwork.org.uk/wp-content/uploads/2009/09/IKIMP_storage-disposal_briefing_r1.pdf


http://www.bmu.de/files/pdfs/allgemein/application/pdf/depvereinfv_begr.pdf

http://www.kystverket.no/arch/_img/9818145.pdf

http://ec.europa.eu/environment/chemicals/mercury/doc/norway_2.doc



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[PARCOM 1985] PARCOM Recommendation 85/1 on Limit Values for Mercury Emissions in Water from Existing Brine Recirculation Chlor-Alkali Plants (exit of factory site), Brussels 1985 [Schedule10 2007] The Landfill (Amendment) Regulations (Northern Ireland) 2004 Statutory , Rule 2004 No. 297, The Landfill (Amendment) Regulations (Northern Ireland) 2004 [Scotland Directive 2005] The Environment Act 1995, The Criteria And Procedures For The Acceptance Of Waste At Landfills (Scotland) Direction 2005 [Seveso Guidance 2005] Guidance on the preparation of a safety report to meet the requirements of Directive 96/82/EC as amended by Directive 2003/105/EC (Seveso II), Report EUR 22113 EN, Institute for the protection and security of the citizen, Major accident hazardous bureau, European Commission, DG Joint Research Centre, 2005 http://mahbsrv.jrc.it/downloads-pdf/safety_report_guidance_EN.pdf [UNEP 2007] Draft technical guidelines on the environmentally sound management of mercury wastes, 2007, http://www.basel.int/techmatters/mercury/guidelines/240707.pdf [UNEP 2009] UNEP, Draft technical guidelines on the environmentally sound management of mercury wastes, 4th Draft, April 2009, http://www.basel.int/techmatters/mercury/guidelines/040409.doc [UNEP 2009 A] UNEP Chemicals, EXCESS MERCURY SUPPLY IN LATIN AMERICA AND THE CARIBBEAN, 2010-2050, ASSESSMENT REPORT, July 2009 http://www.chem.unep.ch/mercury/storage/LAC%20Mercury%20Storage%20Assessment_Final_1July09.pdf [UNEP 2009 B] http://www.chem.unep.ch/MERCURY/ [US ban 2008] Mercury export ban Act 2008, Public Law 110-414 - Oct, 14., 2008, 122 Stat. 4341, http://www.govtrack.us/congress/bill.xpd?bill=s110-906 [VLAREM 1995] VLAREM II: Order of the Flemish Government of 1 June 1995 concerning General and Sectoral provisions relating to Environmental Safety, 1th June 1995, Belgium

http://mahbsrv.jrc.it/downloads-pdf/safety_report_guidance_EN.pdf


http://www.chem.unep.ch/mercury/storage/LAC Mercury Storage Assessment_Final_1July09.pdf


http://www.chem.unep.ch/MERCURY/

http://www.govtrack.us/congress/bill.xpd?bill=s110-906



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[WHO 2005a] World Health Organisation, Policy Paper: Mercury in health care, August 2005; http://www.who.int/water_sanitation_health/medicalwaste/mercurypolpaper.pdf [WHO 2007] World Health Organisation, Preventing disease through healthy environments exposure to mercury, A major public health concerns, Geneva 2007 [WHO 2007a] World Health Organisation, risks of heavy metals from long-range transboundary air pollution, Joint WHO/Convention Task Force on the Health Aspects of Air Pollution, Germany 2007 [WHO 2008] World Health Organisation, Assessing the environmental burden of disease at national and local levels. Environmental Burden of Disease Series, No. 16, Geneva 2008

http://www.who.int/water_sanitation_health/medicalwaste/mercurypolpaper.pdf



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6 Review of the state of the art of storage and disposal options

6.1 General considerations

Almost all mercury compounds are toxic and can be dangerous at very low levels in both aquatic and

terrestrial ecosystems. Mercury is a persistent substance. It can build up or bioaccumulate in living

organisms and inflict increasing levels of harm on higher order species such as predatory fish and fish

eating birds and mammals through a process known as "biomagnification". In the environment,

mercury and its compounds are readily transformed from one form to another and transported over

long and short distances (see chapter 4)

Consequently, each contamination of the environment due to anthropogenic releases of mercury or

its compounds should be prevented or minimised during its extraction, use, transport and temporary

storage or permanent disposal.

Against the background of the present project, the focus here is laid upon the risk that mercury or its

compounds are released under permanent or temporary storage conditions and related pre-

treatment and disposal operations. Corresponding risks are anthropogenic releases of mercury in the

short and long term due to

• leaching or

• evaporation or

• solid releases (e.g. dust)

from

• pre-treatment (immobilisation) and

• storage/disposal operations and

• storage/disposal

Figure 6-1: Illustration of possible releases of mercury related to the temporary or permanent storage of mercury

pre-treatment

disposal operations

storage/ disposal

vapor

leachate

solids (e.g. dust)



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Pre-treatment (immobilisation) before storage or disposal of metallic mercury may require additional

transport and/or handling of the mercury and may be related to additional releases of mercury. An

overview of possible pre-treatment technologies and relevant emissions is provided in chapter 7.

The disposal of hazardous waste generally aims at the isolation of hazardous substances from the

biosphere and groundwater. Related risks are possible due to the release and transport of hazardous

substances from the storage or disposal site. The permeability / impermeability of the geological

barrier depends on the site-specific hydraulic conductivity and the possible appearance of fractures

of the host rock. The corresponding risk depends on the substance properties and on artificial and

natural barriers between the waste and the biosphere. The risk depends therefore on the following

parameters:

• physico-chemical parameters of the hazardous waste (e.g. stability, solubility, reactivity)

• technical parameters of the containments (e.g. material and thickness of the containment,

properties of sealants) and the disposal facility (e.g. engineered barriers)

• natural parameters of the facility (e.g. geology, hydrology)

Once mercury waste is temporarily or permanently stored, the risk of releases depends on the waste

itself (substance/mixture and state of the substance) and the short and long term transmissibility52 of

the artificial and geological barriers that separate the waste from the environment. The number and

in particular the effectiveness of these barriers define the protection of the environment against

adverse effects from the stored waste. This so called multi-barrier concept is in particular applicable

to underground storage but also above-ground storage typically consists of more than one barrier to

prevent hazardous chemicals released from the waste from entering the biosphere.

Figure 6-2: Protection layers for the storage of mercury

The environmental risk of stored mercury waste is therefore related to the short and long-term

transmissibility for liquid mercury, leachate and vapour as possible source of releases, its possible

52 Transmissibility means the permeability of the barriers for components of the waste.

Geological barrier(s) (far field)

Artificial barrier(s) (near-field)

Waste

(source term)



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environmental transport and related environmental and/or human exposure. It must be assessed in

the light of geological and artificial barriers (such as containment, back fillings) and the state of the

waste (e.g. whether it is stabilised or not). For the acceptance of hazardous waste in underground

storage sites, a site-specific safety assessment must be carried out (according to section 2.5 of

Council Decision 2003/33/EC and as defined in Annex A of that Decision). The long term assessment

should be assessed without taking account of the containment of the waste and cavity lining (see

section 1.2.7 Council Decision 2003/33/EC) as it is assumed that the containment will not persist in

the long term. Waste may be accepted only if it is compatible with the site-specific safety

assessment.

For above-ground facilities, waste acceptance criteria are established in Decision 2003/33/EC.

The transmissibility of the barriers is related to the physico-chemical properties of the components

of the stored waste. For the assessment of potential releases and associated risks, a set of physico-

chemical parameters of mercury and relevant mercury compounds is relevant, such as volatility,

solubility, leachability, reactivity, and the octanol/water partition coefficient. An overview of the

most important parameters is given in chapter 4.

Relevant substances are elemental mercury and all mercury compounds that will potentially be

stored (temporarily or permanently). Organic mercury compounds (e.g. methyl mercury) will not be

stored or disposed of. However, it should be noted once again that metallic mercury released in the

environment may be transformed into organic compounds and cause severe environmental and

health risks.

Particularly when considering the underground storage/disposal, specific factors affecting the

behaviour of mercury in the host rock and the geological environment need to be considered apart

from the waste properties and the storage system (layout, containments, storage place and

conditions, monitoring, access conditions, closure strategy, sealing and backfilling, depth of the

storage place). These include particularly (see [Heath 2006]):

• Geology (lithology, structure, stability)

• Hydrogeological factors (hydraulic gradient, hydraulic conductivity / permeability)

• Geochemical factors (pH, redox, other cations and complexation agents in solution)

• Retardation/attenuation processes

o Hydrodynamic dispersion

o Diffusion

o Sorption and ion exchange (pH dependent)

o Precipitation and co-precipitation (redox dependent)

o Microbiological factors



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• Establishment of distribution coefficient, ‘Kd’ (equilibrium ratio of the sorbed to dissolved

concentrations)

Experiences related to the underground storage of liquid waste mercury are not available as mercury

is still a valuable product used for various applications worldwide (see chapter 1.1). Up-to-date

relevant experience or investigations are available from

• permanent storage of mercury containing waste in salt mines (in particular German

experience from storage of hazardous waste) (see section 6.2.2)

• permanent storage in deep hard rock underground formations of hazardous waste (Swedish

experience on deep bedrock and stabilisation as HgS) (see section 6.2.3)

In addition, specific experience and investigation is available from the worldwide work on

underground disposal of radioactive waste which relies particularly on the principle of isolating the

radioactive waste from the biosphere for a very long time (see section 6.2.4).

The review related to the temporary storage of metallic mercury above ground is based on

experience from the temporary storage of liquid mercury in the USA and of Mayasa in Almadén

(former mercury mine), which stores and handles significant quantities of mercury as a product (see

section 6.3).

The containment of the waste is in particular important for the temporary storage of liquid mercury

as it has to ensure a safe containment of the waste for a certain period of time. For long-term

storage the major function of the container is to ensure a safe handling of the waste before storage

(and for a certain time period until the waste cell is closed). An overview of the containers currently

used in Europe for the transport and storage of liquid mercury (as a product) and as well as the

packaging system used in the USA for a foreseen storage period of 40 years, are described in section

6.4).

6.2 Review of underground disposal operations

Underground disposal is based on the principle of isolating waste from the biosphere in geological

formations where it is expected to remain stable over a very long time. Information on experience

from current underground storage of liquid mercury is not available. In the European Union the

acceptance of liquid waste is forbidden in landfills (Article 5(3)(a), Directive 1999/31/EC). A review of

the state-of-the-art of disposal operations for hazardous waste, and in particular metallic mercury, in

salt mines or deep underground hard rock formations can take account of experience with the

underground disposal of hazardous waste and radioactive waste.

Experience with the disposal of mercury-containing waste and other hazardous waste has been

available for several decades (e.g. underground waste disposal since 1972 in a German salt mine).

Valuable information can also be drawn from experience in the underground disposal of radioactive



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waste. In order to ensure an appropriate level of safety via the geological barrier, underground

disposal of radioactive waste is usually carried out in depths ranging from several hundred to about

one thousand metres (see e.g. [IAEA 2009]).

Although the properties of radioactive waste are somewhat different to liquid mercury,53 experiences

from research in particular related to geological requirements of host rocks like the stability are also

valid for the permanent storage of liquid mercury.

The most relevant sources of information related to the underground disposal which were consulted

are listed below:

Table 6-1: Overview of literature related to the storage of liquid mercury

53 Radioactive waste is typically solid or immobilised, partly heat generating and the hazardousness decreases

over a long period. In contrast to this, metallic mercury waste is primarily liquid, it does not generate heat and its hazardousness remains stable over unlimited time.

Review of important literature related to underground storage options

Reference Content

[BGR 2007]

BGR, Bundesanstalt für Geowissenschaften und Rohstoffe, Nuclear waste disposal in Germany - Investigation and evaluation of regions with potentially suitable host rock formations for a geologic nuclear repository, Hannover/Berlin, April 2007

This study summarizes the findings related to a geological disposal of nuclear waste in Germany including minimum requirements for the host rock.

[GRS 2008]

GRS, Gesellschaft für Anlagen- und Reaktorsicherheit (GRS) mbH, Öko-Institute e.V., Institut für angewandte Ökologie, Endlagerung wärmeentwickelnder radioaktiver Abfälle in Deutschland, Anhang Wirtsgesteine – Potentielle Wirtsgesteine und Eigenschaften, Anhang zu GRS-247, ISBN 978-3-939355-22-9, Braunschweig/Darmstadt, September 2008

This annex comprises main properties of possible host rock for the disposal of radioactive waste in Germany. It provides a broad overview of the different properties of potential host rocks including their advantages and disadvantages in view of a safe long term storage.

[IAEA 2009]

Geological Disposal of Radioactive Waste: Technological Implications for Retrievability

http://www-pub.iaea.org/MTCD/publications/PDF/Pub1378_web.pdf

This report provides an overview of the current status of geological disposal of radioactive waste. The report assesses the technological implications of retrievability in geological disposal concepts. Scenarios for retrieving emplaced waste packages are considered, and the publication aims to identify and describe any related technological provisions that should be incorporated into the design, construction, operational and closure phases of a



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A list of all references used for this chapter is provided in chapter 6.5. Additional information

received personally during the research is also included in this section.

6.2.1 Potential host rocks

In Europe, many deep mines of different types of rock exist which might be generally suitable for the

storage of hazardous waste [Popov 2006]. Depending on their geological formation, mines which are

currently still in use might be used as hazardous waste disposal sites in future. Information on

existing underground disposal sites is mainly available for EU 15. But also in the Eastern European

repository.

[KEMAKTA 2007] Lars Olof Höglund and Sara Södergren, Aspects on final disposal of mercury – The need for waste stabilization, 22 March 2007

The purpose of this document was to establish background documentation for the proposal of the Hg-Regulation.

[Popov 2006]

V. Popov, R. Pusch, Disposal of Hazardous waste in underground mines, Wit Press, Southhampton, Boston, 2006

This book contains a collection of articles presenting the current experiences in the utilization of underground mines for the safe storage of hazardous waste. The book provides a broad overview of mines in Europe (active and inactive). In addition, articles by various authors to the following topics are included: Criteria for selection of repository mines, engineered barriers, stability analysis of mines, risk assessment of underground repositories.

[SOU 2008A]

Statens offentliga Utredningar (SOU) 2008: 19: Att slutförvara långlivat farligt avfall i undermarksdeponi i berg - Permanent storage of long-lived hazardous waste in underground deep bedrock depositories, , SOU 2008: 10 April 2008

This study – commissioned by the Swedish government – analyses the permanent storage of mercury in deep bedrock and salt mines. The report provides an account of permanent storage options for mercury-containing waste, and the requirements and risks attendant to the permanent storage of liquid mercury.

A summary on the key findings of the study is available in English [SOU 2008]

[SOU 2001]

NATURVÅRDSVERKET, A Safe Mercury Repository, A translation of the Official Report SOU 2001:58, Report 8105, January 2003

This report was prepared before the Hg-Regulation entered into force. It recommends that waste containing at least one percent mercury by weight be taken to a permanent deep bedrock repository (at least 400m). The repository should isolate mercury from the biosphere for a very long period, preferably more than 1,000 years. The repository should require no maintenance to avoid burdening future generations.



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countries underground disposal sites are in place (e.g. Slovenia) or planned (e.g. Poland).

Appropriate host rock for disposal of metallic mercury according to Council Decision 2003/33/EC are

salt rocks and hard rocks (igneous rocks, e.g. granite or gneiss including also sedimentary rocks e.g.

limestone or sandstone). Furthermore, deep storage in hard rock with an appropriate depth is

defined as an underground storage at several hundred metres depth (WAC Decision, Appendix A (4)).

In a geological sense, the term hard rock includes igneous rocks (e.g. granite or basalt), metamorphic

rocks (e.g. slate, marble, gneiss, schist) and sedimentary rocks (e.g. sandstone, shale, limestone). Salt

rock is a specific sedimentary rock. Further, it can be differentiated between consolidated and non-

consolidated rocks. Consolidated rocks consist of a mixture of minerals with primary solid matrix

material. Examples are breccia/conglomerate, sandstone or claystone. Non-consolidated rocks are

non-bound fragmental rocks without solid matrix material. Examples are gravel, sand or clay. Each

type of consolidated hard rock is theoretically possible for underground disposal sites for mercury.

This generally corresponds to experiences from disposal options for radioactive waste according to

which preferred host rocks could be hard rock (i.e. crystalline igneous rock), clay rock (i.e. igneous

sedimentary rock) and salt rock. Underground laboratories for testing and building confidence in

disposal technologies for the disposal of radioactive waste have been built in all types of potential

host rocks [IAEA 2009].

The host rock properties are decisive for the design and the operational and environmental safety (in

the short and long term) of an underground disposal site and other relevant aspects (e.g.

retrievability, costs, etc.). Relevant properties of potential host rocks are in particular available from

experience in underground disposal of radioactive waste (see [IAEA 2009]), [BGR 2007] and [GRS

2008].

In the following, an overview is provided on the properties, available experiences, economic and

environmental information of potential host rocks for the storage of liquid mercury.



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6.2.2 Salt rock

6.2.2.1 Properties

Salt host rocks exist in different geological formations as layered salt and salt domes, usually of a

sodium or potassium type. Both geological formations may in principle be used for disposal purposes.

The following table summarizes the main properties of salt rock related to its suitability as a host

rock (source: [GRS 2008], [GRS 2009], [Popov 2006]):

Table 6-2: Overview of properties of salt rock

Criteria Properties

Permeability Very low (practically impermeable)

Mechanical Strength: Medium

Deformation behaviour: Visco-plastic (creep)

Stability of cavities: Self-supporting

In situ stresses: Isotropic

Dissolution behaviour: High

Sorption behaviour: Very low

Salt rock is very dry, it contains no free water and offers very good isolation of the waste. Under

natural disposal conditions rock salt is practically impermeable to gases and liquids. Together with an

overlying and underlying impermeable rock strata (e.g. claystone), it acts as a geological barrier

intended to prevent groundwater entering the landfill and, where necessary, effectively to stop

liquids or gases escaping from the disposal area (see Council Decision 2003/33/EC). On the other

hand, salt rocks are highly soluble, thus any access of water would cause severe consequences on the

host rock. Salt rock is perfectly impermeable with respect to water and gas [Popov 2006] as a

consequence no gas producing materials should be stored to avoid an increase of pressure in the

rock. Recent research give indications that in case of gas generation there will be no “explosion” and

the gas will not escape via a macroscopic fracture – as assumed so far. According to [Popp 2007]

recent research micro fractures occur in the near field along existing grain boundaries with the effect

that an increased volume is available for the generated gas. It can be concluded that the permeability

of the surrounding salt rock decreases in the near field and is only relevant for a defined area around

the stored material. It stops as soon as the pressure does not increase anymore. [Brückner 2003,

Popp 2007]

Salt rocks generally have a low sorption capability (see [GRS 2009]. Information related to its sorption

capacity for mercury has not been identified.

The hydraulic conductivity of rock salt is very low. In [GRS 2008] the following values have been

indicated for rock salt:



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Hydraulic conductivity (Kf in m/s) Average depth of

samples

N° of

samples Range Median value

Rock salt 300 – 841 m 75 9.81 x 10-17 - 2.94 x 10-10 5.50 x 10-14

A liner is usually not required in salt formations. Here, rock creep is a continuous process leading to

rock deformation in response to lithostatic pressure. Salt creep will close the void space around

waste packages in the emplacement cells, leading to complete encapsulation. The creep rate

depends on in situ stress (increasing with depth) and temperature.

The investigation of the structure of layered salt mines is easier – compared to salt domes, and well

established investigation methods are available [GSR 2008]. In particular, the presence of brine in

local lenses or irregular structures or fissures may cause difficulties for a safe storage. Therefore, the

presence of such structures has to be excluded via a site-specific safety assessment. [Popov 2006].

Due to its plastic deformation behaviour the salt rock encapsulates wastes in the long term. The

encapsulation process is enhanced by backfill material. Given that salt encapsulation is one of the

main safety elements of a disposal concept in salt, it is advantageous to backfill the emplacement

cells rapidly after waste emplacement, and keeping the disposal cells open has never been

considered in the German salt based repository concept (for disposal of radioactive waste) [IAEA

2009]. The most appropriate backfilling material for salt rock is crushed salt rock with a major barrier

function [Popov 2006]. At the German underground Herfa-Neurode waste disposal site, salt dams are

filled up or stone walls are built in order to separate the storage cells and to facilitate the ventilation

of the disposal site.

The operators of the Herfa-Neurode disposal site assume that the galleries of the underground salt

mine will be completely closed within some thousand years54.

Long-lasting seals in the form of plugs in the shafts leading down to the repository level are required

since water inflow from shallow soil and rock can cause very difficult problems [Popov 2006]. The

plug system has to be adapted to site specific requirements.

6.2.2.2 Experience of underground disposal of hazardous waste in salt mines

Hazardous wastes including mercury contaminated solid wastes have been deposited in underground

salt mines for several decades in Europe. Therefore, an extensive knowledge base on all repository

relevant properties of rock salt and salt formations is available (in particular in Germany).

In Europe, salt mines are currently authorised for the underground disposal of hazardous waste only

in Germany and the UK. Poland is currently considering using specific salt mines for the disposal of

hazardous waste.

54 Personal Communication, Dr. Lukas, K&S Entsorgung GmbH, 5.11.2009



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In France, the first underground landfill was opened in February 1999 in a potash-salt mine in

Wittelsheim, France-Alsace, with a licensed capacity of 320,000 tons (for 30 years). 13 different

waste types including galvanisation sludge, spent catalysts and residues from waste incineration

were licensed. The deposit of explosive and flammable wastes was forbidden. In September 2002, a

fire broke out in the underground landfill which may have been caused by improper disposal. As a

consequence of the fire, the landfill and the adjacent mine were closed. [UBA DE 2004]

Salt mine in the UK

A relatively new salt mine deposit for the storage of hazardous waste has been operating in

Winsford, Cheshire, United Kingdom since 2005 (Minosus rock salt mine). The site is permitted

according to the IPPC directive and has a licence for selected waste codes.

At Minosus rock salt mine, waste disposal takes place at a specific 30-hectare worked-out area of the

mine and its activities will have no impact upon either continuing rock salt extraction or upon the

area dedicated to and used for archiving and document storage.

The site consists of a 200 million year-old bed of rock salt formation and the hazardous waste is

disposed of at a depth of 170m. The storage capacity of the mine is 2 million tonnes of hazardous

waste over the next 20 years including incinerator and heavy industry waste and asbestos. Up to

100,000 tonnes of suitably packaged wastes can be handled each year. [Minosus 2009]

The facility is licensed to handle different categories of waste – including hazardous waste such as air

pollution control residues – some of which will be disposed of and some stored. The range of waste

accepted includes ashes with dangerous substances, which might also be mercury. Currently, the

facility is not permitted to receive mercury wastes (source: questionnaire survey reply UK).

Under its Environment Agency permit, Minosus can accept 42 different categories of waste included

in the European Waste Catalogue. A further 24 potential waste categories are permissible but are

subject to Environment Agency improvement orders. [Minosus 2009]

While the Minosus facility is exempt from the need to meet the leaching limit values imposed by the

Waste Acceptance Criteria Decision, the company does have its own parameters for waste

acceptance55. The waste acceptance procedure follows the provisions of Directive 2003/33/EC (see

chapter 5). The containers will be opened upon arrival for further sampling to verify their contents

and then sealed again before being taken underground.

Before the permit was given to the Minosus mine extensive research and assessments have been

carried out related to the long-term safety of the storage site. “No other waste management facility,

save for those in the nuclear industry, has been as deeply researched and assessed as the Minosus

facility” [extract of the report commissioned by the Environment Agency and prepared by Cranfield

University in 2004, [Minosus 2009]. The elaborated scenarios look forward as far as 50,000 years into

the future.

55 http://www.veoliaenvironmentalservices.co.uk/pages/minosus_wastesaccepted.asp

http://www.veoliaenvironmentalservices.co.uk/pages/minosus_wastesaccepted.asp

http://www.veoliaenvironmentalservices.co.uk/pages/minosus_wastesaccepted.asp



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Salt mines in Germany

Germany has many years of experience in the storage of hazardous waste in underground landfills. In

total, 3 companies are authorised to permanently store mercury containing waste in 5 salt mines

whereof one of the sites is not currently in operation. Official long term safety and risk analysis

studies exist for these disposal sites. Storage is carried out in depths of several hundred metres.

The following is a synopsis of information (on capacities, acceptance criteria, site specific assessment,

other information) from the following underground disposal salt mines (UDSM):

• Germany, Herfa-Neurode (Hesse) underground waste disposal

• Germany, Zielitz (Saxony-Anhalt) underground waste disposal

• Germany, Borth (North Rhine-Westphalia) underground waste disposal (valid permit but not

in operation)

• Germany, Heilbronn (Kochendorf, Baden-Württemberg) underground waste disposal

• Germany, Sondershausen underground waste disposal

All in all, approximately three million tonnes of hazardous waste have been disposed of in the two

disposal sites Herfa-Neurode (since 1972) and Zielitz (since 1995). Herfa-Neurode was the first

worldwide, and is still the biggest hazardous waste underground disposal salt mine. Sondershausen

has been in operation since 2006 and Heilbronn since 1978.

At Heilbronn, Herfa-Neurode, Zielitz and Sondershausen a large variety of waste codes are

authorised for underground waste disposal. Apart from the specifically addressed mercury-

containing waste (e.g. 06 04 04* wastes containing mercury from inorganic chemical processes) also

other types of waste may contain mercury or mercury compounds such as waste types specified as

“containing heavy metals” or “containing hazardous substances” (Directive 2000/532/EC ).

According to information from the operator of the two disposal sites Herfa-Neurode and Zielitz,

several ten-thousands of tonnes could be disposed of in a short time frame. Annual technical

capacities in Zielitz are 70,000 tonnes, in Herfa-Neurode 200,000 tonnes. Currently authorised

capacities at the smaller Zielitz facility amount to approximately two million tonnes (an extension of

the capacities is possible). Sondershausen has a remaining storage volume of more than one million

m³.

Operation of the underground disposals

Prior to the transport of the waste to the facility the generator/owner of the waste has to obtain the

facilities’ approval to transport the waste to the facility. For the approval the waste owner has to

send a description and analysis of the composition of the waste to the facility owner. After a first

check at the disposal site, the documents have to be sent to the relevant authorities and the



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acceptance of the waste has to be approved by the authority.

Typical operations in an underground disposal in salt mines include the following [information based

on a site visit to Herfa-Neurode]:

The waste is transported to the underground disposal site by truck or train. Depending on the waste

identity (toxicity, pH, residual moisture, share of particulate matter), appropriate containers (steel

panel barrels, steel panel containers or large bags) are used for the transport of the waste.

At reception the waste documents, the delivered amounts and the packaging are checked and

random samples of the waste are analysed (degassing, visual inspection, chemical composition).

Waste is only unloaded if the waste is identified as indicated in the waste documents and fulfils

specific waste acceptance criteria. Otherwise the disposal of the waste is rejected. Accepted waste is

unloaded and transported to the shaft where it is then transported underground.

Underground special purpose vehicles bring the waste to the place of final disposal in the mine. The

waste is unloaded from the vehicles and stacked in staples of steel panel barrels, steel panel

containers or large bags.

Walls are built up and separate the single material groups from each other. As soon as a field is filled,

it is closed off with up to 15-metre-wide dams.

The underground disposal sites can be organised like warehouses. A sample of each waste is stored

in a sample room underground. Storage place and storage time can be documented and waste can

be removed from the mine if required.

Safety aspects

Long term

All salt mines can provide proof that the waste is securely isolated, long-term and completely from

the biosphere on the basis of an officially accepted certificate issued by an independent institution.

The German salt mines are classified as landfill for hazardous waste, underground disposal, DHAZ.

Accordingly, they are subject to special requirements listed in Appendix A of Council Decision

2003/33/EC.

Operational phase

The German salt mines are all acknowledged as certified waste management facilities.

In order to minimise risks such as fire, explosion, toxic gas, unintended reactions, unacceptable smell,

infections or radioactive contamination, waste is only accepted if it corresponds to specific waste

acceptance criteria (see 56, 57, 58, 59).

56 http://www.uev.de/eng/pdf/uev_f_04.pdf 57 http://www.ks-entsorgung.com/export/sites/ks-entsorgung.com/de/pdf/annahmebedingungen_utd_herfa-

neurode.pdf (in German)

http://www.uev.de/eng/pdf/uev_f_04.pdf

http://www.ks-entsorgung.com/export/sites/ks-entsorgung.com/de/pdf/annahmebedingungen_utd_herfa-neurode.pdf

http://www.ks-entsorgung.com/export/sites/ks-entsorgung.com/de/pdf/annahmebedingungen_utd_herfa-neurode.pdf

http://www.ks-entsorgung.com/export/sites/ks-entsorgung.com/de/pdf/annahmebedingungen_utd_zielitz.pdf

http://www.ks-entsorgung.com/export/sites/ks-entsorgung.com/de/pdf/annahmebedingungen_utd_zielitz.pdf

http://gses.de.server378-han.de-nserver.de/uploads/media/UTD-Annahmebedingungen_07-2006.pdf



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In accordance with Decision 2003/33/EC, waste is only accepted if random tests have proven that the

waste has the identity as indicated in the corresponding waste documents and fulfils the waste

acceptance criteria. Otherwise the disposal of the waste is rejected.

Depending on the waste identity the waste is disposed of in appropriate containers (steel panel

barrels, steel panel containers or large bags) and eventually an appropriate inner packaging in order

to facilitate the handling of the waste (e.g. during sampling) and/or to protect the containers from

corrosive waste.

Salt mines are typically equipped with a ventilation system. According to the information received

from the operator of Herfa-Neurode, the salt mine is equipped with a permanent monitoring system

which – apart from other parameters – already monitors the mercury concentration in the air.

6.2.2.3 Economic information – hazardous waste in salt mines

According to information from the operators of the disposal sites Herfa-Neurode, Zielitz,

Niederrhein, Heilbronn and Sondershausen (all in Germany), the costs for disposal of 1 tonne of

hazardous waste is approximately 260-900 euros, irrespective of the hazardousness of the disposed

waste (e.g. metallic mercury or pre-treated mercury). The only condition is that the site-specific

waste acceptance criteria are fulfilled. The upper end of the price already includes additional costs

which might result from specific storage requirements for hazardous waste (e.g. separate chamber,

isolated area). The prices are based on recent conditions. Depending on additional requirements that

facilities have to fulfil for the storage of liquid mercury (e.g. regular monitoring and inspection), the

price might be higher. The costs for temporary storage in salt mines depend on the necessary

additional monitoring, inspection requirements and the costs for the retrieval of the stored material.

6.2.2.4 Environmental and safety aspects related to the storage of hazardous waste in salt mines

Due to its plastic deformation behaviour, salt rock may completely enclose metallic mercury in a gas-

tight and impermeable geological barrier. Under natural disposal conditions, rock salt is practically

impermeable to gases and liquids. [BGR 2007]

A study [Siemann 2007] investigated the origin and migration behaviour of mineral bonded gases in

evaporite (salt rock). The study concludes that gases which have been generated during the

sedimentation and diagense (forming of the rock) have not moved significantly before they have

been finally fixed in the investigated salt rock. This means that the gases have been fixed in the salt

rock for 250 million years. Undisturbed salt rock can therefore be seen as gas tight even in cases of

the easily migrating hydrogen molecule.

58 http://www.ks-entsorgung.com/export/sites/ks-

entsorgung.com/de/pdf/annahmebedingungen_utd_zielitz.pdf (in German) 59 http://gses.de.server378-han.de-nserver.de/uploads/media/UTD-Annahmebedingungen_07-2006.pdf (in

German)



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In long term storage, the only effective barrier to prevent hazardous waste entering the environment

is the salt rock and its specific isolation criteria. Therefore, a minimum thickness of the salt layer is

needed around the waste to ensure the safe encapsulation of it. For short-term storage, additional

engineered barriers, such as containment or constructed barriers, can be applied.

For the storage of radioactive waste, minimum requirements for the thickness of the host rock have

been established to ensure a safe storage [BRG 2007]. These criteria are included in section 6.2.4.1.

On the basis of literature available on the subject (e.g. [Popov 2006], [IAEA 2009]), salt mines in

general are seen as appropriate for the storage of hazardous waste. But only mines located several

hundred metres below the ground surface should be considered as appropriate for storage of

hazardous waste [Popov 2006].

[Env Canada 2001] also included the disposal of mercury waste in conventional mines and solution

mines in its analysis. While solution mines60 have been assessed as less appropriate with regard to

health, safety, environment and plant operations, the disposal of mercury waste in conventional

mines (e.g. slat, potash, gypsum, limestone or underground granite) has been assessed as highly

suitable for the disposal of excess mercury. But only on condition that pre-treated waste containing

mercury is placed in a stable semi-soluble form in containers. According to [Env Canada 2001]

conventional mines could also be used as a long-term underground warehouse, if retrievability for

recycling were desired.

[USEPA 2002c] included in the analysis of alternatives for the long-term management of excess

mercury the temporary storage of liquid (bulk) mercury as well as the disposal of pre-treated

(stabilised) mercury waste. In particular, the temporary storage of liquid mercury in an already

existing mine cavity has been evaluated as an appropriate storage option for liquid mercury.

In Germany, the disposal of liquid mercury in salt mines is seen as a long term safe solution as long as

all legal requirements are fulfilled and the long-term assessment of the underground facility allows

the storage of liquid mercury (source: questionnaire survey German EPA).

However, until now only very limited information is available related to the behaviour of liquid

mercury in salt rock. First research results relating to the solubility of metallic mercury and mercury

compounds in saline solutions are available but have to be further investigated [GRS 2008A,

personnel information: Mr. Hagemann, GRS]. Indications suggest that the solubility of mercury in salt

solutions is lower compared to pure water [GRS 2008A] but is nevertheless significantly higher

compared to mercury sulphide for example, see also section 4.1.2.

According to information from German authorities, a project is planned to test the behaviour of

metallic mercury in salt and salt solutions. The intended start of this project is in 2010 (source:

60 Mines which have been created by solution mining which means the extraction of the materials from the

earth by leaching and fluid recovery.



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questionnaire survey German EPA, personal communication Ms. Hempen, BMU61). According to the

information received from the German Environment Ministry, permanent storage of metallic

mercury in a German salt mine would not be authorised before the results of the study are available.

Most probably the planned project also includes investigations about the behaviour of stabilised

mercury or mercury compounds in salt rock.

There are also concerns related to salt host rock as a permanent storage site for liquid mercury.

A Swedish report [SOU 2008] states that salt mines have properties which enable the waste to be

completely enclosed. But for this to occur it is important that “the deformations occur without

cracks, and the shafts, inspection drill-holes and the like that link the terminal storage facility to

flowing groundwater are properly sealed. If waste contamination leaks from the salt formation, it is

crucial that the surrounding rock has a natural ability to immobilise it, to ameliorate the effects of a

leak.”

In the report, possible scenarios for the permanent underground storage of liquid mercury in salt

mines and related potential environmental risks (see [SOU 2008] “Safety analysis and scenarios for

salt mine storage”) are described. The main concerns are:

• Possible sinking of the “heavy” mercury (which is seen as a long process that can take place

over hundreds or thousands of years) and thus increased risk of liquid mercury coming in

contact with open fissures

• Salt rock formations are affected by convergence, thus the waste is subject to pressure over

time which might result in it being squeezed out, into the access shaft for example.

• Fissures in the salt rock might result in a release of the liquid mercury or mercury vapour into

the biosphere.

• Chemical reaction in the storage site (e.g. reaction between mercury and containment) might

result in gas formation and a corresponding pressurisation with the risk of mercury being

pressed out through sealing plugs, fissures or pores of the rock. Corrective measures and

retrieval of waste is more difficult in cases where liquid mercury is stored without containers;

in addition, mercury might very efficiently leach through existing pores and fissures and the

ability of mercury to penetrate might also cause new pores and fissures.

• Possible plug leaks due to very high petrostatic pressure at greater depths. As a consequence

an effective enclosure of the mercury at a depth of 500 m would require plugs with a very

dense structure (max. pore radius: 68-80 nm).

61 BMU: Bundesministerium für Umwelt, Naturschutz und Reaktorsicherheit (Federal Ministry for the

Environment, Nature Conservation and Nuclear Safety, Berlin)



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During a workshop at Oxford in October 200962 in particular the lack of information related to the

behaviour of mercury and mercury compounds in salt rock has been raised as major concern. No

post-closure models related to the long term behaviour of liquid mercury or other mercury

compounds are available up to now. According to expert opinions expressed during the workshop,

post-closure models developed for the disposal of radioactive waste could be adapted to the specific

characteristics of mercury.

6.2.2.5 Conclusions: salt rock

Valuable information on the properties of salt rock is available in particular from the research for a

safe nuclear waste disposal ([GRS 2008], [BGR 2007]). In particular, the salt rock properties such as

gas and liquid impermeability, total encapsulation of the waste, very low hydraulic conductivity and

high stability of cavities qualify salt rock as a host rock for metallic mercury as well as for other

mercury compounds [GRS 2008], [Popov 2006]. Apart from the rock properties the stability of the

formation, the overlying impermeable strata and the exclusion of water entering the storage site are

crucial for underground storage sites in salt mines [Popov 2006], [WAC Decision].

The geological properties of existing underground disposals sites in salt rock in Europe which might

be relevant for the permanent or temporary storage of liquid mercury are well investigated to reduce

the probability of unexpected incidents. A site-specific risk assessment – as outlined in the WAC

decision, Appendix A and prepared by independent experts or institutions – is crucial to determine

the effectiveness of the host rock as a geological barrier and its capability to isolate the waste from

the biosphere over a very long time. Based on the site specific risk assessment a list of waste is

derived which is allowed to be stored in the salt mine. In salt mines only waste can be stored which is

specifically permitted for the site.

In Europe currently 5 underground salt mines are authorised as underground disposal sites for

hazardous waste. Experience with regard to the storage of liquid mercury as well as large amounts of

stabilised mercury (e.g. mercury sulphide) in salt rock is not yet available. The only experience

available is from storage of mercury containing waste in a salt mine in Germany over several

decades.

Several studies ([USEPA 2002c], [Env Canada 2001]) assessed salt mines as an appropriate option for

stabilised mercury. [USEPA 2002c] evaluated the temporary storage of metallic mercury in existing

cavities in salt mines as a possible option.

In general salt mines are seen as safe disposal options for hazardous waste ([Popov 2006], [IAEA

2009], but concerns related to a permanent storage of metallic mercury still remain [SOU 2008] due

to its specific properties. Up to now, specific studies or risk assessments related to the behaviour of

metallic mercury in salt rock are still missing.

62 http://www.mercurynetwork.org.uk/ikimp-safe-storage-and-disposal-workshop-13-14-oct-2009-

presentations/

http://www.mercurynetwork.org.uk/ikimp-safe-storage-and-disposal-workshop-13-14-oct-2009-presentations/




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6.2.3 Hard rock formations

6.2.3.1 Properties of crystalline hard rocks

In the following, the most important properties of crystalline rock (e.g. granite and metamorphic

rocks) are summarised (source: [GRS 2008], [GRS 2009], [Popov 2006]:

Table 6-3: Overview of properties of crystalline rock

Criteria Properties

Permeability Very low (unfractured) to high (fractured)

Hydraulic conductivity Very low to high

Mechanical Strength: High

Deformation behaviour: Brittle

Stability of cavities: High (unfractured) to low (strongly fractured)

In situ stresses: Anisotropic

Dissolution behaviour: Very low

Sorption behaviour: Medium to high

The hydraulic conductivity of crystalline rock depends to a great extent on its physical state (whether

fractured or not). Unfractured crystalline rock has a low hydraulic conductivity. In [GRS 2008] the

following values have been indicated for crystalline rock:


samples

N° of


Granite 302 – 1.480 m 605 2.23 x 10-15 - 4.00 x 10-04 2.80 x 10-08

Gneiss 301 – 1.498 271 4.70 x 10-15 – 1.20 x 10-05 3.00 x 10-10

The permeability of the rock is highly dependent on whether it is fractured or not.

In situ stress (anisotropic) in hard rock formations and the typical deformation behaviour (brittle)

may lead to fractures in the host rock (see [GRS 2009]).

Hard rocks are effectively self-supporting and minimal engineered support and maintenance is

required to prevent failure of the rock walls in the emplacement cells and access drifts. Maintenance

of rock support, if necessary at all, is not expected to be required over extended periods (see [IAEA

2009]). Crystalline rock has excellent stability of the drifts and rooms even at large depths but it has a

relatively high permeability [Popov 2006]. The creep potential of crystalline rock is very low and thus

self-healing is unimportant.



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In the case of hard-rocks (crystalline and sedimentary), total containment is not possible (due to its

brittle deformation behaviour, cracks and faults in the host rock may occur and liquids and gases

could escape from a hard rock depository). In such cases, an underground storage needs to be

constructed in a way that natural attenuation of the surrounding strata mediates the effect of

pollutants to the extent that they have no irreversible negative effects on the environment. This

means that the capacity of the near environment (engineered barriers) to attenuate and degrade

pollutants as well as the state of the waste (e.g. solid waste with a low solubility and volatility) will

determine the acceptability of a release from such a facility (see Council Decision 2003/33/EC).

The investigation of the rock structure of crystalline rock (granite) is very limited in particular with

respect to hydraulic conductivity [GSR 2008]. The homogeneity of the rock is strongly site-related and

examination of a homogenous rock structure is very complex [GRS 2008]. Low permeability is only

guaranteed in unfractured rocks. In the case of fractured rocks, engineered barriers (such as

appropriate containers, backfillings) are required to avoid contamination of the environment.

For the backfilling of rooms and drifts, dense clay material rich in smectites seem to be the most

appropriate material for crystalline rock. Following an article by Pusch published in [Popov 2006]

German Friedland Ton appears to represent an optimum with respect to costs and good isolating

properties. The article refers to a study – published in 2007 by Roland Pusch [Pusch 2007] – which

investigated whether toxic, non-radioactive chemical waste can be safely stored underground.

A major issue of the study was to develop techniques for the isolation of hazardous waste – primarily

mercury – in solid and solidified form (batteries). Various techniques for preparation and application

of the clay-based materials have been tested and found to be very effective as “near-field” isolation

of solid waste represented by mercury batteries. The best isolating medium turned out to be dense

clay material applied in the form of pre-compacted blocks of clay powder or as on-site compacted

clay layers.

According to the study, deep abandoned mines appear to be suitable for the disposal of solid

hazardous waste because of low costs and suitable chemical conditions. The study concluded that

solid or solidified mercury waste and other solidified hazardous waste can be isolated from the

biosphere for hundreds of thousands of years and that subsequent groundwater contamination will

be lower than stipulated by the EU. The study also covers estimations of the rock mechanical stability

around drifts and rooms suitable for disposal of such waste.

Dense clay (bentonite) is also recommended by [BGR 2007] as appropriate backfilling material for

crystalline rock.

Experiences related to the storage of waste in crystalline rock are available but only for stabilised

waste.



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6.2.3.2 Properties of other sedimentary hard rocks (e.g. claystone)

Argillaceous rock covers a wide range of rock types from plastic clays, with transitional types, to

strongly consolidated and partially fractured claystones. Argillaceous rock formations in France

(Callovo-Oxfordian), Canada (Ordovician argilites) and Switzerland (Opalinus Clay) are highly

consolidated sediments.

In the following, the most important properties of argillaceous rock (e.g. granite and metamorphic

rocks) are summarised (source: [GRS 2008], [GRS 2009], [Popov 2006]):

Table 6-4: Overview of properties of Argillaceous rock, Clay / claystone

Properties Argillaceous rock, Clay / claystone

Permeability Very low to low

Hydraulic conductivity Very low

Mechanical strength Low to medium

Deformation behaviour Plastic to brittle

Stability of cavities Artificial reinforcement required

In situ stresses Anisotropic

Dissolution behaviour Very low

Sorption behaviour Very high

Argillaceous rock has a very low hydraulic conductivity but poor stability and the vicinity of the drifts

may be very conductive. In [GRS 2008] the following values related to hydraulic conductivity have

been indicated for argillaceous rock:


samples

N° of


Argillaceous rock 313 – 1.474 m 36 5.50 x 10-15 - 2.05 x 10-10 9.50 x 10-13

Argillaceous rock formations possess relatively high mechanical strength, depending on the particular

structure (fracturing) and mineralogy of the rock. However, these may exhibit some plastic

behaviour, which progressively reduces fracturing but they may also lead to excavation damage

zones around excavations in the repository, depending on the support and rock characteristics.

Appropriate support would be required for operational safety, although it is considered that

excavations could be kept open with suitable maintenance over extended periods. In argillaceous



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rock, short term support (from a few months to some years) is often provided by means of rock bolts

with metallic arches, metallic meshes and/or shotcrete. Concrete linings can subsequently be

deployed to provide mechanical stability for a longer period.

In the case of Boom Clay in Belgium, mechanical support by liner systems is required. Regular

maintenance of the excavation lining may be necessary should the access to excavation remain open

to enable easy access to the waste emplacement cell. The frequency and scale of any maintenance

work will depend on the deformation rate of the rock at the proposed depth and on the design and

properties of the lining.

In-situ-stress in clay rock formations (anisotropic) and the typical deformation behaviour (plastic to

brittle) may lead to fractions in the host rock. Cavities are often not self-stable but must be

supported by mechanical structures (see [GRS 2009]).

The investigation of the rock structure of consolidated argillaceous rock is possible by means of

boreholes and other geophysical methods as they have a limited thickness and composition [GRS

2008].

According to [GRS 2008] argillaceous rock is generally assumed to have adequate strength for the

construction and maintenance of underground drifts, but the stability of drifts can only be

guaranteed by additional reinforcement and supporting measures. These measures are particularly

complex and expensive in unconsolidated clays, therefore storage in consolidated clays is more

appropriate.

Analogous to crystalline rock, clay material rich in smectites are particularly relevant as backfilling

material due to their high isolating potential. [Popov 2006]. See also backfilling crystalline rock.

Argillaceous rocks have proven their long-term effectiveness as geological barriers where they form

tight seals, for example above hydrocarbon reservoirs. Mineralogical, geochemical and geotechnical

investigations of argillaceous rocks are currently being conducted in international rock laboratories.

Little information is available due to a lack of mining experience with these rocks [GRS 2008].

6.2.3.3 Experience of underground disposal of mercury in hard rock formations

Although several hard rock mines (active and inactive) exist in Europe, experience with the disposal

of mercury in hard rock formations is very limited. In deep underground hard rock formations

typically solid industrial waste such as fly-ash from incineration plants is stored [Popov 2006]. These

waste types might contain small amounts of Hg but only in a solid matrix.

Sweden

There is no underground disposal for mercury waste at the moment in Sweden. However it has been

assessed that Swedish bedrock should be able to meet specific requirements [SOU 2008].



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The Swedish government has commissioned an inquiry into permanent deep bedrock storage of

mercury-containing waste. The inquiry commenced in mid-2005 and a final report was presented on

31 January 2008. The report analyses the permanent storage of mercury in deep bedrock and salt

mines. A summary of the report (in English) provides an account of permanent storage options for

mercury-containing waste, and the requirements and risks attendant to the permanent storage of

liquid mercury [SOU 2008].

According to the report, the technical conditions to build secure underground depositories in stable

geological formations are very good. Deep bedrock deposition in mines or at an existing bedrock

facility enables the permanent storage of long-lived hazardous waste, providing both technical

advantages and extensive safety margins. The latter point is naturally dependent on the enclosure of

the waste in a massive geological barrier. Deposition of long-lived, potentially hazardous waste in

underground depositories provides safety advantages that markedly exceed the current European

practice of surface storage for this type of waste. [SOU 2008]

This report states further that all waste, including metallic mercury, must be appropriately stabilised

prior to deposition. Direct deposition of metallic mercury for example in steel containers – as an

alternative to the storage of stabilised mercury – has disadvantages in terms of safe deposition, and

raises new issues which currently lack an adequate knowledge base. Clarification of these key issues

is required to consider the deposition of liquid mercury as a serious alternative. Therefore the report

states that for practical adaptation, it is reasonable that the necessary safety analyses in case of the

deposition of liquid mercury demonstrate that safety margins correspond to what can be achieved

with stabilised mercury deposited in deep geological formations, such as Swedish bedrock [SOU

2008].

Norway

According to a Norwegian report [Kystverket 2008], it could be a problem to find a suitable location

for “deep” geological disposal in Norway. Though Norwegian storage locations may fulfil the criteria

of stable physical and chemical conditions there is the problem that most storage locations in rock

are relatively shallow (<100 m) and not at several hundred metres depth as required in the WAC

Decision.

In Norway there is a need to store mercury containing waste from zinc-production (one site).

Mercury from zinc-production is a by-product and is treated as waste for final disposal. The mercury-

residue from zinc-production is cemented into sarcophagi and placed in a bedrock hall at the

production site. [NO 2005]

Another Norwegian study has investigated the environmental, safety and health consequences from

salvaging mercury and mercury-contaminated sediments from a sunken submarine [Kystverket

2008]. At least two facilities have permits for disposal of mercury containing waste (mercury content

max. 10%). Possible storage locations and costs for the disposal of hazardous waste are included in

the study. The following possible underground storage locations are cited in the study:



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NOAH AS, Langøya, Norway

NOAH is Norway’s largest disposal facility for hazardous waste. It has a permit to receive a total

of 622,000 metric tons of different types of waste per year, including 322,000 metric tons of

inorganic hazardous waste per year. Since the year 2000, NOAH has received approximately

200,000 tons of mercury waste (10% Hg). It has developed a stabilisation method in

cooperation with the University of Oslo, where mercury is absorbed into gypsum and iron

hydroxide. The maximum allowed discharge of mercury to water is 0.0013 kg/day. NOAH is

situated on the island of Langøya and waste can be transported directly to the island by ship.

Miljøteknikk Terrateam AS, Mo i Rana, Norway

Miljøteknikk Terrateam has a large disposal facility in the rock caverns of the former steel

works in Mo i Rana. Miljøteknikk Terrateam has a permit to receive 70,000 metric tons of

inorganic hazardous waste per year. The waste has to be stabilised/solidified before placement

into the rock cavern. Maximum allowed leaching of waste containing mercury which has been

stabilised/solidified is 0.01 mg Hg/l. The leached amount is determined by using the United

States TCLP63 (Toxicity Characteristic Leaching Procedure) test.

There are also other possible disposal facilities in Norway:

Boliden Odda AS, Odda Boliden

Odda has large rock caverns for disposal of mainly jarosite-bearing sludge from smelters, but

also other waste streams containing mercury sulphide compounds. They have 14 large rock

caverns and each is 75,000-220,000 m3. The waste is placed in plastic drums and is then cast in

concrete in the rock caverns.

BIR (Bergen Interkommunale Renholdsverk), Hordaland

BIR has a disposal facility for hazardous waste in a rock cavern in Stendafjellet. Its permit would

probably have to be revised to be able to receive mercury.

Disposal of mercury waste in Norway (allowed for waste with max 10% Hg) will need stabilisation

prior to disposal. According to [Kystverket 2008] binders for stabilisation could be gypsum, cement,

sulphur and sulphides.

The report recommends a temporary storage while immobilisation technologies are developed.

Temporary storage could typically be in salt mines (which are already available), rock caverns,

preferably in deep bedrock permanent depositories in order to achieve non-oxidative conditions

[Kystverket 2008].

63 The leaching tests of various literatures refer to different standards, which make a direct comparison of the

results impossible. In the United States the toxicity characteristic leaching procedure (TCLP) is typically used, whereas in Europe the leaching standard (EN 12457/1-4) is used. (The rarely-used percolating test (prEN 14405) is also possible.)

With the American TCLP test, a liquid/solid ratio of 20 is used whereas the European leaching test uses a liquid/solid ratio of 10 or 2. Hence, the same material results in higher concentration values in the European measurements.



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6.2.3.4 Economic information – hazardous waste in hard rock

In 2001 the report [SOU 2001] published by the Swedish EPA estimated the cost of a deep bedrock

repository having a capacity of about 1,000-20,000 tonnes of high-level mercury waste to be about

SEK64 200-300 million. This represents a cost of approximately SEK 250,000-650,000 per tonne of

pure mercury. The higher figure represents storage of mixed waste such as process waste containing

1-10% mercury. The report [SOU 2008A] contains updated and more detailed information relating to

expected storage costs of stabilised mercury.

The figures below were received from Johan Gråberg, Swedish Ministry of Environment, and give an

overview of estimated costs for the construction of a permanent deep bedrock storage of mercury-

containing waste in connection with an existing bedrock facility (all cost figures have been converted

from SEK to Euro by using an exchange rate of ~0.1 euro = 1 SEK).

- The estimated investment cost for a deep bedrock storage established adjacent to an existing

or former mine or bedrock facility is around 900-1,500 euros per m³ at 10,000m³ stored

volume or 150-190 euros per m³ at 100,000 m³ deposited volume.

- The construction of an entrance ramp is estimated to cost around 5,000 euros/meter.

- The cost for an underground deep bedrock depository is around 50 euros per excavated m³

volume.

- Further costs for equipment such as pumps, cables, ventilation, lights etc should be added to

these costs. The investment cost for equipment is estimated at 20-25 percent of the

construction cost. In addition to this, operational costs should be added for pumping and

ventilation (100,000-200,000 euros/year), staff (100,000-200,000 euros/year) as well as costs

for loading, unloading and transportation of the waste (20,000 euros/year). In total,

operative expenses amount to 250,000-500,000 euros/year.

The report [Kystverket 2008] did not make any assumptions about costs relating to the storage of

elemental mercury. The report only refers to the assumptions made in the Swedish Report [SOU

2001].

6.2.3.5 Environmental and safety aspects related to the storage of hazardous waste in hard rock

Total enclosure of the waste by the host rock is not possible in hard rock depositories [SOU 2008].

Due to its brittle deformation behaviour, hard rock cannot encapsulate metallic mercury or mercury

compounds.

Therefore, additional artificial or engineered barriers are needed to ensure a safe encapsulation of

64 Exchange rate (October 2009): 10 SEK = around 1 euro



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the hazardous waste over a very long time. Although hard rock has a very low hydraulic conductivity

and gas permeability – under the condition it is unfractured– the investigation on the homogeneity

of the rock is very complex [GRS 2008]. It is difficult to exclude the occurrence of fractures or faults

for a relevant dimension of the host rock [GRS 2008].

Containers, which for instance might provide an important additional safety factor for the storage of

metallic mercury, cannot be considered for long-term storage (see Decision 2003/33/EC, Appendix A,

point 1.2.7). Therefore considerations for long-term safety might be based solely on engineered

barriers.

A presentation prepared by the Swedish environmental agency [Eriksson 2006] made the following

recommendation relating to underground storage in bedrock (the Swedish solution for mercury

waste):

- the responsibility for safe storage rests on the waste owners

- mercury in waste streams should be extracted and converted into an insoluble form

- the storage facility should be located at least 400m below ground in granite bedrock

The Swedish EPA concluded as Swedish mercury strategy [Eriksson 2006] that it should;

• Reduce emissions as far as possible

• Phase out use in products and processes

• Collect mercury already in use

• Effect terminal disposal

In addition, the fundamental properties of the surrounding bedrock have been defined as follows (for

stabilised waste only) [Eriksson 2006], [Höglund 2009]:

• Low water permeability

• Absence of major fracture zones

• Chemically stable environment

• Mechanically stable environment

• Reduced risk of unintentional disturbance

• Long transport paths to the surface

• Dilution potential in the recipient bedrock



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The presence of ground water flow in hard rock formations cannot be excluded, but the exchange

rate of deep groundwater in hard rock is expected to be very low [Höglund 2009]. Investigations and

estimates on possible maximum mercury releases from stored mercury sulphide have been made for

a specific underground mine in Sweden. The study concluded that a maximum release of 0.5-10g

mercury/year might be possible under the given conditions (underground water flow). With such a

release rate, existing environmental limit values would be upheld [Höglund 2009]. For comparison,

the hypothetical release rates calculated for non-stabilized mercury waste without any engineered

barriers and with adequate engineered barriers have been calculated. In addition it was estimated

that the effect of chemical stabilisation of metallic mercury would further reduce the release rates by

a factor of 100 in all alternatives [Höglund 2009].

In the studies [Env Canada 2001] and [USEPA 2003] the permanent storage of pre-treated (stabilised)

mercury is assessed as an appropriate solution for the storage of excess mercury. In [USEPA 2002c]

the temporary storage of liquid (bulk) mercury in existing mine cavities has been identified as a

possible option.

In the report [SOU 2008], the storage of liquid mercury in deep underground hard rock formations is

not recommended.

6.2.3.6 Conclusions: hard rock formations

In hard rock formations a total enclosure of the waste by the host rock is not possible ( [Council

Decision 2003/33/EC] Appendix A, Nr. 4.1). Thus, the attenuation and degradation capacity of

artificial barriers determine the long term safety of deep underground hard rock formations

([Höglund 2009], [Popov 2006]).

Valuable information on the properties of hard rock (crystalline rock and argillaceous rock) are

available from the intensive research for nuclear waste deposits ([GRS 2008],[GRS 2009], [IAEA

2009]).

Possible fractures in the hard rock (in particular crystalline rock) and the resulting higher permeability

and higher hydraulic conductivity of hard rock formations might cause releases of liquid mercury or

mercury vapour into the biosphere [GRS 2008].

Due to the possible presence of groundwater flows in hard rock formations, storage of liquid mercury

is seen as more critical due to the higher solubility in comparison to storage of solidified mercury

with its lower solubility ([GRS 2008], [Höglund 2009]). Where storage of stabilised mercury is

concerned (e.g. in form of mercury sulphide), the hydraulic situation has to be very carefully taken

into consideration to avoid non-acceptable emissions from the storage site into the biosphere via

groundwater flows ([Höglund 2009], WAC Decision, Appendix A, Nr. 4.1).

Experience with regard to the storage of metallic mercury as well as stabilised mercury (e.g. mercury

sulphide) in hard rock formations is not yet available. In deep underground hard rock formations

typically solid industrial waste such as fly-ash from incineration plants are stored with small amounts



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of mercury but only in a solid matrix [Popov 2006]. In Norway two underground facilities have a

permit for the storage of stabilised mercury containing waste with a maximal content of mercury of

10% [Kystverket 2008].

In addition, a Swedish study assessed Swedish bedrock to be able to meet specific requirements for

the storage of stabilised mercury [SOU 2008].

Hard rock formations are seen in particular suitable for the storage of stabilised mercury [SOU 2008],

[Höglund 2009]. Literature promoting the storage of metallic mercury in hard rock formations has

not been found.

6.2.4 Radioactive waste

The goal of radioactive waste disposal is passive isolation of waste so that it does not result in undue

exposure to radiation for humans or the environment, now or in the future. This objective can be

achieved by isolating radioactive materials in a disposal system that is located, designed,

constructed, operated and enclosed such that any potential hazard to human health is kept

acceptably low over required periods of time [IAEA 1994].

This goal is generally comparable with the disposal of mercury. As a consequence, experience made

with the geological disposal of radioactive waste may contribute to establishing strategies for the

disposal of mercury.

Apart from the composition and substance properties, the main differences between mercury waste

and radioactive waste under the point of view of storage are that

• the Hazardousness of radioactive waste decreases over a long period of time

• radioactive waste is partly heat-generating

The aims of geological disposal of radioactive waste are, among others, to contain the waste until

most of the radioactivity has decayed and to delay any significant migration of radionuclides to the

biosphere until much of the radioactivity has decayed [IAEA 2006]. Though the hazardousness of

radioactive waste reduces in the long term - according to the half-lives of the corresponding

radionuclides - it still might take several thousand or even millions of years to decay to zero. It has to

be noted that the hazardousness of metallic mercury does not diminish, even in the long term.

6.2.4.1 Experience from underground disposal of radioactive waste

By the late 1970s, it had become clear that underground disposal was the internationally accepted

approach for most types of solid radioactive waste. Towards the end of the 1980s, the issue of

radioactive waste and its management was becoming increasingly important in the political sphere. It



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was seen as one of the technically unresolved issues of nuclear power. [IAEA 2002].

The IAEA radioactive waste classification system provides a framework for defining a generic

approach to radioactive waste management. The system can be linked to potential disposal options

for various waste categories based on their specific characteristics, with specific activity and

longevity of radioactive constituents being the key distinguishing parameters. High-level and long-

lived radioactive wastes require a higher degree of isolation and should be predominantly disposed

of in geological formations (i.e., emplacement in engineered structures at depths of hundreds of

metres). In principle, the higher the activity and the longer the half-life of major radiocontaminants,

the deeper the facility should be. In addition, some national approaches to disposal prefer the

emplacement of all types of radioactive waste (short and long-lived, low and high level) in geological

formations. [IAEA 2007]

In developing any disposal system concept, reliance is placed on a multi-barrier system approach in

which both the site characteristics and the engineered (technical) barriers, namely the waste form

and the packaging, together contribute to the isolation of the radioactive waste from the

environment for time periods that are sufficiently long for radionuclides to decay to acceptably low

levels. [IAEA 2007]

In the meantime, considerable experience has been made concerning the search for appropriate

disposal sites, the construction of waste disposal facilities and their operation. However, even today

much needs to be done concerning siting, construction and operation of spent fuel and radioactive

waste disposal facilities, even if some countries make considerable progress in the establishment of

geological disposal facilities [IAEA 2009b].

It is noteworthy that in the disposal strategy for nuclear waste, the retrievability of waste becomes

increasingly important [IAEA 2009]. The reversibility of waste management options may also be an

important issue in developing disposal strategies for mercury due to various reasons. Arguments for

and against retrievability of radioactive waste are listed in [IAEA 2009] (see section 3.1), several of

these arguments can also be considered valid for mercury disposal.

A very important activity related to the disposal of high level waste and other long-lived waste is the

selection of an appropriate underground disposal site. Such a site should have favourable natural

confinement characteristics for the waste types under consideration, and should be suitable for

implementing all necessary engineered barriers to prevent or retard the potential movement of

radionuclides from the disposal system to the accessible environment. Since the natural

characteristics of the site play an important role in the disposal concept, site selection activities

should be given major consideration in the overall development of an appropriate disposal system

[IAEA 1994].

The process of selecting appropriate sites for underground disposal is underway in several countries.

Geological disposal of radioactive waste is based on the isolation of waste within the geosphere in

locations where it is expected to be stable over a very long time. Repository concepts and potential

host rocks differ between countries. The main host rocks considered are igneous crystalline and



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volcanic rocks, argillaceous clay rocks and salts. The choice of host rock is mainly governed by the

availability of suitable geological formations of convenient thickness and geological setting.

Underground laboratories for testing and building confidence in disposal technologies have been

built in all types of potential host rocks [IAEA 2009].

6.2.4.2 Environmental and safety aspects relating to the underground disposal of radioactive waste

The long term safety of a geological repository for radioactive waste is based on the concepts of

defence in depth and isolation that is provided by the combined effects of multiple, man-made and

natural barriers. The definition of an engineered barrier system refers to the container, backfill and

buffer sealing materials, and any man-made component that is designed to isolate radioactive waste

and limit its release and transport over long periods of time [IAEA 2009].

Scientifically based and well developed exposure models relating to the post-closure safety of

geological disposal of long-lived radioactive waste are available and might be adjusted in 3-5 years to

predict the long term behavior of mercury or mercury compounds. Information relating to potential

host rocks is available and suitable, and can be used as input for such models. The quality and

reliability of the post-closure model is based on the reliability of the input data [source: expert

discussion at the Oxford workshop65]. These data include information on the specific behaviour of

liquid mercury under underground storage conditions (e.g. possible interaction with the salt rock,

behaviour under pressure).

Operational and long-term safety have to be proven by corresponding safety assessments of the

operational phase and long term safety assessments. For example, the German Government recently

published safety requirements concerning the final storage of radioactive waste (see [BMU 2009].

Safety standards for the geological disposal of radioactive waste were published by the International

Atomic Energy Agency in 2006. The report sets out the objective and criteria for the protection of

human health and the environment during the operation of geological disposal facilities, as well as

for the time after such facilities are closed. It also establishes the requirements for ensuring their

safety. According to the report, geological disposal facilities for radioactive waste are designed to

ensure both operational safety and post-closure safety. Operational safety is provided by means of

engineered features and operational controls. Post closure safety is provided by engineered and

geological barriers. [IAEA 2006]

Minimum requirements and criteria for geological repositories for radioactive waste have been

published in [BGR 2007]. The main objective of this report was to identify suitable host rock

formations for a nuclear repository in Germany. Following the report, geoscientific criteria must now


presentations/





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be given priority in the site selection process as they define the geological barrier function of the

geological repositories:

“The identification of regions was therefore conducted at the first step by applying the following

internationally recognised geoscientific and host rock independent exclusion criteria and minimum

requirements compiled in 2002 by the Committee on a Site Selection Procedure for Repository Sites

(AkEnd66):

- Seismic activity: In the repository area, the seismic activities to be expected must not exceed

Earthquake Zone 1 according to DIN 4149.

- Volcanic activity: In the repository area, there must neither be any quaternary nor any

expected future volcanism.

- The thickness of the isolating rock zone must be at least 100m and must consist of rock types

to which a field hydraulic conductivity of less than 10-10 m per second can be assigned.

- The depth of the top of the required isolating rock zone must be at least 300m.

- The repository mine must lie no deeper than 1,500m.

- The isolating rock zone must have an areal extension that permits the realisation of a

repository (minimum 10km² in clay stone).

- There must be no findings or data which give rise to doubts as to whether the geoscientific

minimum requirements regarding field hydraulic conductivity, thickness and extent of the

isolating rock zone can be fulfilled over a period of time in the order of magnitude of one

million years.

... In the second evaluation step, the following criteria are also considered in the selection process

because they are considered to be of crucial geoscientific importance for rock salt and argillaceous

rocks. Their application led to the exclusion of additional regions:

- The 1995 BGR study defined a minimum thickness of 500m for rock salt deposits in salt domes

(300m roof sequence, plus 100m for the underground workings in the mine, plus 100m

underneath the mine). BGR is of the opinion that these criteria are still valid today.

- The 1995 study stipulated a salt roof of at least 300m above the repository zone in salt

domes. The cover rock overlying the top of the salt dome should be at least 200m thick and

consist of horizons impermeable to water.

- The 1995 BGR study assumed that the minimum area required for a nuclear repository in a

salt dome should be 9km2 for the repository itself. This takes into consideration an outer

protective shell with thicknesses of at least 200m, plus a safety margin of at least 20% so that

66 Arbeitskreis Auswahlverfahren Endlagerstandort (AkEnd), this working group was established by the

German Environmental Ministry to elaborate criteria and methods for the selection of repositories for the disposal of nuclear waste



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adequate reserve areas are available, and to ensure that the safety margins are not

jeopardised by unexpected intercalations of anhydrite, potash seams, etc. The 3km2 area

postulated by AkEnd 2002 is therefore considered to be inadequate.

- Another exclusion criterion included for rock salt was the stipulation that the salt body is not

affected by any other mining or drilling.

- Argillaceous rock formations buried to depths below 1000m are expected to be affected by

very difficult rock mechanical conditions, giving rise to very high costs for the excavation and

operation of a repository.

Another difficulty in the use of argillaceous rocks at depths >1000m is associated with the relatively

low heat conductivity of these rocks and the higher temperatures prevailing at such depths. This will

lead to considerable technical problems if waste generating large amounts of heat is emplaced. One

of the criteria for argillaceous rock formations included in the evaluation was therefore the restriction

to depths between 300 and 1000 m below ground level.”

6.2.4.3 Conclusion

Although the disposal of radioactive waste is carried out under different conditions compared to

liquid mercury, one principal common aspect is the safe long-term isolation of the hazardous waste

material from the biosphere [IAEA 2009]. Therefore, in particular the research and investigation into

appropriate host rocks and their function as a geological barrier for a safe storage are relevant for

the underground storage of metallic mercury.

In particular the exclusion criteria and minimum requirements for depository sites should be taken

into consideration when defining acceptance criteria and minimum requirements for the

underground storage of metallic or pre-treated mercury. [BGR 2007] published minimum

requirements and criteria for geological repositories for radioactive waste.

Exposure models related to the post-closure safety of geological disposal of long-lived radioactive

waste are available and might be adjusted in 3-5 years to predict the long term behaviour of mercury

or mercury compounds67. Important for these model calculations are reliable input data.


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6.3 Review of above-ground storage

According to Article 3(1)(b) of Regulation (EC) No 1102/2008, metallic mercury that is considered as

waste may, in appropriate containment, be temporarily stored for more than one year in above-

ground facilities dedicated to and equipped for the temporary storage of metallic mercury.

This provision is by way of derogation from Article 5(3)(a) of Directive 1999/31/EC and allows thus to

dispose of metallic mercury as liquid waste. Following Regulation (EC) No 1102/2008 above-ground

storage of metallic mercury should only be considered as a temporary solution. Therefore, on the

one hand the principle of reversibility of storage has to be followed and on the other hand the

requirements of protection against meteoric water, impermeability towards soils and prevention of

vapour emissions of mercury have to be met in the best way (recital 12).

Contrary to underground disposal sites with natural (geological) barriers, above ground facilities

mainly have artificial barriers as protection against releases of metallic mercury. These artificial

barriers include constructive measures like buildings, special flooring and in particular the packaging

system of the waste. Apart from these artificial barriers, adequate surveillance and security measures

(e.g. fencing, restricted access, emergency plans) have to be implemented as additional protective

measures.

The storage of metallic mercury is quite common due to the fact that at present liquid mercury is not

considered as a waste but as a raw material. Consequently, experiences are already available relating

to the handling, packaging, transport and temporary storage of metallic mercury as a product.

The main purpose of these activities is not the storage of metallic mercury over a long period but the

stockpiling for a limited short-term period. However, existing experiences can be used to define

future criteria for a possible temporary above-ground storage of metallic mercury. The suitability of

existing packaging and storage conditions for long-term storage have to be investigated and where

necessary adapted.

In the following, the two most important existing above-ground warehouses/storage facilities for

liquid mercury in Europe (Almadén) and in the USA (DNSC) are described in detail. Mercury as a

product is also stored by other companies but only in smaller amounts, for example in chlor-alkali

plants, recycling plants.



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6.3.1 Europe

The information related to the storage of liquid mercury at Mayasa is based on the information

received by the questionnaire survey, information available on the internet68 and additional personal

information from Mr. Ramos, Mayasa.

In Europe, the Spanish state-owned company Miñas de Almadén (MAYASA), the operator of the

former mercury mine, is the major company dealing with liquid mercury, apart from other sources,

mainly received from decommissioned chlor-alkali plants. The company uses a reconverted auxiliary

above-ground building as a warehouse for the storage of the mercury. The installation is located

above a former mercury mine. The metallic mercury is either stored in flasks (34.5kg net), containers

(1 tonne) or bulk tanks. The flasks and containers are also used for the transport of liquid mercury

and thus fulfil the requirements of transport regulations (for further information on containment,

see section 6.4). The filling and re-filling of tanks with mercury takes place via pipes and valves.

Displaced air during filling activities is extracted and cleaned via special filters with activated carbon.

The purity of the stored mercury is 99.9%. In case the delivered mercury does not fulfil this criterion,

a cleaning of the mercury takes place before storage.

The bulk tanks are stored in a collecting basin made of concrete which is capable to collect all

mercury included in the bulk tanks. All the areas in which mercury is handled, stored or packaged are

equipped with specially treated (waterproof) flooring (epoxy based paint) which avoid the infiltration

of the metallic mercury in the event of accidental spillage. In addition, the floors have a slight slope

directed to a central collecting basin.

Although gas displacement systems and activated carbon filters are installed, mercury emissions

from operational processes (e.g. filling of tanks) cannot be completely avoided. The storage building

is equipped with appropriate Hg-emission monitoring systems. The measurement results are

regularly evaluated. Accompanying studies related to possible impacts of mercury emissions have

been carried out under the Mersade project (see information below). According to these studies,

direct impacts of the emissions to the environmental surroundings are expected at a maximum

distance (along the direction of the prevailing wind) of 300m from the central point of the

installation. The Hg-emissions from the storage site are estimated (by modeling) to be around 15kg

per year [personal communication Mr. Ramos, Mayasa].

Life Project MERSADE

Currently, an EU financed Life project69 with the title “Mercury Safety Deposit” (Acronym: MERSADE,

project reference: MERSADE LIFE06 ENV/ES/PREP/03) is being carried out by Miñas de Almadén y

Arrayanes, S.A. (Mayasa) together with its partners CENIM (Centro Nacional de Investigaciones

Metalúrgicas) and the University of Castilla la Mancha.

68 http://www.mayasa.es/ing/mersade.asp 69 LIFE is the EU’s financial instrument supporting environmental and nature conservation projects throughout

the EU, as well as in some candidate, acceding and neighbouring countries, for further information see http://ec.europa.eu/environment/life/

http://www.mayasa.es/ing/mersade.asp





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Based on the expertise on handling and storage of mercury of Miñas de Almadén S.A., and by the

description of the current and operational installations, this project aims to develop technical

support for a plan (for the next 50 years) for defining the packaging to be used during the transport

from plants to the site where it is deposited, the procedure for handling the metal and the

construction of a prototype installation for depositing surplus mercury coming from the EU.

[Mersade 2007]

The project is expected to develop a model for the safe deposit of bulk mercury that meets strict

safety requirements and prevents mercury emissions after closure. Within the project, measures will

be elaborated to minimise emissions during the operational workings through a wide range of

passive systems of safety in design and construction, and with a programme of permanent vigilance

and an intervention plan if required.

The project also includes practical investigations of existing storage containers to identify the most

appropriate material for long-term storage. More detailed information on preliminary results and

recommendations are available in section 6.4.3.1.

The second substantial part of the MERSADE project covers the development of a

stabilization/solidification process for mercury and mercury containing wastes. Preliminary

information on the developed technology and the resulting product is available in section 6.4.3.1.

The project started in October 2006 and was expected to be finalized in September 2009. Following

information from Mr. Ramos, the project manager, a six-month extension of the project duration was

agreed with the EC. Thus the final results of the project will only be available by end of March 2010.

6.3.2 USA

The information related to the storage of liquid mercury at DNSC is based on information available

from the MM EIS [DNSC 2004], [DNSC 2004A] [DNSC 2004B], [DNSC 2007], [Hogue 2007] and

personal information from Mr. Dennis Lynch (DNSC).

In the USA, experiences relating to long-term storage periods already exist. Government owned

liquid mercury which is no longer used for military purposes has already been stockpiled for more

than 40 years in four above-ground warehouses.

The Defense National Stockpile Center (DNSC) stores its liquid mercury in 30-gal drums, each

containing six steel flasks that individually hold 34.5kg of the liquid metal in above-ground

warehouses. In total, 4,436 metric tons are stockpiled by the Defense Department and 1,200 metric

tons stockpiled by the Energy Department (see also chapter 5).

As a result of a Mercury Management Environmental Impact Statement (MM EIS) the DNSC is

currently in the process of consolidating its mercury holdings from facilities in New Jersey, Indiana,

and Ohio at one site, the Hawthorne Army Depot in Nevada. This depot was selected as a future



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storage site for liquid mercury currently stockpiled. The depot fulfilled the requirements set out for

the storage site. The defined storage period is 40 years.

The selected mercury storage warehouse at Hawthorne Army depot has to be upgraded to fulfill the

required safety standards for long-term storage of metallic mercury. In general, the following safety

requirements and level of protection have to be fulfilled by the warehouse [DNSC 2004]:

• Sealed warehouse floors (without drains) with epoxy mercury-resistant sealer (Intrusion

protection)

• Intrusion detection

• Adequate lighting for inspection

• Static ventilation

• All doors fitted with 3 inch containment dikes that are incorporated into floor sealant

systems

• Heat, smoke and fire detection system – monitored continuously

• Fire protection system (active fire suppression system, fire extinguisher and alarm system)

• Closely controlled access (Security systems)

• Regular monitoring (routine monitoring and inspections of mercury)

• Protective equipment and supplies

• Emergency procedures (spill prevention control and response procedures)

• Positive contact intrusion detection on all doors, windows and vents – monitored

continuously

• Ramped containment dikes

Figure 6-3: Metallic mercury storage at the Defense National Stockpile Center (source: DNSC)



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The warehouses at the Hawthorne Army Depot are constructed with concrete support columns, steel

roof trusses, and transite roofing. The warehouses have concrete floors and walls (resistant to fire).

Another option at the Hawthorne Army Depot is the use of earth-mounded storage buildings

(igloos).The site has 393 empty, usable igloos. The igloos are made of steel-reinforced concrete and

covered with about 2ft (1m) of soil. The mercury could be stored in about 125 igloos.

Analogues to the existing warehouses the new site will have approved Spill Prevention Control and

Countermeasures and Installation Spill Contingency Plans to ensure that the appropriate response to

a spill is made. State and local emergency response teams are aware of the mercury storage. In case

of a mercury spill, an appropriate response would occur and the spill would be cleaned up to

applicable standards.

Public access to the storage site is restricted by a security system, including guards, locked

warehouses, and other measures. Warehouses are kept locked except for inspections and other

periodic maintenance work. In addition to security, perimeter fencing, and closely controlled access

comparable to the levels of protection at the current mercury storage sites, DNSC would work with

local authorities to ensure that even the most unlikely scenarios would be handled properly.

Maintenance and Inspection Apart from the technical safety measures, periodic maintenance activities and inspections of the

stored mercury by appropriately trained DNSC or contract personnel are essential to ensure that it is

safe and secure. Inspections have to be conducted by trained personnel and include the following

methods:

• visual examinations

• mercury vapor monitoring using state-of-the-art equipment.

In 2002, the DNSC issued the Environmental Inspection Plan for Mercury in Storage (Appendix 4–A in

the Defense National Stockpile Operations and Logistics Storage Manual). The main purpose of this

manual is to improve the inspection and reporting process for mercury storage. The plan also

documents the correct storage and control measures that are required for the protection, safety, and

health of workers and the public, and protection of the environment. The manual provides

procedures for:

• Frequency of inspections

• Temperature, barometric pressure, and humidity measurement

• Vapour monitoring

• Visual inspection

• Documentation and records



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• Corrective action

In case the DNSC action level of 0.025 mg Hg/m³ is exceeded or if metallic mercury is found during a

visual inspection, an investigation has to be initiated to determine the cause. Any defects in the

packaging have to be quickly corrected.

Costs

The facility at Hawthorne will be operated by a contractor. DNSC estimates that storage of mercury

at Hawthorne will cost $.0515 per lb per year, for a total of a little more than $500,000 per year for

the military's entire stockpile of mercury [Hogue 2007].

Cost estimates are also available associated with the permanent, private sector storage of elemental

mercury as a method of safe management of excess non-federal mercury supply. The USEPA study

[USEPA 2007a] examined the costs of private sector storage under two storage scenarios: a storage

facility that uses rented warehouses and a storage facility that includes construction of warehouses

specifically for mercury storage. Estimates of total storage costs assume that over a 40-year period,

either 7,500 or 10,000 metric tons of excess mercury supply will require storage.

Table 6-5: Summary of Estimates of Total Storage Costs (US Dollars) for 40 Years [USEPA 2007a]

Storage Capacity

Total Cost Estimates Rent Scenario Build Scenario

7,500 ton Total Project Costs (undiscounted) 59.5 - 144.2 million 50.0 - 137.7 million

Net Present Value of Total Project Costs 18.5 - 39.9 million 17.8 - 41.0 million

Annualized Costs 1.4 - 3.0 million 1.3 - 3.1 million

Annualized Costs per pound 0.084 - 0.181 0.081 - 0.186

10,000 ton

Total Project Costs (undiscounted) 69.8 - 183.9 million 57.3 - 174.9 million

Net Present Value of Total Project Costs 21.3 - 50.9 million 20.0 - 51.9 million

Annualized Costs 1.6 - 3.8 million 1.5 - 3.9 million

Annualized Costs per pound 0.072 - 0.173 0.068 - 0.177

Note: present value calculation assumes a seven percent discount rate.

6.4 Review of containment

6.4.1 Container systems currently in use

The packaging system is an integrated element of a safe storage of metallic mercury – in particular in

the case of temporary storage. It is an engineered barrier which is designed to ensure operational



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safety during interim storage, transport and waste package handling operations, and may provide a

long term containment function [IAEA 2009].

In the following, the standard steel containers used in Europe for the transport and stockpile of liquid

mercury as raw material are described.

In addition, the foreseen packaging system for the storage of metallic mercury at the DNSC is

described. The system is designed to be safe for a period of 40 years.

6.4.1.1 Europe

The information related to the packaging of liquid mercury is based on the information available,

personal information from Mr. M. Ramos, Mayasa.

Currently, for the transport and stockpile of liquid mercury standard gas and liquid-tight steel flasks

(34.5 kg net70) and containers (1 metric ton net) are in use in Europe. Both are UN-approved (see also

section below) and meet the requirements for transport on the road (ADR71), by rail (RID72) and ship

(IMO73). In addition, the smaller flasks meet the requirements for the shipment by air (IATA74). Both

containers are made of steel with a lacquered interior. For further information on the container

material see section 6.4.3.

Figure 6-4: Examples of standard mercury steel containers used by Mayasa (source: Mayasa)

70 The international unit of measurement of mercury, a 34.5 kg flask, is originally from Almadén and equal to

three old Castilian arrobas of 11.5 kg 71 Agreement on Dangerous Goods by Road 72 Regulations concerning the Intl Transport of Dangerous Goods by Rail 73 International Maritime Organisation 74 International Air Transport Association



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The flasks are suitable for strapped to standard wooden pallets (115 cm X 115 cm x 13.5 cm). The 1

metric tonne containers have a height of 66.2cm and a diameter of 70cm.

Costs:

The costs for the current carbon steel flask mainly used (34.5 kg) are around €10/flask, for a 1 tonne

container the costs are around €700 [personal information: M. Ramos, Mayasa]. Other figures vary

from €600 to €1,100 (stainless steel) for the 1 tonne container [personal information by Euro Chlor].

6.4.1.2 USA (DNSC)

The information relating to the packaging of liquid mercury is based on the information available

from the MM EIS [DNSC 2004B], [DNSC 2007], [Hogue 2007] and personal information from Mr.

Dennis Lynch (DNSC).

The DNSC has 4,436 metric tons of mercury in inventory. The purity of the mercury is between 99.5

and 99.9%. In total, the metallic mercury is stored in 128,662 steel flasks. The mercury inventory is

contained in flasks made of 0.2-in (0.5-cm) thick, low-carbon steel. Each flask contains 34.5kg (76lb)

of liquid mercury and is sealed with a threaded pipe plug. Figure 6-5 shows the dimensions of a

typical flask. Currently, two types of flasks are in use. Newer flasks are seamless and thus they are

not as susceptible to leakage as the older, welded flasks. The older flasks have already been in use for

50 years.

Figure 6-5: typical mercury storage flask [DNSC 2007]

In order to prepare the older flasks for the long-term storage of 40 years, an overpacking of the flasks

took place. This overpacking consists of a 30 gal (114 l) air & liquid tight steel drum. Each drum is

made of 16-gauge, carbon steel and has a removable lid. The drums are lined with an epoxy-phenolic

coating and to improve handling in case of possible leaks, the flasks are enclosed a 6-mil, plastic bag



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and sealed with wire ties. Six flasks are placed in each drum with an absorbent mat on the bottom.

The absorbent mat also serves as a cushioning material. Cardboard dividers that are 1/4-in (0.64-cm)

thick keep the flasks separated (see picture below). The drums are closed with a half inch rubber

gasket and a bolt, providing a water- and air-tight seal.

Figure 6-6: Overpacking concept of mercury containing flask [DNSC 2007]

Before being placed in the drum, each flask was removed from its pallet, cleaned by a mercury

vacuum cleaner, and checked for leakage. The plug on each flask was also checked to make sure that

it was secure.

The drums are stored on metal catch trays made of 12-gauge, painted carbon steel. Each catch tray is

1-in (2.5-cm) deep and can collect the contents of several flasks. The catch trays rest on wooden

pallets. In order for pallets to be easily inspected, they are not stacked at the consolidation site.

The overpack drums meet the U.S. Department of Transportation’s (DOT’s) packaging requirements

for shipping hazardous materials by highway and rail (Title 49 Code of Federal Regulations [CFR]

173.164(d)(2)).

Overpacked mercury would be stored at a consolidated storage site for 40 years. The DNSC assumes

that the overpack drums would not fail during that time. The overpack drums would be opened

during the last year of storage, and the flasks would be checked for leaks. The DNSC assumes that

some flasks would leak and would need to be replaced.

Waste flasks would be moved to a treatment facility for retort and reclamation of scrap metal. The

treatment and disposal or recycling of wastes are not evaluated in this MM EIS because these

activities would occur in commercial facilities with permits for routinely performing these types of

activities.

Of the 108,386 flasks inspected at the New Haven, Somerville, and Warren depots, only eight flasks,

all from the New Haven Depot, were found to be leaking. The eight flasks were replaced and the old

flasks were placed in a 55-gal (208-1) drum and sent to a licensed commercial facility for treatment

and disposal.



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The DNSC mercury at Y–12 is contained in newer, seamless flasks that hold 76 lb (34kg). The flasks

are not overpacked. They are stored in groups of 45 on wooden pallets that measure 38 in by 38 in

by 20 in (96 cm by 96 cm by 51 cm).

The overpacking procedure was accompanied by an independent study of mercury vapor reading

carried out by the State University of New York (SUNY) and New Jersey institute of Technology (NJIT)

[DNSC 2007]. The results showed mercury levels to be below established background reading [DNSC

2007].

Costs:

This overpacking costs about $20 per flask [Hogue 2007]. The center looked into consolidating the

metal into containers holding 1 metric ton of mercury. But DNSC did not pursue this option because

it would have cost about $100 per flask and posed a greater risk of releasing mercury than did

leaving it in the smaller containers. DNSC assumes that 0.74 percent of mercury containers will

require replacement every 40 years, at a cost of $99.79 per container. Dividing the replacement

percentage by four and multiplying it by the replacement cost per container yields the unit cost per

pound of inspecting mercury containers once every ten years. [USEPA 2007a]

6.4.2 Environmental and safety aspects

6.4.2.1 Transport and handling

Currently only the transport requirements for dangerous goods apply to the transport of liquid

mercury. The transport of liquid mercury is regulated under the various transport regulations ADR,

RID, IMO, IATA. Specific packaging provisions for liquid mercury are established and only packaging

complying with the provisions of these regulations is allowed for transport.

Mercury is classified as follows:

UN N° 2809

Class 8: corrosive substances

classification code: C9 (other corrosive substances, liquid)

Special provisions: 5 kg (maximum net quantity per inner packaging in case of combination

packaging)

packaging group: III (substance presenting low danger)

Packaging instructions: P800

Mixed packaging provisions: M15

The following packaging instructions apply for the transport of liquid mercury (UN N° 2809):



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Figure 6-7: Packaging instruction for liquid mercury according to ADR



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In the case of elemental mercury no longer being transported as a product but as waste, additional

provisions have to be taken into consideration, in particular:

• Regulation 1013/2006/EC75 on shipment of waste requiring a notification procedure for all

wastes destined for disposal involved in transboundary transport (see chapter 5 “legal

assessment”)

• Directive 91/689/EEC76 on hazardous waste and Directive 2006/12/EC77 on waste requiring a

record of waste including information on quantity, nature, origin, destination, frequency of

collection, mode of transport and treatment method. Documentary evidence that the

management operations have been carried out to be kept for at least three years

• The specific requirements laid down for waste transports according to ADR

• National requirements for signing waste transport, e.g. according to the German legislation78,

signing the transport with an “A” for waste

Improper handling of metallic mercury might result in mercury emissions with adverse effects to

workers and the environment. No mercury specific provisions are implemented on EU level but the

general established occupational and health regulations have to be taken into consideration during

the handling and transport of metallic mercury (e.g. compliance with existing occupational limit

values for mercury).

To avoid improper handling – which might result in mercury releases – Euro Chlor has implemented

the following specific requirements for the safe handling and transport of liquid mercury to Almadén

(Annex 2 – Technical requirements to the Euro Chlor Voluntary Agreement on Safe Storage of

Decommissioned Mercury):

General

- Mercury shall be delivered to the storage site as a liquid in hermetically sealed containers ready

for storage.

- The containers will be placed in a dedicated area in the storage site.

75 Regulation N 1013/2006 of the European Parliament and of the Council of 14 June 2006 on shipments of

waste (OJ L 190, 12.07.2006, p.1-98), also referred as the ‘Waste Shipment Regulation‘ 76 Council Directive 91/689/EEC of 12 December 1991 on hazardous waste (OJ L 337, 31.12.1991, p. 20) with

last amendment from 19 November 2008, also referred as ‘Hazardous Waste Directive‘ 77 Directive 2006/12/EC of the European Parliament and of the Council of 5 April 2006 on waste (OJ L 114,

27.4.2006, p. 9–21) 78 Act for Promoting Closed Substance Cycle Waste Management and Ensuring Environmentally Compatible

Waste Disposal (Kreislaufwirtschafts- und Abfallgesetz - KrW-/AbfG), 27 September 1994 (BGBl I 1994, 2705)



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Containers:

- The containers will be made of steel, with top connection only (no bottom valves) and should

have ADR/RID approval for transportation. The containers will normally have a capacity in the

region of 1 tonne of mercury. Containers of other capacities may be used if appropriate.

- The containers will be used for transportation and storage to avoid further manipulation of

mercury on the storage site.

- The containers will have a visible indication of their empty and full weights.

Preparation and filling operation:

- Before filling the containers, residual sodium concentration in the mercury will be checked to

ensure that there is no risk of hydrogen production.

- The container shall not be completely filled to avoid overpressure by thermal expansion.

- After filling, the container will be hermetically closed. The filled containers will be weighted for

the quantity of mercury; sealed and properly identified: product with UN code, danger signs,

amount, sender, date and reference number to trace the origin.

Loading and unloading of containers

- During loading and unloading trucks or rail wagons, all precautions will be taken to avoid any

spill and emergency aspiration equipment will be ready to collect accidental spillage.

All members of Euro Chlor still operating chlor-alkali plants using the mercury technology, signed the

agreement and thus have to take into consideration the above stated requirements.

Furthermore Euro Chlor published “Guidelines for the preparation for permanent storage of metallic

mercury above ground or in underground mines” [Euro Chlor 2007] including detailed information on

required quality, containment and packaging of mercury resulting from decommissioned chlor-alkali

plants. It is stated in the document that “Mercury [… ] may be contaminated, so it is necessary to

purify it before transfer to storage containers. The most likely contaminants are water-soluble

(specifically sodium, which has the potential to generate hydrogen in storage)”. In addition the

presence of radioactive traces, which are used to measure the plant mercury inventory, should be

avoided. [Euro Chlor 2007]

Mercury from decommissioned chlor-alkali plants have some small metallic contaminants, like iron,

nickel, copper … usually not detectable (< 20 mg/kg each) [personal information by Euro Chlor].



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6.4.3 Container material

Containers must withstand all anticipated levels of handling, storage, stacking, loading and unloading

conditions and should not become adversely affected by changes in atmospheric conditions,

pressure, temperature and humidity [UNEP 2009].

With respect to the containment of metallic mercury the following primary aspects have to be

fulfilled:

• Reaction stability against its content (also in case of impurities)

• Reaction stability against the surrounding environment

• Mechanical stability

• Suitability for transport (avoidance of additional re-filling)

• Air and liquid tightness

• Monitoring possibilities

Container suitability is largely related to the form and foreseen storage period of the metallic

mercury. In the case of permanent underground storage, the containment is not seen as a protection

measure anymore as the stability of any packaging system cannot be expected for a period of >1,000

years.

Apart from the above described steel containers currently in use, glass containers are also discussed

as possible containers for liquid mercury since glass will not react with mercury. However, due to its

low pressure resistance, fragility and strength, appropriate surrounding packaging (casing) has to be

designed to avoid breakage during transport and handling. Teflon might also be suitable. No specific

information has been found to packaging systems made of glass and teflon.

Pure iron flasks might also be an appropriate material for the storage of liquid mercury as iron does

not react with mercury and it is more stable than glass. The problem with iron is that – depending on

the storage environment (e.g. saline solutions) – iron might corrode. An appropriate coating or

second layer might by necessary. No specific information on pure iron flasks could be identified.

In the case of storage of liquid mercury over a long time, possible reactions of mercury with the

containment have to be taken into consideration. Although for example pure iron does not react

with pure mercury, impurities in the mercury may result in a possible reaction and thus an attack of

the containment.

For pre-treated metallic mercury, the requirements to be fulfilled would be different than those

applying to metallic mercury. Solidified mercury might either be stored in drums or large packs

depending on the structure of the final product.



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In the following, the preliminary findings of the MERSADE project relating to corrosion by liquid

mercury of the container material are described. One objective of the MERSADE project is to identify

appropriate container material for the safe long term storage of metallic mercury. Apart from a

literature review (see section 4.1.2), practical investigations also took place with tanks and flasks in

use for several years.

The Oak Ridge National Laboratory (ORNL) also carried out an extensive assessment of mercury

containers to identify the most appropriate container material as well as container size.

6.4.3.1 Corrosion by liquid mercury of the container material (steel) – Preliminary results of the MERSADE project

The following information is based on [Muñoz, 2009] and [Mersade 2009A] and additional personal

information from Mr. Ramos, Mayasa.

One major objective of Mersade was to identify appropriate container material for the storage of

liquid mercury. Therefore, in a first step the storage containers that have been in use for several

years for the storage of liquid mercury at Almadén have been analysed for potential effects resulting

from the mercury. The stored mercury at Almadén has a purity of 99.9%.

The following equipment has been investigated.

Table 6-6: Tested equipment [Muñoz, 2009], presentation: Mr. Ramos

Capacity Thickness

container

material

Container material In use since

Flask 1 34.5 kg Not indicated Plain carbon steel (low

C, Mn, P steel, DD13)

>7 years

Flask 2 34.5 kg Not indicated Plain carbon steel (low

C, Mn, P steel, DD13)

6 years

Flask 30 34.5 kg 4mm Plain carbon steel (low

C, Mn, P steel, not

DD13)

30 years

Container 1 1 tonne Not indicated AISI 316L79 >10 years

Container 2 1 tonne Not indicated AISI 304L79 6 years

Deposit of scale Not indicated 7mm AISI 30479 steel (304L

C Content limit)

Not indicated

Bulk tank-25 Not indicated 8mm AISI 304 steel 25 years

Pipes / 3.5mm AISI 30479 steel 25 years

79 Classification according to AISI = American Iron and Steel Institute



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In addition, two samples of the stored mercury have been analyzed to identify possible impurities. In

particular one sample shows bismuth, sodium, manganese and potassium concentrations of around

200 ppm and calcium was identified in a concentration of up to 250 ppm. Other substances such as

Ag, Pb, Zn, Al have been found in concentrations below 10 ppm. The following conclusions have been

drawn:

Conclusions: packaging (flasks, containers)

• samples had a good optical appearance with no significant damage

• FLASK 1: some iron oxides were observed on the damaged areas as well as below the

protective coating on specimens taken from non damaged areas

• Profile depletion by the GDOES technique for Cr, Ni and Mn shows that for CONT.-1 (AISI

316L) the depleted areas are deeper (2,5 μm) than for CONT.-2 (AISI 304) (1 μm).

Additionally, for CONT.-1 the depth of the affected zone increases up to 4 μm when the

specimens evaluated were taken from the bottom of the tank.

• FLASK-30 shows a deeper damage since the average thickness of the iron oxide layer may

reach 30-40μm which is about 1% of the thickness of the steel, reaching up to 200μm, 5% of

the thickness.

Conclusions: Installations (pipes, tanks):

• Intergranular attack on the surface, but the depth of damage on the steel is rather small

• Bulk tank 25, which has been used for Hg storage for 25 years, showed small amounts of

damage of 40µm depth (0,5% of the total thickness) --->max 5,000 years (8mm thickness)

• The deposit of scale showed the same results: 20µm (<0,3% of the total thickness) - max.

8,750 years (7mm thickness)

• Pipe: Under flowing conditions, the attack was more severe, resulting in a regression of the

surface and increased roughness of the surface.

• Due to the elevated presence of impurities in the mercury, it is not possible to conclude that

the identified attacks can be attributed exclusively to the mercury.

Preliminary overall conclusion resulting from the MERSADE project:

“Stainless steel AISI 304 shows a good performance in metallic mercury under static and isothermal

conditions, since after 25 years the steel only shows a slight attack on the surface. These results

suggest that this steel grade seems suitable for constructing the long term storage depository.”



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The planned prototype for a bulk storage container will be constructed with stainless steel AISI 304.

6.4.3.2 Assessment of mercury storage containers by the Oak Ridge National Laboratory (ORNL)

The ORNL has been working for several years on the assessment of mercury storage containers to

identify the most appropriate container material as well as container size for the storage of liquid

mercury. In the following, a summary of the research activities is provided, based on presentations

[ORNL 2009] and [ORNL 2009A].

The main findings of the research are:

- Mild steel and stainless steel containers are immune to pure mercury (purity >99,5%)

for anticipated exposure conditions and are appropriate for long-term storage

- Avoid acceptance of “unknown” compositions of Hg, at least until more information

is available

- Mercury is compatible with iron and mild steel up to ~400°C (solubility of iron in Hg

<< 0.1 ppm at RT, mercury does not chemically wet steel at RT in the presence of air)

- The evaluation of flasks with a life time of up to ~50 years service confirmed the

absence of steel interaction with mercury

- Welds are likely to be the weakest point in containers

The outcome of the research activities has been used as input for research on the design of

appropriate storage containers.

As acceptable container materials, carbon steel (ASTM A36 minimum) or stainless steel (~316L) have

been identified. Carbon steel is recommended as it has further advantages compared to stainless

steel. Stainless steel

• is more than twice the cost of carbon steel

• has lower material strength

• but provides better exterior corrosion protection than carbon steel

The purity of the stored mercury should be at least 99.5% and the remaining impurities within it

should not be capable of corroding carbon or stainless steel (i.e., nitric acid solutions, chloride salt

solutions, or water).

For a protective coating for the exterior surface of the containers, epoxy paint or electro plating are

recommended. For the inner surface, no protective coating is required for as long as mercury meets

purity requirements and no water is present inside the container.



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For a plug, a National Pipe Thread (NPT) plug with Teflon® tape is recommended, as it provides an

excellent seal at low cost.

The presentation [ORNL 2009A] also includes a comparison of storage containers with different sizes

(3 l flask, 1, 2, 3 and 10 metric tonne containers) and the pros and cons relating to their storage

function.

Based on the results of the above described investigations, DOE published in November 2009

“Interim Guidance on Packaging, Transportation, Receipt, Management, and Long-Term Storage of

Elemental Mercury” [DOE 2009].

The document provides a framework for the standards and procedures associated with a DOE-

designated elemental mercury storage facility (see chapter 5.4.2) with a focus on the RCRA (Resource

Conservation and Recovery Act) permitting of such a facility and planning for that storage facility’s

needs. This document provides general guidance on standards and illustrative procedures that are

current, consistent, and best suited for supporting the DOE program for the receipt, management,

and long-term storage of mercury generated in the United States. The document lays down that a

detailed analysis of the purity of the elemental mercury has to be prepared. This purity analysis shall

“confirm a minimum purity of 99.5% (per volume) and list all impurities and their weight percent of

content. The total liquid shipment per container is on a volume basis, and the percent impurities are

on a weight basis. The impurities shall not be capable of corroding carbon or stainless steel. To

prevent degradation of the container, nitric acid solutions, chloride salts solutions, water, and other

possible corrosion agents are prohibited. The mercury shall be free of any added radiological

components.”

6.4.4 Conclusions

Above ground storage of the “product” liquid mercury has already been practiced for several years

and experiences with the storage of large quantities of liquid mercury are available in particular in

the USA and Spain. Also experiences are available related to the handling, packaging, transport of

metallic mercury.

In Europe, the Spanish state-owned company Miñas de Almadén (MAYASA), the operator of the

former mercury mine, is the major company dealing with liquid mercury. According to an agreement

with Euro Chlor, MAYASA receives all excess mercury from western European chlorine producers.

The required minimum purity for the acceptance of mercury is > 99.9%.

Currently, for the transport of liquid mercury, standard gas and liquid-tight steel flasks (34.5 kg net)

and containers (1 metric ton net) are in use in Europe. The storage at Almadén also takes place in

bulk tanks which are stored in collecting basins capable to collect all mercury included in the bulk

tanks.

In the USA, government owned liquid mercury (more than 5,500 metric tons) which is no longer used

for military purposes has already been stockpiled for more than 40 years in four above-ground



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warehouses. It is planned to store this metallic mercury for another 40 years in a selected warehouse

[DNSC 2004]. The selection of the warehouse was accompanied by intensive research related to

minimum requirements for the storage site and the containment ([ONRL 2009], [ONRL 2009A]). The

purity of the stored mercury is above 99.5%.

Intensive research related to appropriate containers for the storage of metallic mercury has been

carried out in specific projects in the US ([ONRL 2009], [ONRL 2009A]) and in Spain ([Muñoz, 2009],

[Mersade 2009A]).

Within both projects, containers actually used since several years/decades for the storage of metallic

mercury have been analysed on possible effects by the stored mercury. Based on the results from the

analytical investigations of the storage containers, requirements related to container material

suitable for long term storage have been derived. Both concluded that suitable container material is

available for a temporary storage of metallic mercury.

Recently, the Department of Energy (DOE) published “Interim Guidance on Packaging,

Transportation, Receipt, Management, and Long-Term Storage of Elemental Mercury” [DOE 2009]

which is based on the outcome of the above described investigations.



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6.5 References

[BGR 2007] BGR, Bundesanstalt für Geowissenschaften und Rohstoffe, Nuclear waste disposal in Germany - Investiagtion and evaluation of regions with potentially suitable host rock formations for a geologic nuclear repository, Hannover/Berlin, April 2007, http://www.bgr.bund.de/nn_335086/EN/Themen/Geotechnik/Downloads/WasteDisposal__HostRockFormations__en,templateId=raw,property=publicationFile.pdf/WasteDisposal_HostRockFormations_en.pdf [BMU 2009] Bundesministerium für Umwelt, Natur und Reaktorsicherheit, Sicherheitsanforderungen an die Endlagerung wärmeentwickelnder radioaktiver Abfälle, Berlin, 2009, http://www.bmu.de/files/pdfs/allgemein/application/pdf/endfassung_sicherheitsanforderungen_bf.pdf [Brückner 2003] Brückner, D.; Lindert, A., Wiedemann, M., The Bernburg Test Cavern - A Model Study of Cavern Abandoment, SMRI Fall Meeting, 5 - 8. Oct. 2003, Chester, UK, 69 – 89, 2003 [Council Decision 2003/33/EC] Council Decision, of 19 December 2002 establishing criteria and procedures for the acceptance of waste at landfills pursuant to Article 16 of and Annex II to Directive 1999/31/EC (2003/33/EC) [DNSC 2003] Defense National Stockpile Center, Draft Mercury Management Environmental Impact Statement, 2003 [DNSC 2004] Defense National Stockpile Center, Record of Decision for the Mercury Management EIS, April 2004 [DNSC 2004A] Defense National Stockpile Center, Final Mercury Management Environmental Impact Statement, Executive Summary, 2004 [DNSC 2004B] Defense National Stockpile Center, Final Mercury Management Environmental Impact Statement,Volume I, 2004 [DNSC 2004C] Defense National Stockpile Center, Human Health and Ecological Risk Assessment Report for the Mercury Management EIS, Volume II, 2004 [DNSC 2007] Defense National Stockpile Center, Fact Sheet: Mercury Over-Packing, Storage & Transportation, May 2007 [DNSC 2007A] Defense National Stockpile Center, Fact Sheet: Somerville Depot, February 2007

http://www.bgr.bund.de/nn_335086/EN/Themen/Geotechnik/Downloads/WasteDisposal__HostRockFormations__en,templateId=raw,property=publicationFile.pdf/WasteDisposal_HostRockFormations_en.pdf



http://www.bmu.de/files/pdfs/allgemein/application/pdf/endfassung_sicherheitsanforderungen_bf.pdf




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[DOE 2009] U.S. Department of Energy, Interim Guidance on Packaging, Transportation, Receipt, Management, and Long-Term Storage of Elemental Mercury, U.S. Department of Energy Office of Environmental Management Washington, D.C., November 13, 2009, http://www.mercurystorageeis.com/Elementalmercurystorage%20Interim%20Guidance%20(dated%202009-11-13).pdf [Env Canada 2001] National Office of Pollution prevention, Environment Canada, The Development of retirement and long term storage options of mercury, Draft final report, Ontario, June 2001 [Eriksson 2006] L. Eriksson, Swedish policy for a mercury free environment, presentation, Swedish Environmental Protection Agency [Euro Chlor 2007] Euro Chlor, Guidelines for the preparation for permanent storage of metallic mercury above ground or in underground mines, Env Prot 19, 1st Edition, October 2007 [EU COM 2001] European Commission, Integrated Pollution Prevention and Control (IPPC) - Reference Document on Best Available Techniques in the Chlor-Alkali Manufacturing industry -, http://ec.europa.eu/comm/environment/ippc/brefs/cak_bref_1201.pdf [FZK 2007] Forschungszentrum Karlsruhe in der Helmhotz - Gemeinschaft: Schwerpunkte zukünftiger FuE-Arbeiten bei der Endlagerung radioaktiver Abfälle (2007 - 2010), Förderkonzept des BMWT, Dezember 2007 http://www.fzk.de/fzk/groups/ptwte/documents/internetdokument/id_064588.pdf [Gibb 2000] Fergus Gibb, A new scheme for the deep geological disposal of high-level radioactive waste, Journal of the Geological Society, Jan 2000 http://jgs.geoscienceworld.org/cgi/content/abstract/157/1/27 [GRS 2008] GRS, Gesellschaft für Anlagen- und Reaktorsicherheit (GRS) mbH, Öko-Institute e.V., Institut für angewandte Ökologie , Endlagerung wärme entwickelnder radioaktiver Abfälle in Deutschland, Anhang Wirtsgesteine – Potentielle Wirtsgesteine und Eigenschaften, Anhang zu GRS-247, ISBN 978-3-939355-22-9, Braunschweig/Darmstadt, September 2008 http://www.fzk.de/fzk/groups/ptwte/documents/internetdokument/id_067981.pdf [GRS 2009] GSR Gesellschaft für Anlagen- und Reaktorsicherheit, Legislation and Technical Aspects of Regulations on Waste Containing Mercury in Europe and Germany, presentation by Thomas Brasser at the Latin American Mercury Storage Project Inception workshop, Montevideo, Uruguay, April 22-23, 2009 [Heath 2006] Mike Heath, Health environmental and safety questions related to the underground storage/disposal of mercury over time, Presentation at the EEB Conference on EU Mercury surplus management and




http://www.fzk.de/fzk/groups/ptwte/documents/internetdokument/id_064588.pdf

http://jgs.geoscienceworld.org/cgi/content/abstract/157/1/27




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mercury-use restrictions in measuring and control equipment, Brussels, 19 June 2006; http://www.zeromercury.org/EU_developments/HEATH-storage.pdf [Hogue 2007] Cheryl Hogue, Mercury Excess, congress and EPA probe possibility of long-term storage of liquid metal, Chemical & Engineering News, July 2, 2007, Volume 85, Number 27, pp. 21-23 http://pubs.acs.org/cen/government/85/8527gov1.html [Höglund 2009] Höglund, Lars Olof, Underground storage and disposal in hard rock based on a chemically-stable mercury solid, Presented at Workshop of Safe Storage and Disposal of Redundant Mercury, St Anne’s College, Oxford, 13th and 14th October, 2009; http://www.mercurynetwork.org.uk/wp-content/uploads/2009/10/Hoglund1.pdf [IAEA 1994] SITING OF GEOLOGICAL DISPOSAL FACILITIES - A Safety Guide, 1994, http://www-pub.iaea.org/MTCD/publications/PDF/Pub952e_web.pdf [IAEA 2002] Issues relating to safety standards on the geological disposal of radioactive waste, Proceedings of a specialists meeting held in Vienna, 18–22 June 2001, June 2002, http://www-pub.iaea.org/MTCD/publications/PDF/te_1282_prn/t1282_part1.pdf [IAEA 2003] Technical Reports Series No. 413, Scientific and Technical Basis for the Geological Disposal of Radioactive Wastes, Vienna 2003 http://www-pub.iaea.org/MTCD/publications/PDF/TRS413_web.pdf [IAEA 2007] Disposal Aspects of Low and Intermediate Level Decommissioning Waste, Results of a coordinated research project 2002–2006, IAEA-TECDOC-1572, December 2007 http://www-pub.iaea.org/MTCD/publications/PDF/TE_1572_web.pdf [IAEA 2009] Geological Disposal of Radioactive Waste: Technological Implications for Retrievability http://www-pub.iaea.org/MTCD/publications/PDF/Pub1378_web.pdf [IAEA 2009b] Joint Convention on the Safety of Spent Fuel Management and on the Safety of Radioactive Waste Management, Third Review Meeting of the Contracting Parties 11 to 20 May 2009, Vienna, Austria, SUMMARY REPORT, 20 May 2009 http://www-ns.iaea.org/downloads/rw/conventions/third-review-meeting/final-report-english.pdf [IfG 2007] Institut für Gebirgsmechanik GmbH, Gebirgsmechanische Zustandsanalyse des Tragsystems der Schaftanlage Asse II, Kurzbericht, November 2007 [K+S 2009] K+S, Underground Waste Disposal, presentation by Alexander Baart at the Latin American Mercury Storage Project Inception workshop, Montevideo, Uruguay, April 22-23, 2009; http://www.chem.unep.ch/mercury/storage/Inception_workshop_LatinAmerica.htm


http://pubs.acs.org/cen/government/85/8527gov1.html

http://www.mercurynetwork.org.uk/wp-content/uploads/2009/10/Hoglund1.pdf


http://www-pub.iaea.org/MTCD/publications/PDF/Pub952e_web.pdf

http://www-pub.iaea.org/MTCD/publications/PDF/te_1282_prn/t1282_part1.pdf


http://www-pub.iaea.org/MTCD/publications/PDF/TRS413_web.pdf

http://www-pub.iaea.org/MTCD/publications/PDF/TE_1572_web.pdf


http://www-ns.iaea.org/downloads/rw/conventions/third-review-meeting/final-report-english.pdf




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[KEMAKTA 2007] Lars Olof Höglund and Sara Södergren, Aspects on final disposal of mercury - The need for waste stabilisation, 22 March 2007 [Kystverket 2008] Det Norske Veritas AS, Kystverket Norwegian Coastal Administration - Salvage of U-864 - Supplementary studies - disposal, report NO. 23916-6, Revision N° 01, 2008 http://www.kystverket.no/arch/_img/9818145.pdf [Mersade 2007] M. Ramos, Estimation of figures for total quantity for possible storage from EU countries and in adhesion process taking in account the caustic-soda industry and others., Status Report Literature review, T 1.2, Life Project Number Life06 ENV/ES/PRE/03, July 2007; http://www.mayasa.es/Archivos/Mersade/WEB%20Estimated%20quantity%20of%20Hg%20to%20store%20INSIDE%20EU%20after%20export%20ban%20MAYASA.pdf [Mersade 2007 A] M. Ramos, Literature review concerning corrosion problems in mercury and stabilisation of liquid Hg, Status Report Literature review, T 1.3 and T 1.4, Life Project Number Life06 ENV/ES/PRE/03, February 2007; http://www.mayasa.es/Archivos/Mersade/WEB%20Literature%20review%20concerning%20to%20mercury%20corrosion%20and%20stabilisation%20of%20liquid%20Hg.pdf [Mersade 2007 B] P. Higueras, J. M. Esbrí, Literature review concerning environmental mercury monitoring, Status Report, Life Project Number Life06 ENV/ES/PRE/03, March 2007; http://www.mayasa.es/Archivos/Mersade/WEB%20Literature%20review%20concerning%20environmental%20mercury%20mon….pdf [Mersade 2009] Process for the Stabilization of Liquid mercury, via mercury sulfide, by the use of polymeric sulfur, F.A. López, A. López-Delgado and F.J. Alguacil, Consejo superior de investicadiones cientificas (CSIC), Centor nacional de investigations metalúrgicas (CENIM) [Minosus 2009] http://www.veoliaenvironmentalservices.co.uk/pages/minosus_main.asp [Muñoz, 2009] C. Muñoz, M.T. Dorado, A. G´mez-Coedo, J.J. de Damborenea, A. Conde, Corrosión en depsitos de almacenmiento de mercurio, 2009, http://www.mayasa.es/Archivos/Mersade/Poster-LIFE.pdf [Nirex 2004] United Kingdom Nirex Limited: A Review of the Deep Borehole Disposal Concept for Radioactive Waste, Nirex Report no. N/108, June 2004 [NO 2005] Stakeholder meeting in Brussels 8 September 2005, Additional questions, Answers from the Norwegian authorities http://ec.europa.eu/environment/chemicals/mercury/doc/norway_2.doc


http://www.mayasa.es/Archivos/Mersade/WEB Estimated quantity of Hg to store INSIDE EU after export ban MAYASA.pdf


http://www.mayasa.es/Archivos/Mersade/WEB Literature review concerning to mercury corrosion and stabilisation of liquid Hg.pdf


http://www.veoliaenvironmentalservices.co.uk/pages/minosus_main.asp

http://www.mayasa.es/Archivos/Mersade/Poster-LIFE.pdf




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[öko institut 2007] Methodenentwicklung für die ökologische Bewertung der Entsorgung gefährlicher Abfälle unter und über Tage und Anwendung auf ausgewählte Abfälle, 30.11.2007 http://www.oeko.de/oekodoc/730/2007-110-de.pdf?PHPSESSID=rphc29st47qbq49u3paetrc2t7 [ORNL 2009] Pawel S. J., Oak Ridge National Laboratory, Assessment of Mercury Storage Containers, Presentation October 2009, http://www.mercurynetwork.org.uk/ikimp-safe-storage-and-disposal-workshop-13-14-oct-2009-presentations/ [ORNL 2009A] Carroll, Adam J., Oak Ridge National Laboratory, Design of Mercury Storage Containers, Presentation October 2009, http://www.mercurynetwork.org.uk/ikimp-safe-storage-and-disposal-workshop-13-14-oct-2009-presentations/ [Popov 2006] V. Popov, R. Pusch, Disposal of Hazardous waste in underground mines, Wit Press, Southhampton, Boston, 2006 [Popp 2007] Popp. T.; Wiedemann, M.; Böhnel, H., Minkley, W.; Manthei, G., Untersuchungen zur Barriereintegrität im Hinblick auf das Ein-Endlager-Konzept ,Institut für Gebirgsmechanik GmbH, Leipzig, UFOPLAN-Vorhaben: SR 2470, Ergebnisbericht, 2007 [Pusch 2007] Pusch, Roland, Project on underground disposal of toxic chemical waste like mercury batteries, Roland Pusch, Geodevelopment International AB, Lund, 2007 [Siemann 2007] M. Siemann, Herkunft und Migration mineralgebundener Gase der Zechstein 2 Schichten in Zielitz, Technische Universität Clausthal Institut für Endlagerforschung Fachgebiet Mineralogie, Geochemie, Salzlagerstätten, published in Kali und Steinsalz, ISSN 1614-1210, Heft 3/2007, page 26, http://www.vks-kalisalz.de/images/pdfs/K_Stein_3_07.pdf [SKB 1999] Deep repository for long-lived low- and intermediate-level waste, Preliminary safety assessment. Swedish Nuclear Fuel and Waste Management Co (SKB), Stockholm, 1999 [SKB 2000] What requirements does the KBS-3 repository make on the host rock? Geoscientific suitability indicators and criteria for siting and site evaluation. Swedish Nuclear Fuel and Waste Management Co (SKB), Stockholm, 2000 [SOU 2001] NATURVÅRDSVERKET, A Safe Mercury Repository, A translation of the Official Report SOU 2001:58, Report 8105 • January 2003, http://www.naturvardsverket.se/Documents/publikationer/620-8105-5.pdf [SOU 2008] Statens offentliga Utredningar (SOU) 2008: 19 Permanent storage of long-lived hazardous waste in underground deep bedrock depositories, Summary of key findings, SOU 2008: 10 April 2008

http://www.oeko.de/oekodoc/730/2007-110-de.pdf?PHPSESSID=rphc29st47qbq49u3paetrc2t7





http://www.vks-kalisalz.de/images/pdfs/K_Stein_3_07.pdf

http://www.naturvardsverket.se/Documents/publikationer/620�8105�5.pdf



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[SOU 2008A] Miljödepartementet, Att slutförvara långlivat farligt avfall i undermarksdeponi i berg, ISBN 978-91-38-22922-4, 2008 [Spiegel 2007]

Gau in der Grube, Michael Fröhlingsdorf, Sebastian Knauer, 17/2007

[UBA DE 2004] Umweltbundesamt, Background paper on permanent storage in salt mines prepared by the Federal Environment Agency, Berlin, Germany, 29 July 2004; http://www.basel.int/techmatters/popguid_may2004_ge_an1.pdf [UNEP 2009] UNEP, Draft technical guidelines on the environmentally sound management of mercury wastes, 4th Draft, April 2009, http://www.basel.int/techmatters/mercury/guidelines/040409.doc [USEPA 2002c] Hugh W. McKinnon, Preliminary analysis of alternatives for the long term management of excess mercury, EPA/600/R-03/048, 2002, http://www.epa.gov/nrmrl/pubs/600r03048/600R03048.pdf [USEPA 2004] Application of the analytic hierarchy process to compare alternatives for the long-term management of surplus mercury, Paul Randall, Linda Brown, Larry Deschaine, John Dimarzio, Geoffrey Kaiser, John Vierow, 6 January 2004 USEPA 2007a] US EPA, Mercury Storage Cost Estimates, final report, November 2007 http://earth1.epa.gov/mercury/stocks/Storage_Cost_Draft_Updated_11-6-final.pdf

http://www.basel.int/techmatters/popguid_may2004_ge_an1.pdf


http://earth1.epa.gov/mercury/stocks/Storage_Cost_Draft_Updated_11-6-final.pdf



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7 Review of immobilization, solidification and other appropriate technologies for metallic mercury waste

Metallic mercury is liquid and has a high vapour pressure at 20°C. These properties make the storage

as well as the disposal of mercury difficult due to possible risks for the environment. In addition, the

high vapour pressure of liquid mercury may result in mercury emissions during handling, storage

and/or disposal. To avoid these negative effects, intensive investigations took place during the last

year to develop technologies to stabilize or immobilize liquid mercury before storage. In the

following, these technologies are designated pre-treatment technologies.

The main purpose of the pre-treatment technologies is to

• improve the handling

• reduce possible risks by reducing the volatility and/or toxicity

• reduce possible risks by improving the leaching properties

The use of pre-treatment technologies may also influence the required safety measures for above-

ground as well as underground storage facilities.

For example, in the case of liquid mercury storage in an above-ground facility, damage to the

packaging may lead to a release of mercury emissions to the environment, depending on the

implemented safety measures (e.g. collecting basin, air monitoring system). The risk of accidental

release of mercury is significantly reduced or even non-existent if liquid mercury is solidified and

stored as solid waste.

With regard to underground disposal in particular, the enhanced leaching properties might be

arguments for a pre-treatment of metallic mercury before temporary or permanent storage in order

to minimise the risk of mercury being released into the environment from the storage site. On the

other hand, pre-treatment may also result in additional emissions of mercury during the treatment

process and additional handling operations. For subsequent temporary or permanent storage the

changed properties and environmental behaviour of the pre-treated material have to be taken into

consideration, for instance

• long-term stability and safety of the compound (e.g. under mechanical pressure in

underground disposal)

• completeness of the reaction

• leachability

• retrievability of elemental mercury



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• long-term experiences/tests

In addition, environmental, health and safety-related impacts during the treatment process have to

be considered.

The pre-treatment of metallic mercury aims at the immobilisation of the mercury. There can be

differentiation between “stabilization” and “solidification” depending on the technology used. Pre-

treatment can also be a combination of both.

According to Decision 2000/532/EC, stabilisation is defined in the following manner: ‘Stabilisation

processes change the dangerousness of the constituents in the waste and thus transform hazardous

waste into non-hazardous waste. It should be taken into account, that solidification processes only

change the physical state of the waste by using additives, (e.g. liquid into solid) without changing the

chemical properties of the waste’.

Similar definitions of stabilization and solidification are provided by UNEP [UNEP 2009]:

• Stabilization refers to techniques that chemically reduce the hazard potential of a waste by

converting the contaminants into less soluble, mobile, or toxic forms. The physical nature

and handling characteristics of the waste are not necessarily changed by stabilization; and

• Solidification refers to techniques that encapsulate the waste, forming a solid material, and

does not necessarily involve a chemical interaction between the contaminants and the

solidifying additives. The product of solidification, often known as the waste form, may be a

monolithic block, a clay-like material, a granular particulate, or some other physical form

commonly considered “solid”.

In stabilisation processes, metallic mercury is blended with a substance (e.g. sulphur) or substances

which react chemically to a new, less volatile, soluble or toxic compound. In the case of solidification,

the mercury is simply embedded in a solid matrix without forming a new mercury compound by a

chemical reaction. The matrix is solid either because the melting point of the matrix is well above

room temperature or due to a curing process. Often the term encapsulation is used for the

solidification process. Encapsulations are commonly used in the treatment of hazardous waste.

Encapsulation (solidification) is applied to prevent hazardous waste from coming into contact with

potential leaching agents. Encapsulation can further be split into Microencapsulation and

Macroencapsulation.

Microencapsulation means a process of surrounding or enveloping one substance with another

substance on a very small scale, yielding capsules that might range from less than one micron to

several hundred microns. In the case of metallic mercury, the core material would be mercury with a

wall / coating material around it. Macroencapsulation involves pouring the encasing material over

and around a large mass of the core material which should be encapsulated; thereby enclosing it in a

solidified block. The two processes can also be combined.

Cement, Portland cement and lime are the most commonly used materials for solidification/



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encapsulation of hazardous metal waste; however, research continues into the use of other binders

and additives to enhance performance of the final waste form and to reduce project costs.

[USEPA2002]

The following figure provides an overview of applied and discussed immobilization technologies for elemental mercury.

Figure 7-1: Overview of immobilisation technologies for metallic mercury

In the following, the currently discussed pre-treatment options for metallic mercury are presented.

The overview includes technologies which are only available as patents as well as technologies

already in a trial stage. In many cases patents or literature refer to the same process (e.g. sulphur

stabilisation) but under different process conditions. Therefore, as a first step, the process in general

is described and afterwards variations of the process are listed and described. An overview of the

examined literature is provided at the beginning of each process description.

The literature search resulted in a long list of patents and other scientific literature dealing with the

stabilization of contaminated wastes, including mercury contaminated waste. These patents include

the separation of Hg from the waste. As the focus of the project is the stabilization of elemental Hg,

these patents are not useful in the light of the project background and have not been taken into

consideration.

The main purpose of this section is to provide an overview of the state of development of currently

discussed immobilisation technologies relevant for liquid mercury. Based on this overview the pre-

selection of the most promising technologies will take place (see section 8.9). Therefore, information

already available related to these aspects is included as preliminary information in this section (e.g.

solubility). In addition, the state of realisation of the technology is indicated.



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7.1 Sulphur stabilization

The most common natural occurrence of mercury is as cinnabar (HgS) from which metallic mercury is

derived. Therefore, one of the most important and well investigated approaches is the reconversion

of liquid mercury close to its natural state as HgS.

The production of HgS can result in two different types, alpha-HgS (Cinnabar) and beta-HgS (meta-

cinnabar). Pure alpha-HgS (intensive red colour) has a slightly lower water solubility compared to

pure beta-HgS (black colour). Natural occurring alpha-HgS crystals are called cinnabar and cinnabar

ore and are the most common mercury modification in nature.

The process has been described and investigated in many different patents and other scientific

literature. The following table offers an overview of the relevant documents found relating to this

process. The information on the general process is summarised in section 7.1.1 (Technical

background). In the case of specific process conditions or specific variations, these are described –

together with the state of development – in section 7.1.4 (Use of the technology).

Table 7-1: Sulphur stabilization: overview of the relevant literature

Relevant literature overview for sulphur stabilisation

Reference Content

Salvage of U-864 – supplementary studies – disposal [Kystverket 2008]

General description of the process

Treatment of elemental mercury [US20080234529] General description of the process

Advances in Encapsulation Technologies for the Management of Mercury-contaminated Hazardous Wastes [USEPA 2002b]

General description of the process

Preliminary analysis of alternatives for the long term management of excess mercury. [USEPA 2002c]

General description of the process and assessment

Economic and Environmental Analysis of Technologies to Treat Mercury and Dispose in a Waste Containment Facility. [USEPA 2005]

General description of the process and assessment

Mersade [Mersade 2007a] General description of the process

Stabilisation of metallic mercury [SAKAB DELA 2009]

Description of a pilot scale plant

Disposal of wastes containing mercury [CA1011889]

Treatment of waste with sulphuric acid and neutralisation with lime slurry

Production of non-fading cinnabar from the elements [DE453523]

Mixing of mercury and sulphur together with a solution of 1:1 monosulphide

Mercury immobilization, A requirement for permanent disposal of mercury waste in Sweden [ÖREBRO 2006]

Production of HgS with different sulphur and mercury ratio. Different solubility tests analyses for elemental mercury.

Method for stabilization of metallic mercury using Reaction of mercury metal with sulphur in the solid



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Relevant literature overview for sulphur stabilisation

Reference Content

sulphur [US20080019900 A1] state. Mercury / sulphur molar ratio of 1/1 to 1/3.

Disposal of elemental mercury via sulphur reaction by milling [Lopez 2008]

Formation of HgS in non stoichiometric conditions with mechanical energy (ball mill).

Preparation of mercury sulphide [US3061412] HgS production with sulphur and sodiumsulphide

Verfahren und Vorrichtung zur Herstellung von Quecksilber zur anschließenden Entsorgung [EP 2 072 467 A2]

Batch process to produce Mercury sulphide, established by DELA

Verfahren und Vorrichtung zur Herstellung von Quecksilber zur anschließenden Entsorgung [EP 2 072 468 A2]

Continuous process to produce Mercury sulphide, established by DELA

Mercury wastes evaluation of Treatment of mercury surrogated waste [USEPA 2002]

Comparison of four different stabilizing surrogated sludges

Mercury wastes evaluation of bulk elemental mercury [USEPA 2002a]

Comparison of three vendors stabilizing bulk elemental mercury

7.1.1 Technical background:

Due to their strong affinity, sulphur and mercury form a very stable product either as beta HgS

(meta-cinnabar, black, beta-phase) or alpha HgS (cinnabar, red, alpha phase). Naturally bonded

mercury is mainly found in combination with sulphur, forming the alpha-phase of a crystal, so called

Cinnabar. Solid beta HgS can be converted by thermal treatment into the alpha form. Alpha-HgS is

more stable with lower leaching levels and therefore the most favourable reaction product. The

production of alpha-HgS needs a more precise adjustment of production parameters compared to

the production of beta-HgS.

In general, HgS is produced by blending mercury and sulphur under ambient conditions for a certain

time, until mercury(II)sulphide is produced. To start the reaction process, a certain activation energy

is required which may be provided by intensive mixing of the blend.

Among other factors, higher shear rates and temperatures during the process support the

production of the alpha phase, whereas a longer process time favours the creation of beta cinnabar.

Excessively long milling in the presence of oxygen can lead to the production of mercury(II)oxide. As

HgO has a higher water solubility than HgS, its creation should be avoided by milling under inert

atmospheric conditions or addition of an antioxidant (e.g. sodium sulphide). The process is robust

and relatively simple to carry out. The HgS is insoluble in water and non-volatile, chemically stable

and unreactive, being attacked only by concentrated acids. As a fine powdery material its handling is

subject to specific requirements (e.g. risk of dust releases).

This stabilisation process leads to an increase of the volume by a factor of ~300% and of the weight

by ~16-60% compared to elemental mercury.



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Leaching values from beta-HgS products are typically much higher than alpha HgS products

(production of beta-HgS seems to be more prone to impurities compared to alpha-HgS) , therefore

beta-HgS is often not the endpoint of a possible pre-treatment process but the starting point for

further treatment processes (e.g. SPSS, see section 7.2).

7.1.2 Economic information

The costs of this process depend on the costs for the raw material (e.g. sulphur, ~€0.25/kg) and on

the process conditions. The process conditions include energy costs for the milling process, heating if

required, duration of the process, etc...

7.1.3 Environmental information

The physico-chemical properties of the products have been collected and included in Annex 4.

Available data about the solubility product in water have been found which is, for alpha-HgS = 2*10-54

and for beta HgS = 2*10-53 at 25°C [SPC 2009]. Both solubility products are very low, but the alpha

phase is the more stable modification related to lower solubility and lower leaching values.

7.1.4 Use of the technology

As already stated above, this process has been described and investigated by many different

scientific institutions and companies. The most developed process from the implementation point of

view is the DELA process, for which a pilot plant already exists. A second process for the production

of mercury(II) sulphide is from Bethlehem apparatus.

Stabilisation of metallic mercury [SAKAB/DELA 2009] [EP 2 072 467 A2]

In this invention a pilot plant for the production of mercury sulphide is described. The process

involves mixing of mercury and sulphur. The resulting HgS is a powder with about 16% increased

weight compared to the original elemental mercury. The pilot plant has a batch size of 5 kg of

elemental mercury and the process duration is between 90 and 240 minutes. According to

SAKAB/DELA, a line with a capacity of about 3 to 6 tonnes per day can be constructed. The apparatus

is kept below ambient pressure to avoid Hg vapour emissions. According to information from

SAKAB/DELA, the costs for the pre-treatment and subsequent disposal are estimated at around

€2,000/t. At present, further tests are being carried out.

Method and apparatus for generating mercury(II) sulphide from elemental mercury [Bethlehem apparatus]

The information for this process has been directly provided by the relevant company (Bethlehem

apparatus) by telephone conversation and e-mail exchange. No literature could be identified which

describes and evaluates this process.

The product of the process is a mercury sulphide crystal grown in a controlled temperature and



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pressure atmosphere. They use slightly more sulphur than is required for stochiometric combination.

By weight the crystal is 16 per cent sulphur and 84 per cent mercury. When mixed with polyethylene

the mix is 75 % polyethylene, 21 % mercury and 4 % sulphur.

Disposal of elemental mercury via sulphur reaction by milling [Lopez 2008]

According to this reference, the reaction between elemental Hg and S in non-stoichiometric

conditions was facilitated by means of mechanical energy provided by a planetary ball mill

comprising of four stainless steel balls. The leaching behaviour of the product against milling time

was checked. The process was carried out at lab scale using ca. 25 g of elemental Hg.

Mersade [2007a]

In the most extended processes mercury reacts with powdered sulphur and/or liquid sulphur

(polysulfide) to form mercuric sulphide. Mercuric sulphide is the most stable compound formed

between mercury and sulphur. It exists in two stable forms. Ones in the black cubic tetrahedral form

(metacinnabar) and the other stable form is the red hexagonal form found in natures as cinnabar.

Both forms are insoluble in water and in acidic solutions. In alkaline solutions with excess of sulphur

anions HgS is solubilized. In the stabilization of soluble mercury in mercury-containing materials by

the formation of insoluble mercury sulphides, it is desirable to minimize the formation of mercury

polysulfide complexes which can be eluted or leached from deposits in effluents which would contain

Hg concentrations higher than desired. This can be accomplished by the selection of the inorganic

sulphur compound. Mercury polysulphide formation may also be minimized or eliminated by the

addition of a polysulphide inhibitor (alkali metal sulphite, alkali metal bisulphite and alkali metal

metabisulphite).

Mercury wastes evaluation of treatment of mercury surrogated waste [USEPA 2002]

In this study, different pre-treatment technologies had been compared: sulphur stabilization, SPSS,

amalgamation and formation of mercuric sulphide followed by cement-containing proprietary

stabilization. The product from the mercury sulphide process has a mercury content of 72 wt % (after

encapsulation). Therefore the product has increased by 38.9 % by weight on a dry basis compared to

the mercury surrogated waste. The mercury sulphide was soil-like.

Mercury wastes evaluation of bulk elemental mercury [USEPA 2002a]

In this study three pre-treatment technologies had been compared: sulphur stabilization, SPSS and

amalgamation. The mercury sulphide process (sulphur stabilisation) is a multi-step process that can

be stopped at a given stage dependent on what the performance specification is. The first step

(primary stabilization) consists of conversion of elemental mercury to mercuric sulphide (beta-HgS).

This step fits the EPA definition of elemental mercury amalgamation. The primary product is then

subject to micro and macro encapsulation utilizing a range of polymeric and other agents to attain

the desired product specification. The final product was a bead-like material that had a top diameter

of 9.5 mm.



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The product resulting from the primary stabilisation (sulphur stabilisation) has a mercury content of

55 wt%. Therefore the product has increased by 81.8 % by weight on a dry basis compared to the

mercury surrogated waste. The mercury sulphide form was soil-like.

After the encapsulation process the product from the mercury sulphide process has a mercury

content of 44 wt%. Therefore the product has increased by 127 % by weight on a dry basis compared

to the mercury surrogated waste. The final form was microencapsulated pellets. The leaching values

for the final pellets are dependent on the pH value and were about 0.001mg/l at pH=2, ~0.01mg/l at

pH = 8, and ~0.1 mg/l at pH = 12.

Economic and Environmental analyses of Technologies to treat mercury and dispose in a waste

containment facility [USEPA2005]

Information available for the Option B (sulphur stabilisation process) process closely parallels that

available for Option A (SPSS process). The treatment of elemental mercury was evaluated by EPA;

TCLP testing of treated elemental mercury was conducted by DOE. In addition, existing general

mercuric sulphide formation data can similarly be applied to the sulphur-based Option B technology.

USEPA data show a trend in leaching results with respect to pH, with results lowest in acidic

conditions and highest in basic conditions (see Figure B-1). The results were consistently below the

UTS level at all but the highest range of pH. The Option B process has been used for the treatment of

approximately 7600 kg (3.5 tons) of radioactive elemental mercury since 2001. Therefore the process

is in active use and development.

Preliminary analysis of alternatives for the long term management for excess mercury [USEPA 2002c]

Raw materials for the ADA / Permafix treatment process include a sulphur-based reagent. The

treated material can be a granular material or a monolithic material. Permafix proposed to treat 880

flasks of mercury per week (66,800 lb) and generate 150 55-gallon drums. This represents a volume

increase of 14 times. The vendor estimates it would take three years to process the 4,890 tons of

mercury stockpile. The ADA amalgamation process, a batch process, consists of combining liquid

mercury with a proprietary sulphur mixture in a pug mill; in one application a 60-liter capacity pug

mill was used for treatment of an elemental mercury waste. Treatment of the liquid mercury was

conducted by adding powdered sulphur to the pug mill, while a specific amount of mercury was

poured into the mill. While the processing of mercury in the pug mill was performed without the

addition of heat, the reaction of mercury with sulphur is exothermic at room temperature, and the

mixture increases in temperature during processing.

7.1.5 Overview of patents

In the following, a short overview is provided on available patents relating to the sulphur stabilisation

process. All these tests have been carried out on a laboratory scale.

Production of non-fading cinnabar from the elements [DE453523]



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In the described process 20g of mercury and 3.2g of sulphur are added under stirring to a solution of

potassium monosulphide. The process includes several steps and takes at least 2 hours. During the

process the solution is slightly yellow. Alternatively, potassium sulphide can be used as a reactant

with subsequent treatment with potassium monosulphide. To promote the mixing process, glass

beads can be added.

Treatment of elemental mercury [US20080234529]

A brief description of a sulphur stabilisation process, involving a chemical reaction between sulphur

and mercury to form mercury sulphide, which may be effected by blending and grinding a mixture of

mercury and elemental sulphur under ambient conditions. The process is robust and relatively simple

to carry out, and the mercury(II) sulphide which is produced is insoluble and non-volatile in water

and chemically stable and unreactive, being attacked only by concentrated acids. However, some

refinement of process control is required with this method and, although no suffering from the same

problems as liquid mercury, in terms of volatility and proneness to leaching, mercury(II)sulphide is

still a toxic material requiring disposal and, as a fine powdery material which presents its own

handling difficulties.

Verfahren und Vorrichtung zur Herstellung von Quecksilber zur anschließenden Entsorgung [EP 2072467A2]

The invention is a process for the production of mercury sulphide. The reactants are elemental

mercury and elemental sulphide or a sulphur connection. The process takes place at 50 °C and/or

reduced pressure (0.95 bar instead of 1 bar). The temperature of 50 °C increases the amount of

mercury in the vapour phase and therefore the production of mercuric sulphide is promoted. The

product shall be produced in a discontinuous process.

Verfahren und Vorrichtung zur Herstellung von Quecksilber zur anschließenden Entsorgung [EP 2072468A2]

The invention is a process for the production of mercury sulphide. The reactants are elemental

mercury and elemental sulphide or a sulphur connection. The process shall takes at temperatures

above the boiling point of mercury (>580 °C). The temperature can be increase in case a lower

pressure is used. The high temperature increases the amount of mercury in the vapour phase and

therefore the production of mercuric sulphide is promoted. The product shall be produced in a

continuous process.

Method for stabilization of metallic mercury using sulphur [US 20080019900 A1]

This patent describes tests which have been carried out on a laboratory scale, with an amount of

about 55g of elemental mercury and on a semi-pilot scale with 1kg of elemental mercury. During 9

test series, the influence of the presence of a grinding agent, the ratio of Hg/S, stirring rate,

temperature and the degree of filling the machine is studied.



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Preparation of mercury sulphide [US3061412]

Within this technique, elemental mercury, elemental sulphur and sodium polysulphide are mixed to

produce a finely divided dispersion of mercury sulphate. Due to its large surface area and the

resulting negative leaching behaviour mercury sulphate is not suitable for disposal. During several

experiments on a laboratory scale (200-400g elemental Hg), different ratios of Hg, S and Na2S have

been investigated.

Disposal of wastes containing mercury [CA1011889]

This patent describes a waste treatment technology in which the waste is treated with a minor

amount of sulphuric acid in the presence of an oxidizing agent to convert the metallic mercury to

mercury compounds. The waste is blended with a sufficient amount of spent pickle liquor to convert

the mercury compounds to basic mercuric sulphate. The sulphate is then precipitated as insoluble

basic mercuric carbonate by adding lime. The amount of lime has to be sufficient to precipitate

substantially all the mercury sulphate as basic mercuric carbonate to yield a solid mass comprising an

insoluble form of mercury and having a small proportion of liquid containing less than 10 ppb of

soluble mercury.

The process does not describe a production of mercuric sulphide, but a production for mercury

carbonate. The process includes a sulphur connection (sulphuric acid) and is therefore included in

this chapter.

7.1.6 Further details concerning the realization of the process

Two companies have been identified which utilise sulphur stabilization in pilot plants or large scale

laboratory application which could provide additional information on technical, environmental and

economic aspects of the technology.

The information included is based on personal communication with the companies.

7.1.6.1 Sulphur stabilisation according to SAKAB / DELA

In the following, the technology of SAKAB / DELA is described. The scaling up of the process is

currently taking place.

Process description and equipment

Reactants The Reactants are technical sulphur and technical elemental mercury

which was received from the chlor-alkali industry and was not further

processed before treatment.

Process description The process which is used by DELA is a sulphuring method capable of

treating elemental mercury. The reactor is filled with elemental sulphur

(slight stoichiometric excess of sulphur) and mercury, and if needed, with

additives. The additives can be added to receive a granular product

instead of a powder. The inner atmosphere of the reactor is filled with



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nitrogen. The process is carried out with 0.1 bar absolute, which is 0.9 bar

below atmospheric pressure. The total quantity of sulphur is added into

the reaction vessel. Afterwards, the elemental mercury is continually

added to the vessel within approximately 15 to 20 minutes. The

temperature is monitored and the reactor can be cooled to prevent a

temperature increase which might occur due to energy generated by the

mixing process and the exothermic reaction of mercury and sulphide.

After about two hours the product can be removed from the vessel.

Process conditions Most of the tests so far have been performed without heating. Additional

heating of the HgS at the end of the process (~250 °C) leads to a higher

alpha-HgS content and thus an increased quality of the product... It is

foreseen that the pilot-scale facility will have a heating option and that

the whole process will take place at a temperature between 100 and

200°C.

Throughput Currently, a laboratory scale reactor with volume of about 5 liters exists.

The process is carried out in batches with a processing time of about 120

minutes (90-240 min) per batch.

Emissions Due to the use of a vacuum (100 mbar) in the reaction vessel, a dust filter

system and an activated carbon filter, the Hg-emissions should be close to

zero (no measurement results available).

Energy consumption The energy requirements of the process have not been assessed.

Expected operational

costs

According to estimates, the costs will be about € 2,000/tonne, packaging,

transport and final underground disposal in salt mines of the produced

HgS included.

Patent DE 10 2008 006 A1, EP 2072 467, EP2072 468 A2

Implementation time In February 2010, DELA has installed a large scale application which shall

be capable of stabilizing 1,000 tonnes of elemental mercury each year.

Due to the lack of large scale testing experiments so far no parameter

adjustments or test results could be provided.

Implementation costs No information is provided for implementation costs.

Resulting Product

Final product The final product is cinnabar (red). No elemental mercury (silver) or meta-

cinnabar (black) could be detected in an X-ray structure analyses. It is a

fine powder with a density of 2.5-3.0g/cm3. The single crystals have a

density of about 8.2g/cm3.

Product stability The leaching limit values from test runs under stable conditions range

between 0.01 mg/kg and 0.04 mg/kg with an average value of 0.026 mg

Hg/kg (tests according to EN12457/1-4).. Tests show that the product is

stable up to 350 °C. In its current state, the product of the laboratory-



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Resulting Product

scale facility could be disposed of on hazardous and non-hazardous

landfills according to the WAC Decision 2003/33/EC (hazardous landfills

0.2 mg/l (2 mg/kg) and non-hazardous 0.02 mg/l (0.2 mg/kg)).

Volume and weight The volume of the mercury sulphide powder is about six times the

volume of elemental mercury. The weight is increased by about 16%.

Emissions from the

product

Mercury vapour tests have been performed. However, no mercury

vapour could be detected (LOD=0.003 mg/m3).

If additives are introduced, the product form can be changed into a

granular form (1-4mm). Thus, dust emissions could be further reduced

and handling facilitated.

7.1.6.2 Sulphur stabilization according to Bethlehem Apparatus

Bethlehem Apparatus is situated in the United States. Their patent is still pending but they have a

developed and running, stable process.


Reactants The reactants are sulphur and elemental mercury. The use of

polyethylene to produce pellets was abandoned.

Process description Elemental mercury is brought into contact with elemental sulphur.

resulting in HgS. The crystal formation is considered to be very sensitive

to temperature and pressure changes.

Process conditions No information available

Throughput Early runs have been batch sizes of about 22.5kg of mercury. The last few

runs have been in the range of 90kg. It was decided to work with 45kg

batches due to easy processability and possible reruns in 24 hour periods.

It is planned to attach 10 or 20 units to a single mercury feed. With such a

set-up, the operating system will be capable of processing 500 to 1000kg

of mercury per day.

Emissions The process takes place in a sealed container and no emissions should

occur. This container is capable of holding 1-10 bar pressure at 530°C.

Energy consumption No information is provided for energy consumption.


costs

The stabilization costs are about 5-6 $ / pound which is about 8,000 to

9,000 €/tonne of elemental mercury.

Patent The patent has been approved but the official number has not been

received yet. The application is: U.S. Patent Application No. 12/255,403,

Title: A METHOD AND APPARATUS FOR GENERATING MERCURY (II)

SULFIDE ELEMENTAL MERCURY

Implementation time No information is provided for the implementation time.

Implementation costs About €700,000 for a facility to stabilize 300t per year.



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Resulting Product

Final Product The product is a powder with the bulk of the material of approximately

50 mesh size. It easily breaks down into less than 250 mesh size. When

removed from the reaction chamber there are also clumps with a

diameter of approximately 1 cm. The product of the treatment is HgS and

was compared with data on file for naturally occurring cinnabar using x-

ray diffraction. The results show complete similarity. No elemental

mercury could be detected when a pellet was analysed in computer aided

tomography.

Product stability The leaching values which were measured had an average of

0.0143 mg/kg (EPA TCLP)

Volume and weight The powder density is about 5g/cm3.

Emissions from the

product

No emissions from the product are known.



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7.2 Sulphur Polymer Stabilisation/Solidification SPSS

The Sulphur Polymer Stabilisation Solidification (SPSS) process is based on the process of sulphur

stabilisation with the advantage that, in the case of SPSS, the final product is monolithic with a low

surface area. This favours the vapour and leaching performance of the product.

Table 7-2: Sulphur Polymer Stabilisation/Solidification: overview of the relevant literature

Relevant literature overview for Sulphur Polymer Stabilisation/Solidification

Reference Content

Mercury Bakeoff: Technology comparison for the treatment of mixed waste mercury contaminated soils at BNL [Mercury Bakeoff 1999]

General description of the SPSS process for mercury contaminated soils.

Mersade Mercury Safety Deposit [Mersade 2007a]

General description of different stabilization, solidification techniques, among others SPSS.

Sulphur polymer stabilization/solidification (SPSS) treatability of simulated mixed-waste mercury contaminated sludge [Waste Management 2002]

General description of the SPSS process for a surrogated sludge contaminated with 5000 ppm Hg

Advances in Encapsulation Technologies for the management of Mercury-contaminated Hazardous Wastes [EPA 2002b]

General description of different immobilization techniques and cost estimates

Economic and Environmental analyses of technologies to treat mercury and dispose of it in a waste containment facility [USEPA 2005]

General information about costs and techniques for sulphur stabilization, sulphur polymer stabilization/solidification and amalgamation.

Treatment Technologies for Mercury in Soil, Waste and Water [USEPA 2007]

General description of techniques and cost estimates

Determination of acute Hg emissions form solidified-stabilized cement waste forms [ORNL 2002]

General information about SPSS

Using Sulphur Polymer Stabilisation/Solidification Process to Treat Residual Mercury Wastes form Gold Mining Operations [Brookhaven-Newmont 2003]

Batch scale SPSS treatment.

Advances in Encapsulation Technologies for the Management of Mercury-Contaminated Hazardous Wastes [USEPA 2002b]

Comparison of different stabilization techniques (SPSS, CBPC, Macroencapsulation) from different literature sources.

Sulphur polymer solidification/stabilization of elemental mercury waste. [Waste Management 2001]

Tests for SPSS by adding triisobutyl phosphine and sodium sulphide are presented.

Process for the stabilization of liquid mercury, via mercury sulphide, by the use of polymeric

Physical and chemical data of SPSS of mercury



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Relevant literature overview for Sulphur Polymer Stabilisation/Solidification

Reference Content

sulphur [Mersade 2009]

Emerging Technologies in Hazardous Waste Management [ACS Kazakhstan 2000]

Production of SPC and encapsulation of contaminated phosphor gypsum

Mercury wastes evaluation of bulk elemental Mercury [USEPA 2002a]




Treatment of mercury containing waste [US6399849 B1]

Stabilizing mercury containing waste with SPC and encapsulation

Method and apparatus for stabilizing liquid elemental mercury [US 6403044 B1]

Detailed experiment description of stabilizing elemental mercury with sulphur and calcium polysulphide to receive a monolithic product.

Process for the encapsulation and stabilization of radioactive, hazardous material [US 5678234]

General description of encapsulation with sulphur cement

7.2.1 Technical background

Sulphur polymer stabilization is a modification of sulphur stabilization. Within this process elemental

mercury reacts with sulphur to mercury(II)sulphide. Simultaneously, the HgS is encapsulated and

thus the final product is a monolith. The process relies on the use of ~95 wt% of elemental sulphur

and 5% of organic polymer modifiers also called sulphur polymer cement (SPC). The SPC can be

dicyclopentadiene or oligomers of cyclopentadiene.

The process has to be carried out at a relatively high temperature of about 135°C, which may lead to

some volatilization and thus emission, of the mercury during the process. In any event, the process

requires the provision of an inert atmosphere in order to prevent the formation of water soluble

mercury(II)oxide.

In the case of SPC, beta-HgS is obtained. The addition of sodium sulphide nonahydrat results in

alpha-HgS as a product.

A relatively high Hg load of the monolith (~70%) can be achieved with this process, as there is no

chemical reaction of the matrix required to set and cure. The process is robust and relatively simple

to implement and the product of it is very insoluble in water, has a high resistance to corrosive

environment, is resistant to freeze-thaw cycles and has a high mechanical strength. During the

process, volatile losses are liable to occur and therefore appropriate engineering controls are

needed. Engineering controls to avoid possible ignition and explosions are also necessary.

Additionally, the volume of the resulting waste material is considerably increased.



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Polysulphide is added to elemental mercury and sulphur in order to obtain a monolithic product, but

the synthesis of a mercury polysulphide complex, with a higher leaching value compared to mercury

sulphide, shall be avoided. This can be done by adding the sulphur first and in a second step the

sulphur polymer. Formation of mercury polysulphide can also be avoided by adding a polysulphide

inhibitor.

The generation of toxic H2S can be inhibited by limiting the exposure of the stabilizing inorganic

sulphur compounds to air and sunlight or by adding antioxidants.

7.2.2 Economic information

According to various studies, the costs vary from 2.88 $/kg (~2 €/kg) elemental mercury

[USEPA2002b] and between 2.6 $ and 26 $/kg (~€2 and €20/kg) [USEPA 2005] of treated elemental

mercury. The wide range of costs from the report [USEPA 2005] is due to variation of different

parameters, which are: technology (ADA or DOE process, whereas the ADA process is considered to

be twice expensive compared to the DOE process), mobile and stationary construction, with or

without macroencapsulation and considered amount of mercury to be treated (5,000 or 25,000

tonnes).

7.2.3 Environmental information

The physical chemical properties of the products have been collected and included in Annex 4.

Available data about the leachability of the SPSS product are in the range of ~0.02mg/l [Brookhaven-

Newmont 2003] and the volatility is about 0.41-0.74mg/kg (18°C) [Waste Management 2001].


Using Sulphur Polymer Stabilisation/Solidification Process to Treat Residual Mercury Wastes from Gold Mining Operations [Brookhaven-Newmont 2003]

Two experiments are described, which have been performed with 500 and 250ml mercury and a

waste load of 33 to 37%. 2% of hydrated sodium sulphide and 65 to 61% SPC have been used. The

products were approximately cylindrical pellets with a largest dimension of 9.5mm. The TCLP results

for Hg have been between 0.009 and 0.039mg/l.

Advances in Encapsulation Technologies for the Management of Mercury-Contaminated Hazardous Wastes USEPA 2002b], Sulphur polymer solidification/stabilization of elemental mercury waste. [Waste Management 2001]

In this reports the same process is described, which is the SPSS treatment of radioactive Hg° with

different additives.

The report includes examples for the optimisation of the SPSS process with additives in a 5 gallon,

heavy gauge steel drum. Triisobutyl phosphine sulphide and sodium sulphide have been tested as

additives. The additives (except pure Triisobutyl phosphine) improved the leaching behaviour as well



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as the reaction time. Instead of 16 hours, the process could be finalized within 8 hours. This process

is a two step single-vessel process. Mercury SPC and quartz cobbles were placed in the drum, which

was covered and then purged with argon through one of the vents. In the first step equal weights of

mercury and SPC were mixed in the reaction vessel assuring a six fold, molar excess of sulphur to

mercury which facilitates a faster reaction. Prior to mixing the reaction vessel was purged with argon.

The vessel was heated to ~ 40 °C with agitation to accelerate the mercuric sulphide reaction. Once

the mercury had completely reacted with the sulphur, extra SPC was added and the temperature was

increased to 135.5 ± 5 °C with agitation, until the mixture melted. The molten product was then

poured into metal cans where it cooled into a monolithic waste form. The final product had a

mercury load of 33.3°%.

The untreated material had a TCLP of 2.64mg/l whereas the SPSS treated material had a TCLP of

between 0.02 and 0.4mg/l. Adding 3% triisobutyl phosphine to the SPC changed the TCLP to >0.4mg/l

and using 3% Na2S.9H2O to the SPC resulted in a TCPL of between 0.0013 to 0.05mg/l. Therefore,

adding 3% of Na2S.9H2O generated the best results. Additional information is available on the pH

dependency.

Process for the stabilization of liquid mercury, via mercury sulphide, by the use of polymeric sulphur [Mersade 2009]

In this study, the physical characterization and durability of a SPSS concrete with approximately 50%

of filler, sand and gravel as well as 30% of mercury are measured. It has been tested that the

comprehensive strength is about 57 N/mm2, the flexural strength is about 8.5 N/mm², the density is

about 3.1g/cm³ and the porosity is less than 2%.

Emerging technologies in hazardous waste management [ACS Kazakhstan 2000]

This report includes the production of SPC and its use for the stabilization of phosphorgypsum sand

waste. In the described process, molten sulphur (140°C) was reacted with a mixture of 2.5% of

polyester grade dicyclopentadiene and 2.5% of a proprietary reactive polymer. After 4 hours, the

molten SPC was cooled and solidified. The use of 3% sodium sulphide resulted in a TCLP mercury

concentration of 26µg/l. Based on the observation from different tests at different times, it is

assumed that leachable mercury may decrease over time.

Mercury wastes evaluation of bulk elemental Mercury [USEPA 2002a]

The technologies compared in the report are: SPSS sulphur stabilization with micro and macro

encapsulation and amalgamation.

The SPSS process is conducted in two stages. The first step is a reaction between elemental mercury

and powdered sulphur polymer cement to generate mercuric sulphide (HgS). During reaction the

vessel is placed under inert nitrogen gas to prevent mercuric oxide (HgO) formation and heated to 40

°C to enhance the sulphide formation. The purpose of this first step is to chemically stabilize the

mercury. The purpose of the second step is to solidify the product. The mixture is heated to 130 °C to

melt the thermoplastic sulphur binder. It is then poured into a mould. On cooling the reacted



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sulphide particles become microencapsulated within the monolithic sulphur matrix

The mercury content of the product from the SPSS process was 33 wt% and had an therefore an

increase of 203% by weight. The volume increase is 1,500%. The final form was monolithic and it was

estimated that mercury losses to air were about 0.3%. The leaching values for the final pellets are

dependent on the pH value and were about 0.01 mg/l at pH=2, ~30 mg/l at pH = 8, 0.01mg/l at pH =

11 and ~140mg/l at pH = 12.


Treatment of mercury containing waste [US6399849 B1]

In this patent, several examples for a SPSS have been performed. The tests were made with 5kg of

elemental mercury and 5kg SPC (containing 5% elemental sulphur). Additionally, 3% of the additives

sodium sulphide, triisobutyl phosphine sulphide and a 1:1 mixture of both have been added.

Untreated mercury had a TCLP concentration of 2.64mg/l and SPC without any additive had a TCLP

concentration of 0.02mg/l (if the processing time was enough for a complete reaction). Adding 3%

triisobutyl phosphine sulphide resulted in a TCLP concentration of 0.42mg/l whereas 3% sodium

sulphide resulted in a TCLP concentration of 0.026. By adding 1.5% triisobutyl phosphine sulphide

and 1.5% sodium sulphide to the mixture, the final product had a TCLP concentration of 0.064mg/l.

Vapour tests show that the vapour pressure of Hg sharply decrease over the span of one week from

approximately 37µg/l to approximately 3µg/l. The decrease in Hg vapour is explained by the theory

of an ongoing curing process of elemental mercury with free sulphur in the matrix.

Process for the encapsulation and stabilisation of radioactive, hazardous material [US 5678234]

The patent provides a detailed description of the process of encapsulation of hazardous waste. The

waste loading is about 40 w/w% waste, 52.5% modified sulphur cement, 7% anhydrous sodium

sulphide and 0.5 % glass fibres to increase the physical strength of the product. Compressive strength

and leaching tests were performed but the focus is not set on mercury.

Method and apparatus for stabilizing liquid elemental mercury [US 6403044 B1]

In this work various tests with elemental mercury containing waste and mercury chlorine were

performed. A promising example was the experiment to combine 13.5kg of mercury with 6.75kg of

elemental sulphur, 2.7 litres of calcium polysulphide and 6.75kg of sand. The leaching test resulted in

0.1mg/l; whereas a test without the sand resulted in 2mg/l.



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7.2.6 Further details concerning realization of the process

Two companies have been identified which apply the SPSS process at least on a laboratory scale and

which could provide additional information on technical, environmental and economic aspects of the

technology.


7.2.6.1 SPSS According to ADA Technology

ADA Technology is the owner of the technology only. The licensee is M&EC, a company in Oak Ridge,

TN.


Reactants The reactants of the process are elemental mercury, sulphur, polysulfide

(calcium polysulphide, or sodium polysulphide) and sand

Process description It is a batch process consisting of combining elemental mercury with a

proprietary sulphur mixture in a pug mill. Treatment of the liquid mercury

was conducted by adding powdered sulphur to the pug mill, while a pre-

weighed amount of mercury was poured into the mill. As the mill

continues to mix and the reaction takes place, additional substances as

sand or water can be added to provide temperature control and sufficient

volume for efficient mixing to take place. While the processing of mercury

in the pug mill is performed without heating, the reaction of mercury with

sulphur is exothermic at room temperature. and the temperature of the

mixture increases but shall not exceed 100 °C.

Process conditions No further information than that provided in the process description

could be provided for the process conditions.

Throughput A batch size of 50 kg has already been used which would result in a daily

throughput of 250 kg/day. A scale up to 375kg/batch is considered

possible by the vendor. In this case the yearly throughput is expected to

be 1,000t/year if five mixers are used in parallel.

All together, 10 metric tonnes of radioactive mercury has already been

stabilized by the Company.

Emissions Off-gas is passed through a High Efficiency Particulate Airfilter (HEPA),

and then passed through a sulphur-impregnated carbon filter. Mercury

vapour concentration above the plug mill is below the threshold limit



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value (TLV) of 50 mg/m3.

Energy consumption No information could be provided for energy consumption.


costs

No information could be provided for operational costs.

Implementation costs No information could be provided for implementation costs.

Patent US 6,403,044 B1

Implementation time 10t of waste have already been stabilised by 50 kg/batch. But no

information could be provided for a larger facility e.g. 375 kg/batch

Resulting product

Final product The final product is a granular waste, which consist of HgS and sulphur

polymer cement, and can be poured into drums.

Product stability For this product, only leaching values (TCLP) at different pH values are

available. The lowest leaching behaviour can be achieved at a pH value of

2 with 0.001 mg/l. In a more or less linear trend the leaching value

reaches a maximum of ~0.1 mg/l at pH value of 12.

Volume and weight The weight of the material increases by about 100 % and the volume

increases by about 2200 %.

Emissions from the

product

No emissions from the product except leaching are known.



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7.2.6.2 SPSS according to DOE

The patent assignee is Brookhaven Natural Laboratory, which is one of ten laboratories overseen and

primarily funded by the office of science of the U.S. Department of energy (DOE). The process results

in a product containing traces of mercury, further investigations are on hold due to economic

reasons.


Reactants The reactants are elemental mercury, sulphur polymer cement (SPC) and

sodium sulphide.

Process description This process is a two stage single vessel (vertical mixer/dryer) batch process

that results in mercuric sulphide stabilised in a sulphur polymer matrix. In

the first step, mercury is reacted with powdered sulphur polymer cement

and additives to form a stable mercury sulphide compound. Next, the

chemically stabilized mixture is melted in a sulphur polymer matrix, mixed

and cooled to form a monolithic solid waste form in which the stabilized

mercury particles are microencapsulated within a sulphur polymer matrix

[USEPA 2002c].

Process conditions In the first reaction step the reactor is heated to 40- 70 °C and in a second

step to 135 °C. The whole process takes place under an inert gas atmosphere

(nitrogen or argon).

Throughput A 1 ft3 (0.03 m3) mixer has already been realized, capable of stabilizing about

20 kg mercury per shift. Assumptions have been provided for the following

mixer sizes. 10 m3 mixers could stabilize about 7,600 kg/day, 1.8 m3 mixers

have a daily throughput of 1,400 kg and 0.28 m3 mixers have a daily

throughput of 270 kg/day. All these assumptions are based on an average

batch time of twelve hours and two shifts per day.

Emissions The process produces some mercury vapour, so a ventilation system is

required to filter out the vapour. Since the process is carried out at a high

temperature (135°C), heat exchangers are included in the ventilation system.

A liquid nitrogen cryogenic trap condenses the mercury vapour and it is

recycled back into the process. Trials have shown that 99.7 % of the mercury

is retained in the product.

Energy consumption No information could be provided for the energy consumption of the

process.

Expected

operational costs

No information could be provided for the expected operational costs of the

process. From a different study [USEPA 2003] an estimated full scale cost is



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provided with about 2.88 $/kg (~2,000 €/t).

Implementation

costs

No information could be provided for the implementation costs of the

process.

Patent US 6,399,849

Implementation

time

No information could be provided for the implementation time of the

process.

Resulting product

Final product The product is a monolithic structure with a mercury content of 33%, 65%

sulphur polymer cement and 2% sodium sulphide.

Product stability

In order to determine leaching behavior, the TCLP process was used for

different pH values. The results have been in a range of 0.005 and 45 mg/l.

The reason for this wide range of leaching behaviour was not the pH

dependency but a small amount of elemental mercury which was still

existing in the final product. It is considered by the inventors that by

adjusting the processing methodology (e.g. mixing method, introduction of

waste material) the product quality can be increased and that the process

can be controlled better. No further work has been done so far in this field.

Volume and weight

The Volume of the product is about 15-18 times the original elemental

mercury whereas the weight increased by a factor of 3. The mercury content

of the final product is 33 %

Emissions from the

product




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7.3 Amalgamation

Many metals interact with liquid mercury and an alloy is formed. These alloys are called amalgams. If

the amount of the non-mercury metal is small, the amalgam is still liquid and the viscosity of the

amalgam increases with higher concentration of the non-mercury metal in the amalgam.

Table 7-3: Amalgamation: overview of the relevant literature

Relevant literature overview for amalgamation

Literature Content

Treatment Technologies for Mercury in Soil, Waste and Water [USEPA 2007]

General description of techniques and cost estimates

Advances in Encapsulation Technologies for the management of Mercury-contaminated Hazardous Wastes [USEPA 2002b]


Determination of acute Hg emissions from solidified-stabilised cement waste forms [ORNL 2002]

General description of the volatile behaving of mercury after amalgamation.

Economic and Environmental analyses of technologies to treat mercury and disposed of in a waste containment facility [USEPA 2005]

General information about costs and techniques for sulphur stabilisation, sulphur polymer stabilisation/solidification and amalgamation.

Mersade Mercury Safety Deposit [Mersade 2007a]

General description about different stabilization, solidification techniques, among others amalgamation.



Mercury wastes evaluation of Bulk elemental Mercury [USEPA 2002a]


Process for treating mercury in preparation for Disposal [US5034054]

Mercury is mixed with an inorganic powder (copper, zinc, nickel and sulphur) resulting in a permanent bonding of the mercury to the powder in a solid form.

Treatment of elemental mercury [WO2005092447 A2] and [US20080234529 A1]

Amalgamation as a first step , followed by a cementation process with Ordinary Portland Cement (OPC)


Amalgamation means the dissolution and solidification of mercury in other metals such as copper,

selenium, nickel, zinc and tin, resulting in a solid, non-volatile product. The amalgamating metal is

preferably provided in the form of a fine powder, thereby providing the maximum surface area and

promoting increased efficiency of reaction. In general, the preferred amalgamation metal is copper.



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Amalgamation is a subset of solidification technologies and does not involve a chemical reaction.

Different amalgamation processes exist: aqueous and non-aqueous. The non-aqueous process is

suitable for elemental mercury. This process involves the mixing of finely divided powder into liquid

mercury, forming a solidified amalgam. This technology is a speedy process for the treatment of

elemental mercury. However, mercury in the resulting amalgam is susceptible to volatilization or

hydrolysis. Therefore, amalgamation is typically used in combination with an encapsulation

technology.

Disadvantages come from the difficulties to scale up and the need for dilute nitric acid to achieve

high efficiency.

The use of nickel has to be considered critically due to its hazardous properties. In addition, prices of

potentially suitable metals are relatively high.

7.3.2 Economic background

The prices of the metals used for the amalgamation (Cu ~€3/kg, Zn ~€1 /kg, Sn €9/kg) [LME] as well

as the adverse raw material/elemental mercury ratio of suggested 3:1 result in relatively high costs

of this technology. (HgCu = €9/kg treated mercury, HgZn = €3/kg and HgSn €27/kg).

7.3.3 Environmental background

The physical-chemical properties of the products have been collected and included in Annex 4.

Available data about amalgams is mainly indicated at 0.2 mg/l (TCLP) and a further encapsulation

step is therefore recommended.


Mercury wastes: evaluation of treatment of mercury surrogated waste [USEPA 2002]

The technologies compared in this report are: sulphur stabilisation, SPSS, amalgamation and

formation of mercuric sulphide followed by cement-containing stabilization.

The waste load for the amalgamation process followed by a precipitation of stable salt was ~45 wt%

and had an increase of 120% by weight. The final form was soil-like and it was estimated that the

mercury loss to air was about 0.05%.

Mercury wastes: evaluation of Bulk elemental Mercury [USEPA 2002a]

The technologies compared in this report are: sulphur stabilisation, SPSS and amalgamation.

The waste load for the amalgamation process followed by a precipitation of stable salt was ~20 wt%

and had an increase of 400% by weight. The final form was monolithic. The leaching values for the

final pellets are dependent on the pH value and have been about 30 mg/l at pH=2, ~0.2mg/l at pH =

8, 0.1mg/l at pH = 11 and ~0.02mg/l at pH = 12.



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In a separate test, mercury and selenium were heated and allowed to react in the vapour phase. The

leaching value of the mercuric selenide was tested at different chlorine concentrations in the water.

At pH 7 the addition of 500 ppm of chloride increased solubility from 0.007mg/l to 0.021mg/l.


Process for treating mercury in preparation for disposal [US5034054]

In different experiments, amalgamation of 1 pint of mercury was tested. In the case of amalgamation

with copper it was determined, that a compound agitation with a copper/mercury ratio of 3:1 for 40

minutes provided an optimum result. The product is a powder with a copper appearance,

satisfactory for disposal in landfills (for US conditions). In the case of a copper/mercury ratio of 1:1

elemental mercury remained even after 45 min of compound agitation. Another test showed that 2

hours of reciprocal agitation with a copper/mercury ratio of 3:1 yielded an unacceptable high

amount of liquid mercury.

In a final experiment, sulphur was used instead of copper. After 20 minutes of compound agitation of

a mixture with a sulphur/mercury ratio of 3:1 the mercury was solidified. However a mercuric

sulphide gas was noticed.

Treatment of elemental mercury [WO2005092447 A2] and [US20080234529 A1]

Amalgamation tests have been performed and the greatest success was observed when copper was

added to mercury in a ratio of 2:3. In addition, a 1:1 w/w of a 0.1 M diluted aqueous nitric acid

should be employed for optimum results. This mixture was subjected to vigorous agitation until the

amalgam reaction was completed. The amalgam sludge is suitable for treatment with an appropriate

cementitious particulate filler material such as OPC (or a mixture of a blast furnace slag (BFS) with

Ordinary Portland Cement in a ratio of 3:1). The whole process is conducted at room temperature.

The amalgamation stage is complete after 5-10 minutes whereas the curing of the BFS and OPC takes

24 to 48 hours. The mercury concentration of the final product is about 14%. The final product shall

be suitable for immediate disposal (according to the US legal requirements).



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7.4 Phosphate ceramic/glass stabilization: Chemical bonded phosphate ceramic (CBPC)

The first efforts to stabilize mercury or mercury compounds with phosphate glass started in 1970. In

the relevant patent, HgO was stabilized with different phosphates and metal oxides. The product of

this technology is a Chemically Bonded Phosphate Ceramic (CBPC).

Table 7-4: Phosphate ceramic/glass stabilization: overview of the relevant literature

Relevant literature overview for phosphate ceramic/glass stabilization

Literature Content

Method for producing chemically bonded phosphate ceramics and for stabilizing contaminants encapsulated therein utilizing reducing agents[USWagh Singh]

General information about CBPC and magnesium potassium phosphate (MKP) and examples with different wastes.

Advances in Encapsulation Technologies for the Management of Mercury contaminated Hazardous Wastes [USEPA 2002b]


Polymer coating for immobilizing soluble ions in a phosphate ceramic product [US6153809A]

General description for CBPC and applying a polymer coating to the exterior surface of the CBPC product

Evaluation of chemically bonded phosphate ceramics for mercury stabilization of mixed synthetic waste [USEPA 2003]

Leaching tests of CBPC containing Hg- and HgCl2 contaminated wastes. Cost estimation

Chemically bonded phosphate ceramics for stabilization and solidification of mixed waste [USWagh]

Experience on bench scale stabilization of various waste streams containing Hg in the CBPC process.

Mercury stabilization in chemically bonded phosphate ceramics [USWagh 2000]

Detailed explanation for producing a CBPC with mercury contaminated waste and improvement by adding Na2S or K2S.

Mercury containing phosphate glass [US3499774]

Process description of the production of mercury phosphate glass with the reactants HgO, P2O5 and a metal of Group I-II, lead or aluminum.



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Chemically bonded phosphate ceramics (CBPCs) are fabricated by an acid-base reaction between

calcinated magnesium oxide (MgO) and mono-potassium-phosphate (KH2PO4) in solution to form a

hard dense ceramic of magnesium potassium phosphate hydrate. For this purpose calcinated

magnesium oxide powder and monopotassium phosphate is stirred under an aqueous condition to

produce Magnesium potassium phosphate (MKP). In a second step, the MKP is combined with the

mercury. The process temperature is low (<80°C) and therefore little hazardous off-gasses arise and

no secondary waste is generated.

CBPC treatment of elemental Mercury will form low solubility chemical bonded phosphate solids

(Hg3(PO4)2), but a further improved stabilization by forming HgS in a first step, can be realised with a

small amount of sodium sulphide (Na2S) or potassium sulphide (K2S). The sulphides significantly

improve the performance of the final CBPC waste and are therefore recommended. An excess of

sulphide will increase the leachability and therefore careful processing is needed.

The product of the CBPC process can have a mercury load as high as 78% with a density of 1.8g/cm³.

The immobilisation is a result of chemical stabilisation and a physical encapsulation (solidification).

Studies have been carried out to show stabilization of waste streams only, which were contaminated

with small amount of mercury. In the case of elemental mercury, some significant work will have to

be carried out to develop a process to treat mercury in large quantities, though theoretically this can

be achieved.

An advantage for phosphate glass is the high physical stability.


The total costs, including raw materials, labour and disposal for the CBPC process is about 15.45 $/kg

(~€10/kg) elemental mercury [USEPA 2002b].


The physical-chemical properties of the products have been collected and included in Annex 4. The

solubility of Hg3(PO4)2 is 1.4*10-8 mol/l and for HgHPO4 = 2.8*10-7. This is equal to a mercury

concentration of 2.8 and 56µg/l respectively. Even though these values are very low, the leaching

value of HgS is much lower (4.5 *10-25 mol/l or 10-16 µg/l) [USWagh 2000].



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7.4.4 Use of technology

Evaluation of chemically bonded phosphate ceramics for mercury stabilization of mixed synthetic waste [USEPA 2003]

In this evaluation, CBPCs of elemental mercury with a concentration of 50% and 70% Hg in the

stabilised waste form have been produced.

For the 50% load, 300g Hg were mixed with 2g Na2S and 160g water. After 10 minutes of mixing, it

was combined with 300g MKP binder.

For the 70% load, 400g Hg were mixed with 2.67 g Na2S and 120g water. After 10 minutes of mixing,

it was combined with 172g MKP binder.

These mixtures were transferred into plastic vertical cylindrical moulds and allowed to set until

solidified. The moulds were cured by air-drying for about three weeks.

In the case of untreated Hg the leaching behaviour is ~250mg/l at pH of 2 and ~35µg/l at pH 12.

Stabilised waste with 50% Hg had a leaching concentration of ~3mg/l at pH 2 and ~8µg/l at pH 12.

Stabilised waste with 70% Hg had a leaching concentration of ~6mg/l at pH 2 and ~1.4 mg/l at pH 12.

The results are shown in Figure 7-2.

Figure 7-2: Leaching behaviour of stabilized waste with different Hg loads and at different pH values.



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Chemically bonded phosphate ceramics for stabilization and solidification of mixed waste [USWagh]

In this report the CBPC technology to encapsulate different wastes is described. Among other wastes,

the encapsulation of Hg-contaminated wastes from light bulbs is also presented. The examples were

performed in 5-gals drums with a waste load of about 40%. For the Hg-contaminated wastes,

potassium sulphide was added. The final product had a TCLP leaching value of 0.05 ppb of Hg in the

leaching water.

Mercury stabilization in chemically bonded phosphate ceramics [USWagh 2000]

This report describes different types of wastes that have been treated to form CBPC and to bind

mercury as Hg3(PO4)2 within the ceramic. It was shown that the limit value of TCLP 0.2 mg/l could not

be reached. Therefore, it is recommended to add a sulphide as Na2S or K2S to receive HgS which is

encapsulated within the ceramic. An excess of sulphide favours the formation of HgSO4 which has a

disadvantageously high solubility product. The waste was added to the binder mixture (K2S, MgO,

and KH2PO4) and to a stoichiometric amount of water. The mixture was mixed for 30 minutes and

poured into a mould to set within 2 hours. The hard and dense ceramic was stored for 3 weeks for

good curing. Leaching tests and long term leaching tests delivered sufficient stability for EPA limits.


Mercury containing phosphate glass [US3499774]

In this patent different combinations of HgO, Li2O and P2O6 have been used to produce phosphate

glass. The focus was to produce a glass with good optical characteristics. The mercury content in the

different glasses is between ~30 to 70% with a density between 3 to 6.5g/cm3.

7.5 Solidification/encapsulation

The following techniques are used for hazardous waste treatment. No reports have been published

which cover the encapsulation of elemental mercury but the processes shall be briefly described here

for a complete overview of stabilisation encapsulation techniques. All these processes only

encapsulate mercury but do not interact chemically with the mercury:

Polyethylene Encapsulation [US-EPA2002]

The polyethylene encapsulation is dependent on the extruder used, a macro-encapsulation process

or a combined micro- and macro-encapsulation process. Low density polyethylene (LDPE) is less

prone to cratering and cracking than high density polyethylene (HDPE). The resulting material has a

high mechanical strength, flexibility and chemical resistance. The waste load can be up to 70% and

the equipment is commercially available. The disadvantage is that this process requires higher

temperature and therefore Hg emissions from the process can occur. This technique can be

combined with a stabilisation process.



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Encapsulation with Asphalt [US-EPA2002]

Asphalt micro-encapsulation can be used for encapsulation of different wastes. For mercury

containing waste, cold-mix asphalt seems to be more appropriate than hot-mix asphalt due to the

possible volatilization of mercury. As there is no chemical reaction between the asphalt and the

mercury a stabilizing pre-treatment step is necessary.

Encapsulation with Polyester and Epoxy resin [US-EPA2002]

With polyester and epoxy resin encapsulation, waste loads of 50% have been reported but no

information for the usability for metallic mercury is available. As there is no chemical reaction

between the polyester nor the epoxy resin with the mercury, a stabilizing pre-treatment step is

necessary.

Encapsulation with Synthetic Elastomers [US-EPA2002]

Synthetic rubbers have been used for microencapsulation and stabilisation of metal contaminated

waste. As there is no chemical reaction between the synthetic elastomer with the mercury a

stabilizing pre-treatment step is necessary.

Encapsulation with Polysiloxane [US-EPA2002]

Polysiloxane or ceramic silicon foam (CSF) have been used for the encapsulation of waste and

consists of 50 wt% vinylpolydimethyl-siloxane, 20 wt% quartz, 25 wt% proprietary ingredients and

less than 5 wt% water. The material sets at room temperature and is resistant to extreme

temperatures, pressures and chemical exposure. The waste loading can be up to 50 wt%. As there is

no chemical reaction between polysiloxane and the mercury, a stabilizing pre-treatment step is

necessary.

Sol gels encapsulation [US-EPA2002]

Sol gels are a combination of organic polymers and inorganic ceramics. The polymer and silicon

dioxide are combined first and then mixed with the waste and then solidified to encapsulate the

waste. The temperature for this process is about 70°C and a waste loading of 30 to 70% can be

achieved.

DolocreteTM encapsulation [US-EPA2002],

DolocreteTM is a calcined dolomitic binder material that can be used for microencapsulation of

inorganic, organic and low-level radioactive waste.

Encapsulation with calcium carbonate and magnesium oxide (CaCO3-MgO) [US6399848 B1]

The hazardous waste material is added to a settable composition forming a slurry and allowing the

slurry to set to encapsulate the waste material. The settable composition is a powdered, flowable

cement composition, containing calcium carbonate and a caustic magnesium oxide. Different



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additives such as aluminium sulphate of citric acid can be added to increase the performance.

Encapsulation with ladle furnace slag [WO2005039702 A1]

When ladle furnace slag is subjected to an alkali-activated (2M NaOH) process with thermal

treatment, the non-reactive ladle furnace slag undergoes a chemical reaction and forms a durable

cementitious matrix capable of advantageously stabilizing mercury ions. The mercury ions are

precipitated into stable heavy metal compounds such as mercury sulphides and are encapsulated by

the matrix slurry as the matrix slurry sets into a monolith structure. The amount of mercury in

comparison to the ladle furnace slag is ≤ 1%.

7.6 Encapsulation of stabilized mercury with cement

Cement solidification is an encapsulation technique as listed in section 7.5. This technique is

described separately because tests with a starting material of metallic mercury, which was pre-

treated before encapsulation, have already been carried out and a patent is available. This technique

has only been realised on a laboratory scale.

Table 7-5: Cement solidification: overview of the relevant literature

Relevant literature overview for ordinary Portland cement solidification

Literature Content

Method for producing inorganic hardened body [JP2002255671]

General description of inorganic hardened body by using fibre and cement.

Treatment of elemental mercury [WO2005092447 A2]

Describes the encapsulation technique with ordinary portland cement (OPC). A pre-treatment technique is recommended.

Encapsulation process [Lopez 2009] Description of a sulphur stabilization technology, combined with a cement encapsulation.

Procedimiento de estabilizacion de mercurio liquid mediante cemento polimerico de azufre, via sulfuro de mercurio [P200930672]

Patent application for a process of a sulphur stabilization technology, combined with a cement encapsulation


Cement (e.g. ordinary Portland cement [OPC]), acting as the cementitious filler material is used for

the encapsulation of elemental mercury. To improve the leaching properties, a previous stabilisation

step (amalgamation with Cu) is carried out. Additional inorganic fillers can be added to this process

as pulverised fuel ash, hydrate lime, finely divided silica, limestone flour and organic and inorganic

fluidizing agent and especially blast furnace slag (BFS). The ratio of the inorganic filler to the

cementitious filler material can be in the range of 3:1 w/w. The immobilised mercury shall be mixed



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in a ratio of 1:1 w/w with the filler material.


The cost estimate is $16.37 per kg for conventional Portland cement stabilization (including disposal)

[US-EPA 2003]


No relevant environmental data have yet been found for the OPC encapsulation of mercury.


Treatment of elemental mercury [WO2005092447 A2]

In a first experiment, 80g of amalgam sludge (20g Hg, 30g Cu and 30ml dilute nitric acid) are stirred

with 40g OPC and 120g BFS. Water was added to this mixture as necessary. The mixture was covered

and allowed to stand for 48 hours at ambient temperature. The product was suitable for immediate

disposal according to the US legislation requirements.

In a second experiment, 100g mercury, 150g copper and 150ml 0.1 M nitric acid were intensively

stirred for 30 minutes to receive an amalgam sludge. This sludge was mixed with 300 g BFS and 100 g

OPC resulting in a Hg load of 14%. The mixture was poured into a mould and left for 24 hours for

curing.

7.6.5 Further details concerning realization of the process

One institution has been identified which applies the sulphur stabilization in combination with the

encapsulation technique, which could provide additional information on technical, environmental

and economic aspects of the technology.

7.6.5.1 Cement encapsulation technique according to MERSADE


The process was developed in the context of the EU Life-project Mersade. The technology is until

now only performed on a semi-laboratory scale. A larger scaling up has not yet started.



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Reactants The reactants are elemental mercury, elemental sulphur, polymeric

sulphur, coarse and fine gravel, sand and CaCO3. The concrete block has a

mercury content of 30%.

Process description The stabilization takes place in a two-step process. In the first step the

elemental mercury is stabilized with sulphur to meta-cinnabar with a

planetary ball mill. In a second step this meta-cinnabar is incorporated in

a polymeric S-concrete matrix, composed of gravel, sand, filler, elemental

sulphur and modified sulphur.

Process conditions The concrete matrix is prepared at 140°C and at room temperature

Throughput The facility is still only on a small scale, producing 6 kg of a final product

per batch and a throughput of 4 kg/

Emissions Due to the laboratory scale, emissions can occur during the milling of

sulphur and liquid mercury

Energy consumption No information could be provided for the energy consumption of the

process.


costs

The cost for the stabilization of metallic mercury at a full scale application

is estimated to be between 15,000 and 17,000 €/tonne metallic mercury.

Implementation costs No information could be provided for the implementation costs of the

process.

Patent Patent application N° P200930672, priority date: 9 September 2009

[P200930672]

Implementation time No information could be provided for the implementation time of the

process.

Resulting Product

Final Product The final product is prepared in the form of a monolithic material of

16x16x4 cm. The shape of the ashlars can also be changed.

Product stability The concrete blocks have a water absorption by capillary of 0.07 g/cm2.

The water permeability under low pressure (RILEM) shows no water

absorption under low pressure. To determine the leaching behaviour the



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Resulting Product

TCLP procedure was used and the average value was ~0,102mg/l. The

concrete block shows very good mechanical properties with a

comprehensive strength of 57.2 ± 44 N/mm2 and a flexural strength of

8.5 ± 1.17 N/mm2.

Volume and weight

The density of the concrete block is about 3.1-3.2 g/cm3 and has a total

porosity of ~2% and a closed porosity of ~0.6%. The mercury loaded

concrete blocks have a higher density and lower pore volume than a

mercury free reference. The reason is that it is expected that meta-

cinnabar particles fill interparticle interstices and the higher size pores

which exist in the initial S-concrete. The volume of the product is

approximately 13 times higher than elemental mercury and the weight is

increased by a factor of 3.

Emissions from the

product No emissions from the product except leaching are known.



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7.7 Conclusion

Based on an extensive literature search including patent data bases, scientific data bases and other

relevant recent publications numerous pre-treatment technologies have been identified. Wherever

possible, the authors or companies, developing the technologies, have been approached directly to

receive the most recent information on the state of the art of the technology and their state of

implementation.

The identified technologies could be allocated to 6 categories depending on the used technology or

stabilization process (see Table 7-6).

Apart from the technologies already realised in large scale application only very limited information

on costs or environmental aspects of the process are available.

An evaluation of the technologies against technical, environmental and economic requirements is

included in section 8.

In particular the sulphur stabilization and the SPSS technologies are already well developed and

available at a full-scale application. Detailed data on operation conditions and final products as well

as some information concerning costs are available and included in the previous section. In addition,

an overview on the most important information related to technologies already realised in large-

scale application is compiled in Annex 5.

Sulphur stabilisation

The stabilisation with sulphur has been widely described in literature such as [DE453523],

[CA1011889], [ÖREBRO 2006], [US3804751], [Lopez 2008], [Kystverket 2008], [Mersade 2007a],

[USEPA 2002], [GRS 2009A] and [USEPA 2005]. Literature refers to the stabilisation of metallic

mercury but also to mercury-containing waste.

In general sulphur is seen as an appropriate stabilisation agent and the stabilisation process with

sulphur is considered to be an effective stabilisation process. If testing results have been presented in

literature [US EPA 2005], the sulphur containing stabilisation techniques show good test results with

respect to the stability of the product. Due to intensive research work a continuous improvement of

the process could be observed.

At present, only two companies realised this process on a large-scale application, SAKAB/DELA,

Germany and Bethlehem Apparatus, USA. Literature available related to the latest process conditions

are patents, presentations [DELA 2009] or direct information from the companies.

DELA has published some patents on the production of mercury sulphide. Patents are available for a

continuous process [EP 2072 468 A2] as well as for a discontinuous process [EP 2072 467 A2]. The

currently realised process refers to patent No. EP 2072 467 A2 (batch process).



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Details of the process have been gathered by telephone conversation, e-mails and a visit. During

2009 the process was continuously developed and the parameters have been adjusted.

Since the end of 2009, stable and low leaching values are realised and the mercury concentration in

the gaseous phase was measured and was below the limit of detection of the used analysis

instrument (0.003 mg/m³).

In February 2010 a large-scale application (installed capacity: 1,000 t/year) has been installed by the

company DELA80. At the moment no test results of the product could be provided.

Recently, a patent of Bethlehem Apparatus concerning the stabilisation of metallic mercury with

sulphide has been approved and an official number is expected in the near future81. All the data

related to the process developed by Bethlehem Apparatus has been gained by telephone

conversation and a filled in questionnaire from the company.

The quality of the stabilised product is comparable to the product resulting from the SAKAB/DELA

process. The leaching value is in the same range and no unreacted metallic mercury could be

detected when analysed with x-ray diffraction or by computer aided tomography. With both

methods no mercury could be detected82.Sulphur polymer stabilisation/solidification (SPSS)

The different literatures ([Brookhaven_Newmont 2003], [US6399849B1], [ACS Kazakhstan 2000],

[USEPA 2002a]) describing the SPSS process developed by the Department of Energy (DOE) evaluate

this pre-treatment technology as a stable process which is fully developed. Only one report ([USEPA

2002a, vendor A]) indicated leaching values - measured at different pH values – which seemed higher

than expected. After direct contact with DOE83 it turned out that this technique still needs some R&D

to optimize the technology and improve quality control (i.e. to ensure complete reaction of all the Hg

and therefore consistently low leachability). The high leaching values reported in the report result

from an incomplete stabilisation of the metallic mercury. Only 99.7% of the mercury is retained in

the product.

Apart from DOE another company (ADA Technology) has been identified which has developed a pre-

treatment process based on SPSS. The process is described in detail in literature (e.g. [USEPA 2002a,

vendor B], [USEPA 2005]). In addition several discussions and e-mail exchanges took place with ADA

Technologies as well as with M&EC, the licence holder of this technology. The installation costs of the

facility are stated in the report [USEPA2005] to be about 2,000,000 € and the estimated cost per year

(for 1,000 t/year) have been set at about 2,700,000 €. According to ADA Technology this economic

calculation of the report [USEPA 2005] is considered to be rather conservative. ADA Technology

which has 15 years of experience in developing mercury stabilisation solutions indicated that on the

80 E-mail: Miriam Ortheil, DELA GmbH, 6 January 2010 81 E-mail: Bruce J. Lawrence, president, Bethlehem Apparatus Co. Inc., 5 January 2010, U.S. Patent Application

No. 12/255,403 82 E-mail: Bruce J. Lawrence, president, Bethlehem Apparatus Co. Inc., 19 August 2009 83 E-mail statement from Mr. Kalb, Division Head, Brookhaven National Laboratory, 28.08.2009



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basis of their experience mercuric sulphide is the most stable and least soluble form of mercury.84

Amalgamation

Technologies based on amalgamation of mercury with other metals are widely described (especially

[USEPA 2007], [USEPA 2002a], [WO2005092447 A2] [US5034054]), but the stability and suitability of

the resulting amalgam for a final storage are highly questionable. Report [USEPA 2002a] compares

leaching limit values of different pre-treatment technologies. The leaching values indicated for the

amalgamation process (vendor C) are higher compared to the other pre-treatment technologies

using sulphur as a stabilisation agent. Especially at lower pH values (pH <4) the poor quality of this

stabilisation technology can be recognised. No information on a potential commercial use has been

found. The poor stabilisation performance of amalgams is a general accepted opinion [USEPA 2002a]

and no expert could be found who would favour amalgamation as a stabilisation technique. In many

cases as in the patent [US5034054] amalgamation is combined with an encapsulation step.

CBPC

The stabilisation of metallic mercury by chemical bonded phosphate ceramic processes are well

described in the literature, e.g. [US Wagh], [US Wagh Singh], [USWagh]). Evaluating the literature,

the reader has the impression that this technology is ready to be used to stabilise metallic mercury.

To verify this information Mr. Wagh was contacted. The following statement has been received by e-

mail85: “The phosphate bonded ceramic technology has not been used or demonstrated for

elemental mercury. We have developed detailed solubility models to produce suitable formulation

for treating metals, but we have not carried out any experimental work.” It was also stated that still a

lot of work has to be done to develop a process to treat mercury in large quantity, though

theoretically this would be possible.

Encapsulation

A lot of information related to encapsulation processes has been identified. In particular [USEPA

2002b] describes encapsulation processes in detail. But all technologies deal with the encapsulation

of mercury containing waste. Investigations using an encapsulation technique with metallic mercury

could not be found. Numerous patents are available describing encapsulation of mercury

contaminated waste (e.g. [WO2005 039702 A1]). A rough screening of these patents was carried out

but no suitable technologies for the treatment of pure metallic mercury have been identified. Due to

its liquid state, metallic mercury is completely different to mercury-contaminated waste (solid) and

therefore stabilisation technologies cannot be easily transferred.

Only one encapsulation technology with a prior sulphur stabilization of the metallic mercury shows

promising results [Mersade 2009A]. It can be considered that the main stabilisation is due to the

sulphurisation and not the encapsulation [Mersade 2007A]. Currently information only is available

from the institution developing this technology.

84 E-Mail statement from Mr. Jim Butz, vice president of Operations from ADA Technology, Inc. 06.07.2009 85 e-mail from Mr. Wagh, dated 23.06.2009



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A patent promoting the encapsulation of immobilised mercury (either by sulphur stabilisation,

sulphur polymer stabilisation/solidification, chemically bonded phosphate ceramic or copper) with

Ordinary Portland Cement (OPC) is described by [WO 2005092447 A2]. A practical use of this

technology could not be found.

In the following table a short overview on the realised pre-treatment per categories is given:

205


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Table 7-6: Overview on existing pre-treatment technologies for liquid mercury

Existing pre-treatment technologies Process Company Elemental mercury

per batch Daily Throughput for one existing line

Complete stabilisation

Hg content in product

Comments

DELA 5 kg 60 kg/day 84 wt% Large scale application available but not tested yet.

Sulphur stabilisation

Bethlehem apparatus

50 kg 275 kg/day 84 wt% No scaling up is planned but the parallel use of many small lines is proposed to meet quantity needs, when needed

M&CE 50 kg 250 kg/day 50 wt% 10 tonnes already stabilised SPSS

DOE 20 kg 40 kg/day X 33 wt% Incomplete reaction, presence of elemental mercury in the product

Amalgamation X X X X X

The technology is currently not economically used for Hg stabilisation

CBPS X X X X X

The technology is currently not economically used for Hg stabilisation

Encapsulation without stabilisation

X X X X X The technology is currently not economically used for Hg stabilisation

Sulphurisation / Encapsulation

MERSADE 2 kg 100 kg/day 30 wt% Needed time period for a large scale application: 3-5 years

Reference number 07.0307/2009/530302/ETU/G.2.2 206


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7.8 References

[ACS Kazakhstan 2000] Emerging Technologies in Hazardous Waste Management 8 D. William Tedder and Frederick G. Pohland, 2000 [Brookhaven Newmont 2003] Using the Sulfur Polymer Stabilization/Solidification Process to Treat Residual Mercury Wastes from Gold Mining Operations B. Bowerman, J. Adams, P.Kalb, R-Y Wan and M. LeVier 24-26 February 2003, http://www.bnl.gov/isd/documents/25533.pdf [CA1011889] McCord, Andrew T. and Wagner, lois E., Disposal of wastes containing mercury, Chem-Trol pollution Services

[CENIM 2009]

The application of sulphur concrete to the stabilization of Hg-contaminated soil, 1st Spanish national

conference on advances in materials recycling and eco-energy, F.A. López, C.P. Román, I. Padilla, A.

López-Delgado and F.J. Alguacil, 2009

[DELA 2009] Workshop on the safe storage and disposal of redundant mercury, Stabilisation of mercury for final disposal by formation of mercury sulphide, Miriam Ortheil, DELA, St Anne´s College, Oxford (UK), 13th & 14th October, 2009 [DE453523] Herstellung von lichtecher Zinnober aus den Elementen, Deutsches Reich, Alexander Eibner, 7. April 1925 [EP 2 072 467 A2] Verfahren und Vorrichtung zur Herstellung von Quecksilbersulfid zur anschließenden Entsorgung, Bonman Christian, EP2 072 467 A2 [EP 2 072 468 A2] Verfahren und Vorrichtung zur Herstellung von Quecksilbersulfid zur anschließenden Entsorgung, Bonman Christian, EP2 072 468 A2 [GRS 2009A] GSR Gesellschaft für Anlagen- und Reaktorsicherheit, Technologies for the stabilization of elemental mercury and mercury-containing wastes, Final Report, GRS – 252, ISBN 978-3-939355-27-4, October 2009 [JP2002255671] Method for producing inorganic hardened body, Suzuki Shinchi, Watanabe Hiroshi, Shimada Kyoko, JP2002255671, 2002 [Kystverket 2008] Det Norske Veritas AS, Kystverket Norwegian Coastal Administration - Salvage of U-864 -

http://www.bnl.gov/isd/documents/25533.pdf



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Supplementary studies - disposal, report NO. 23916-6, Revision N° 01, 2008 http://www.kystverket.no/arch/_img/9818145.pdf [LME]

London metal exchange , http://www.lme.co.uk/

[Lopez 2008] F.A. López, F.H. Alguacil, C.P. Roman, H. Tayibi and A. López-Delgado, Disposal of elemental mercury via sulphur reaction by milling, 2008 ; http://digital.csic.es/bitstream/10261/7692/1/DISPOSAL%20ELEMENTALHg.pdf [Lopez 2009] Stabiliszation of mercury by sulphur concrete: Study of the Durability of the Materials obtained, F.A. López, C. Pérez, A. Guerrero, S. Goñi, F.J.Alguacil and A. López-Delgado, 1st Spanish National Conference on Advances in Materials Recycling and Eco-Energy, Madrid, 12-13 November 2009 [Mercury Bakeoff 1999] Mercury Bakeoff: Technology Comparison for the Treatment of Mixed Waste Mercury Contaminated Soils at BNL] P.D. Kalb, J.W. Adams, L.W. Milian, G. Penny, J. Brower, A. Lockwood Brookhaven National Laboratory 2 March 1999 [Mersade 2007 A] M. Ramos, Literature review concerning corrosion problems in mercury and stabilisation of liquid Hg, Status Report Literature review, T 1.3 and T 1.4, Life Project Number Life06 ENV/ES/PRE/03, February 2007; http://www.mayasa.es/Archivos/Mersade/WEB%20Literature%20review%20concerning%20to%20mercury%20corrosion%20and%20stabilisation%20of%20liquid%20Hg.pdf [Mersade 2007 B] P. Higueras, J. M. Esbrí, Literature review concerning environmental mercury monitoring, Status Report, Life Project Number Life06 ENV/ES/PRE/03, March 2007; http://www.mayasa.es/Archivos/Mersade/WEB%20Literature%20review%20concerning%20environmental%20mercury%20mon….pdf [Mersade 2009] Process for the Stabilization of Liquid mercury, via mercury sulfide, by the use of polymeric sulfur, F.A. López, A. López-Delgado and F.J. Alguacil, Consejo superior de investicadiones cientificas (CSIC), Centor nacional de investigations metalúrgicas (CENIM) [ÖREBRO 2006] Margareta Svensson, Mercury immobilisation, A requirement for permanent disposal of mercury waste in Sweden, http://www.sakab.se/upload/dokument/pdf/Laddningsbara%20filer/Forskning%20&%20utveckling/Mercury_immobilization.pdf 3rd February 2006 [ORNL-2002] MEASUREMENTS OF MERCURY RELEASED FROM SOLIDIFIED/STABILIZED WASTE FORMS–FY 2002 http://www.clu-in.org/download/contaminantfocus/mercury/DOE-Measurements-of-Mercury115769.pdf


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[ORNL 2002a] Determination of acute Hg emissions form solidified -stabilized cement waste forms, C.H. Mattus, 2002 [P200930672] López FA, López-Delgado A, Alguacil FJ and Alonso M., Procedimiento de estabilizacion de mercurio liquid mediante cemento polimerico de azufre, via sulfuro de mercurio, P200930672 (2009) [SAKAB/ DELA 2009] Stabilization of metallic mercury, Fact sheet, Susanne Kummel, 2009 [SPC 2009] http://www.ktf-split.hr/periodni/en/abc/kpt.html [Spiegel 2007] Gau in der Grube, Michael Fröhlingsdorf, Sebastian Knauer, 17/2007 [UNEP 2009] UNEP, Draft technical guidelines on the environmentally sound management of mercury wastes, 4th Draft, April 2009 [UNEP 2009 B] http://www.chem.unep.ch/MERCURY/ [USEPA 2002] Mary Cunningham, John Austin, Mike Morris, Evaluation of Treatment of Mercury Surrogate waste, final report, 2002 [USEPA 2002a] Mary Cunningham, John Austin, Mike Morris, Greg Hulet, Mercury wastes evaluation of treatment of bulk elemental mercury, 2002 [USEPA 2002b] Paul M. Randall, Sandip Chattopadhyay, Wendy E. Condit, Advances in encapsulation technologies for the management of mercury-contaminated hazardous wastes, 2002 [USEPA 2002c] Hugh W. McKinnon, Preliminary analysis of alternatives for the long term management of excess mercury, EPA/600/R-03/048, 2002, http://www.epa.gov/nrmrl/pubs/600r03048/600R03048.pdf [USEPA 2003] Evaluation of chemically Bonded Phosphate Ceramics for Mercury Stabilization of a Mixed Synthetic Waste, Land Remediation and Pollution Control Division National Risk Management Research Center Sandip Chattopadhyay, Paul M. Randall, March 2003 http://www.epa.gov/nrmrl/pubs/600r03113/600r03113.pdf [US EPA 2005] Paul Randall, Economic and Environmental Analysis of Technologies to Treat Mercury and Dispose in a Waste Containment Facility, April 2005 http://www.epa.gov/nrmrl/pubs/600r05157/600r05157.pdf




http://www.epa.gov/nrmrl/pubs/600r03113/600r03113.pdf




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[USEPA 2007] U.S. Environmental Protection Agency, Treatment Technologies For Mercury in Soil, Waste, and Water, EPA-542-R-07-003, 2007, 2007 http://www.epa.gov/tio/download/remed/542r07003.pdf [US20080019900 A1] Christelle Riviere-Huc, Vincent Huc, Emilie Bosse, Method for stabilisation of metallic mercury using sulphur, Oblon, Spivak, Mccleland Maier & Neustadt, 24. January 2008 [US20080234529 A1] Treatment of elemental mercury, Moore & Van Allen PLLC, Henry Boso Chan, Raymond Hall, 25. Sep. 2008 [US3061412] Preparation of mercuric sulfide, Anthony Giordano, 30. October 1962 [US3499774] Mercury-containing phosphate glass University Park Woldemar A. Weyl 10. March 1970 [US3704875] Removal of mercury from effluent streams, Penwalt Corporation, Paul Francis Waltrich,05. December 1972 [US5034054] Process for treating mercury in preparation for disposal, Ecoflo Inc., Jeffrey C. Woodward, 23 July 1991 [US5347072] Stabilizing inorganic substrates, Harold W. Adams, 13. September 1994 [US5562589] Stabilizing inorganic substrates Harold W. Adams, 8. October 1996 [US5569153] Method of immobilizing toxic waste material and resultant products, Southwest Research Institute, William A. Mallow, Robert D. Young, 29. October 1996 [US5678234] Process for the encapsulation and stabilization of radioactive, hazardous and mixed wastes, Peter Colombo, Paul D. Kalb, John H. Heisser, US 5,678,234, 1997 [US6399848 B1] Encapsulation of hazardous waste materials, Dolomatrix International Limited, Dino Rechichi, 04. July 2002 [US6399849 B1] Treatment of mercury containing waste, Brookhaven Science Associates LLC, Paul D. Kalb, Dan Melamed, Bhavesh R Patel, Mark Fuhrmann, 04 July 2002




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[US6153809A] Polymer coating for immobilizing soluble ions in a phosphate ceramic product, Dileep Singh, Arun S. Wagh, Kartikey D. Patel, US 6,153,809, 2000 [US6403044 B1] John E. Litz, Thomas Broderick, Robin M. Stewart, Method and apparatus for stabilizing liquid elemental mercury, ADA Technology Inc., 11. July 2002 [US Wagh] Chemically Bonded Phosphate Ceramics for Stabilization and Solidification of mixed waste, Energy Technology Division Arun S. Wagh, Dileep Singh, Seung-Young Jeong, [US Wagh 2000] Mercury Stabilization in Chemically Bonded Phosphate Ceramics; Energy Technology Division Argonne National Laboratory Dilep Singh, Arun Wagh, Seung Young Jeong http://www.anl.gov/techtransfer/Available_Technologies/Material_Science/Ceramicrete/wagh-mercury.pdf [US Wagh Singh] Method for producing chemically bonded phosphate ceramics and for stabilizing contaminants encapsulated therein utilizing reducing agents; United States Government; Dileep Singh, Arun Wagh, Seung-Young Jeong http://www.osti.gov/bridge/purl.cover.jsp;jsessionid=5971569EAD6B8B9106D1BE27F5F19563?purl=/782750-nscUTZ/webviewable/ [Wagh-1] Personal information Mr. Wagh [Waste Management 2001] Sulfur Polymer Solidification/Stabilization of elemental mercury waste M. Fuhrmann, D. Melamed, P.D. Kalb, J.W. Adams, L.W. Milian 14 August 2001 [Waste Management 2001]

Sulfur polymer solidification/stabilization of elemental mercury waste, Waste Management 22 (2002)

327-333, M. Fuhrmann, D. Melamed, P.D. Kalb, J.W. Adams, L.W. Milian, 2001

[Waste Management 2002] Sulfur polymer stabilization/solidification (SPSS) treatability of simulated mixed-waste mercury contaminated sludge J.W: Adams, B.S. Bowerman, P.D. Kalb 24-28 February 2002 http://www.wmsym.org/archives/2002/Proceedings/11/511.pdf [WO2005039702 A1] A method and composition for stabilizing waste mercury compounds using ladle furnace slag, Nanyang Technological University Sun, Darren Delai, Tay, Joo Hwa, Cheong, Hee Kiat, 06. May 2005 [WO2005092447 A2] Treatment of elemental mercury, Nuclear Fuels PLC, Chan, Henry, Boso 22. March 2005

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8 Screening analysis of options

The main goal of this study (and also of the Hg-Regulation) is to find an economically viable

permanent solution for the long-term storage of liquid mercury with minimized environmental

impacts which prevent the re-entry of the waste mercury onto the market. For this purpose, existing

options have to be investigated in a screening analysis.

It should be noted that possible storage facilities have to fulfil the requirements set out in Directive

1999/31/EC (landfill directive, with the exception of Article 5 (3)(a)) and Decision 2003/33/EC (WAC

decision, with the exception of section 2.4, Annex I). But as the existing provisions are established for

the storage of solid waste it is necessary to investigate if these provisions are sufficient to ensure

safe storage of metallic mercury with its specific properties (e.g. liquid state, high vapour pressure).

In contrast to the other options, option 6 (pre-treatment of metallic mercury) consists of numerous

sub options representing different pre-treatment technologies (for detailed information on the pre-

treatment technologies, see chapter 7). A differentiation is needed as each pre-treatment option is

different in relation to its environmental performance, costs and in particular, maturity of the

technologies.

The main objective of the screening analysis is to evaluate the options identified in section 3 against

minimum technical, environmental or economic requirements. An investigation will be carried out to

determine whether appropriate minimum requirements are already available by applying existing

and implemented legal provisions (e.g. in the WAC Decision) or if additional requirements for the

facilities or criteria for the acceptance of the waste are necessary.

Options which do not fulfil the minimum requirements will not be further investigated. The feasibility

of the options as regards their implementation time and costs will also be taken into consideration.

In the following, specific criteria will be described in detail.

The screening analysis results in a short list of options which have been assessed as feasible for the

storage of the mercury waste (metallic or in stabilized form) under the pre-condition that the derived

additional facility-related requirements and acceptance criteria are fulfilled.

The analysis is based on the information compiled in the review chapters 4-7.



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8.1 Identification of minimum requirements for storage options

Technical minimum requirements

The technical minimum requirements which the options have to fulfil have been mainly derived from

the provisions in Regulation (EC) No 1102/2008 but also other relevant minimum requirements

related to the technical performance of the pre-treatment technologies are included in the screening

analysis.

For the permanent underground storage of liquid mercury in deep hard rock or salt formations, the

following technical minimum requirements have to be fulfilled by the options (recital 11, Hg-

Regulation):

• protection of groundwater against mercury

• prevention of vapour emissions of mercury

• impermeability to gas and liquids of the surroundings and

• firmly encapsulating the wastes at the end of the mines' deformation process

Furthermore, deep underground hard rock formations have to provide a level of safety and

confinement equal to those of salt mines.

The Regulation also foresees appropriate containment for the storage (Article 3 (1)). The

containment and the lining of the mercury have no barrier function in the underground long term

storage (WAC Decision, Appendix A, Nr. 1.2.4) Therefore, the main function of the containment and

the lining is to ensure a safe handling of the liquid mercury and a safe encapsulation of the liquid

mercury until the cell and the salt mine are closed.

For the temporary underground storage of liquid mercury in deep hard rock and salt formations, the

following technical minimum requirements have to be fulfilled by the options (recital 11, Hg-

Regulation):

• protection of groundwater against mercury


• impermeability to gas and liquids of the surroundings and

• reversibility/retrievability

Temporary storage is only seen as bridging of the gap until a permanent solution is found. Therefore,

storage should take place in a way that subsequent processing of the metallic mercury waste is not

hindered or made impossible.



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In the case of a temporary storage, the containment on the one hand ensures a safe handling and

storage of the waste, and on the other hand it might also be part of the multi-barrier system to

protect the biosphere against mercury emissions. Therefore, an appropriate containment suitable for

the temporary storage conditions (salt mines or hard rock formations), as stated in the Regulation

(EC) N° 1102/2008, is also a minimum requirement for temporary storage.

For the temporary storage of liquid mercury in above ground facilities, the following technical

minimum requirements have to be fulfilled (recital 12, Hg-Regulation):

• reversibility

• protection of mercury against meteoric water

• impermeability towards soils and


The same minimum requirements related to the containment apply as described above for the

temporary storage in underground disposal sites.

Environmental and health related minimum requirements

Environmental minimum requirements are defined by existing environmental limit values. Options

that are further investigated are only those that guarantee proper compliance with existing

environmental limit values for example for leaching rates, underground water and/or air. Relevant

limit values are included in chapter 4.2.3.

In addition, the protection of workers has to be ensured by complying with relevant occupational

limit values and periodic monitoring. Varying occupational limit values have been established for

mercury and its inorganic divalent compounds in the EU Member States. An overview on the relevant

values is given in chapter 4.1.5)

Economic minimum requirements

Options will not be further examined that – compared to viable options – generate additional costs

without providing technical or environmental benefits or added value.

Technologies that have been evaluated (e.g. due to technical or economic aspects) as not suitable at

the current state of development may be taken into consideration again (within an iterative

investigation procedure) in case no adequate technology could be identified in the feasibility analysis

and they might be expected to be a solution in the future, combined with the option of temporary

storage now.



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8.2 Feasibility of options

In addition to the above-described minimum requirements, the feasibility of implementation is

discussed.

The feasibility of implementation evaluates the identified options against their availability until 15

March 2011 (date on which significant quantities of liquid mercury will be characterised as waste due

to the entry into effect of the export ban regulation)and their general adequacy against the given

background (capacity to store all expected mercury waste).

The result of the feasibility assessment is also the basis for the decision if a temporary storage of

liquid mercury is required because no suitable permanent solution would be available up to 15

March 2011.

Feasibility of implementation

Capacity available

It is estimated that around 8,000-9,000t of liquid mercury would have to be stored within the next

ten years. This amount would result in a net storage volume of around 700m³. Feasible options

should have the capability to store this amount or volume, taking also into account additional space

required for the packaging of liquid mercury.

Experience available

Experience already available related to large-scale operations and with the storage of comparable

waste/products is required for proper implementation.

Implementation time

The implementation time of a possible option is also an important criterion for its large-scale

feasibility. Options with an implementation time of more than 2 years in cases of temporary storage

are not considered feasible, since a solution for a temporary storage at least, has to be found by 15

March 2011. In the case of permanent storage, no time restriction related to the implementation is

foreseen since on the one hand a temporary storage can be used as an interim solution. On the other

hand, investigations related to long-term safety of the stored mercury might be very time-consuming

and should not be restricted.

Implementation costs

Implementation costs cover not only the costs for the practical implementation of the option, but

also take account of estimated costs related to research still needed for the proper implementation

of the option.



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8.3 Acceptance criteria for metallic mercury and appropriate containment, procedure for the acceptance at the storage facility

For a safe storage of the waste metallic mercury, its specific properties and components have to be

defined for the acceptance at the storage site. In order to facilitate handling, it is recommended to

establish only one set of acceptance criteria and procedure for metallic mercury and for the

container, which is valid for all types of storage facilities (underground/above-ground,

temporary/permanent).

8.3.1 Acceptance criteria for metallic mercury

The acceptance criteria are defined in a way that no unacceptable risks arise for the storage facility.

Any deviation from these defined criteria might result in possible risks for either the facility

surroundings or the workers, or both of these.

To be accepted for the temporary or permanent storage waste metallic mercury should meet the

following minimum acceptance criteria:

- Purity of the mercury: > 99.9 % per weight

- Max. metallic contaminates (like iron, nickel, copper): < 20 mg/kg each

- Presence of sodium < 1 mg/kg

- No residual radioactivity (e.g. from tracers used in the chlor-alkali industry)

- No impurities capable of corroding carbon or stainless steel (e.g. nitric acid solution, chloride salts

solutions, or water)

Justification:

The purity of the liquid mercury is the most important factor. The higher the purity, the lower the

risk that the stored mercury contains impurities, which might interact with the containment or the

storage environment. Experiences and investigations related to appropriate container material are

available (MERSADE, see chapter 6.4.3.1 and ORNL, see chapter 6.4.3.2). These investigations are

based on the examination of existing containers that have been used for several years for the storage

of liquid mercury. The minimum purity of the stored mercury was 99.5% (ORNL) and 99.9%

(MERSADE).

[ORNL 2009] recommends only storing mercury with a purity of at least 99.5% (per volume) to avoid

any unforeseeable reactions due to a lower purity of mercury.

Mercury recovered from the chlor-alkali plants has a purity above 99.9% [personal information by

Euro Chlor]. This value is currently also applied as minimum criteria for the stored liquid mercury at

Almadén. All accepted mercury from chlor-alkali plants has to fulfil this criterion. In case this



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requirement is not fulfilled, a purification of the mercury by distillation has to be carried out prior to

the storage (see chapter 6.3.1). Following the precautionary principle it is recommended to establish

a purity of 99.9% per weight for metallic mercury as this quality was used for the investigation and

derivation of container material. With this purity the quality requirement of existing investigations is

covered.

Apart from the purity, also the content of certain contaminants should be known and – if necessary –

excluded or restricted. Euro Chlor has an internal quality standard for mercury. Following this

standard metallic contaminants, such as iron, nickel, copper should be below 20 mg/kg each

[personal information by Euro Chlor]. Following Euro Chlor this quality can be achieved by chlor-alkali

plants which present the most important source of metallic mercury to be stored. Therefore it is

recommended to establish - at least for mercury coming from chlor-alkali plants – this limit value.

In addition, the presence of radioactive components (e.g. from tracers used in the chlor-alkali

industry) and sodium has to be checked and avoided following the standard of Euro Chlor [Euro Chlor

2007]. According to [Euro Chlor 2007] sodium should be avoided due to the fact that it might

produce hydrogen during the storage.

The U.S. Department of Energy (DOE) published in November 2009 minimum acceptance criteria for

temporarily stored mercury [DOE 2009], see also chapter 6.4.3.2. Apart from the minimum purity

requirement of 99.5% (per volume), the absence of any radiological components, the document set

out that any impurities capable of corroding carbon or stainless steel, such as nitric acid, chloride

salts, or water, should not be present in liquid mercury for permanent or temporary storage. It is

recommended to introduce this criterion for the temporary and permanent storage liquid mercury in

Europe as well.

Currently at Almadén no limit value for sodium, metallic contaminants and radioactive components

are established. Following information received by Mayasa (personal information Mr. Ramos)

accepted mercury (not from chlor-alkali-plants) show for example concentrations of sodium up to

200 ppm. Also for other elements like potassium, calcium, boron concentration above the quality

standard of Euro Chlor are accepted at Mayasa.

However, here again the precautionary principle should be applied. To avoid any adverse effects

during the storage due to the production of hydrogen it is therefore recommended to introduce the

above mentioned criteria.

It is further recommended to establish a specific waste code for metallic mercury from chlor-alkali

plants fulfilling the above described criteria. Following the precautionary principle it is recommended

to apply these criteria also for mercury resulting from other sources. Deviations from these criteria

have to be checked and would need a justified case-by-case justification.

Another argument for a specific waste code for metallic mercury is that it would be easier to track

the route of the mercury from different sources.

The screening analysis is based on the assumption that the stored liquid mercury fulfils the above



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stated minimum requirements.

8.3.2 Appropriate containment

The containment has to ensure a safe handling and storage of the waste over a certain time. In the

case of a temporary storage, the containment might also be part of the multi-barrier system to

protect the biosphere against mercury emissions.

Based on the information provided in chapter 6.4.3 the storage containers for liquid mercury have to

fulfil the following minimum requirements:

- Container material: Stainless steel (AISI 304, 316L) or carbon steel (ASTM A36 minimum)

- Container has to be gas and liquid tight

- Outer side of the container must be resistant against the storage conditions

- Containers should be certified for the storage of mercury

- Welds should be avoided as far as possible

Justification:

The type of container material is based on experiences and investigations related to appropriate

container material (MERSADE, see chapter 6.4.3.1 and ORNL, see chapter 6.4.3.2).

Only containers should be allowed which are gas and liquid tight, so no mercury or mercury vapour is

able to escape from the container. The container should be certified for the storage of mercury. This

can either be proven by a paper certificate from the producer including the type number or indicated

in a data plate which is fixed at the container. These recommendations are technically obvious (see

chapter 6.4) and required to adequately protect workers health and the environment.

For above-ground storage long-term experience are in particular available from an existing above-

ground warehouses/storage facilities for liquid mercury in Europe (Almadén) and in the USA (DNSC),

see also chapter 6.3. These containers are also seen as appropriate for storage in underground

disposal sites in particular in the dry atmosphere of salt mines.

Welds are the weakest point in the container and should therefore be avoided as far as possible (see

chapter 6.4.3.2).

Each facility can define which size of containers is acceptable (depends on the facility conditions).

8.3.3 Acceptance procedure

The standard waste acceptance procedure as defined in Directive 1999/31/EC and Decision

2003/33/EC shall apply for metallic mercury. Metallic mercury is only allowed to be accepted if it is



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addressed in the site-specific risk assessment and included in the list of waste authorized to be

stored at a specific site. Prior to the shipment of the mercury an approval by the facility operator is

necessary. For this purpose the waste owner has to send information on the amount and

characteristics of the waste to the storage facility.

In addition, the following requirements shall be fulfilled:

- Only acceptance of metallic mercury which fulfils the minimum requirements as set out in

section 8.3.1 (verification required either by sampling or a certificate issued by a certified

person)

- Visual inspection of the container, no acceptance of damaged, leaking or corroded containers

- Only acceptance of containers with adequate labelling (at least according to the transport

requirements)

- Only acceptance of containers with a certificate which confirms the appropriateness for the

storage of liquid mercury

Justification:

In order to ensure that a container fulfils the minimum requirements as mentioned in chapter 8.3.2 a

certificate is needed. By the mean of this certificate the operator of the storage facility is able to

verify if the container is appropriate for the storage of liquid mercury.

The certificate – might also be a plate permanently fixed on the container - should include as a

minimum, identification number of the container, container material, producer of the container,

date of production and a confirmation that only mercury has been stored/transported in the

container (exclusion of storage of products which might react with mercury or the container

material).

The acceptance procedure at underground storage facilities typically includes visual inspection,

sampling and analysis of the received waste (WAC Decision). To avoid the opening of the mercury

containers and thus possible mercury emissions, it is recommended that the acceptance of sealed

containers accompanied by a certificate – issued by a certified person - which verifies the quality of

the mercury is possible.

In the case of the acceptance of sealed containers it is crucial that there is a reliable proof that the

containers only contain mercury which fulfils the minimum acceptance criteria as mentioned in

section 8.3.1. To avoid mercury is accepted which does not fulfil the minimum criteria, the filling and

the sealing of the containers should be supervised by a certified person. It is essential that the

supervising person has basic knowledge on the process and required quality of the mercury. With the

requirement that a certified person should supervise the filling and sealing on the one hand it is

assured that the person has a basic knowledge on the process and required quality of the mercy. On

the other hand incorrect information or misuse of the certificate could be avoided.



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The certificate, which has to be issued by the certified person, should include at least:

- Name and address of the company (waste owner)

- Place and date of packaging

- The purity of the mercury (min. >99.9%) and, if relevant, description of the impurities

(analytical report has to be provided)

- Quantity of the mercury

- Any specific comments

- Signature

One major advantage of the acceptance of sealed containers is that mercury emissions occurring

during the opening process can be reduced and thus a possible exposure of workers with mercury

can be avoided. In addition the risk of damaging of the plugs or improper re-closing of the flask -

which might result in a release of small amounts of mercury during the storage - can be significantly

reduced. On the other hand there is the risk that mercury is stored which does not fulfil the

minimum quality requirements due to wrong information included in the certificate. In case of any

suspicion that the quality criteria might not be met random samples should be carried out.

Sealed containers accompanied by an incomplete certificates or certificates issued by unknown

certification institutions have either to be rejected or the waste acceptance procedure as required by

the WAC has to be applied.

Record keeping

In general the recordkeeping for hazardous waste is designed to track hazardous waste from its

generation to final disposition.

With respect to the record keeping of the basic characterisation and compliance testing no specific

time frame is given in the Annex of the WAC Decision. Each Member State has to determine the

period of time these records have to be kept. The time for sample keeping from the on-site

verification is set by the WAC Decision for a minimum of one month.

In case of temporary storage it is recommended that the documents have to be stored for at least 3

years after the termination of the storage.

In case of a permanent storage of liquid mercury the Member State specific requirements should

apply but the records should at least be kept until the closure of the disposal site.

A plan of the storage area should be kept also after the closure of the storage site.

Records and plans must be available for inspection by regulators.



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8.4 Option 1l: permanent storage of liquid mercury in salt mines

In chapter 6.2.2, an overview is provided on basic characteristics of salt rock formations and their

qualification as a permanent disposal facility for hazardous waste.

In the following, an evaluation of the options conforming to the minimum requirements described in

chapter 8.1 is carried out. As already stated above, metallic mercury is only allowed to be stored in

facilities which fulfil the requirements of the landfill directive and the WAC decision.

8.4.1 Technical minimum requirements

In the case of permanent underground storage in salt mines, the potential storage site needs a

permit as an underground landfill, including a site specific risk assessment as outlined in Appendix A

of the WAC decision. The site-specific risk assessment has to include the following:

1. geological assessment;

2. geomechanical assessment;

3. hydrogeological assessment;

4. geochemical assessment;

5. biosphere impact assessment;

6. assessment of the operational phase;

7. long-term assessment;

8. assessment of the impact of all the surface facilities at the site

9. assessment of other risks (e.g. protection of workers)

More detailed information on the site-specific risk assessment is included in section 5.2.3.

Based on the site-specific risk assessment, the list of acceptable waste has to be derived for each

storage site. As a consequence, the storage of liquid mercury in underground facilities is only possible

when it is demonstrated that the level of isolation from the biosphere is acceptable (WAC Decision,

Appendix A, Nr. 2.3).

Salt rock fulfils the requirement to be impermeable to gas and liquids (WAC Decision, Appendix A, Nr.

3.2). Therefore, in cases of vapour emissions of mercury from the waste after the sealing of the mine

or disposal cell, these should then still remain enclosed in the salt rock.

Due to its plastic properties, salt rock has a creeping potential, and thus a firm encapsulation of the

waste at the end of the mines’ deformation process is possible. Decision 2003/33/EC describes the

role of salt mines as follows: With the overlying and underlying impermeable rock strata (e.g.



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anhydrite), it acts as a geological barrier intended to prevent groundwater entering the landfill and,

where necessary, effectively to stop liquids or gases escaping from the disposal area.

Its function as a geological barrier to protect groundwater against mercury strongly depends on the

geological conditions of the salt rock. In particular the thickness and composition of the salt rock as

well as the overlying and underlying impermeable strata (e.g. anhydrite or claystone) define the

protection level of the storage facility. Therefore, minimum requirements for theses parameters – in

addition to the requirements already included in Decision 2003/33/EC – are recommended to be

established to prevent mercury from entering the biosphere due to inappropriate geological

conditions.

Although the disposal of radioactive waste is carried out under different conditions compared to

metallic mercury, one principal aspect is the same – the safe long-term isolation of the hazardous

waste material from the biosphere. Intensive research related to safe storage of radioactive waste in

geological deposits has been carried out (see section 6.2.4). Valuable information is available in

particular on minimum requirements related to the geological effectiveness of salt rocks. Based on

the findings of this research, exclusion and minimum requirements have been defined which an

underground disposal site should fulfil for safe storage (see section 6.2.4.2). Some of these minimum

criteria, which are not already covered by the site-specific assessment as outlined in Appendix A of

the WAC decision, are also seen as being relevant for the storage of liquid mercury. In particular, the

minimum thickness of the isolating salt rock being at least 100m, as well as the minimum depth of

the storage site being 300m, these conditions should be fulfilled as additional safety factors.

In case a storage site does not fulfil these criteria (300m minimum depth and 100m minimum

thickness of the isolation rock) it has to be proven by a separate document that due to other

geological criteria or measures this deficit can be compensated. The determination of the

effectiveness of the geological salt rock barrier by a time factor is seen as an appropriate criterion for

the safe storage of liquid mercury in salt mines. It is proposed to set a time limit for which the

geological barrier has to protect the biosphere against the entry of mercury from the storage site. For

radioactive waste, a similar approach is currently being discussed (see section 6.2.4). Following the

recommendations of 6.2.4.2, the radioactive waste has to be safely enclosed for one million years.

Due to the fact that the hazardousness of mercury, in contrast to the hazardousness of radioactive

waste, will not decrease over time, it is recommended to apply at least the same period of time for

mercury as for radioactive waste.

Therefore, a site-specific safety assessment has to be carried out including a long term safety

assessment which verifies the effectiveness of the geological barrier against liquid mercury. By

means of the assessment, it has to be proven that mercury will not pass the overlying impermeable

strata and thus enter the biosphere for a period of time in the order of magnitude of one million

years.

The storage of liquid mercury has to take place in a separate cell to avoid any reaction of the storage

containers with other chemicals. The cells have to be separated by salt barriers or other adequate

artificial barriers. As a minimum, a distance of 100m should be kept from access shafts and other



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waste storage areas to ensure a safe encapsulation.

The container also has to fulfil the minimum requirements as set out in chapter 8.3.2. Its main

function is to ensure a safe handling and storage at least until the closure of the cell.

During the operational phase of the storage cell, in case of spills or leaks, it is important that

adequate measures are established to prevent liquid mercury from entering other parts of the salt

mine. It is recommended to store the containers in collecting basins which are able to capture the

total amount of the stored liquid mercury. The collecting basins can be constructed as pits in the salt

rock or other constructed basins. Adequate linings and slopes should be installed which allow an easy

collection of the mercury.

The following table presents a summary of the outcome of the evaluation including the minimum

requirements and the identified additional facility-related requirements. The last column of the table

indicates if an option fulfils the requirements – either due to the application of already existing

provisions and/or by applying the identified additional requirements.

Technical minimum

requirements

Additional facility related requirements Minimum

requirements

fulfilled

Geological barrier enables the

protection of groundwater

against mercury

Geological barrier enables the

prevention of vapour emissions

of mercury

Geological barrier ensures

impermeability to gas and

liquids of the surroundings

The salt rock ensures a firm

encapsulation of the waste at

the end of the mines'

deformation process

- Effectiveness of the geological barrier in

terms of migration time for mercury to the

biosphere >1 million years (verification by a

site-specific assessment including a long

term safety verification)

- Minimum thickness of the isolating salt rock:

100m (justified exemption possible)

- Minimum depth of the storage area: 300m

(justified exemption possible)

- Minimum distance from access shafts and

other waste storage areas: 100m

- No storage together with other waste

- Storage of the liquid mercury containers in

collecting basins able to catch the whole

amount of stored mercury

The check mark (“ ”) does not mean that any existing landfill does already fulfil the minimum

requirements for the storage of metallic mercury. It simply indicates that if the storage site fulfils the

described additional facility-related requirements (together with the requirements set out in the



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landfill directive and the WAC Decision) it would be suitable for the storage of metallic mercury.

If existing storage facilities are available which already fulfil the requirements or if there is still need

for further investigation/research or approval by the authorities, this will be assessed under the

category “feasibility of implementation”.

8.4.2 Environmental minimum requirements

The criteria that no existing environmental limit values are allowed to be exceeded is not relevant for

the permanent storage of liquid mercury in salt mines as the technical minimum requirements

already imply a total enclosure of the liquid mercury in salt rocks for a certain time period.

The protection of workers has to be ensured during the whole operational phase of the storage cell.

Therefore, during this phase, adequate monitoring, control measures and inspection schemes have

to be defined to avoid mercury emissions from the stored mercury due to leaking storage containers

or improper handling. Proper ventilation is required and in case of any incidents, adequate

protection equipment and emergency plans have to be available. In addition, workers have to be

adequately informed and trained in case of any incidents.

Mercury vapour monitoring system

Annex III of the landfill directive already foresees specific requirements relating to a monitoring and

after-care control.

Where there is permanent storage of liquid mercury in salt mines, monitoring is only necessary

during the operational phase of the storage cell. After the closure of the salt mine, no after-care

measures are necessary, because the salt rock is considered to provide total containment and the

waste will only come into contact with the biosphere in the event of an accident or an event in

geological time (e.g. earth movement) (Nr. 3.2, Appendix A, WAC). By means of failure scenarios the

possible consequences of accidents or geological events have to be included in the site-specific risk

assessment. In the site-specific risk assessment, the probability of such accidents or events has to be

assessed.

During the operational phase, a continuous mercury vapour monitoring system has to be established

which should have a minimum sensitivity ensuring the recommended indicative limit value of 0.02mg

mercury/m³ (8 hour TWA) [SCOEL 2007] is not exceeded.

The vapour detection equipment should be installed at head level and near to the ground as mercury

vapour is heavier than air and thus the concentration of mercury is higher at ground level. The

monitoring system should be equipped with a visual as well as an acoustic alert system in case the

limit value is exceeded. The proper functioning of the monitoring system has to be checked at least

once every 12 months.



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Regular inspection

Apart from the continuous monitoring system, also regular visual inspections of the containers

should be carried out by an authorised inspector. These regular visual inspections should also include

a control ensuring proper installation of the necessary minimum requirements as stated in the

permit for the storage of liquid mercury. The inspection interval should not be more than 12 month.

After the detection of a leak, all relevant emergency measures – as laid down in internal instructions

manuals – have to start immediately. The operator of the facility has to take any measures to prevent

that workers are exposed to mercury emissions and to avoid mercury or mercury vapour entering the

environment. Within one month after the detection of the leak and the subsequent remedial actions

an inspection should take place to ensure that the origin of the leak has been eliminated and a

proper operation of the storage facility is ensured. A documentation of any leak and the subsequent

activities is required.

Emergency plans

The WAC decision foresees an assessment of the operational phase to identify possible risks for the

storage facility as well as for the workers (WAC, Appendix A, 1.2.6 and 1.2.9). Potential incidents

have to be described, evaluated and appropriate contingency measures have to be implemented.

Where there is storage of metallic mercury, emergency plans addressing the specific risks of metallic

mercury have to be established and adequate personal protection equipment has to be available. In

addition, workers have to be adequately informed and trained in case of any incidents.


requirements

Additional facility-related requirements or

acceptance criteria

Minimum

requirements

fulfilled

No exceeding of current

environmental limit values

Protection of workers during

operational phase (monitoring and

regular inspection)

Installation of a permanent mercury vapour monitoring systems - with a sensitivity of at least 0.02 mg

mercury/m³ - visual and acoustic alert system - annual maintenance and control of the

system - sensors have to be installed at ground

level and head level Regular visual inspection of the container and the storage site by a certified person - max. interval: 12 months, or - 1 month after detection of a leak Availability of emergency plans and adequate protective equipment suitable for



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requirements


acceptance criteria

Minimum

requirements

fulfilled

metallic mercury Information and training of workers on how to deal with liquid mercury

8.4.3 Economic minimum requirements

Disposal in salt mines, compared to other storage options, entails moderate costs. The permanent

storage of liquid mercury in appropriate containment would result in costs between €260-€900/t for

the storage (see section 6.2.2.3) and between 600 – 1,100 €/t mercury (see section 6.4.1) for the

container.

The economic minimum requirements are fulfilled without additional requirements.

8.4.4 Feasibility of implementation

In the European Community, 5 underground disposal sites in salt rock have been identified which are

permitted to accept hazardous waste. The remaining capacity of each underground disposal site

would be sufficient for the storage of the expected volume of liquid mercury (700 m³ net, without

packaging). According to information from the operators of the mines, storage would probably only

be possible in two of these mines (one site is currently not in use, the other sites envisage problems

in obtaining a permit).

Experience related to the storage of hazardous waste in salt rock is available in Germany in

particular. For more than 20 years, Germany has disposed of hazardous waste in salt mines.

Up to now, none of the existing facilities has a permit for the storage of pure metallic mercury, since

it was excluded from the storage due to its liquid status. However, German salt mines for example

have a permit to accept waste containing mercury, such as “fluorescent tubes and other mercury-

containing waste” (waste code 20 01 21*).

Quite extensive information is available on the properties of possible host rocks, information related

to the specific behaviour of liquid mercury in underground conditions is still very limited. Extensive

experiences, models and simulations are available for the storage of radioactive waste. The models

related to the post-closure safety of geological disposal sites are well developed and might also be

applicable to liquid mercury. According to experts, the adaption of the radioactive waste models to

liquid mercury is expected to take around 3-5 years (see section 6.2.4.2) under the precondition that

sufficient reliable data on the behaviour of metallic mercury is available.

German authorities generally consider the storage in salt mines as safe, but very little is currently



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known on the long-term behaviour of metallic mercury under storage conditions in salt rock (e.g.

behaviour in case of increased pressure, possible interactions with the host rock). Therefore,

according to information from German authorities, a project is planned to test the behaviour of

metallic (and probably also of solidified) mercury in salt rock. The outcome of this study is an

essential input to the site specific risk assessment for salt mines required for the application for a

permit to store liquid mercury. Only based on this information a safe encapsulation of the metallic

mercury can be ensured for a timeframe of 1 million years.

The intended start of this project is in 2010 (source: questionnaire survey German EPA, personal

information by Ms. Hempen). Following the information received from the German EPA, the

permanent storage of metallic mercury in a German salt mine before the results of the study are

available would not be authorised.

Relevant legal requirements like the adaption of the long-term safety assessment and the formal

permit to be allowed to store liquid mercury will need additional time. Therefore, it is not expected

that this procedure will be finalized before 2011. The time for the preparation of disposal cells in the

salt mines is expected to be relatively short, since for example, ventilation and monitoring systems

have already been installed in mines formerly used for the exploitation of salt.

The costs for the implementation of the option depend on the additional requirements which have

to be implemented, but they are expected to be comparatively low.

Minimum requirements Additional requirements Feasibility

fulfilled

Capacity Experience Only underground sites which already have

experience with the storage of hazardous waste

Approval of authorities is given Knowledge of the behaviour of metallic mercury at underground storage conditions

? Implementation time ? Implementation costs



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8.4.5 Summary: option 1l

Minimum requirements Additional facility related requirements or acceptance

criteria required

Minimum requirements

fulfilled

Technical minimum requirements YES Environmental minimum requirements YES

Economic minimum requirements YES

Feasibility of implementation YES ?

The option 1 l “permanent storage of liquid mercury in salt mines” is promising because there are

suitable sites that fulfil the technical, environmental and economic minimum requirements – under

the precondition that the additional facility related requirements and acceptance criteria are

fulfilled.”

With regard to the feasibility of implementation by 2011 there are doubts due to the fact that

reliable information on the long-term behaviour of liquid mercury in salt mines is still lacking.

Therefore, problems are expected for availability of this option in good time (expressed by “?”).



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8.5 Option 2l: temporary storage of liquid mercury in salt mines

In chapter 6.2.2, an overview is provided on basic characteristics of salt rock formations and its

qualification as a permanent disposal facility for hazardous waste.

In the following, an evaluation of the option is carried out in view of the minimum requirements

described in section 8.1. As already stated above, metallic mercury is only allowed to be stored in

facilities which fulfil the requirements of the landfill directive and the WAC decision.


With regard to the protection of groundwater against mercury, prevention of vapour emissions of

mercury and impermeability to gas and liquids of the surroundings, the same requirements apply as

for permanent storage of liquid mercury.

In contrast to permanent storage, the temporary storage option has to fulfil the technical minimum

requirements only over a certain time period, thus a long-term safety verification of the effectiveness

of the geological barrier for 1 million years is not necessary for temporary storage. However, during

the defined storage time, the relevant technical minimum requirements have to be fulfilled. As a

consequence, the effectiveness of the container to prevent mercury emissions will mainly determine

the feasibility of this option. The salt rock surrounding is only an additional safety factor in case of

spills or any unforeseeable events which would result that the stored mercury would be released

from the container. In this case the gas and liquid impermeable salt rock would act as additional

geological barrier. Because even in the worst case that not all spilled mercury could be recovered the

salt rock system still would act as geological barrier in the long term and prevent the liquid mercury

entering the biosphere.

The minimum criteria set for the permanent storage related to the depth and minimum thickness of

the geological barrier are not relevant for the temporary storage as the container provides the main

safety for the storage.

The container has to fulfil the minimum requirements as set out in chapter 8.3.2. Its main function is

to ensure a safe handling and storage. In case of a temporary storage the liquid mercury has to be

stored in a way that a subsequent processing of the liquid mercury is not hindered or made

impossible. This can be achieved by appropriate containment, which does not, or only to a very

limited extent, react with the mercury.

Storage of liquid mercury has to be in a separate cell to avoid any reaction of the storage containers

with other chemicals. The cells have to be separated by salt barriers or other adequate artificial

barriers.

In addition, the reversibility of the storage of liquid mercury has to be fulfilled, which means that the



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cavities where the liquid mercury is stored have to be stable enough for a defined storage time.

Although salt rock has a high creeping potential, the convergence of drifts lasts several hundred

years until the drift is closed. The stability and the secure access to the cavities should be guaranteed

for at least 100 years.

Adequate measures have to be established to avoid spills or leaks allowing liquid mercury to enter

other parts of the salt mine. It is recommended that containers are stored in collecting basins which

are able to capture the whole amount of the stored liquid mercury. The collecting basins can be

constructed as pits in the salt rock or in other construction forms. Adequate linings and slopes should

be installed which allow an easy collection of the mercury.

Technical minimum requirements Additional facility related requirements or

acceptance criteria

Minimum

requirements

fulfilled

Protection of groundwater against

mercury

Prevention of vapour emissions of

mercury

Impermeability to gas and liquids of

the surroundings

Retrievability of waste

- Cavity stability and secure access to the

storage area >100 years


- Minimum distance to access shafts and

other waste storage areas: 100 m

- Storage of the liquid mercury

containers in collecting basins able to

catch the whole amount of stored

mercury


During the whole temporary storage time adequate monitoring, control measures and inspections

schemes have to be defined to avoid mercury emissions from the stored mercury due to untight

storage containers or improper handling. Proper ventilation is required and in case of any incidents

adequate protection equipment and emergency plans have to be available. In additions workers have

to be adequately informed and trained in case of any incidents.

The same monitoring, inspection and emergency requirements apply as for the permanent storage of

metallic mercury in salt mines (see chapter 8.4.2).



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requirements

Additional facility related requirements or

acceptance criteria

Min.

requirements

fulfilled

No exceeding of current



operational phase

Installation of permanent mercury vapour monitoring systems - with a sensitivity of at least 0.02mg



level and head level Regular visual inspection of the container and the storage site by a certified person - max. interval: 12 months, or - 1 month after detection of a leak Availability of emergency plans and adequate protective equipment suitable for metallic mercury Information and training of workers in how to deal with liquid mercury


Disposal in salt mines, compared to other storage options, entails moderate costs. Temporary

storage of liquid mercury in appropriate containment would result in the same costs as for

permanent storage, between €260 and €900/t for the storage and between €600 and €1,100/t for

the container. Additional costs will result for the retrieval of the waste after the temporary storage

time.

The economic minimum requirements are fulfilled without any additional requirements.


In the European Community, 5 underground disposal sites in salt rock have been identified which are

permitted to accept hazardous waste. The remaining capacity of each underground disposal site

would be sufficient for the storage of the expected volume of liquid mercury. According to

information from the operators of the mines the storage would probably only be possible in two of

these mines (one site is currently not in use, the other sites envisage problems in obtaining a permit).



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Experience related to the storage of hazardous waste is available in Germany in particular. For more

than 20 years, Germany has disposed of hazardous waste in salt mines. But no experience is available

for the temporary storage of liquid mercury.

The preparation time for the cells and the implementation of the waste acceptance procedure are

expected to be relatively short as for example ventilation and monitoring systems are already

installed in mines formerly used for the exploitation of salt (see chapter 6.2.2.2). The adaptation of

these systems to the required standards should be possible within a short time.

In Germany, the possibility of long-term storage of liquid mercury in salt mines is already foreseen in

national laws (see section 5.3). According to German law, long-term storage in salt mines (landfill

class IV) is possible under the precondition that the landfill is adapted for the purpose of disposing of

metallic mercury and this aspect is taken into particular consideration in the site-specific safety

assessment.

In addition, an application for a permit for the temporary storage of liquid mercury is required,

including the additional requirements for a safe storage of it. An expertise has to be provided by the

owner of the mine to ensure the proper implementation of the minimum requirements. Although

such a permit is currently not yet available, there are no doubts that it will be provided within the

required time frame. The application time is expected to be not more than 1 year.

The costs for the implementation of the option depend on additional requirements which have to be

implemented, but they are expected to be comparatively few.


fulfilled

Capacity Experience Only underground sites which already have

experience with hazardous waste

Implementation time Approval of authorities is given Expertise on proper implementation of

minimum requirements ?




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8.5.5 Summary: Option 2l

Minimum requirements Additional facility-related requirements or acceptance

criteria required


fulfilled



Feasibility of implementation YES ?

Option 2l “temporary storage of liquid mercury in salt mines” would be a possibility if authorities give

their approval for storage of liquid and the minimum requirements relating to the facility and the

acceptance criteria are fulfilled.

8.6 Option 3l: permanent storage of liquid mercury in deep underground hard rock formations

In chapter 6.2.3, an overview is provided on basic characteristics of hard rock formations and their

qualification in accommodating permanent disposal facilities for hazardous waste.

In the following, an evaluation of the options in view of the criteria described in chapter 8.1) is

carried out. As already stated above, metallic mercury is only allowed to be stored in facilities which

fulfil the requirements of the landfill directive and the WAC decision.


According to Regulation (EC) N° 1102/2008 Article 3(1)(a) the permanent storage of liquid mercury in

deep underground hard rock formations has to provide an equal level of safety and confinement to

those of salt mines.

In the case of hard-rock storage, total containment is not possible. Therefore the underground

storage needs to be constructed in a way that natural attenuation of the surrounding strata mediates

the effect of pollutants to the extent that they have no irreversible negative effects on the

environment. As a consequence, the capacity of the artificial barriers (near environment) to

attenuate and degrade pollutants will determine the acceptability of a release from such a facility.

Hard rock formations are less impermeable against gas and liquids than salt rock, particularly due to

possible fractures in the rock body. For the same reason, the hydraulic conductivity is also higher



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when compared to salt rock (see section 6.2.3)

Within the long term safety assessment for deep underground storage sites in hard rock, it has to be

demonstrated that any discharges of hazardous substances from the storage will not reach the

biosphere – including the upper parts of the groundwater system accessible to the biosphere – in

amounts or concentrations that will cause adverse effects. Therefore, the water flow paths to and in

the biosphere have to be evaluated, including the impact of variability on the geohydraulic system. A

Swedish study [Höglund 2009, Höglund 2009A] estimated – for a specific site – the maximum release

of mercury per year in the case of storage of mercury sulphide. The study concluded that 0.5-10g

mercury/year would be released as a maximum to the biosphere. Taking into account that the

solubility in water of liquid mercury (5.6*10-2 mg/l at 25°C see Annex 4) is by several orders of

magnitude higher than the solubility of mercury sulphide (9*10-24 mg/l, see Annex 4), significantly

higher release values could be expected.

In the case of permanent storage, the containment of the liquid waste mercury and the lining of

cavities should not be taken into account for the long-term safety assessment (WAC Decision,

Appendix A, Nr. 1.2.7). As a consequence in the long term the geological system (hard rock) has the

major barrier function. Although adequate rock structures might be available, the investigations to

exclude the presence of possible fractures is very complex and their presence cannot be completely

excluded. Therefore mercury might enter the biosphere via fracture systems.

Typically, multi-barrier systems are applied in hard rock formations. In the case of liquid mercury, the

long-term safety of these barriers cannot be guaranteed and thus mercury entering the biosphere

cant not be completed prevented in particular in case of liquid mercury with its higher solubility

compared to stabilised waste. Therefore, the technical minimum requirement "equal level of safety

and confinement to those of salt mines" is not fulfilled by this option.

Technical minimum requirements Additional facility-related

requirements or

acceptance criteria

Minimum

requirements

fulfilled

Geological barrier enables the protection of

groundwater against mercury No

Geological barrier enables the prevention of vapour

emissions of mercury No

Geological barrier ensures impermeability to gas and

liquids of the surroundings No

Firmly encapsulating the waste at the end of the

mines' deformation process

No

Equal level of safety and confinement to those of salt

mines

No



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Minimum requirements Additional facility-related requirements or acceptance

criteria required


fulfilled

Technical minimum requirements no no Environmental minimum requirements / /

Economic minimum requirements / /

Feasibility of implementation / /

For option 3l “permanent storage of liquid mercury in deep underground hard rock formations,” no

sites could be identified in the scope of this study that would fulfil the technical minimum

requirements for the storage of liquid mercury. Also involved stakeholders could not suggest any

suitable site.

8.7 Option 4l: temporary storage of liquid mercury in deep underground hard rock formations

In chapter 6.2.3, an overview is provided on basic characteristics of hard rock formations and their

qualification as permanent disposal facilities for hazardous waste.

In the following, an evaluation of the options pertaining to the above-described criteria is carried out.

As already stated above, metallic mercury is only allowed to be stored in facilities which fulfil the

requirements of the landfill directive and the WAC decision.


With regard to the protection of groundwater against mercury, prevention of vapour emissions of

mercury and impermeability to gas and liquids of the surroundings, the same requirements apply as

for the permanent storage of liquid mercury in underground hard rock formations. When looking at

the assessment of option 3l, it is obvious that hard rock formations do not fulfil the minimum

requirements for a permanent safe storage of liquid mercury.

In contrast to permanent storage, the temporary storage option has to fulfil the technical minimum

requirements only over a certain time period, thus a long-term safety verification of the effectiveness

of the geological barrier is not necessary for temporary storage. However, during the defined storage

time, the relevant technical minimum requirements have to be fulfilled. As a consequence, the



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effectiveness of the artificial barriers (near environment, container) in particular, to attenuate and

degrade pollutants will determine the feasibility of this option.

According to the information available, it would be possible to build storage cavities fulfilling these

requirements, although practical experiences in underground storage sites are not available (see

section 6.2.3.2).

The container has to fulfil the minimum requirements as set out in chapter 8.3.2. In the case of a

temporary storage, the liquid mercury has to be stored in such a way that a subsequent processing of

the liquid mercury is not hindered or made impossible. This can be achieved by appropriate

containment, which does not, or only to a very limited extent, react with the mercury.

The storage of liquid mercury has to take place in a separate cell to avoid any reaction of the storage

containers with other chemicals. The cells have to be separated by adequate artificial barriers.

The reversibility of the storage of liquid mercury has to be fulfilled, which means that the cavities

where the liquid mercury is stored have to be stable enough for a defined storage time. The stability

of cavities is, in particular, given for crystalline hard rock formations. In argillaceous rock, the cavity

stability is not given and thus it would have to be stabilised by engineered barriers. The stability of

cavities should be guaranteed for at least 100 years.

Adequate measures have to be established to avoid spills or leaks allowing liquid mercury to enter

the rock. It is recommended to store the containers in collecting basins, which are able to capture

the total amount of the stored liquid mercury. Adequate linings (Hg resistant sealing or material able

to attenuate mercury like bentonite, see chapter 6.2.3.1and slopes should be installed, which

facilitate an easy collection of the mercury.

The most critical point is seen in possible spills or vapour emissions that might result in an intrusion

of mercury into the host rock. Mercury, once entering the host rock, might enter the biosphere due

to possible fractures in the rock body.

Technical minimum requirements Additional facility-related requirements or

acceptance criteria

Minimum

requirements

fulfilled

Protection of groundwater against

mercury ?


mercury ?

Impermeability to gas and liquids of

the surroundings ?

Reversibility of storage


storage area for >100 years



other waste storage areas





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Technical minimum requirements Additional facility-related requirements or

acceptance criteria

Minimum

requirements

fulfilled

capture the stored mercury

- Proof that in cases of spills and leaks no

mercury enters the host rock


During the entire temporary storage time, adequate monitoring, control measures and inspection

schemes have to be defined to avoid mercury emissions from the stored mercury due to leaking

storage containers or improper handling. Proper ventilation is required and in the case of any

incidents, adequate protection equipment and emergency plans have to be available. In addition,

workers have to be adequately informed and trained for such incidents.

With regard to compliance with environmental limit values, it has to proven by adequate model

calculations that possible mercury emissions will not exceed existing environmental limit values.


metallic mercury in salt mines.


requirements


acceptance criteria

Minimum

requirements

fulfilled

No exceeding of existing


Model calculation to prove the compliance with environmental limit values



regular inspection)

Installation of a permanent mercury vapour monitoring systems - with a sensitivity of at least 0.02mg



level and at head level Regular visual inspection of the containers and the storage site by a certified person - max. interval: 12 months, or - 1 month after detection of a leak Availability of emergency plans and adequate protective equipment suitable for



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requirements


acceptance criteria

Minimum

requirements

fulfilled

metallic mercury Information and training of workers on how to deal with liquid mercury


Storage costs for the temporary storage of liquid mercury in hard rock formations are seen as

relatively low. However, the costs for the preparation of the cells and the artificial barriers seem to

be significantly higher compared to salt rock facilities. Costs are expected in a dimension that this

solution - considering also the less sustainable environmental performance of this option - will have

difficulties to fulfil economic minimum requirements. However, it cannot be excluded that an

economically viable solution can be established in Europe. Cost estimates relating to the preparation

of a storage cell are available in section 6.2.3.4.

Though there might be feasible hard rock formations for a temporary storage of liquid mercury, the

assumed high investment costs to prepare an appropriate cell have to be taken into consideration.

Looking at the cost information received from the Swedish Ministry of Environment (see chapter

6.2.3.4) the preparation costs and operation costs might be very high for a limited period of time and

a limited volume of liquid mercury (700 m³).


Euromines86 indicated that the underground disposal site in Odda, Norway might be an option for the

temporary storage of liquid mercury. No information on the precise depth of this disposal site could

be identified but one report [Kystverket 2008] indicated that the disposal sites might not fulfil the

criteria of several hundreds of meters of depth as stated in the WAC Decision for deep underground

hard rock formation.

Currently this underground disposal site has only a permit to store e.g. mercury sulphide (see chapter

6.2.3.3). Other relevant storage sites could not be identified in the scope of this study.

Potential storage sites have to be prepared for the storage of liquid mercury and a permit for a

temporary storage has to be issued. It is highly questionable whether within the given timeframe

adequate storage facilities will be identified, also preparing adequately the corresponding waste cells

will be rather unlikely within the given time frame.

86 Personal Information of Euromines (European Association of Mining Industries)



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Minimum requirements Additional facility-related requirements or acceptance criteria required


fulfilled

Technical minimum requirements YES ? Environmental minimum requirements YES

Economic minimum requirements ?

Feasibility of implementation / ?

Given the experience already gained in storing other hazardous wastes in hard-rock formations, the

temporary storage of liquid mercury in hard rock formations would be a possibility in case adequate

capacities are available and permits for the storage of liquid mercury are available at the latest until

2012.

Based on the assessment of the current situation in the EU, however, this solution – although

feasible – seems to be very unlikely to be implemented within the given time frame.

8.8 Option 5l: temporary storage of liquid mercury in above-ground facilities

In chapter 6.3, an overview is provided on the current state of the art of above-ground storage of

metallic mercury.

In the following, an evaluation of the options concerning the criteria described in section 8.1 is

presented.


The Hg-Regulation sets out that temporary storage of liquid mercury is possible at above-ground

facilities that are dedicated and equipped for the storage of it.

In addition, the Hg-Regulation lays down that all provisions of the landfill directive as well as of the

WAC decision (except WAC Nr. 2.4) apply to these facilities. As a consequence, storage sites for the

temporary storage of liquid mercury need a valid landfill permit in case the storage takes place for

more than 1 year prior to disposal and for more than 3 years prior to recovery or treatment

(confirmation of a subsequent disposal or recovery/treatment is required).

The provisions set out in the landfill directive in Annex I (General requirements for all classes of



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landfills), thus apply for storage facilities for metallic mercury. In addition, the Hg-Regulation sets out

that the liquid mercury should be protected against meteoric water.

According to Regulation (EC) N° 1102/2008 the Seveso Directive (Directive 96/82/EC, see chapter

5.2.2) shall apply for the temporary above ground storage of liquid mercury. The Seveso directive

aims at the “prevention of major accidents which involve dangerous substances, and the limitation of

their consequences for man and the environment, with a view to ensuring high levels of protection”

(Article 1, Directive 96/82/EC).

The Seveso Directive requires that the possible risks of the storage of liquid mercury have to be

identified and evaluated in a safety report by taking into consideration the specific properties of

liquid mercury. In particular, the risks of accidental release have to be taken into consideration and

adequate measures have to be implemented to reduce on the one hand, the risk of accidental

releases, and on the other hand to minimize subsequent potential negative effects to the

environment. The assessment under the Seveso directive also includes possible scenarios in cases of

natural disasters such as floods but also man-made threats such as terrorist attacks. Adequate

management plans have to be established to fulfil these requirements.

Currently, the storage of liquid mercury takes place in warehouses. In order to protect the stored

liquid mercury against meteoric water and to guarantee impermeability towards the soil, the best

option for the above-ground storage seems to be construction of a building with engineered barriers

to protect the environment against mercury emissions.

The protection of the soil can be achieved by sealed floors, with a mercury-resistant sealer, which

can prevent the intrusion of mercury into the soil, for example in cases of accidental spills. In

addition, the containers have to be stored in areas where – in case of an accidental release of the

mercury – the total amount of the stored mercury can be collected and retrieved. This can either be

achieved by storing the containers with the liquid mercury in an appropriate collecting basin or by

implementing appropriate other measures, for example by ramped containment dikes that are

incorporated into the floor sealant and connected to appropriate collecting basins.

Above-ground storage is only seen as temporary storage, therefore the liquid mercury has to be

stored in such a way so that a subsequent processing of it is not hindered or made impossible. This

can be achieved by appropriate containment that fulfils the minimum requirements as set out in

chapter 8.3.2).

The storage of liquid mercury has to take place in a separate area to avoid any reaction of the

storage containers with other chemicals. The areas have to be separated by adequate barriers, for

example concrete walls. In addition adequate fire protection and ventilation systems should by

installed.

To avoid any unauthorised removal of the stored mercury the storage area should be secured.



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Technical minimum requirements Additional facility related requirements or

acceptance criteria

Minimum

requirements

fulfilled

Reversibility of storage

Protection of mercury against

meteoric water

Impermeability towards soil


mercury

- Storage in constructed building with

engineered barriers to protect the

environment against mercury emissions



catch the whole amount of the stored

mercury

- Hg-resistant sealants for the floor and

installation of a slope towards a

collection sump

- Fire protection system

- Ventilation system


- Area should be secured to prevent

unauthorised removal of the mercury


During the entire temporary storage time, adequate monitoring, control measures and inspection

schemes have to be defined to avoid mercury emissions from the stored mercury due to leaking

storage containers or improper handling. Proper ventilation is required and in cases of any incidents

adequate protection equipment and emergency plans have to be available. In addition, workers have

to be adequately informed and trained in such cases.


metallic mercury in salt mines.

To avoid any negative impacts of the surrounding area due to mercury emission, in addition to the

continuous on site measurements, immission measurements should take place before the temporary

storage starts and after 1 year. Based on this information it can be decided if additional measures to

protect the environment might be required.



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Minimum requirements Additional facility related requirements or

acceptance criteria

Min.

requirements

fulfilled

No exceeding of existing


Hg-limit values for air (WHO)

Installation of a regular immission monitoring system of the surrounding of the storage facility



regular inspection)

Installation of permanent mercury vapour monitoring systems - with a sensitivity of at least 0.02mg



level and at head level Regular visual inspection of the container and the storage site by a certified person - min. interval: 12 months, or - 1 month after detection of a leak Availability of emergency plans and adequate protective equipment suitable for metallic mercury Information and training of workers on how to deal with liquid mercury


The costs related to this option highly depend on the availability of existing facilities and the

possibility to adapt these facilities to secure above-ground landfills for the storage of liquid mercury.

If existing warehouse facilities can be used which have already implemented parts of the required

standards, then the costs seem to be acceptable. If construction of new buildings is necessary, then

the costs will be significantly higher.


Currently, in the European Community no landfill site has been identified which fulfils the

requirements for the storage of liquid mercury waste. The most appropriate facility for a central

storage is the warehouse of Almadén, which is currently used for the storage of the product liquid

mercury. The currently installed capacity for the storage of liquid mercury is below 8,000t.



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The owner of the Almadén warehouse has long-term experience with the handling of liquid mercury

and has already installed monitoring systems and safety measures to prevent mercury releases from

the facility. But the facility does not fulfil the requirements of a landfill and also does not have a

permit for the storage of waste. Thus, a permit has to be requested which might be very time

consuming.

In Germany, the possibility of long-term storage of liquid mercury in above ground landfills dedicated

to the storage of hazardous waste is already foreseen in national law (see section 5.3). According to

German law, long-term storage in above-ground disposal sites for hazardous waste (landfill class III)

is possible under the precondition that the landfill has to be explicitly appointed for the storage of

mercury and needs to be operationally and technically equipped for this purpose.

Apart from Almadén, other companies also have experience with the storage of liquid mercury as a

product. In particular, recycling companies extracting mercury from waste as well as operators of

chlor-alkali plants have experience related to the handling and storage of liquid mercury but typically

only with smaller amounts. In principal, other companies could also apply for a permit for the

temporary storage of liquid mercury. The potential storage sites have, on the one hand, to fulfil the

requirements laid down in the landfill directive and the WAC decision (permit as landfill), implement

the requirements of the Seveso Directive and they also have to provide adequate storage conditions

for liquid mercury. No information is available on existing storage capacities.

In particular already permitted landfills could be potential storage sites as they already fulfil the

requirements of the landfill directive and WAC Decision. The application process for an

amendment/extension of an existing permit is seen by far less time consuming and cost intensive as

the application for an entire permit as landfill.

The implementation costs and time widely depend on the possibility to use already existing facilities.

It is expected that adequate facilities will be available until 2011.


fulfilled

Capacity ? Experience Experience with the handling of liquid

mercury Approval of authorities is given ? Implementation time ? Implementation costs ?



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Minimum requirements Additional facility-related requirements or acceptance criteria

required


fulfilled



Feasibility of implementation ? ?

Option 5l “temporary storage of liquid mercury in above ground facilities” would be possible if

adequate capacities are available and permits for the storage of liquid mercury are available at the

latest by 2011.



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8.9 Option 6: Pre-treatment

In Chapter 7, an overview is provided on different stabilization and solidification techniques for liquid

mercury currently available or under development.

Based on the information, a screening of the pre-treatment technologies was carried out to identify

those which fulfil defined minimum requirements concerning technical, environmental and economic

aspects. Afterwards, the feasibility of implementation of the options is checked against criteria like

the capacity and time to implement the option.

Based on the outcome of the screening analysis one of the following conclusion is relevant:

i An appropriate technology for pre-treating elemental mercury is available and already

realised to handle the expected quantity of elemental mercury.

ii An appropriate technology for pre-treating elemental mercury is available but not realised in

a scale to handle the expected quantity of elemental mercury. It is expected that it could be

realised by March 2011.

iii An appropriate technology for pre-treating elemental mercury is available but not realised to

handle the expected quantity of elemental mercury. It is not expected that it will be realised

by March 2011.

iv An appropriate technology for pre-treating elemental mercury is not available and is not

expected to be in place in a reasonable time to handle the expected quantity of elemental

mercury.

The appropriate statement will provide an indication of which way “Option 6 Pre-treatment” should

be further considered.



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8.9.1 Technical, environmental and economic minimum requirements

The following figure illustrates the screening process for the selection of suitable pre-treatment

options.

Figure 8-1: Decision scheme for the selection of suitable pre-treatment processes


Technical minimum requirements shall ensure that a technically feasible solution is achievable. If

there are only theoretical considerations, a solution cannot be considered as “appropriate” as

experiences on the applicability in the large scale are lacking.

A technical minimum requirement requesting a full large-scale application would be desirable as it

would clear any uncertainties about usability in the future. However, this requirement would have

the disadvantage that technologies, which are currently not yet available in a large scale application –

but could be realised within the needed time frame – would not be considered.

The question for the establishment of a technical minimum criteria was therefore, which status of

process realisation is required to prove that the process is more developed than just laboratory scale

but to leave enough space for promising processes that still need up-scaling. According to various

experts’ judgements, the project team decided to use the following criterion:

Available process capable of stabilizing >1kg of elemental mercury can be treated in one batch

With this criterion, the possible upgrading potential has to be evaluated additionally for each

technology.



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The environmental minimum requirements focus on the necessary quality of the stabilised/

encapsulated product. They define limits to reduce the risk to human health and to the environment

to a reasonable level.

In the following, the environmental minimum requirements for the stabilised products are listed.

• A Vapour pressure (e.g. < 0.003 mg/m³) to guarantee a metallic mercury free, stabilised

product

• Leaching limit value of the stabilized product <2mg/kg dry mass (L/S =10 l/kg; EN 1247/1-4)

Justification

The purpose of measuring the vapour pressure is to reduce/exclude risks to human health and the

environment. Elemental mercury in particular has a high vapour pressure with the danger of air

emissions. A minimum requirement of a very low vapour pressure ensures that in the final product,

elemental mercury is only present in trace amounts and that emissions from the final product into air

can be considered as negligible.

For this criteria several realisation possibilities could be considered

• A set limit value of 0.003 mg/m³ can been chosen, as it has been demonstrated by at least

one company that this value could constantly be accomplished. The procedure of the

measurement was to enclose 100 g of HS in a flask. The Flask was connected to the mercury

vapour analyzer and after a duration of 1 hour (for a equilibrium of the sample with the gas

phase) a valve is opened and the measurement starts. The measurement was done at room

temperature ~ 20 °C and the mercury vapour analyzer Jerome 431-X [Jerome 431] has been

used with a sensitivity of 0.003 mg/m3.

• A CEN Standard as EN 13806:2002 “Foodstuffs - Determination of trace elements -

Determination of mercury by cold-vapour atomic absorption spectrometry (CVAAS) after

pressure digestion” could be introduced for the determination of the mercury concentration

in the air. For this CEN standard another limit value would have to be set.

• Other test methods are used to prove that no trace amounts of metallic mercury are in the

stabilised product (e.g. by XRD, computer aided tomography)

The second requirement concerns the leaching behaviour of the stabilised product. All stabilisation

techniques follow the target of obtaining a mercury compound which has a very low solubility in

water. If the process is not well under control, mercury compounds/impurities such as HgO or HgCl

are produced which have a much higher solubility in water and lead to unacceptable leaching values.



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According to Decision 2000/532/EC, stabilisation is defined as a process that transforms hazardous

waste into non-hazardous waste. The WAC Decision (2003/33/EC) sets leaching limit values for

disposal in above-ground landfills. Due to the minimum requirement of a maximum leaching value of

<2mg/kg, at least a disposal on a landfill for hazardous waste is possible.

With the minimum requirement of the leaching value below 2mg/kg dry mass, it can be guaranteed

that the amount of easily dissolvable impurities is kept within a given range and it can be considered

that if the stabilised product is brought in contact with water, the acute risk for the environment is

low. The limit value is chosen as it is the same limit value hazardous waste has to fulfil to be disposed

in landfills for hazardous waste according to the WAC Decision.


Economic minimum requirements focus on the costs for each tonne of elemental mercury which has

to be treated. The purpose of this requirement is to accept a wide range of feasible pre-treatment

technologies but to exclude options without any chance of being implemented in practice.

In the following table, the economic minimum requirements for the stabilised products are listed.

Costs of stabilization: <€20,000 per metric tonne elemental mercury

This value is intentionally set very high to avoid that options with a good environmental performance

would be excluded only due to economic reasons.

Technologies that have been evaluated (e.g. due to technical or economic aspects) as not suitable at

the current state of development, may be taken into consideration again (within an iterative

investigation procedure) if no adequate technology could be identified in the feasibility analysis.

8.9.5 Assessment of pre-treatment technologies

Assessing technical minimum requirements (> 1kg mercury/batch)

Information about the realised amounts of stabilised elemental mercury in one batch have been

gathered from the relevant companies and institutions and compared against the minimum

requirement of 1kg/batch.

Assessing against environmental minimum requirements

Vapour pressure of the stabilised product (<0.003mg/m³):

In many cases, the vapour pressure has not been measured due to the simple fact that a complete

reaction was considered and therefore the mercury vapour is negligible. A lack of information was

not considered to justify a disqualification of the product, especially if other tests were performed



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(e.g. XRD, computer aided tomography) and no remaining elemental mercury was detected.

Leaching limit value of the stabilised product (< 2mg/kg dry matter, L/S=10 l/kg EN 12457/1-4)

In many cases, the leaching test TCLP as established by the US EPA has been used and not the

European standard EN 12457/1-4. The results of the different methods cannot be easily converted

from one system to the other by applying a conversion factor as they are carried out under different

conditions and parameters. Therefore the following approach for the assessment has been made:

Standard Leaching value related to dry mass [mg/kg]

Test condition; liquid: solid ratio [l/kg]

Leachate concentration [mg/l]

EN 12457/1-4 2 10:1 0.2 TCLP 4 20:1 0.2

A concentration of 4 mg/kg dry matter or a leachate concentration of 0.2 mg/l using the TCLP

standard (with an L/S = 20 l/kg) is considered to be comparative with 2mg/kg dry matter according to

the EN 12457/2 or 4 standard (with an L/S = 10 l/kg).

Assessing economic minimum requirements (<€20,000/tonne)

Little information has been provided concerning the costs for treatment, but none of the

technologies which passed the technical and environmental requirement give any reason to exceed

the economic minimum requirement to be above €20,000/tonne of stabilised elemental mercury.

The following table provides an assessment of the technical, environmental and economic minimum

requirements for the already realized stabilization/encapsulation technologies of elemental mercury

discussed in section 7:



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Pre-treatment technologies which fulfil the set criteria are marked with “ ” and technologies which fail the set criteria are marked with “ ”.

Table 8-1: Summary of the assessment of used pre-treatment technologies against minimum requirements

Assessment of pre- treatment technologies against minimum requirements Minimum requirements

Environmental

Technical Vapour pressure Leaching value

Economic

Minimum requirements (>1kg/batch) (<0.003mg/m³) (<2mg/kg) (<€20,000/t)

Existing technologies Minimum requirements

Environmental Process Company

Technical Vapour pressure Leaching value

Economic

Minimum requirement

fulfilled

DELA 5kg Below LOD ~ 0.026mg/kg

(EN 12457/1-4) <2,000 €/t

1) Sulphur stabilisation Bethlehem

apparatus 50kg

Below limit of detection of XRD and computer aided

tomography ~ 0.0143mg /kg (TCLP) <9,000 €/t

M&CE 50kg Not measured ~ 0,1mg/l (TCLP) =>2mg/kg (TCLP)

No information provided

2) SPSS

DOE 20kg 11 mg/m³ on 1st day

~ 30mg/l (TCLP) =>60mg/kg (TCLP)

No information provided

3) Amalgamation 1) n.d. n.d. n.d. 4) CBPC 1) n.d. n.d. n.d. 5) Encapsulation without stabilisation 1) n.d. n.d. n.d. 6) Encapsulation with stabilisation

MERSADE 2kg Not measured ~ 0.1 mg/l (TCLP) =>2mg/kg (TCLP)

15,000-17,000 €/t

1) Only available in laboratory scale

2) n.d.: no data available



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8.9.6 Technology overview of Option 6

As described in section 7, there are different technologies for pre-treatment of elemental mercury.

For the assessment of the minimum requirements in particular the encapsulation technologies have

been further divided related to the specific matrix material used (6a – 6z). Basis for the following

assessment is the information provided in section 7.

Pre-treatment technologies which fulfil the set criteria are marked with “ ” and technologies which

fail the set criteria are marked with “ ”.

Table 8-2: Summary of the assessment of pre-treatment technologies

Summary overview

Minimum requirements fulfilled?

No Process Product

Technical Environmental Economic

Suitable

pre-treatment

process

Additional

comments

6 a Sulphur stabilisation HgS Yes Yes Yes

6 b SPSS HgS Yes Yes Yes

6 c Amalgamation HgX No No No Encapsulation

needed

6 d CBPC Hg3(PO4)2 Yes No No Stabilisation

needed

6 e CBPC Na2S/K2S HgS/Hg3(PO4)2 No Yes No High physical

strength

6 f OPC-

Encapsulation

Hg / OPC No No

6 g Poly-ethylene Hg in matrix No No

6 h Asphalt Hg in matrix No No

6 i Polyester /

Epoxy resin

Hg in matrix No No

6 j Synthetic

Elastomers

Hg in matrix No No

6 k Poly-siloxane Hg in matrix No No

6 l Sol Gel Hg in matrix No No

6 m Dolocrete TM Hg in matrix No No

6 n CaCO3-MgO Hg in matrix No No

Enca

psul

atio

n te

chni

ques

6 o Ladle furnace

slag

Hg in matrix

No

No No

Stab

iliza

tion

need

ed



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Summary overview

Minimum requirements fulfilled?

No Process Product

Technical Environmental Economic

Suitable

pre-treatment

process

Additional

comments

6 p Encapsulation

HgS/cement HgS/cement Yes Yes Yes

Intensive

ongoing

development

6 q Amalgamation

/OPC

HgX/OPC Yes No

6 r Poly-ethylene HgS or HgX in

matrix Yes No

6 s Asphalt HgS or HgX in

matrix Yes No

6 t Polyester /

Epoxy resin

HgS or HgX in

matrix Yes No

6 u Synthetic

Elastomers

HgS or HgX in

matrix Yes No

6 v Poly-siloxane HgS or HgX in

matrix Yes No

6 w Sol Gel HgS or HgX in

matrix Yes No

6 x Dolocrete TM HgS or HgX in

matrix Yes No

6 y CaCO3-MgO HgS or HgX in

matrix Yes No

Enca

psul

atio

n of

pre

-tre

ated

(sta

biliz

ed) m

ercu

ry

6 z Ladle furnace

slag

HgS or HgX in

matrix

No

Yes No

The technical minimum requirements are currently only fulfilled by three options (6a, 6b and 6p). All

other technologies are only available in lab scale application <1kg liquid mercury/batch or have not

been performed with liquid mercury yet. In particular, most of the encapsulation processes are

performed with mercury contaminated waste and not with liquid mercury.

As a result of the assessment, currently only the options 6 a (Sulphur stabilization), Option 6 b (SPSS)

and Option 6 p (Encapsulation of HgS in cement) fulfil the technical, environmental and economic

minimum requirements. All these technologies include sulphur as the main stabilizing agent.



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8.9.7 Feasibility of immobilization techniques

Due to the fact that by March 2011 the export ban of mercury enters into force and in addition

mercury from specific applications has to be considered as waste, it has to be assessed whether

appropriate pre-treatment technologies will be available by this date or not. To identify if and when a

pre-treatment technology will be available as an application capable of stabilising the expected

amounts of metallic mercury, a feasibility study is performed.

For this purpose, the following feasibility criteria have been established:

• Implementation time before March 2011

• Capacity: appr. 1,000t/year

• Permit from the competent authority

The capacity of 1,000t/year is required, because the expected amount of metallic waste mercury

from relevant applications is expected to be 8,000 to 9,000 tonnes until 2020. Lower capacity would

result in the need of a temporary storage prior to the stabilisation process. It is not necessary that

one company covers the whole capacity. But it has to be considered that there might be only one

company capable to treat the whole amount of metallic mercury.

For the operation of the facility a valid permit is required and available before March 2011.

The four companies that are currently capable of stabilizing elemental mercury (pre treatment 6 a,

6 b and 6 c) are located in Europe (pre treatment 6 a and 6 p) and the United States of America (pre-

treatment 6 b, two companies). Detailed information on these technologies is included in section 7.

Due to the export ban, in 2011 the American companies would have to build up a facility in Europe or

licences would have to be bought from the patent owners to build a stabilization facility in Europe.

Up to now, there are no ongoing plans for such a project and thus the realization of these

technologies in Europe until 2011 is not seen as possible.

The remaining two companies located in Germany (pre-treatment Option 6a) and Spain (pre-

treatment Option 6 p) are in different development stages for their processes.



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Table 8-3: Assessment of feasibility requirements

Feasibility requirement fulfilled Feasibility requirements

Option 6a Option 6p

Implementation time Has to operate before March 2011

Capacity 8,000-9,000 tonnes within 9 years =>

~ 1,000t/year

Approval of authorities is

given

?

Recently (January 2010) the German company using the technology of Option 6a “Sulphur

stabilization“ has realised a full size facility, but has not tested it yet. The open engineering tasks for

this new facility are considered by the company to be negligible. Due to the experience with similar

plants, this statement can be considered as reliable. The expected throughput is considered to be

about 1,000 tonnes per year, and would therefore be able to treat the total expected amount of

liquid mercury within 8 to 9 years, provided that the elemental mercury is delivered in a more or less

constant stream. A permit is submitted and should be accepted within 2010.

For the technology developed in Spain recently (9 September 2009), an application for a patent has

been made on 9 of September 2009 with the application N° P200930672 [P200930672]. From their

point of view, an industrial scale facility would take about 3 to 5 years. No data is available for the

throughput of one full scale stabilisation line.

8.9.8 Minimum acceptance criteria for stabilised mercury

Based on the above assessment it is recommended to establish the used environmental minimum

requirements as minimum acceptance criteria for stabilised mercury:

- vapour pressure of the stabilised metallic mercury < 0.003mg/m³

- leaching value below 2mg/kg dry mass (L/S=10 l/kg; EN 12457/1-4).

These criteria could be implemented by establishing a specific waste code for waste from the

stabilisation of metallic mercury.



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8.9.9 Feasibility of permanent storage of pre-treated elemental mercury

The main purpose of the pre-treatment of metallic mercury is to change the liquid state into a solid

form to improve the handling, reduce possible risks by reducing the volatility and toxicity and to

reduce possible environmental risks by improving the leaching properties. As a consequence, after

the pre-treatment process, a stabilized and solid (waste) product is the result with quite different

properties than metallic mercury.

The storage requirements set out in Regulation (EC) N° 1102/2008 only apply to metallic mercury.

Therefore, for the pre-treated metallic mercury, the provisions of this Regulation are no longer valid.

After the pre-treatment process of the metallic mercury, only the provisions and requirements laid

down in the landfill directive (1999/31/EC) and the WAC Decision (2003/33/EC) apply to storage.

Decision 2000/532/EC87 foresees the following waste code for stabilised waste:

19 03 stabilised/solidified wastes

19 03 04* wastes marked as hazardous, partly stabilised88

19 03 05 stabilised wastes other than those mentioned in 19 03 04

Therefore, depending on its properties, different storage options are possible following existing legal

requirements. A temporary storage of the pre-treated mercury is not foreseen as it does not provide

the requested type of solution. Therefore, after pre-treatment only permanent storage options are

considered further. The following permanent storage options in combination with the feasible pre-

treatment option are possible:

Option 6l-1s: Permanent storage of mercury sulphide in salt rock formations

Option 6l-3s: Permanent storage of mercury sulphide in hard rock formations

Option 6l-7s: Permanent storage of mercury sulphide in above-ground facilities

Acceptance of stabilised mercury in underground facilities is only possible after a positive site-

specific risk assessment (Nr. 2.3, Appendix A, Decision 2003/33/EC). The site specific assessment has

to be carried out as outlined in the WAC Decision and has to demonstrate that the level of isolation

from the biosphere is acceptable.

Therefore, in the case of storage of stabilised mercury in underground storage sites (hard rock

87 Commission Decision of 3 May 2000 replacing Decision 94/3/EC establishing a list of wastes pursuant to Article 1(a) of Council Directive 75/442/EEC on waste and Council Decision 94/904/EC establishing a list of hazardous waste pursuant to Article 1(4) of Council Directive 91/689/EEC on hazardous waste (2000/532/EC), OJ L 226, 6.9.2000, p. 3 88 The asterisk indicates that the waste is classified as hazardous



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formations or salt mines) potential risks related to the storage of stabilised mercury should be

addressed adequately. The assessment is based on the assumption that the stabilised waste fulfils

the minimum acceptance criteria as recommended in the previous section. The acceptance and

sampling procedures apply as defined in the WAC decision.

8.9.9.1 Option 6l-1s: Permanent storage of mercury sulphide in salt rock formations:

The storage of mercury containing waste in salt mines has already been practiced for several years

(see also chapter 6.2.2.2). Therefore, the permanent storage of stabilized mercury in the form of

mercury sulphide is seen as a feasible option. The only requirement is that the storage of mercury

sulphide has to be taken into consideration in the site-specific assessment and – if the storage site

has been assessed as suitable – it has to be included in the permit.

In Germany, at least 3 salt mines already have a permit which includes the storage of the waste

codes N° 19 03 04 and 19 03 05.

The storage of mercury sulphide in salt rock formations has to take place in a separate area to avoid

any reaction of the storage containers with other chemicals. The areas have to be separated by

adequate barriers.

8.9.9.2 6l-3s Permanent storage of mercury sulphide in hard rock formations:

Following the safety philosophy for hard rock of Appendix A of the Decision 2003/33/EC, protection

of the groundwater can only be fulfilled by demonstrating the long-term safety of the installation.

For a deep storage in the hard rock, this requirement is respected in that any discharges of hazardous

substances from the storage will not reach the biosphere, including the upper parts of the

groundwater system accessible for the biosphere, in amounts or concentrations that will cause

adverse effects. Therefore, in particular, the water flow paths to and in the biosphere should be

evaluated (Appendix A, section 4.1, Decision 2003/33/EC) (see also section 5.2.5 of this report).

In the case of the storage of stabilised mercury (e.g. in form of mercury sulphide), the hydraulic

situation has to be taken into consideration very carefully to avoid non-acceptable emissions from

the storage site to the biosphere via groundwater flows. In the site-specific assessment the storage

of mercury sulphide should be addressed and at least the compliance with the currently existing

environmental limit values should be assured. The acceptance of stabilised mercury has to be

included in the permit.

Information on the existing storage of mercury containing waste in hard rock formations is very

limited (see section 6.2.3.3). But a Swedish study [SOU 2008] concluded that Swedish hard rock

formations would be suitable for the storage of mercury sulphide (see chapter 6.2.3.3). In addition,

two facilities in Norway have a permit for the storage of mercury containing waste (max. 10% Hg).

Therefore, the permanent storage of stabilized mercury as mercury sulphide is seen as a feasible

option.



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8.9.9.3 6l-7s Permanent above ground storage of pre-treated elemental mercury:

In the case of an above-ground storage of stabilised mercury, the provisions of the landfill directive

and the WAC decision have to be fulfilled. Stabilised mercury is only allowed to be stored at a landfill

if it fulfils the requirements set out for the specific storage site. In general, stabilised waste with a

waste code 19 03 04 or 19 03 05 can be disposed of on existing above ground landfills, but some

additional precautions might be considered in the case of mercury sulphide.

In the case of above-ground disposal, the long term behaviour of waste is more crucial compared to

underground storage due to the partially higher interaction with the environment. It is possible that

a reaction of metallic mercury with water and bacteria could take place and the very toxic

methylmercury could be formed. The minimum requirement of the vapour pressure below 0.003

mg/m³ in the stabilised products indicates that the amount of metallic mercury is negligible and

therefore this reaction should not take place. However, concerns remain, since little is known of the

long-term behaviour and stability of the product, especially at higher temperatures or pressures. For

this purpose, additional safety measures should be considered for above-ground disposal.

To exclude or at least minimise the risk of conversion or interaction of the stored material in the case

of an above-ground storage of stabilised waste, the following additional facility requirements are

recommended:

1) Storage in separated cells, no storage together with other waste (especially biodegradable

waste or waste with a high pH value, e.g. above pH = 10)

2) The cell shall be sufficiently self-contained

3) Appropriate measures shall be taken to limit the possible uses of the land after closure of the

landfill in order to avoid human contact with the waste

4) After closure, a plan shall be kept of the location of the landfill/cell indicating that stabilised

mercury waste has been deposited

5) No works shall be carried out on the landfill/cell that could lead to a release of the stabilised

mercury (e.g. drilling of holes)

6) A final top cover shall be put on the landfill/cell.

Justification:

Ad 1)/2):

As already stated above, little is known on the long-term behaviour of stabilised mercury and

possible interactions with other wastes. In particular biodegradable waste might pose a risk to

interact with HgS as it might include bacteria, water and other unknown constituents and still an

active decomposition process might be ongoing. Tests show, that in case of mercury sulphide,

mercury concentration in leachate increases sufficiently above a pH value of 10, as described in



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section 7.1.4, 7.2.4. and 12.5. Therefore it is recommended to store stabilised mercury in separated

and self contained cells to avoid contact with other wastes.

Ad 3)/4):

After the closure of the landfill the risk increases of unintentional removal or re-entering of the

stored mercury due to human activities. For example, in case the landfill area is not adequately

isolated and protected against human intrusion (e.g. drilling, excavation) an uncontrolled distribution

of the stored waste might occur. Therefore appropriate long term measure should be implemented

(e.g. documentation and record keeping of the stored waste at a separate location). It is also

recommended to keep plans of the storage location after closure of the landfill, to facilitate

corrective measures in case of any kind of unforeseen incidence or of a significant increase of

mercury compounds in the surrounding of the landfill area is detected.

Ad 5)

Any release of the stored material from the storage cell has to be avoided to prevent exposure of

workers. Another reason of such releases is that any kind of uncontrolled long or short time release

of the stored material from the landfill body increases the risk of methylmercurate formation.

As a consequence it is necessary to implement measures which prevent any destruction of the

storage cell and its protection against unintended releases (e.g. due to drilling activities).

Ad 6)

The final top cover will serve to prevent dispersion and will reduce potential leachate via reduction

caused by meteoric water.

An advantage of above ground storage is that emission control and counter measures are easier,

compared to underground storage systems.

With regard to the control and monitoring procedures in operation and in the after-care phase, the

requirements set out in Annex III of the WAC decision should apply. To avoid any negative effects on

the environment it is recommended to include in the leachate testing the parameter

“methylmercury”. Recently (October 2009), a quick test method was published to measure trace

amounts of methylmecury, which might be feasible for testing. [Ramon-Knut 2009]

In any case, the WAC decision requires that the basic characterisation of the stabilised metallic

mercury has to include information to understand the behaviour of waste in landfills. This concerns

especially the co-disposal of carbon containing (biodegradable) wastes and wastes with high pH

values.

One possible safety measure could be the establishment of a separate EWC code for stabilized

metallic mercury waste. This would have the advantage that this type of waste can be specifically

defined and linked to specific requirements. Another advantage is the immediate and clear



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identification of this waste type, highlighting the exceptional position of it compared to other

stabilized wastes. This would reduce the chance of a possible mismatch with other stabilized wastes

and incorrect disposals thereof. Furthermore a separate waste code would facilitate to track the final

destination of stabilised mercury.

It is also recommended to further investigate the long-term behaviour of metallic mercury under

landfill conditions with a special focus on potential methylation effects.

8.9.10 Summary Option 6l and its permanent storage

From the assessment of the technologies against the minimum requirements, it was determined that

two different pre-treatment technologies already exist in Europe that are able to fulfil all necessary

minimum requirements. It was investigated in the feasibility study, that the realisation of a large-

scale application of Option 6p still needs about 3 to 5 years.

In the case of Option 6a, a pilot plant demonstrated the reliability of this technology and a full-scale

application has been established. The permit as well as the proper function and the product quality

of the full-scale application are still lacking. The operator stated that the shortcomings will be solved

within the year 2010. Due to their experience in the field of treating mercury contaminated waste,

handling metallic waste and the proper function of the pilot plant this seems reasonable.

As a consequence the following conclusion is valid:

“An appropriate technology for pre-treating elemental mercury is available but not realised on a

scale to handle the quantity from the industry of elemental mercury to be stabilised/encapsulated. It

is expected that it could be realised by March 2011.”

Stabilized mercury can be disposed of in salt rock and hard rock, as well as above ground, following

the existing legal requirements. In the case of above-ground disposal, additional safety requirements

should be considered to avoid any kind of decomposition of the stabilized waste.

Minimum acceptance criteria for stabilised metallic mercury are recommended. In addition elaborate

BAT-Reference documents should be prepared for pre-treatment technologies for metallic mercury.

These documents should include information on how the process has to be performed in the best

way in order to avoid mercury emissions during handling and processing, and to ensure the quality of

the end product. In addition, adequate monitoring measures should be described.



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8.10 Summary of the screening analysis

In the screening analysis, the identified options have been evaluated against minimum requirements

and on their feasibility of implementation. Several options fulfil the minimum requirements but

problems are seen relating to an implementation by 2011. Therefore, in the following table a

differentiation has been made between the fulfilment of the technical, environmental and economic

minimum requirements and the feasibility of implementation of the option by 2011. The question

marks in the table stand for uncertainty concerning implementation being on time.

Table 8-4: Results of the evaluation of the options for storage of liquid mercury

Option Technical,

environmental and

economic minimum

requirements fulfilled

Implementation

feasible by 2011

1l Permanent storage of liquid mercury in salt

mines

Yes ?

2l Temporary storage of liquid mercury in salt

mines

Yes ?

3l Permanent storage of liquid mercury in deep

underground hard rock formations

No /

4l Temporary storage of liquid mercury in deep


?89 /

5l Temporary storage of liquid mercury in above-

ground facilities

Yes ?

6l-1s Pre-treatment + permanent storage of

stabilised mercury in salt mines

Yes ?


stabilised mercury in deep underground hard

rock formations

Yes ?


stabilised mercury in above-ground facilities

Yes ?

When considering permanent solutions, the permanent storage in salt rock as well as the pre-

treatment options with a subsequent permanent storage are considered to be feasible against

89 Due to expected high costs and the difficulties to identify an adequate site it seems unlikely that this option

will be realised.



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technical, environmental and economic criteria – on condition that the elaborated additional criteria

and facility requirements are fulfilled.

For some permanent solutions, uncertainties remain relating to their availability in March 2011. If

these uncertainties – which might result from the lack of research data or uncertainties relating to

the duration required to apply for a specific permit – are solved by 2011, then these options are seen

as feasible. The option “permanent storage of liquid mercury in deep underground hard rock

formations” does not fulfil the minimum requirements as deep underground hard rock facilities will

not provide the equal level of safety and confinement for metallic mercury as salt mines.

Uncertainties in case of a permanent storage in salt rock refer in particular to the behaviour of

metallic mercury in salt rock. Currently no sufficient information is available on the behaviour of

metallic mercury under storage conditions in salt rock such as the behaviour in case of increased

pressure or possible interactions with the host rock. A study is planned by the German Ministry of

Environment which should investigate the behaviour of metallic mercury in salt rock. The outcome of

this study is an essential input to the site specific risk assessment for salt mines required for the

application for a permit to store liquid mercury. Only based on this information a safe encapsulation

of the metallic mercury can be ensured for a timeframe of 1 million years.

The evaluation of pre-treatment technologies resulted in the conclusion that technologies are

available which fulfil the technical, environmental and economic minimum requirements. Different

technologies based on sulphur stabilization have been assessed as a suitable pre-treatment option.

The availability of at least one technology on an industrial scale in 2011 is seen as very probable.

There are other technologies developed enough to be available on an industrial scale within the next

3-5 years. It has to be noted that the assessment of the feasibility of pre-treatment options was

carried out bearing in mind that in 2011 the export ban for metallic mercury enters into force and the

mercury from specific applications has to be considered as waste. Therefore, it was necessary to

check whether appropriate pre-treatment technologies would be available by this date.

Technologies that have been assessed as not feasible by 2011 are not necessarily excluded in the

future. The assessment provides only an overview of which technologies are available at that date.

It is recommended to elaborate BAT-Reference documents for pre-treatment technologies.

For the final disposal of stabilized mercury underground disposal sites in salt mines, deep hard rock

formations as well as above ground landfills are seen as feasible options. In particular in case of

above ground storage missing information related to the long-term behaviour of stabilized mercury

and/or possible interaction with other stored waste requires additional research.

In order to reduce the existing uncertainty about implementation feasibility being on time

combinations of options in the sense of “temporary options + permanent options” are also possible.

The possibility of temporary storage for liquid mercury should be limited to a certain time period. In

order to determine the time period, the availability of appropriate permanent storage options is the



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main criteria. Looking at the expected availability of permanent options (with or without pre-

treatment) a timeframe of 5 years is recommended for a temporary storage.

A review of the Regulation (EC) N° 1102/2008 is foreseen as being published not later than 15 March

2013 (Article 8 (2)). Therefore, an update on the availability of pre-treatment technologies fulfilling

the minimum criteria is recommended in the context of this review. Based on this review, it has to be

decided if a temporary storage still has to be kept as a possible storage option for metallic mercury as

currently foreseen in the Hg-Regulation. With a timeframe of 5 years for the temporary storage of

metallic mercury the industry has a good basis for future plannings and negations with temporary

storage facilities. In addition in case of any delays in the review process of the Regulation (EC) N°

1102/2008 there is still enough buffer to avoid any problems or additional costs as the maximum

temporary storage time is exceeded

With regard to the temporary storage options, the storage of liquid mercury in salt mines and the

storage in above ground facilities fulfil the technical, environmental and economic minimum criteria.

The temporary storage in salt mines has been assessed as a feasible option in relation to the

implementation time as it is expected that the relevant permits and approval will be available in

time. The feasibility of above-ground storage of liquid mercury is determined by the availability of

capacities and the time to apply for a permit. The application time for a permit to store metallic

mercury is difficult to estimate as it depends on the actual permit of the site. If the site already has a

permit as landfill the application time is not expected to be more than 0.5 - 1 year. If no permit for a

landfill is available it is estimated that the application time will be more than 1 year.

The option “temporary storage of liquid mercury in deep underground hard rock formations” might

fulfil the minimum requirements. But due to the expected high cost and the difficulties to identify an

adequate site within the given timeframe, it seems very unlikely that this option will be realised.



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8.11 References

[DOE 2009] U.S. Department of Energy, Interim Guidance on Packaging, Transportation, Receipt, Management, and Long-Term Storage of Elemental Mercury, U.S. Department of Energy Office of Environmental Management Washington, D.C., November 13, 2009, http://www.em.doe.gov/pdfs/Elementalmercurystorage%20Interim%20Guidance_11_13_2009.pdf [Euro Chlor 2007] Euro Chlor, Guidelines for the preparation for permanent storage of metallic mercury above ground or in underground mines, Env Prot 19, 1st Edition, October 2007 [Höglund 2009A] Höglund, Lars Olof Assessing the behaviour and fate of mercury should it be released from a disposal facility, Presented at Workshop of Safe Storage and Disposal of Redundant Mercury, St Anne’s College, Oxford, 13th and 14th October, 2009, http://www.mercurynetwork.org.uk/wp-content/uploads/2009/10/Hoglund2.pdf [Jerome 431] ARIZONA INSTRUMENT LLC, JEROME® 431-X mercury vapor analyzer, Operation manual, April 2009 http://www.azic.com/pdf/manual_700-0046.pdf [P200930672] López FA, López-Delgado A, Alguacil FJ and Alonso M., Procedimiento de estabilizacion de mercurio liquid mediante cemento polimerico de azufre, via sulfuro de mercurio, P200930672 (2009)

[Ramon-Knut 2009]

The Determination of Methylmercury in Real Samples Using Organically Capped Mesoporous

Inorganic Materials Capable of Signal Amplification, Estela Climent, M. Dolores Marcos, Ramón

Martínez-Máñez, Félix Sancenón, Juan Soto, Knut Rurack, Pedro Amorós, Angew. Chemie, 121/45

(2009) 8671-8674, http://www.speciation.net/Public/News/2009/10/30/4666.html

[TCLP 1992]

TCLP Method 1311, http://www.epa.gov/osw/hazard/testmethods/sw846/pdfs/1311.pdf, 1992




http://www.azic.com/pdf/manual_700-0046.pdf

http://www.speciation.net/Public/News/2009/10/30/4666.html

http://www.epa.gov/osw/hazard/testmethods/sw846/pdfs/1311.pdf



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9 Summary of acceptance criteria and additional facility related requirements

In the following the identified acceptance criteria and additional facility related requirements are

summarised. It is important to note that only sites with a valid permit for the disposal of (hazardous)

waste have been investigated. The provisions set out in the landfill directive as well as in the WAC

decision are still valid for the disposal of liquid or stabilized mercury. The following acceptance

criteria and facility related requirements have to be fulfilled additionally to the provisions set out in

the above mentioned legal documents.



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9.1 Proposed acceptance criteria for metallic mercury and additional facility related requirements

Salt mine with valid permit as underground storage facility for hazardous waste (DHAZ) Above ground storage site with valid

permit for the storage of hazardous waste, category C

Storage option

Permanent storage Temporary storage Temporary storage

Waste acceptance criteria for metallic mercury Hg

- Purity of the mercury: > 99.9 % per weight

- Max. metallic contaminates (like iron, nickel, copper): < 20 mg/kg each

- Presence of sodium < 1 mg/kg

- No residual radioactivity (e.g. from tracers used in the chlor-alkali industry)

- No impurities capable of corroding carbon or stainless steel (e.g. nitric acid solution, chloride salts solutions, or water)

Containment - Container material: Stainless steel (AISI 304, 316L) or carbon steel (ASTM A36 minimum)

- Container has to be gas and liquid tight

- Outer side of the container must be resistant against the storage conditions

- Containers should be certified for the storage of mercury

- Welds should be avoided as far as possible



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Salt mine with valid permit as underground storage facility for hazardous waste (DHAZ) Above ground storage site with valid permit for the storage of hazardous waste,

category C

Storage option


Waste acceptance procedure

- Only acceptance of metallic mercury which fulfils the minimum acceptance criteria as set out above (verification required either by sampling or a certificate issued by a certified person)

- Visual inspection of the container, no acceptance of damaged, leaking or corroded containers

- Only acceptance of containers with adequate labelling (at least according to the transport requirements)

- Only acceptance of containers with a certificate which confirms the appropriateness for the storage of liquid mercury

The certificate – might also be a plate permanently fixed on the container - should include as a minimum, the identification number of the

container, container material, producer of the container, date of production and a confirmation that only mercury has been stored/transported in

the container (exclusion of storage of products which might react with mercury or the container material).

In the case of sealed containers, the filling and the sealing of the containers should be supervised by a certified person, which confirms that only

mercury of the required specification is contained in the sealed containers. The certificate, which has to be issued by the certified person, should

include at least:

- Name and address of the company (waste owner)

- Place and date of packaging

- The purity of the mercury (min. >99.9%) and, if relevant, description of the impurities (analytical report has to be provided)

- Quantity of the mercury

- Any specific comments

- Signature



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category C

Storage option


Record keeping Documents referring to the metallic mercury (e.g.

basic characterization, compliance testing) shall be

kept at least until the closure of the disposal site.

A plan of the storage area should be kept also after

the closure of the storage site.

Documents referring to the metallic mercury (e.g. basic characterization, compliance

testing) shall be kept at least 3 years after the termination of the storage.

Facility related requirements

- Effectiveness of the geological barrier in terms of

migration time for mercury to the biosphere >1

million years (verification by a site-specific

assessment including a long term safety

verification)

- Minimum thickness of the isolating salt rock:

100m (justified exemption possible)

- Minimum depth of the storage area: 300m

(justified exemption possible)

- Minimum distance from access shafts and other

waste storage areas: 100m


- Storage of the liquid mercury containers in

collecting basins able to catch the whole amount

of stored mercury


storage area >100 years



other waste storage areas: 100 m

- Storage of the liquid mercury containers

in collecting basins able to catch the

whole amount of stored mercury

- Storage in constructed building with

engineered barriers to protect the

environment against mercury

emissions



catch the whole amount of the stored

mercury

- Hg-resistant sealants for the floor and

installation of a slope towards a

collection sump

- Fire protection system

- Ventilation system


- Area should be secured to prevent

unauthorised removal of the mercury



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category C

Storage option


monitoring, inspection and emergency requirements

Installation of a permanent mercury vapour monitoring systems - with a sensitivity of at least 0.02 mg mercury/m³ - visual and acoustic alert system - annual maintenance and control of the system - sensors have to be installed at ground level and head level

Regular visual inspection of the container and the storage site by a certified person

- max. interval: 12 months, or - 1 month after detection of a leak

Availability of emergency plans and adequate protective equipment suitable for metallic mercury Information and training of workers on how to deal with liquid mercury

Installation of a regular immission monitoring system of the surrounding of the storage facility. Installation of permanent mercury vapour monitoring systems - with a sensitivity of at least 0.02mg

mercury/m³ - visual and acoustic alert system - annual maintenance and control of

the system - sensors have to be installed at ground

level and at head level Regular visual inspection of the container and the storage site by a certified person - min. interval: 12 months, or - 1 month after detection of a leak

Availability of emergency plans and adequate protective equipment suitable for metallic mercury Information and training of workers on how to deal with liquid mercury



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9.2 Proposed acceptance criteria for stabilized mercury and additional facility related requirements

Storage option Salt mine with valid permit as underground storage facility for

hazardous waste (DHAZ)

Hard rock formation with valid permit as underground storage

facility for hazardous waste (DHAZ)

Above ground storage site (with valid permit)

Waste acceptance criteria for stabilised Hg

- A Vapour pressure (e.g. < 0.003 mg/m³) to guarantee a metallic mercury free, stabilised product

- Leaching limit value of the stabilized product <2mg/kg dry mass (L/S =10 l/kg; EN 1247/1-4)

Waste acceptance procedure

Standard waste acceptance procedure applies as defined in the landfill directive and the WAC decision.

Facility related requirements

- Storage of stabilised mercury has to be taken into consideration in the site-specific assessment

- Storage of stabilised mercury in salt rock formation has to take place in a separate area to avoid any reaction with other waste

- Storage area has to be separated by adequate barriers

- Site-specific assessment has to be carried out for the safe storage of stabilised mercury and a long term proof has to be provided which indicates at least the compliance with the currently existing environmental limit values

- Storage of stabilised mercury in hard rock formations has to take place in a separate area to avoid any reaction with other chemicals.

- The areas have to be separated by adequate barriers

- Storage in separated cells, no storage together with other waste (especially biodegradable waste or waste with a high pH value, e.g. above pH = 10)

- The cell shall be sufficiently self-contained

- Appropriate measures shall be taken to limit the possible uses of the land after closure of the landfill in order to avoid human contact with the waste

- After closure, a plan shall be kept of the location of the landfill/cell indicating that stabilised mercury waste has been deposited

- No works shall be carried out on the landfill/cell that could lead to a release of the stabilised mercury (e.g. drilling of holes)

- A final top cover shall be put on the landfill/cell

Monitoring and control

Standard monitoring and control procedures apply as defined in the landfill directive and the WAC decision.

In addition “Methylmercury” should be included as parameter in the leachate control.



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10 Assessment of options

The goal of the study is to identify a “permanent solution for the long-term storage of liquid mercury

with minimized environmental impacts to acceptable costs” and to set up corresponding acceptance

criteria. The results so far show that there might be more than one acceptable permanent solution.

Therefore an environmental and economic assessment of the options is carried out to highlight the

advantages and disadvantages of the various options and option combinations. If an option or a

combination of options fulfills all acceptance criteria, it can be chosen by industry. So the question

might come up why an assessment and a consequent recommendation list are necessary at all.

The answer on this question and correspondingly the justification of the final assessment is to offer

industry an information and decision basis where they can see the advantages of options under

different criteria. This might lead to a preference of solutions that provide environmental advantages

against other options with equal costs. Also a preference might be generated for less expensive

solutions with the same level of environmental safeness.

It should be emphasised that the results of the assessment can serve as a decision basis for

concerned companies and authorities, the exclusion of options is not a target of this investigation.

The options and option combinations which have been considered to fulfil the minimum

requirements from Section 8 are used as a basis for the assessment. The following table gives an

overview of all remaining relevant option combinations:

Option / option

combination

Description

1l Permanent storage of liquid mercury in salt mines

6l-1s Pre-treatment + Permanent storage of stabilised mercury in salt mines

6l-3s Pre-treatment + permanent storage of stabilised mercury in deep underground hard rock formations

6l-7s Pre-treatment + permanent of stabilised mercury in above ground facilities

2l-1l Temporary storage of liquid mercury in salt mines + Permanent storage of liquid mercury in salt mines

2l-6l-1s Temporary storage of liquid mercury in salt mines + Pre-treatment + permanent storage of stabilised mercury in salt mines

2l-6l-3s Temporary storage of liquid mercury in salt mines + Pre-treatment + permanent storage of stabilised mercury in deep underground hard rock formations

2l-6l-7s Temporary storage of liquid mercury in salt mines + Pre-treatment + permanent of stabilised mercury above ground storage



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Option / option

combination

Description

5l-1l Temporary storage of liquid mercury in above ground facilities + Permanent storage of liquid mercury in salt mines

5l-l6-1s Temporary storage of liquid mercury in above ground facilities + Pre-treatment + permanent storage of stabilised mercury in salt mines

5l-6l-3s Temporary storage of liquid mercury in above ground facilities + Pre-treatment + permanent storage of stabilised mercury in deep underground hard rock formations

5l-6l-7s Temporary storage of liquid mercury in above ground facilities + mines + Pre-treatment + permanent of stabilised mercury above ground facilities

10.1 Economic assessment of the options

In the following a rough assessment of the cost for each option has been carried out. For the

economic assessment the following costs of each option have been estimated and evaluated:

- Permanent storage costs (incl. Engineering and construction costs if necessary)

- Costs of a temporary storage of metallic mercury

- Costs for maintaining, monitoring and inspection of the permanent storage site

before its final closure (time period depends on the expected closure time of the

storage site)

- Transportation costs

- Capital costs for the pre-treatment facility

- Operating and maintenance costs for the pre-treatment process

The assessment is based on information available. For many parameters only estimates are possible

as no quantification is available.

The most cost effective solution is a permanent option without any further treatment. Each option

including temporary storage and/or pre-treatment is more cost intensive as additional handling,

processing and transports are required. Storage costs charged for the disposal in salt mines are

expected to be in a range between 260 - 900 € per tonne (see chapter 6.2.2.3). Storage costs at hard

rock formations are in general low but highly depend on the necessary engineering and construction

measures which have to be implemented for the specific waste and/or location.

Specific containers are only required for the storage of metallic mercury. Costs for these containers



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are in a range between 600 - 1,100 Euros per tonne. For stabilised products big bags or drums are

used which are significantly cheaper (~ 10 €/t).

The costs for a temporary storage depend on the need for additional constructions (e.g. construction

of a storage building) and the duration of the storage. Also costs for the retrieval of the waste and

the necessary rebuilding measures of the storage site have to be taken into consideration. In addition

costs for staff working at the facility are relevant.

Within the investigation some technologies have already been assessed as suitable for the pre-

treatment of mercury. Therefore the duration of the temporary storage is expected to be in a frame

of 3-5 years.

Transport costs are in particular relevant for combined options which means options including a

temporary storage and/or pre-treatment and a subsequent permanent storage. Transport costs for

8,000 – 9,000 t of metallic mercury are expected in a range between 1.1 – 1.3 million Euro

(calculations based on actual transport costs received from Mayasa). The transport capacity of a

truck is 22 t of metallic mercury.

The availability of storage sites only plays a minor role in case of metallic mercury. As the main

producers of metallic mercury waste (chlor-alkali plants) are spread around Europe (see chapter 1.1)

the existence of several storage options for metallic mercury would not significantly reduce the costs

but would require additional costs for the preparation of storage sites for a relatively low volume of

waste (700 m³ not including container).

In case of a temporary storage prior to a pre-treatment the costs will increase significantly as

additional transports (from the temporary storage site to the pre-treatment site to the final disposal

site) are necessary. The pre-treatment results in a product with higher volume and weight compared

to metallic mercury. As a consequence transport costs and the number of transports significantly

increase. Therefore it is advantageous to have short distances from the pre-treatment site to the

storage site. As for pre-treated products different types of landfills (salt mines, hard rock

underground formations, above ground) are possible the transport costs might be reduced by

selecting the nearest adequate site.

Cost estimates are available for the sulphur stabilisation process. According to DELA the pre-

treatment inclusive transport costs and final disposal of the product would be around 2,000 €/t

metallic mercury (see chapter 7.1.4). These costs also include the capital costs and the operational

costs for the plant.

The costs for the inspection should be rather low in case of annual inspection routine by certified

inspectors.

The costs for a permanent monitoring of the air should also be rather low. Suitable technology is

available which allows a permanent surveillance of the storage area including acoustic and visual

alert systems.



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Option 1l: Permanent storage of liquid mercury in salt mines

This option is considered to be the most beneficial economic solution. Storage costs are expected to

range between 300 – 900 €/t Hg plus the costs for the container with around 600 – 1,100 €/t Hg. The

transport costs are relatively low as only one transport from the waste generator to the salt mines is

required.

Option 2l-1l (Temp. storage in salt rock + perm. storage in salt rock)

Temporary storage of metallic mercury prior to a permanent storage in salt mine is considered to be

nearly as economic beneficial as option 1l – in case both take place in the same mine. No additional

transport or handling costs are required. If this is not the case additional transport costs and handling

costs for retrieval of the waste occur.

Option 6l-1s (Pre-treatment + perm. storage in salt rock)

The pre-treatment process is the most cost intensive part of this option. The costs for the

stabilisation, the transport to the disposal site and the final disposal costs are at least 2,000 €/t

metallic mercury. Currently only one company offers this price. All other technologies seem to be

more expensive.

A cost advantage of option 6l-1s compared to option 1l is the containment as no specific container is

required. The stabilized product can be disposed in relatively cheap big bags or drums. On the other

hand the storage cost will increase significantly due to the increased amount of waste which has to

be stored. Storage costs are typically charged per tonne of waste. Each stabilisation process results in

higher volume as well as increased weight compared to metallic mercury. For the sulphur

stabilisation an elevation of the weight (at least 16%) and volume (around 500%) has to be

considered.

The transport costs are higher compared to option 1l and option 2l-1l as additional transports are

required. The transport costs from the pre-treatment plant to the final disposal site depend on the

distance and the number of available storage site.

Option 6l-3s (Pre-treatment + perm. storage in hard rock)

The economic situation of option 6l-3s is very similar to the above described option 6l-1s. The mere

disposal costs of pre-treated mercury in hard rock or salt rock formations are relatively low

compared to the other costs. No information is available on the number of sites fulfilling the

requirements for the storage of stabilised mercury in hard rock formations.

Option 6l-7s (Pre-treatment + perm. above ground)

Also this option is comparable with option 6l-1s with regard to the costs. Although the above-ground

disposal is economically beneficial compared to underground disposal, the difference is expected to

have only a small consequence on the overall expenses. The storage is recommended in separated



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cells which result in additional costs.

This option might result in lower transport costs as it can be expected that several suitable hazardous

waste landfills are available all over Europe.

Option 2l-6l-1s (Temp. storage in salt rock + pre-treatment + perm. storage in salt rock)

This option is comparable to option 6l-1s but additional expenses arise due to additional handling,

transports and monitoring expenditures during the temporary storage phase.

Option 2l-6l-3s (Temp. storage in salt rock + pre-treatment + perm. storage in hard rock)

The expenditure of this option is comparable with option 2l-6l-1s. Again the disposal costs only have

a low effect on the overall costs.

Option 2l-6l-7s (Temp. storage in salt rock + pre-treatment + perm. above ground)

Also this option is comparable with option 2l-6l-1s due to the negligible effect of the disposal costs.

Option 5l-1l (Temp. storage above ground + perm. storage in salt rock)

Compared to option 2l-1l higher costs result for this option due to additional transport costs of the

metallic mercury. In addition it is expected that significantly higher costs for the construction of

storage site are required compared to salt mines. The storage costs of this option highly depend on

the availability of already existing suitable storage sites. In case a building has to be constructed or

rebuilt the costs for this option rise significantly. Also additional handling (retrieval of the waste) and

staff costs (operation of the storage site) increase the overall costs of this option compared to option

2l-1l.

Option 5l-6l-1s (Temp. storage above ground + pre-treatment + perm. storage in salt rock)

The pre-treatment costs and storage costs of this option are comparable to option 2l-6l-1s The

temporary storage costs of this option highly depend on the availability of already existing suitable

storage sites. In case a building has to be constructed or rebuilt the costs for this option rise

significantly.

Option 5l-6l-3s (Temp. storage above ground + pre-treatment + perm. storage in hard rock)

This option is similar to option 5l-6l-1s. Again the mere disposal costs either in salt rock or hard rock

formation hardly change the economic situation.

Option 5l-6l-7s (Temp. storage above ground + pre-treatment + perm. above ground)

Also this option was assessed to be in the same range as option 5l-6l-1s or option 5l-6l-3s. Again the

difference in the costs of the mere disposal can be neglected.



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10.2 Environmental assessment of the options

For the environmental assessment the following parameters have been estimated and evaluated for

each option:

- Level of protection of the environment in case of permanent storage

Protection of the ground water against mercury

Protection of the biosphere

- Hg-emissions during storage and handling

- CO2 emissions resulting from transport

- Energy consumption (expressed as CO2 emissions)

- Reversibility (in case of temporary and permanent storage)

- Safety of workers

- Removal of mercury from the biosphere

- Prevention against natural events (floods, earthquakes, weather,)

- Monitoring possibility

- Possibility of corrective actions with or without incidents

- Safety margins in case of incidents

The level of protection of the environment and as a consequence also the human health is the most

important criteria of the environmental assessment. Independently of which type of waste is stored -

metallic or stabilised - the entering of mercury or mercury compounds into the environment has to

be prevented as far as possible.

Underground storage sites provide generally a higher level of protection of the environment against

mercury emissions compared to above ground storage sites. Each underground storage facility needs

a site specific risk assessment which provides the long term safety of the stored waste in the facility.

Mercury emissions might occur during the transport, handling but also storage of the metallic

mercury. It is obvious that the number of handling processes will increase the probability of mercury

emissions. Therefore single permanent storage solutions will be assessed as environmentally more

favourable concerning mercury emissions than options including pre-treatment or temporary storage

with a subsequent permanent storage.



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Each transport is referred to CO2 emissions. Therefore options with several transport requirements

are assessed as less environmental favourable then options with only one transport way. On the

other hand options which include the possibility of several storage sites all around Europe are seen

as environmentally more beneficial as regards the CO2 emissions resulting from transports due to

shorter distances. The risk of mercury emission during the transport of stabilised products is

negligible but the number of transports increases resulting in higher corresponding CO2 emissions.

For the transport of metallic mercury the requirements of the transport of hazardous waste apply.

The risk of an incident is seen as very low but in case it happens the consequences for the

environment are significantly higher compared to the transport of stabilised mercury.

The energy consumption of permanent storage without a prior treatment or temporary storage is

estimated as very low. Energy consumption is in particular relevant for options with pre-treatment

processes. For the stabilisation of the metallic mercury energy is required, but due to the fact that in

case of the sulphur stabilisation the process is slightly exothermic the energy consumption is seen as

moderate. But energy is required e.g. to provide vacuum conditions or for the mixing.

The retrievability of the stored waste has to be ensured in case of a temporary storage anyway. In

case of a permanent storage of stabilised waste only the storage in hard rock formations and above

ground storage would allow the retrieval of the permanently stored waste. Due to their creeping

potential the retrieval of a permanently stored waste in salt mines is only possible for a certain time

period.

The safety of workers includes the prevention against possible exposure to mercury and mercury

vapour. In case of a temporary storage or pre-treatment the probability of an exposure is higher

compared to a single permanent solution in salt mines. But also a permanent storage in salt mines

might have the risk of exposure to mercury e.g. in case of leaking containment or any other incident.

The removal of the mercury from the biosphere is relevant for the permanent storage. A permanent

storage providing the highest degree of removal of the mercury from the biosphere is

environmentally more favourable. In particular permanent underground storage facilities are

constructed and designed in a way to remove the waste from the biosphere.

Permanent above ground storages have the disadvantage that interaction with the environment and

emission of the waste to the environment are more likely compared to underground options. Also

the consequences of natural catastrophes are considered to have a stronger impact in case of above

ground storage compared to underground storage options. Above ground options are also more

likely exposed to man-made risks such as terrorist attacks or plane crash.

These disadvantages might be compensated by the easier access to the waste in case of any

incidents. The monitoring and the possibility of interventions are easier in case of above ground

facilities.

In the following the options identified in chapter 8 will be assessed against the above described



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environmental aspects.

Option 1l (Permanent storage of liquid mercury in salt rock)

The storage in salt rock is generally seen as a safe storage option. Under the pre-condition that a safe

encapsulation of the waste mercury is ensured, a high level of protection of the biosphere is given.

But compared to the disposal of stabilised mercury lower safety margins apply in case of an

unforeseen severe incident like flooding of the salt mine – due to the significantly higher solubility of

metallic mercury in water compared to stabilised mercury. When the whole storage site collapses

(flooding of the mine) there are no possibilities to prevent mercury entering to the environment.

Once the facility is closed the retrieval of the waste is very difficult or even not possible without

major risks for the whole storage site.

The disadvantage is that little is known about the long-term behaviour of liquid mercury in the salt

rock formation. After the closure of the salt mine the possibility of corrective actions with or without

an incident is low or not given.

Option 6l-1s (Pre-treatment + perm. storage in salt rock)

This Option is considered to be the most beneficial solution from an environmental point of view.

The solid pre-treated product should, in a long term, be encapsulated within the salt rock formation.

Even in case the pre-treated product gets in contact with water due to unforeseeable circumstances

the low solubility of the product keeps the environmental pollution within a limit, and emissions are

distributed within a very long time period. Due to this a rapid release of mercury to the environment

and therefore a strong local contamination can be regarded to be unlikely.

On the other side, possible mercury emissions during the handling, stabilisation and transport have

to be taken into consideration. Further transports are required to bring the stabilised product to the

storage site. From an environmental point of view the increased CO2 emissions from the transport

are negligible compared to the higher protection level of the environment.

Mercury emission during the stabilisation processes highly depend on the established emission

control measures. Applying state-of-the art equipment (BAT Reference document required) reduces

significantly mercury emissions during the handling and stabilisation process.

Option 6l-3s (Pre-treatment + perm. storage in hard rock)

Underground hard rock formation storage facilities are seen as a safety storage option by applying

adequate multi-barrier systems. A total encapsulation of the waste is not possible as it is the case in

salt rock formation and which is an additional environmental safety factor.

Option 6l-3s is comparable to option 6l-1s but due to the fact that in hard rock formations a total

encapsulation is not possible and in addition presences of water cannot be completely excluded. The



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risk of mercury entering the biosphere via water flows over the long term has been assessed slightly

higher compared to salt mines.

On the other hand hard rock formations with stable cavities allow corrective measures over a long

time period. With reference to the safety of workers no difference are seen between salt mines and

hard rock formations. The retrievability of the stored material is given.

Option 6l-7s (Pre-treatment + perm. above ground)

The permanent above ground storage of stabilised mercury has been assessed as less favourable as

the underground storage options. The risk of an interaction with the environment (e.g. penetrating

rain water, floods) with a subsequent release of mercury from the storage site has been assessed

higher compared to underground storage. Although in case of unforeseen incidents potential

emissions can be detected and counter measures could be applied the risk of mercury entering the

environment is still very high. Once the protection barrier of the site is destroyed the possibility to

stop mercury entering the environment is very limited.

The retrievability of the waste is given but on the other hand the risk of unauthorised retrieval of the

stabilised waste is higher compared to underground storage.

Option 2l-1l (Temp. storage in salt rock + perm. storage in salt rock)

As option 1l, option 2l-1l is a relatively safe disposal opportunity with the same pros and cons as

option 1l and therefore has the same score for the environmental assessment.

Option 2l-6l-1s (Temp. storage in salt rock + pre-treatment + perm. storage in salt rock)

Option 2l-6l-1s is similar to option 6l-1s with respect to the environmental safety of the final disposal.

But it is assessed lower due to additional handling and transports processes resulting from prior

temporary storage. The metallic waste has to be transported to the salt mine and after a certain time

the mercury has to be retrieved, stabilised and then again transported to an underground salt mine

disposal site. The additional movements and handling processes compared to option 6l-1s might

result in higher mercury emissions. Also mercury emissions might occur during the storage phase. In

addition, higher CO2 emissions and safety risks have to be considered from the increased number of

transports.

Option 2l-6l-3s (Temp. storage in salt rock + pre-treatment + perm. storage in hard rock)

Option 2l-6l-3s is similar to option 6l-3s but as is the case in option 2l-6l-1s the temporary storage

includes higher environmental safety risks and risk of additional emissions of mercury which lower

the environmental evaluation compared to 6l-3s.

Option 2l-6l-7s (Temp. storage in salt rock + pre-treatment + perm. above ground)

Option 2l-6l-7s is considered to be similar to option 6l-7s but again the temporary storage step



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results in additional handling and movements of the mercury with increased risk of mercury

emissions, CO2 emissions and also incidents resulting in mercury emissions.

Option 5l-1l (Temp. storage above ground + perm. storage in salt rock)

This option is generally seen as a safe storage option but the temporary above ground storage of

metallic mercury has been assessed slightly less favourable from the environmental point of view

then the temporary underground storage in salt mines. Above-ground storage sites are more

exposed to natural events such as floods or manmade risks e.g. terrorist attacks. Though the safety

assessment has to consider these risks a total exclusion is not possible.

With respect to the transport higher risks compared to option 2l-1l arise due to the higher number of

transports. The metallic mercury has to be transported from the waste generator to the storage site

and from the storage site to the final disposal site.

For the subsequent permanent storage of the metallic mercury in salt mines, the same apply as

described in option 1l.

Option 5l-6l-1s (Temp. storage above ground + pre-treatment + perm. storage in salt rock)

This option can be compared with option 2l-6l-1s. In both cases handling of the elemental mercury is

necessary which is prone to the risk of additional mercury emissions. Comparing option 5l-6l-1s with

option 2l-6l-1s a slightly higher environmental risk from the temporary storage above ground

compared to salt rock formation is considered. The assessment of the environmental aspect is

therefore lower.

Option 5l-6l-3s (Temp. storage above ground + pre-treatment + perm. storage in hard rock)

Option 5l-6l-3s is similar to option 2l-6l-3s but as is the case in option 5l-6l-1s the higher

environmental risk of the temporary above ground storage reduces the assessment.

Option 5l-6l-7s (Temp. storage above ground + pre-treatment + perm. above ground)

Option 5l-6l-7s can be compared with option 2l-6l-7s. Again the temporary above ground storage

reduces the assessment compared to option 2l-6l-7s.



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10.3 Overview on the result of the assessment

The following picture illustrates the result of the economic and the environmental assessment of

options in section 10.1 and 10.2. All feasible options are listed in the diagram due to their economic

and environmental appropriateness. No scales are introduced as for the target of this analysis a

comparative assessment is regarded as sufficient.

The red line in the diagram represents the target function that is generated by weighting

environmental and economic sub-targets. Different target functions can be generated if different

weighting is applied. However, the general principle of such a decision making scheme will remain,

what says that those alternatives that are on the right hand site represent qualified options for the

recommendations. Every decision maker might generate a different target function. If a target

function cannot be agreed on, options 1l; 2l-1l; 6l-1s will remain for the final selection. This is based

on the principle of Pareto-Efficiency in decision making schemes [Ehrgott 2000].

Economic advantages

III

III

Environmental advantages

1l2l-1l

6l-1s 6l-3s6l-7s

5l-6l-1s

2l-6l-3s

5l-6l-3s5l-6l-7s

2l-6l-7s

2l-6l-1s

5l-1l



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11 Conclusions and Recommendations

One major objective of Regulation EC (N°) 1102/2008 is to ensure a safe storage of surplus mercury

which is considered as waste and to prevent it from re-entering the market. The goal of the study

was to identify feasible storage options and – if necessary – to define draft acceptance criteria and

minimum requirements for the implementation.

1. Possible options for a safe storage of surplus mercury are available

The following permanent storage options (without a prior temporary storage) have been assessed as

possible options:

- Permanent storage of metallic mercury in salt mines

- Pre-treatment of metallic mercury with a subsequent permanent storage in salt

mines

- Pre-treatment of metallic mercury with a subsequent permanent storage in deep


- Pre-treatment of metallic mercury with a subsequent permanent storage in above

ground facilities

Uncertainties are based on the fact that sufficient capacities for pre-treatment are announced for

March 2011 but do not yet exist. Further uncertainties concern the availability of these options in the

given time frame also temporary storage options have been screened and identified90:

- Temporary storage of metallic mercury in salt mines

- Temporary storage of metallic mercury in above-ground facilities

These options are most probably available by March 2011. Slight uncertainties are caused by the fact

that for the storage of liquid mercury at landfills (above ground and underground) currently no

disposal site has a valid permit.

2. Acceptance criteria and additional facility related requirements have been developed

For all options which have been assessed as possible options for a safe storage of liquid mercury

acceptance criteria and additional facility related requirements have been developed and are now

available. These concern in particular:

- Minimum acceptance criteria and procedure for metallic mercury

(e.g. purity > 99.9% per weight) and its containment (e.g. carbon steel container)

9090 Temporary storage in hard rock formations might be a feasible option but within the scope of the report no

site could be identified fulfilling the technical and economic criteria within the given time frame



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- Minimum acceptance criteria for stabilised mercury

(e.g. leaching rate below 2 mg/kg dry mass)

- Additional facility related requirements for the permanent storage in salt rock

(e.g. minimum depth of the storage area: 300 m)

3. Recommended options

Based on an economic and environmental assessment the following options are recommended:

1. Pre-treatment (Sulphur stabilisation) of metallic mercury and subsequent permanent storage

in salt mines (highest level of environmental protection, acceptable costs)

2. Pre-treatment (Sulphur stabilisation) of metallic mercury and subsequent permanent storage

in a hard rock underground formation (high level of environmental protection, acceptable

costs)

3. Permanent Storage of metallic mercury in salt mines (high level of environmental protection,

most cost effective option)

4. Recommended timeframe for a temporary storage

Due to the fact that currently no permanent solution is available – all potential permanent solutions

still have a certain level of uncertainty related to their availability by March 2011 – temporary

storage solutions are required to bridge the gap until final solutions are available. A period of 5 years

is recommended as timeframe for the temporary storage.

A review of the Regulation (EC) N° 1102/2008 is foreseen not later than 15 March 2013. Within this

review process the actual availability of permanent options should be checked and the requirement

of future temporary storage and timeframe discussed.



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12 Annexes

12.1 Annex 1: Questionnaire

Questionnaire to the project

“Requirements for facilities and acceptance criteria for the disposal of metallic mercury”

We would be very grateful if you could send back the questionnaire until 22 June 2009 to [email protected].

Name:

Institution:

Telephone number:

e-mail:

Function:

Please find attached the filled in questionnaire

I would be interested to further discuss this topic by a telephone call, possible dates when I am available:

No interest in further discussions

mailto:[email protected]



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Questions

1. Do you know recent or ongoing research / scientific activities related to disposal options of metallic mercury waste?

If available, please indicate contact persons, documents or links.

2. Do you know recent or ongoing research / scientific work related to pre-treatment techniques for metallic mercury waste?

If available, please indicate contact persons, documents or links.

3. What is the current legal framework related to the disposal and /or treatment of metallic mercury in your country?

4. What are the current ways of treatment of metallic mercury and disposal of metallic mercury within your country?

5. Are there any national preferences as regards the options stated in Regulation (EC) N° 1102/2008 (salt mines, deep underground hard rock formations) in which way metallic mercury should permanently be disposed of?

If yes, please indicate reasons for the preferences.

6. Do you have appropriate storage possibilities in your country?

7. Do you have specific experiences related to the underground storage of hazardous waste?

8. Which type of containment should be used for the storage (permanent or temporary)?

9. Do you see a pre-treatment of metallic mercury (e.g. solidification) as essential before a safe storage?



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10. Do you have any experiences and/or preferences related to pre-treatment technologies of metallic mercury?

If yes, please indicate relevant contact persons, documents or links.

11. Which aspects are most important for you related to the revision of the annexes I, II and III of Directive 1999/31/EC on landfill of waste?

e.g. any specific suggestions on what would especially need to be revised, any additional options

12. Which further items related to the disposal of metallic mercury would be of special interest for you?



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12.2 Annex 2: Literature overview

[ACS Kazakhstan 2000] Emerging Technologies in Hazardous Waste Management 8 D. William Tedder and Frederick G. Pohland, 2000 [Aluminium 2004] Corrosion of Aluminium, Christian Vargel, ISBN: 0 08 044495 4, 2004 [ATSDR 1999] U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES, Public Health Service, Agency for Toxic Substances and Disease Registry, TOXICOLOGICAL PROFILE FOR MERCURY, 1999; http://www.atsdr.cdc.gov/toxfaqs/TF.asp?id=115&tid=24 [Benoit 1999] Benoit, J.M., Mason, R.P., Gilmour, C.C., Estimation of mercury-sulfide speciation in sediment pore waters using octanol-water partitioning and implications for availability to methylating bacteria, Environmental Toxicology and Chemistry, Vol. 18, No. 10, pp. 2138-2141, 1999 http://www.serc.si.edu/labs/microbial/pubs/Benoit%20et%20al%20ET&C%201999.pdf [Benoit 2001] Benoit, J.M., Gilmour, C.C., Mason, R.P., The influence of sulphide on solid-phase mercury bioavailability for methylation by pure cultures of Desulfobulbus propionicus, (2001), Environmental Science and Technology, 35 (1), pp. 127-132, 2001 [BGR 2007] BGR, Bundesanstalt für Geowissenschaften und Rohstoffe, Nuclear waste disposal in Germany - Investigation and evaluation of regions with potentially suitable host rock formations for a geologic nuclear repository, Hannover/Berlin, April 2007, http://www.bgr.bund.de/nn_335086/EN/Themen/Geotechnik/Downloads/WasteDisposal__HostRockFormations__en,templateId=raw,property=publicationFile.pdf/WasteDisposal_HostRockFormations_en.pdf [BMU 2009] Bundesministerium für Umwelt, Natur und Reaktorsicherheit, Sicherheitsanforderungen an die Endlagerung wärmeentwickelnder radioaktiver Abfälle, Berlin, 2009, http://www.bmu.de/files/pdfs/allgemein/application/pdf/endfassung_sicherheitsanforderungen_bf.pdf [Brookhaven 2001] P.D. Kalb, J.W. Adams and L.W. Milian, Sulfur Polymer Stabilization/Solidification (SPSS) Treatment of Mixed-Waste Mercury Recovered from Environmental Restoration Activities at BNL, January 2001 [Brookhaven 2002] Discover Brookhaven, Volume 1 number 1 spring 2002, page 7, Paul Kalb, Spring 2002 [Brookhaven Newmont 2003] Using the Sulfur Polymer Stabilization/Solidification Process to Treat Residual Mercury Wastes from Gold Mining Operations B. Bowerman, J. Adams, P.Kalb, R-Y Wan and M. LeVier 24-26 February 2003, http://www.bnl.gov/isd/documents/25533.pdf

http://www.atsdr.cdc.gov/toxfaqs/TF.asp?id=115&tid=24

http://www.serc.si.edu/labs/microbial/pubs/Benoit et al ET&C 1999.pdf






http://www.bnl.gov/isd/documents/25533.pdf



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[Brückner 2003] Brückner, D.; Lindert, A., Wiedemann, M., The Bernburg Test Cavern - A Model Study of Cavern Abandoment SMRI Fall Meeting, 5 - 8. Oct. 2003, Chester, UK, 69 – 89, 2003 [CA1011889] McCord, Andrew T. and Wagner, lois E., Disposal of wastes containing mercury, Chem-Trol pollution Services

[Caucus 2003] Quicksilver Caucus, Mercury Stewardship Best Management Practices, 2003, http://www.ecos.org/files/720_file_QSC_BMP_Oct_03.pdf. [CCOHS 1998] Canadian Centre for Occupational Health & Safety, Chemical profile mercury, preparation date 1998, copyright 2007 http://www.ccohs.ca/oshanswers/chemicals/chem_profiles/mercury/ [CENIM 2009] The application of sulphur concrete to the stabilization of Hg-contaminated soil, 1st Spanish national conference on advances in materials recycling and eco-energy, F.A. López, C.P. Román, I. Padilla, A. López-Delgado and F.J. Alguacil, 2009, http://digital.csic.es/bitstream/10261/18465/1/S02_3.pdf [Concorde 2004] Concorde EastWest Spr., Mercury flows in Europe and the world: the impact of decommissioned chlor-alkali plants, February 2004 http://ec.europa.eu/environment/chemicals/mercury/pdf/report.pdf [Concorde 2006] Concorde EastWest Spr., Mercury flows and safe storage of surplus mercury, 2006 http://ec.europa.eu/environment/chemicals/mercury/pdf/hg_flows_safe_storage.pdf [Concorde 2009] Concorde sprl, Assessment of excess mercury in Asia, 2010-2050, May 2009 http://www.chem.unep.ch/mercury/storage/Asian%20Hg%20storage_ZMWG%20Final_26May2009.pdf [Council Decision 2003/33/EC] Council Decision, of 19 December 2002 establishing criteria and procedures for the acceptance of waste at landfills pursuant to Article 16 of and Annex II to Directive 1999/31/EC (2003/33/EC) [COWI 2007] COWI, Follow-up study on the implementation of Directive 1999/31/EC on, June 2007 the landfill of waste in EU-25, Final Report - Findings of the Study http://web.rec.org/documents/ECENA/training_programmes/2008_06_budapest/session1/7-implementation_eu_25_2007_cowi_report.pdf [COWI 2008] COWI A/S and Concorde East/West Sprl, Options for reducing mercury use in products and

http://www.ecos.org/files/720_file_QSC_BMP_Oct_03.pdf

http://www.ccohs.ca/oshanswers/chemicals/chem_profiles/mercury/

http://digital.csic.es/bitstream/10261/18465/1/S02_3.pdf

http://ec.europa.eu/environment/chemicals/mercury/pdf/report.pdf

http://ec.europa.eu/environment/chemicals/mercury/pdf/hg_flows_safe_storage.pdf







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applications, and the fate of mercury already circulating in society, December 2008 http://ec.europa.eu/environment/chemicals/mercury/pdf/study_report2008.pdf [DE453523] Herstellung von lichtecher Zinnober aus den Elementen, Deutsches Reich, Alexander Eibner, 7. April 1925 [Decreto 2003] Criteri di ammissibilità dei rifiuti in discarica. Ministero dell'ambiente e della tutela del territorio, 13 marzo 2003, Italy http://www.reteambiente.it/normativa/4355/dm-ambiente-13-marzo-2003/ [DELA 2009] Workshop on the safe storage and disposal of redundant mercury, Stabilisation of mercury for final disposal by formation of mercury sulphide, Miriam Ortheil, DELA, St Anne´s College, Oxford (UK), 13th & 14th October, 2009 [Deponieverordnung 2008] 39. Verordnung des Bundesministers für Land- und Forstwirtschaft, Umwelt und Wasserwirtschaft über Deponien, Januar 2008, Germany [DepVereinfachV 2009] Verordnung zur Vereinfachung des Deponierechts, Germany 27. April 2009, http://www.bmu.de/files/pdfs/allgemein/application/pdf/depvereinfv.pdf [DNSC 2004] Defense National Stockpile Center, Record of Decision for the Mercury Management EIS, April 2004 [DNSC 2004A] Defense National Stockpile Center, Final Mercury Management Environmental Impact Statement, Executive Summary, 2004 [DNSC 2004B] Defense National Stockpile Center, Final Mercury Management Environmental Impact Statement, Volume I, 2004 [DNSC 2004C] Defense National Stockpile Center, Human Health and Ecological Risk Assessment Report for the Mercury Management EIS, Volume II, 2004 [DNSC 2007] Defense National Stockpile Center, Fact Sheet: Mercury Over-Packing, Storage & Transportation, May 2007 [DNSC 2007A] Defense National Stockpile Center, Fact Sheet: Somerville Depot, February 2007 [DOE 1999] U.S. Department of Energy, Mercury Contamination – Amalgamate (contract with NFS and ADA) - Stabilize Elemental Mercury Wastes - Summary report, DOE/EM-0472


http://www.reteambiente.it/normativa/4355/dm-ambiente-13-marzo-2003/

http://www.bmu.de/files/pdfs/allgemein/application/pdf/depvereinfv.pdf



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[DOE 2009] U.S. Department of Energy, Interim Guidance on Packaging, Transportation, Receipt, Management, and Long-Term Storage of Elemental Mercury, U.S. Department of Energy Office of Environmental Management Washington, D.C., November 13, 2009, http://www.em.doe.gov/pdfs/Elementalmercurystorage%20Interim%20Guidance_11_13_2009.pdf [Drott 2007] Drott, a., Lambertsson, L., Björn, E., Skyllberg, U., Importance of dissolved neutral mercury sulfides for methyl mercury production in contaminated sediments, Environmental Science and Technology, 41 (7), pp. 2270-2276, 2007 [Ehrgott 2000] Ehrgott, Matthias, Multicriteria Optimization, Lecture Notes in Economic and Mathematical Systems 491, Springer Verlag, 2000 [EIA EU 2005] Communication from the Commission to the Council and the European Parliament on Community Strategy Concerning Mercury, EXTENDED IMPACT ASSESSMENT, 2005 http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=COM:2005:0020:FIN:EN:PDF [Env Canada 2001] National Office of Pollution prevention, Environment Canada, The Development of retirement and long term storage options of mercury, Draft final report, Ontario, June 2001 [Env Canada 2004] Environment Canada, Mercury and the environment, Internet document: http://www.ec.gc.ca/MERCURY/EH/EN/eh-i.cfm, last update 2004-02-04, accessed on 29 June 2009 [EP 2 072 467 A2] Verfahren und Vorrichtung zur Herstellung von Quecksilbersulfid zur anschließenden Entsorgung, Bonman Christian, EP2 072 467 A2 [EP 2 072 468 A2] Verfahren und Vorrichtung zur Herstellung von Quecksilbersulfid zur anschließenden Entsorgung, Bonman Christian, EP2 072 468 A2 [Eriksson 2006] L. Eriksson, Swedish policy for a mercury free environment, presentation, Swedish Environmental Protection Agency [EU COM 2001] European Commission, Integrated Pollution Prevention and Control (IPPC) - Reference Document on Best Available Techniques in the Chlor-Alkali Manufacturing industry -, http://ec.europa.eu/comm/environment/ippc/brefs/cak_bref_1201.pdf [EU COM 2002] Report from the Commission to the Council concerning mercury from the Chlor-alkali industry, COM (2002) 489 final, http://eur-lex.europa.eu/smartapi/cgi/sga_doc?smartapi!celexplus!prod!DocNumber&lg=en&type_doc=COMfinal&an_doc=2002&nu_doc=489









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http://www.vks-kalisalz.de/images/pdfs/K_Stein_3_07.pdf



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[SKB 2000] What requirements does the KBS-3 repository make on the host rock? Geoscientific suitability indicators and criteria for siting and site evaluation, Swedish Nuclear Fuel and Waste Management Co (SKB), Stockholm, 2000 [SOU 2001] NATURVÅRDSVERKET, A Safe Mercury Repository, A translation of the Official Report SOU 2001:58, Report 8105 • January 2003, http://www.naturvardsverket.se/Documents/publikationer/620-8105-5.pdf [SOU 2008] Statens offentliga Utredningar (SOU) 2008: 19 Permanent storage of long-lived hazardous waste in underground deep bedrock depositories, Summary of key findings, SOU 2008: 10 April 2008 [SOU 2008A] Miljödepartementet, Att slutförvara långlivat farligt avfall i undermarksdeponi i berg, ISBN 978-91-38-22922-4, 2008 [SPC 2009] http://www.ktf-split.hr/periodni/en/abc/kpt.html [Spiegel 2007] Gau in der Grube, Michael Fröhlingsdorf, Sebastian Knauer, 17/2007 [TRGS 900] Technische Regeln für Gefahrstoffe. Arbeitsplatzgrenzwerte. Ausgabe: Januar 2006, zuletzt geändert und ergänzt: GMBl Nr. 28 S. 605 (v. 2.7.2009), http://www.baua.de/nn_16806/de/Themen-von-A-Z/Gefahrstoffe/TRGS/pdf/TRGS-900.pdf [UBA DE 2004] Umweltbundesamt, Background paper on permanent storage in salt mines prepared by the Federal Environment Agency, Berlin, Germany, 29 July 2004; http://www.basel.int/techmatters/popguid_may2004_ge_an1.pdf [UK PID 1996] National Poisons Information Service UK, Mercury MONOGRAPH FOR UKPID, 1996 [UNEP 2002] UNEP, Global mercury assessment, 2002, http://www.chem.unep.ch/mercury/Report/Final%20Assessment%20report.htm [UNEP 2006] UNEP, Summary of supply, trade and demand information on mercury, Analysis requested by UNEP Governing Council decision 23/9 IV, Geneva, Nov. 2006; http://www.chem.unep.ch/mercury/mandates.htm [UNEP 2007] Draft technical guidelines on the environmentally sound management of mercury wastes, 2007, http://www.basel.int/techmatters/mercury/guidelines/240707.pdf

http://www.naturvardsverket.se/Documents/publikationer/620�8105�5.pdf




http://www.basel.int/techmatters/popguid_may2004_ge_an1.pdf

http://www.chem.unep.ch/mercury/Report/Final Assessment report.htm

http://www.chem.unep.ch/mercury/mandates.htm




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[UNEP 2009] UNEP, Draft technical guidelines on the environmentally sound management of mercury wastes, 4th Draft, April 2009 [UNEP 2009 A] UNEP Chemicals, EXCESS MERCURY SUPPLY IN LATIN AMERICA AND THE CARIBBEAN, 2010-2050, ASSESSMENT REPORT, July 2009 http://www.chem.unep.ch/mercury/storage/LAC%20Mercury%20Storage%20Assessment_Final_1July09.pdf [UNEP 2009 B] http://www.chem.unep.ch/MERCURY/ [US ban 2008] Mercury export ban Act 2008, Public Law 110-414 - Oct, 14., 2008, 122 Stat. 4341, http://www.govtrack.us/congress/bill.xpd?bill=s110-906 [USEPA 2000] Mercury stabilization in chemically bonded phosphate ceramics, Arun S. Wagh, Dileep Singh and Seung Young Jeong, March 2000 [USEPA 2000a] Proceedings and Summary Report, Workshop on Mercury in Products, Processes, Waste and the Environment: Eliminating, Reducing and Managing Risks from Non-Combustion Sources, 22-23 March 2000 [USEPA 2002] Mary Cunningham, John Austin, Mike Morris, Evaluation of Treatment of Mercury Surrogate waste, final report, 2002 [USEPA 2002a] Mary Cunningham, John Austin, Mike Morris, Greg Hulet, Mercury wastes evaluation of treatment of bulk elemental mercury, 2002 [USEPA 2002b] Paul M. Randall, Sandip Chattopadhyay, Wendy E. Condit, Advances in encapsulation technologies for the management of mercury-contaminated hazardous wastes, 2002 [USEPA 2002c] Hugh W. McKinnon, Preliminary analysis of alternatives for the long term management of excess mercury, EPA/600/R-03/048, 2002, http://www.epa.gov/nrmrl/pubs/600r03048/600R03048.pdf [USEPA 2003] Evaluation of chemically Bonded Phosphate Ceramics for Mercury Stabilization of a Mixed Synthetic Waste, Land Remediation and Pollution Control Division National Risk Management Research Center Sandip Chattopadhyay, Paul M. Randall, March 2003 http://www.epa.gov/nrmrl/pubs/600r03113/600r03113.pdf [USEPA 2004] Application of the analytic hierarchy process to compare alternatives for the long-term management




http://www.govtrack.us/congress/bill.xpd?bill=s110-906





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of surplus mercury, Paul Randall, Linda Brown, Larry Deschaine, John Dimarzio, Geoffrey Kaiser, John Vierow, 6 January 2004 [US EPA 2005] Paul Randall, Economic and Environmental Analysis of Technologies to Treat Mercury and Dispose in a Waste Containment Facility, April 2005 http://www.epa.gov/nrmrl/pubs/600r05157/600r05157.pdf [USEPA 2007] U.S. Environmental Protection Agency, Treatment Technologies For Mercury in Soil, Waste, and Water, EPA-542-R-07-003, 2007, 2007 http://www.epa.gov/tio/download/remed/542r07003.pdf USEPA 2007a] US EPA, Mercury Storage Cost Estimates, final report, November 2007 http://earth1.epa.gov/mercury/stocks/Storage_Cost_Draft_Updated_11-6-final.pdf [US20080019900 A1] Christelle Riviere-Huc, Vincent Huc, Emilie Bosse, Method for stabilisation of metallic mercury using sulphur, Oblon, Spivak, Mccleland Maier & Neustadt, 24. January 2008 [US20080234529 A1] Treatment of elemental mercury, Moore & Van Allen PLLC, Henry Boso Chan, Raymond Hall, 25. Sep. 2008 [US3061412] Preparation of mercuric sulfide, Anthony Giordano, 30. October 1962 [US3499774] Mercury-containing phosphate glass University Park Woldemar A. Weyl 10. March 1970 [US3704875] Removal of mercury from effluent streams, Penwalt Corporation, Paul Francis Waltrich, 05. December 1972 [US3804751] Disposal of wastes containing mercury, Chem-Trol Pollution Services Inc., Andrew T. mc Cord and Louis E. Wagner [US4230486] Process for removal and recovery of mercury from liquids, Olin Corporation, Italo A. Capuano, Patricia A. Turley, 28. October 1980 [US4354942] Jerry J. Kaczur, James C. Tyler Jr., John J. Simmons, Stabilization of mercury in mercury-containing materials, Olin corporation, 19. October 1982 [US4844815] Stabilisation of mercury containing-waste, Chemical Waste Management Inc, Milton Ader, Edward F. Glod, Edward G. Fochtman, 04. Juni 1989



http://earth1.epa.gov/mercury/stocks/Storage_Cost_Draft_Updated_11-6-final.pdf



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[US5034054] Process for treating mercury in preparation for disposal, Ecoflo Inc., Jeffrey C. Woodward, 23 July 1991 [US5347072] Stabilizing inorganic substrates, Harold W. Adams, 13. September 1994 [US5562589] Stabilizing inorganic substrates Harold W. Adams, 8. October 1996 [US5569153] Method of immobilizing toxic waste material and resultant products, Southwest Research Institute, William A. Mallow, Robert D. Young, 29. October 1996 [US6153809] HS in phosphate glass, The united States of America as represented by the United States Department of Energy, Dileep Singh, Arun S, Wagh, Kartujey D, Patel, 28. November 2000 [US6399848 B1] Encapsulation of hazardous waste materials, Dolomatrix International Limited, Dino Rechichi, 04. July 2002 [US6399849 B1] Treatment of mercury containing waste, Brookhaven Science Associates LLC, Paul D. Kalb, Dan Melamed, Bhavesh R Patel, Mark Fuhrmann, 04 July 2002 [US6153809A] Polymer coating for immobilizing soluble ions in a phosphate ceramic product, Dileep Singh, Arun S. Wagh, Kartikey D. Patel, US 6,153,809, 2000 [US6403044 B1] John E. Litz, Thomas Broderick, Robin M. Stewart, Method and apparatus for stabilizing liquid elemental mercury, ADA Technology Inc., 11. July 2002 [US Wagh] Chemically Bonded Phosphate Ceramics for Stabilization and Solidification of mixed waste, Energy Technology Division Arun S. Wagh, Dileep Singh, Seung-Young Jeong, [US Wagh 2000] Mercury Stabilization in Chemically Bonded Phosphate Ceramics; Energy Technology Division Argonne National Laboratory Dilep Singh, Arun Wagh, Seung Young Jeong http://www.anl.gov/techtransfer/Available_Technologies/Material_Science/Ceramicrete/wagh-mercury.pdf [US Wagh Singh] Method for producing chemically bonded phosphate ceramics and for stabilizing contaminants encapsulated therein utilizing reducing agents; United States Government; Dileep Singh, Arun Wagh, Seung-Young Jeong http://www.osti.gov/bridge/purl.cover.jsp;jsessionid=5971569EAD6B8B9106D1BE27F5F19563?purl=/782750-nscUTZ/webviewable/







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[VLAREM 1995] VLAREM II: Order of the Flemish Government of 1 June 1995 concerning General and Sectoral provisions relating to Environmental Safety, 1th June 1995, Belgium [Wagh-1] Personal information Mr. Wagh, 23.06.2009, e-mail [Waste Management 2001] Sulfur Polymer Solidification/Stabilization of elemental mercury waste M. Fuhrmann, D. Melamed, P.D. Kalb, J.W. Adams, L.W. Milian 14 August 2001 [Waste Management 2002] Sulfur polymer stabilization/solidification (SPSS) treatability of simulated mixed-waste mercury contaminated sludge J.W: Adams, B.S. Bowerman, P.D. Kalb 24-28 February 2002 http://www.wmsym.org/archives/2002/Proceedings/11/511.pdf [Webmin] http://webmineral.com [WHO 2003] World Health Organization Geneva, Concise International Chemical Assessment Document 50, ELEMENTAL MERCURY AND INORGANIC MERCURY COMPOUNDS: HUMAN HEALTH ASPECTS, 2003 [WHO 2004] Guidelines for Drinking-water quality 3rd edition, Geneva, World Health Organization, http://www.who.int/water_sanitation_health/dwq/fulltext.pdf [WHO 2005] World Health Organisation, Mercury in Drinking-water, Background document for development of WHO Guidelines for Drinking-water Quality, 2005 [WHO 2005a] World Health Organisation, Policy Paper: Mercury in health care, August 2005; http://www.who.int/water_sanitation_health/medicalwaste/mercurypolpaper.pdf [WHO 2006] World Health Organisation, Guidelines for drinking-water quality incorporating first addendum. Vol. 1, Recommendations. – 3rd ed.Electronic version for the Web, 2006 [WHO 2007] World Health Organisation, Preventing disease through healthy environments exposure to mercury, A major public health concerns, Geneva 2007 [WHO 2007a] World Health Organisation, risks of heavy metals from long-range transboundary air pollution, Joint WHO/Convention Task Force on the Health Aspects of Air Pollution, Germany 2007 [WHO 2008] World Health Organisation, Assessing the environmental burden of disease at national and local levels. Environmental Burden of Disease Series, No. 16, Geneva 2008

http://www.wmsym.org/archives/2002/Proceedings/11/511.pdf

http://webmineral.com/

http://www.who.int/water_sanitation_health/dwq/fulltext.pdf

http://www.who.int/water_sanitation_health/medicalwaste/mercurypolpaper.pdf



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[WO2005039702 A1] A method and composition for stabilizing waste mercury compounds using ladle furnace slag, Nanyang Technological University Sun, Darren Delai, Tay, Joo Hwa, Cheong, Hee Kiat, 06. May 2005 [WO2005092447 A2] Treatment of elemental mercury, Nuclear Fuels PLC, Chan, Henry, Boso 22. March 2005 [Wood 1974] Wood, J.M.: Biological Cycles for Toxic Elements in the Environment, Science, 15, 1043-1048, 1974 [ZERO Hg 2006] Zero Mercury working group, EU Mercury Surplus Management and Mercury-Use Restrictions in Measuring and Control Equipment, Report from the EEB Conference, October 2006



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12.3 Annex 3: Data base research - results

A systematic data base research was carried out to identify relevant literature for this study. The

following scientific data bases have been screened for relevant literature:

• Dialog© Dissertation Abstracts Online (35)

• Dialog© Enviroline (40)

• Dialog© Environmental Engineering Abstracts (64)

• Dialog© Environmental Sciences (File 76)

• Dialog© WasteInfo (110)

• Dialog© Federal Research in Progress (FEDRIP) (File 266)

• UFORDAT91: (Database of the Germany EPA on research projects)

• ULIDAT92 (Database of the Germany EPA on environmental literature)

For the search the following key words and their combinations have been used:

− mercury alone or in combination with

o metallic

o liquid

o elemental

− Storage

− Waste

− Disposal

− Underground

− Stabilization

− Solidification

− Immobilization

− Transport

− Encapsulation

− Treatment

In case of a large number of hits (e.g. “Mercury AND waste” resulted in 3383 hits) the search was

further refined by additional key words like “underground” or “immobilization”. Based on available

abstracts a pre-selection of relevant literature was made. Literature which is obviously not relevant

91 http://doku.uba.de/cgi-bin/g2kadis?WEB=JA&ADISDB=VH&SATZNR=83198 92 http://doku.uba.de/cgi-bin/g2kadis?WEB=JA&ADISDB=VH&SATZNR=83198






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for this study e.g. “Application of Ferric Sludge to immobilize leachable mercury in soils and

concrete” was excluded by this procedure. If a clear decision was not possible whether the literature

is relevant or not, a more detailed evaluation of the study was carried out. The studies were

evaluated with respect to their content and their bibliographic references.

In case of important publications or literature referring to stabilization and solidification technologies

the authors have been contacted to receive the latest information on the current status of the

technology. The literature research was focused on stabilization and solidification processes for

metallic mercury. Stabilization and solidification processes for mercury containing waste only have

been considered if there was an indication that the corresponding process could also be relevant for

the treatment of metallic mercury.

The following tables show an overview of the results of the different key word searches.



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Results of the search in the DialogWeb databases Dialog© Dissertation Abstracts Online (35), Dialog© Enviroline (40), Dialog©

Environmental Engineering Abstracts (64), Dialog© Environmental Sciences (File 76), Dialog© WasteInfo (110), Dialog© Federal Research

in Progress (FEDRIP) (File 266)

No. Mercury Waste Disposal Storage Underground Stabilization Solidification Immobilization Transport Hits Further refining with search-term

Hits

1 3383

Underground 14

2 3383

Geological 8

3 3383

Immobilization 19

4 3383

Storage 190

5 2401

Underground 14

6 2401

Geological 31

7 2401

Immobilization 27

8 2401

Storage 169

9 205 Underground 23 10 205 Geological 16 11 205 Immobilization 7 12 205 Storage 13 32 14 124 15 225 Underground 4 16 225 Geological 1 17 225 Immobilization 25 18 225 Storage 22 19 56 20 693 Underground 16 21 693 Geological 46 22 693 Immobilization 11 23 693 Storage 26



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Results of the search in all DialogWeb Databases within the category “Science and Technology

No. Metallic Elemental Liquid Mercury Hg Stabilization Solidification Immobilization Encapsulation Treatment Hits

1 0

2 0

3 0

4 0

5 31

6 0

7 0

8 0

9 0

10 0

11 7

12 2

13 5

14 0

15 64

16 0

17 0

18 0

19 0

20 0

21 0

22 2

23 0

24 0

25 2

26 0

27 2

28 0

29 0

30 5



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Results of the search in the UFORDAT database

No. Metallic Elemental Liquid Mercury Hg Stabilization Solidification Immobilization Encapsulation Treatment Hits 1 11 2 7 3 23 4 1 5 0 6 11 7 0 8 0 9 0 10 0 11 1 12 9 13 0 14 4 15 2 16 26 17 9 18 31 19 2 20 2 21 45 22 22 23 31 24 0 25 10 26 45 27 2 28 31 29 1

30 5



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Results of the search in the ULIDAT database

No Metallic Elemental Liquid Mercury Hg Stabilization Solidification Immobilization Encapsulation Treatment Hits 1 0 2 0 3 5 4 0 5 15 6 0 7 0 8 5 9 0 10 15 11 3 12 0 13 6 14 0 15 30 16 3 17 0 18 6 19 0 20 30 21 12 22 5 23 9 24 0 25 0 26 12 27 5 28 9 29 0 30 0



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No. Mercury Waste Disposal Storage Underground Stabilization Solidification Immobilization Transport Hits 1 49 2 6 3 0 4 1 5 1 6 0 7 5 8 13 Results of the search in the ULIDAT database

No. Mercury Waste Disposal Storage Underground Stabilization Solidification Immobilization Transport Hits 1 44 2 30 3 14 4 0 5 11 6 7 7 23 8 6631



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No. Metallic Elemental Liquid Mercury Hg Storage Permanent storage Hits

1 5

2 0

3 5

4 0

5 5

6 0

7 5

8 0

9 5

10 0

11 5

12 0

13 15

14 1

15 15

16 0



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Results of the search in the ULIDAT database

No. Metallic Elemental Liquid Mercury Hg Storage Permanent storage Hits

1 13

2 0

3 13

4 0

5 13

6 0

7 13

8 0

9 13

10 0

11 13

12 0

13 26

14 1

15 26

16 1



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12.4 Annex 4: Physico-chemical properties of metallic mercury and products resulting from different immobilisation technologies

The following list provides an overview on physic-chemical properties of metallic mercury as well as for relevant productions resulting from discussed immobilization technologies. This will be successively updated with new information received during the project running time.

Physico - chemical properties of the products received from different immobilisation techniques

Product CAS Density [g/cm³] Hg conc. [wt%] Solubility product KSP Compressive strength Solubility

Hg 7439-97-6 13.534 g/cm3 at 25°C [WHO 2003]

100 Not applicable Not applicable 5.6*10-2 mg/l at 25 °C [USEPA 2007]

2.9*10-2 mg/l [GRS 2008A] alpha HgS 1344-48-5 8.17 [Mindat]

8.1 [Webmin] 86 2.0*10-49 [US Wagh 2000]

2.0*10-54 [SPC 2009] No data available 9*10-23 g/l [US Wagh 2000]

7*10-21 g/l [SPC 2009]

beta HgS No data available 7.75 [Webmin] 86 2.0*10-53 [SPC 2009]

No data available No data available

HgS polymer Not applicable 3.1 [Mersade 2009] 33 [WM 2002]

Not applicable 57 N/mm2 [Mersade 2009] Not applicable

Hg OPC Not applicable No data available No data available Not applicable No data available Not applicable

Hg3(PO4)2 10451-12-4 1.8 [USWagh Singh] 75 7.9*10-46 [US Wagh 2000] ~ 30 MPa [US Wagh] 2.8*10-6 gl/l [US Wagh 2000]

HgHPO4 7782-66-3 1.8 [USWagh Singh] 67 7.9*10-14 [US Wagh 2000] ~ 30 MPa [US Wagh] 5.6*10-5 g/l [US Wagh 2000]

HgO 21908-53-2 11.1 [Inchem] 93 As mercury (II) hydroxide 3.6*10-26 g/l [SPC 2009]

No data available 1.5 g/l (saturated NaCl solution) [GRS 2008A]

HgCl2 10112-91-1 5.4 g/cm3 (25°C) [USEPA 2007]

74 No data available No data available 69 g/l (20°C) [USEPA 2007] 1,200 g/l (saturated NaCl solution)

[GRS 2008A] Hg2Cl2 7487-94-7 7.15 g/cm3 (19°C)

[USEPA 2007] 85 No data available No data available 2*10-3 g/l (20°C) [USEPA 2007]



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Physico - chemical properties of the products received from different immobilisation techniques

Product Leaching behaviour Volatility

decomposition/melting -/boiling point [°C]

Production temperature [°C] classification according to

Directive 67/548/EEC

Hg 250 mg/l (TCLP) [USEPA 2003]

vapour pressure: 0.3 Pa at 25°C [WHO 2003] 9,7-12,7 mg/kg (18°C) [Waste management 2001]

357 boiling point [USEPA 2007]

Not applicable

Repr.Cat.2; R61 T+; R26 T; R48/23 N; R50/53

alpha HgS

pH = 2: 0.001 mg/l pH = 8: 0.01 mg/l pH = 12: 0.1 mg/l [USEPA 2002a]

0,18-0,14 mg/kg (18°C ) [Waste management 2001]

386 melting point 584 boiling point [MSDS Kremer]

~ 130 [Brookhaven-Newmont 2003] No data available

beta HgS No data available No data available No data available No data available No data available

HgS polymer

0.009 – 0.039 mg/l (TCLP) [Brookhaven-Newmont 2003] pH = 2: 0.01 mg/l pH = 8: 30 mg/l pH = 12: 140 mg/l [USEPA 2002a]

0,41-0,74 mg/kg (18°C ) [Waste management 2001]

No data available 135 °C [USEPA 2002c] No data available

Hg OPC 7.7 – 51 mg/l [US Wagh 2000] No data available Not applicable No data available No data available

Hg3(PO4)2 No data available No data available No data available 80

[US Wagh Singh] No data available

HgHPO4 No data available No data available No data available 80

[US Wagh Singh] No data available

HgO 1500 mg/l [GRS 2008A] No data available 500 melting point [Inchem]

~ 300 °C [Ho Wi 1995] T+; R26/27/28 R33 N; R50/53

Cu-Hg Amalgam

pH = 2: 30 mg/l pH = 8: 0.2 mg/l pH = 12: 0.02 mg/l [USEPA 2002a]

No data available No data available No data available No data available



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12.5 Annex 5: Summary of technologies available in large-scale application

The following table provides an overview of the information received from the companies developing or running the process.

Sulphur stabilization according to

SAKAB / DELA Sulphur stabilization according to Bethlehem Apparatus

SPSS According to ADA Technology

SPSS according to DOE Cement encapsulation technique according to MERSADE

Process description and equipment Reactants technical sulphur and technical

elemental mercury which was received from the chlor-alkali industry and was not further processed before treatment

sulphur and elemental mercury; use of polyethylene to produce pellets was abandoned

elemental mercury, sulphur, polysulfide (calcium polysulphide, or sodium polysulphide) and sand

elemental mercury, sulphur polymer cement (SPC) and sodium sulphide

elemental mercury, elemental sulphur, polymeric sulphur, coarse and fine gravel, sand and CaCO3; the concrete block has a mercury content of 30%.

Process description

The process which is used by DELA is a sulphuring method capable of treating elemental mercury. The receiver tanks are filled with elemental sulphur (slight surplus) and mercury, and if needed, with additives. The inner atmosphere of the facility is filled with nitrogen. The process is carried out with 0.1 bar absolute, which is 0.9 bar below ambient pressure. The whole amount of the sulphur is added into the reaction vessel. Afterwards, the elemental mercury is continually added to the sulphur within approximately 15 to 20 minutes. The temperature is monitored and cooling of the exothermic reaction can be carried out. After about two hours the product can be removed from the vessel.

Elemental mercury is brought into contact with elemental sulphur, resulting in HgS (Cinnabar). The crystal formation is considered to be very sensitive to temperature and pressure changes.

It is a batch process consisting of combining elemental mercury with a proprietary sulphur mixture in a pug mill. Treatment of the liquid mercury was conducted by adding powdered sulphur to the pug mill, while a pre-weighed amount of mercury was poured into the mill. As the mill continues to mix and the reaction takes place, additional chemicals are added. While the processing of mercury in the pug mill is performed without the addition of heat, the reaction of mercury with sulphur is exothermic at room temperature, and the mixture increases in temperature during processing.

This process is a two stage single vessel (vertical mixer/dryer) batch process that results in mercuric sulphide stabilised in a sulphur polymer matrix. In the first step, mercury is reacted with powdered sulphur polymer cement and additives to form a stable mercury sulphide compound. Next, the chemically stabilized mixture is melted in a sulphur polymer matrix, mixed and cooled to form a monolithic solid waste form in which the stabilized mercury particles are microencapsulated within a sulphur polymer matrix [USEPA 2002c].

The stabilization takes place in a two-step process. In the first step the elemental mercury is stabilized with sulphur to meta-cinnabar with a planetary ball mill. In a second step this meta-cinnabar is incorporated in a polymeric S-concrete matrix, composed of gravel, sand, filler, elemental sulphur and modified sulphur.



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Sulphur stabilization according to SAKAB / DELA

Sulphur stabilization according to Bethlehem Apparatus



Process conditions

Most of the tests so far have been performed without heating. Additional heating of the HgS at the end of the process (~250 °C) leads to good process results. It is foreseen that the pilot-scale facility will have a heating option and that the whole process will work at a temperature between 100 and 200°C.

No information available No further information than that provided in the process description could be provided for the process conditions.

The process is heated in the second step to a temperature of 135 °C. Oxidation of mercury does not occur as the mercury has already been stabilized with sulphur in the first step.

The concrete matrix is prepared at 140°C and at room temperature

Throughput Currently, a laboratory scale facility with a reaction volume of about 5 liters exists. The process is carried out in batches with a processing time of about 120 minutes (90-240 min) per batch.

Early runs have been batch sizes of about 22.5kg of mercury. The last few runs have been in the range of 90kg. It was decided to work with 45kg batches due to easy processability and possible reruns in 24 hour periods. It is planned to attach 10 or 20 units to a single mercury feed. At such a time, the operating system will be capable of processing 500 to 1000kg of mercury per day.

A batch size of 50kg has already been used which would result in a daily throughput of 250 kg/day..A scale up to 375kg/batch is considered possible by the vendor. In this case the yearly throughput is expected to be 1,000t/year if five mixers are used in parallel. All together, 10 metric tonnes of radioactive mercury has already been stabilized by the Company.

A 1 ft3 (0.03 m3) mixer has already been realized, capable of stabilizing about 20 kg mercury per shift. Assumptions have been provided for the following mixer sizes. 10 m3 mixers could stabilize about 7,600 kg/day, 1.8 m3 mixers have a daily throughput of 1,400 kg and 0.28 m3 mixers have a daily throughput of 270 kg/day. All these assumptions are based on an average batch time of twelve hours and two shifts per day.

The facility is still only on a small scale, producing 6 kg of a final product per batch and a throughput of 4 kg/



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Emissions Due to the use of a vacuum (100 mbar) in the reaction vessel, a filter system and an activated carbon filter, the Hg-emissions should be close to zero (no measurement results available).

The process takes place in a sealed container and no emissions should occur. This container is capable of holding 1-10 bar pressure at 530°C.

Off-gas is passed through a High Efficiency Particulate Airfilter (HEPA), and then passed through a sulphur-impregnated carbon filter. Mercury vapour concentration above the plug mill is below the threshold limit value (TLV) of 50 mg/m3.

The process produces some mercury vapour, so a ventilation system is required to filter out the vapour. Since the process is heated (135°C), heat exchangers are included in the ventilation system. A liquid nitrogen cryogenic trap condenses the mercury vapour and it is recycled back into the process. Trials have shown that 99.7 % of the mercury is retained in the product.

Due to the laboratory scale, emissions can occur during the milling of sulphur and liquid mercury

Energy consumption

The energy consumption has not been evaluated. A three phase electrical power is necessary.

No information is provided for energy consumption.

No information could be provided for energy consumption.

No information could be provided for the energy consumption of the process.

No information could be provided for the energy consumption of the process.

Expected operational costs

According to estimations, the costs will be about €2,000/tonne, packaging, transport and final disposal underground of the produced HgS included.

The stabilization costs are about 5-6 $ / pound which are about 8,000 to 9,000 €/tonne of elemental mercury.

No information could be provided for operational costs.

No information could be provided for the expected operational costs of the process. From a different study [USEPA 2003] an estimated full scale cost is provided with about 2,000 €/t.

The costs for the stabilization of metallic mercury at a full scale application is estimated to be between 15,000 and 17,000 €/tonne metallic mercury.

Patent DE 10 2008 006 A1, EP 2072 467, EP2072 468 A2

It is expected that the official patent number will be available by beginning of February 2010.

No information could be provided for implementation costs.

No information could be provided for the implementation costs of the process.

No information could be provided for the implementation costs of the process.

Implementation time

It is envisaged to install a pilot-scale facility with a volume of 500 l and a capacity of about three tonnes per day (three shifts) by January 2010.

No information is provided for the implementation time.

US 6,403,044 B1 US 6,399,849 P200930672


No information is provided for implementation costs.

About €700,000 for a facility to stabilize 300t per year.

No information could be provided for implementation time.

No information could be provided for the implementation time of the process.

No information could be provided for the implementation time of the process.



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Resulting Product Final product The final product is cinnabar (red).

No elemental mercury (silver) or meta-cinnabar (black) could be detected in an X-ray structure analyses. It is a fine powder with a density of 2.5-3.0g/cm3. The single crystals have a density of about 8.2g/cm3.

The product is a powder with the bulk of the material of approximately 50 mesh size. It easily breaks down into less than 250 mesh size. When removed from the reaction chamber there are also clumps with a diameter of approximately 1cm. The product of the treatment is cinnabar and was compared with data on file for naturally occurring cinnabar using x-ray diffraction. The results show complete similarity. No elemental mercury could be detected when a pellet was analysed in computer aided tomography.

The final product is a granular waste, which consist of HgS and sulphur polymer cement, and can be poured into drums.

The product is a monolithic structure with a mercury content of 33%, 65% sulphur polymer cement and 2% sodium sulphide.

The final product is prepared in the form of a monolithic material of 16x16x4 cm. The shape of the ashlars can also be changed.

Product stability

The leaching limit values from test runs under stable conditions range between 0.01 mg/kg and 0.04 mg/kg with an average value of 0.026 mg Hg/kg (EN12457/1-4).. Thermal information of the product shows that it is stable up to 350 °C. In its current state, the product of the laboratory-scale facility could be disposed of on hazardous and non-hazardous landfills according to the WAC Decision 2003/33/EC (hazardous landfills 0.2 mg/l (2 mg/kg) and non-hazardous 0.02 mg/l (0.2 mg/kg)).

The leaching values which were measured had an average of 0.0143 mg/kg (EPA TCLP)

For this product, only leaching values (TCLP) at different pH values are available. The lowest leaching behaviour can be achieved at a pH value of 2 with 0.001 mg/l. In a more or less linear trend the leaching value reaches a maximum of ~0.1 mg/l at pH value of 12.

In order to determine leaching behavior, the TCLP process was used for different pH values. The results have been in a range of 0.005 and 45 mg/l. The reason for this wide range of leaching behaviour was not the pH dependency but a small amount of elemental mercury which was still excising in the final product. It is believed that this inconsistency can be avoided by changing the processing methodology (e.g. mixing method, introduction of waste material) but no further work has been done so far in this field.

The concrete blocks have a water absorption by capillary of 0.07 g/cm2. The water permeability under low pressure (RILEM) shows no water absorption under low pressure. To determine the leaching behaviour the TCLP procedure was used and the average value was ~0,102mg/l. The concrete block shows very good mechanical properties with a comprehensive strength of 57.2 ± 44 N/mm2 and a flexural strength of 8.5 ± 1.17 N/mm2.

Volume and weight

The volume of the cinnabar powder is about six times the

The powder density is about 5g/cm3.

The weight of the material increases by about 100 % and

The Volume of the product is about 15-18 times the original

The density of the concrete block is about 3.1-3.2 g/cm3.



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volume of elemental mercury. The weight is increased by about 16%.

the volume increases by about 2200 %.

elemental mercury whereas the weight increased by a factor of 3.

And has a total porosity of ~2% and a closed porosity of ~0.6%. The mercury loaded concrete blocks have a higher density and lower pore volume than a mercury free reference. The reason is that it is expected that meta-cinnabar particles fill interparticle interstices and the higher size pores which exist in the initial S-concrete. The volume of the product has approximately 13 times more volume than the elemental mercury and the weight is increased by a factor of 3.

Emissions from the product

Mercury vapour tests have been performed. However, no mercury vapour could be detected (LOD=0.003 mg/m3). If additives are introduced, the product form can be changed into a granular form (1-4mm). Thus, dust emissions could be further reduced and handling facilitated.

No emissions from the product (except leaching) are known.




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Contact details:

BiPRO GmbH Grauertstr. 12

81545 Munich, Germany Phone: +49-89-18979050

Fax: +49-89-18979052 URL: http://www.bipro.de

http://www.bipro.de/