EUROFER believes that the restriction of the use of mercury in the society in general, thereby preventing it from ending up in various waste streams such as steel scrap, is the best way of lowering the emissions of mercury from steel plants.
EUROFER welcomes the opportunity to comment on the development of an EU Mercury Strategy. Since the steel industry is neither producing, using nor recycling mercury we have chosen not to answer the specific questions posed in the consultation document but would instead like to present our general comments on mercury in relation to the steel industry.
Some of the data in the consultation document are taken from the European Pollutant Emission Register and even though this might be the best source of information at this moment it is important to remember that the inventory has only been performed once and can only be considered as a snap-shot of the current situation. Furthermore, the data is a mix of estimated, measured and calculated data and many years of reporting are needed before a clear picture will be available.
Steel making
The steel industry does not use mercury in any of its processes and it is important to know that mercury is an unwanted accompanying element and not a substance desired in the steel making process. Mercury enters the steel plant via the raw materials, mainly steel scrap, coal and iron ore. Scrap is generally considered to be the main source of mercury even though the amounts can vary substantially depending of the origin of the scrap. The scrap with the largest mercury content seems to be shredded scrap and scrap from electric and electronic equipment where the mercury originates from switches and relays.
In the steel making process the mercury is completely evaporated and only insignificant trace amounts can be found in the finished steel product. Most of the evaporated mercury is captured by filters and ends up in the filter dust which is treated accordingly.
It is important to realize that while fulfilling the EU objective of increased recycling, as an important step towards sustainable development, some undesired effects, like emissions of mercury, may be unavoidable.
Coke making
Coke making requires high quality coal with specific requirement concerning e.g. strength and density which normally have a very low mercury content limiting therefore releases of mercury from the coke making plant.
Laboratory equipment used in the steel industry does in some cases contain mercury but the companies are continuously working on their phase-out as other alternatives become available.
EUROFER believes that the restriction of the use of mercury in the society in general, thereby preventing it from ending up in various waste streams such as steel scrap, is the best way of lowering the emissions of mercury from steel plants.
In the next coming years we will also see the result of the full implementation of the directives on end of life vehicles and waste from electric and electronic equipment which EUROFER is convinced will improve the situation considerably. Implementation of other environmental legislation such as the IPPC directive and the air quality daughter directives will also make important contributions. EUROFER therefore recommends the future strategy to focus on the phase-out of the use of mercury in society and the evaluation of the implementation of the above mentioned directives.