[] TL: DUMPING BY ANOTHER NAME -- THE RECYCLING OF IMPORTED HAZARDOUS WASTES INBILBAO, SPAIN BY THE ASER COMPANY. SO: Greenpeace International (GP) DT: June 26, 1991 Keywords: toxics europe waste disposal hazardous waste trade spain business problems reports gp / [part 1 of 2] A Greenpeace Report 26 June 1991 Written by: Jim Puckett Local research: Jon Ugarte Contributors: Anita Fokkema Peter Jorgensen Juantxo Lopez de Uralde Meg Huby Ruth Stringer Ruth Swindlehurst Jon Ugarte Special Assistance: Lesley Hunter Jos Meijer Lisa Lark Photos: Bob Edwards Originally Printed on chlorine-free paper by: Grafisch Centrum Amsterdam TABLE OF CONTENTS ABSTRACT 1 INTRODUCTION 3 PART I - BILBAO--THE IDEAL EUROPEAN DUMPING GROUND 4 CONTAMINATION IN BILBAO 6 Cancer 6 Occupational Tumours 6 Atmospheric Contamination 7 Urban and Industrial Solid Wastes 7 The Ria Del Nervion 8 Soil and Sediment Contamination 10 WASTE IMPORTS 11 PART II - ASER S.A. 14 ASER - An Introduction 14 ASER - "The Best" 16 Promises, Promises 17 What Is Wrong With This Picture? 17 THE WASTE - Where it comes from 18 Sources 18 Staalvalsevaerket -- One Generator 18 THE WASTE - What it is 23 "Steel Dust" 23 Organic Chemicals in "Steel Dust" 25 Dioxins in Steel Dust 25 Badische Stahlwerke in Kehl 26 THE WAELZ PROCESS - What ASER does with the waste 28 THE NEW WASTE - What it is 29 Heavy Metals 29 Lead 31 Cadmium 32 Dioxins and Furans 34 The Fate of Dioxins in the Waelz process 34 Toxicity of Dioxin 36 THE NEW WASTE - Where it goes 36 Water Discharges 36 Air Emissions 38 Slag 39 Leachate Test Tricks 40 Where the Slag goes 42 THE MONEY 44 Imported Profits 44 The Brokers 45 HAZARDOUS WASTE TRADE AND THE LAW 47 The Path of Least Resistance 47 Pressures to Export 47 Existing Waste Trade "Control" Legislation 48 Recycling Loopholes 48 "Non-Ferrous Metals" 50 The European Commission's Proposed Regulation 51 The Single European Market for Waste - 1993 51 Spain 52 Spain in the Paris and Oslo Conventions and North Sea Conference 52 CONCLUSION 54 GREENPEACE RECOMMENDATIONS 57 ABSTRACT Bilbao is a city located in the Basque country of northern Spain. For almost a century it has suffered devastating environmental abuse. During those years, iron, chemical and shipbuilding related industries have wreaked havoc on local ecosystems. The estuary known as Ria del Nervion is virtually dead. Cancer rates in the area are notably high. Soil and sediment contamination are so high as to legally qualify vast areas of the physical environment as hazardous waste. Out of this ferment, a new industry has recently arisen. It is an industry which depends largely on imported hazardous wastes, particularly metals scraps, slags and filter dusts. Much of this material is of the same type as wastes which also flow from rich northern countries to the Third World. The generators of these hazardous wastes pay brokers to take them away. The brokers in turn pay the disposers or recyclers to take them. The disparity in comparative disposal costs globally and within Europe causes wastes to move from rich to poor communities. Currently within the European Community, and in all heavily industrialised countries, efforts to exempt recycled hazardous wastes from hazardous waste transport prohibitions and controls are well under way. Prodded by a substantial recycler and waste generator lobby, politicians are seeking ways to make it easier to transport waste to those facilities which claim they are involved in forms of recycling or "further use". Such efforts undermine the desired goals of minimising waste transport, national self-sufficiency in waste management, and most importantly, waste prevention. The recycling of hazardous waste is not waste prevention. It is not clean production. Rather, due to the hazardous materials and processes involved, it can be a very dirty form of hazardous waste dumping. As long as waste generators can sell off their hazardous waste problems to poorer, already contaminated communities such as Bilbao, they will never have any incentive to institute clean production methods and prevent hazardous waste from being produced in the first place. Greenpeace chose the ASER company in Bilbao as a case study because it is considered one of the best examples of recycling. We reasoned that if the best is operating without adequate regard for the environment, then certainly the whole recycling industry is deserving of greater scrutiny and regulation. The ASER hazardous waste recycling company in Bilbao has been given an award by the European Commission for environmental action. From its founding, ASER was hailed as part of the solution to Bilbao's degraded environment. But this report reveals that ASER is actually just one more addition to the long list of polluters and dumpers in Bilbao. And the majority of ASER's pollution source comes neither from its area of economic influence or environmental impact - it comes from abroad. ASER releases many thousands of tonnes of heavy metals in to the environment each year. The company has erroneously claimed that the 60,000 tonnes of slags it dumps on the surrounding community each year is inert. It seems little concerned over the fact that it receives and emits an estimated 200 grammes of extremely toxic dioxin each year. Greenpeace urges all countries that generate hazardous waste to prohibit its export. Likewise the Basque Community is urged to demand that the Spanish central Government take action to ban waste imports. Regulators truly concerned with our growing hazardous waste crisis, will seek to prohibit all forms of hazardous waste trade rather than seek means to facilitate it. Greenpeace recommends that: 1. Spain immediately cease importation of all hazardous, including nuclear wastes. (DON'T DUMP ON SPAIN) 2. The EC immediately ban the export of all hazardous, including nuclear wastes to non-EC destinations. (COMMUNITY SELF SUFFICIENCY) 3. The OECD countries immediately ban the export of all hazardous, including nuclear wastes to all non-OECD destinations. (BAN THIRD WORLD DUMPING) 4. All OECD countries achieve national self- sufficiency (no import or export of hazardous, including nuclear wastes) within 5 years. (BAN HAZARDOUS WASTE TRADE) 5. The European Commission and the OECD Environment Committee conduct a complete environmental audit of all waste recycling technologies which process wastes generated in member countries. (INVESTIGATE HAZARDS OF RECYCLING NOW) 6. No legislative distinctions be allowed between hazardous wastes bound for "further use" and hazardous wastes bound for "final disposal" (CLOSE ALL RECYCLING LOOPHOLES NOW) 7. The Treaty of Rome be amended at the earliest opportunity to establish that "free trade" considerations are always subservient to environmental considerations, and that hazardous wastes are not considered as either a commodity or a service. (HAZARDOUS WASTE IS NO GOOD) 8. Legislation establishing incentives and requirements for the implementation of clean production methods (non-hazardous products, non-hazardous inputs, and non-hazardous processes, producing no hazardous waste) be enacted as soon as possible. (NO TIME TO WASTE, CLEAN PRODUCTION NOW) INTRODUCTION Today, in the wake of numerous hazardous waste trade scandals of the late 1980s, Greenpeace has observed that an increasing amount of hazardous waste traded across national borders, goes to facilities that claim to be recycling it. On the face of it, the process of extracting usable materials from hazardous wastes sounds like an activity preferable to dumping the material in a landfill or burning it in an incinerator. Indeed this would likely be true were these the only choices left us. However, what is forgotten is that recycling is very often used as a pretext for making profits from waste disposal. It is little understand that almost any waste can be claimed to be of "use" to the poorest segments of our society, and that recycling proposals tend to target poor communities. It is overlooked that hazardous waste recycling can be a very dirty, marginal business with little regard for environmental or occupational health. Many have confused recycling with waste prevention and fail to realise that when you recycle a hazard you are usually left with a hazard - either by creating hazardous products or new hazardous wastes. Often these recycling processes are not allowed or would be more highly regulated in the same countries where the waste is generated. Therefore, these types of marginal recycling operations tend to concentrate in poorer global communities where labour is cheap and environmental standards and enforcement is weak. Within the European context, southern and eastern Europe are now getting the "development opportunity" to re-use the industrial waste of the north and west. Within these "second- class" European countries, lie communities that by their existing environmental and economic degradation, are most vulnerable to more abuse in the form of poison-tainted profit. One such community is that of Bilbao in Spain. Meanwhile, in political arenas, such as the institutions of the European Community, the United States Congress and within the Organisation of Economic Co-operation and Development (OECD), efforts are well under way to de-regulate the hazardous waste recycling trade. A debate has begun on whether to exempt all or some recycled waste streams from the legislation governing the transboundary movement of wastes. Those supporting exemptions echo the huge metals industry lobby which claims that recycling is always better for the environment and that it must be made as easy and as free from regulation as possible. They claim that in order to make it more economical, it is often necessary to transport wastes long distances. One of the most important waste streams for which the fight for exemption rages is the so-called "non-ferrous metals" waste. Many industrial lobbyists are claiming that this category of waste should not even be considered hazardous. Greenpeace feels that its time to shine a light on all hazardous waste recycling operations, to look past the "green" rhetoric of recycling and see what really happens. For the purposes of illustration, we have chosen one hazardous waste, one recycler, located in one community. PART I BILBAO--THE IDEAL EUROPEAN DUMPING GROUND Bilbao is a densely populated port city on the northern coast of the Basque region of Spain (see map). At the end of the nineteenth century the area featured quiet pastoral farmland and fishing villages. From the beginning of this century, however, the area soon experienced dramatic industrialisation; primarily along the banks of the Bilbao estuary -the Ria del Nervion. This industrialisation has largely been due to the smelting and refining of the vast iron ore deposits in the nearby Triano mountain range. The population of the city grew steadily until 1950, and then in the next 35 years more than doubled with the lure of jobs made possible by the rapid uncontrolled growth of naval shipyards, petro-chemical industries and a coal-fired power plant. Today Bilbao qualifies as one of the most polluted city regions in all of western Europe. Cancer rates are extremely high. The Ria del Nervion estuary is biologically almost completely dead with virtually no treatment for the continual dumping and leaching of industrial and human wastes. Not one river is fishable, swimmable or drinkable. Hundreds of dumpsites, some right on the banks of the Ria del Nervion, leach hazardous contaminants into the waterways and groundwater. Every year 14,340 tonnes of sulphur dioxide are released into the atmosphere. And the atmospheric pollution often gets trapped between the mountains and the sea, making the concentrations rise to extremely dangerous levels. Because of the conflict over Basque nationalism, and the rise in unemployment in the 1980s, environmental issues have never been a top priority for citizens in Bilbao. Many people have lost all hope of eliminating the disastrous pollution. Recently a new generation of industry has settled in the region and threatens to add even more pollution sources. This industry relies primarily on the importation of wastes from the rest of Europe. The community of Bilbao is becoming the metals scrap melting pot for all of Europe. This industry includes dumpsites as well as recycling operations, or a combination of both. Every day tonnes of scrap computers, cables, aluminium slags, dusts from pollution control devices, and so on, are imported by the boat-load and trucked to dirty processing centres, particularly in the Erandio-AsŁa neighbourhood. Pollution is not a new phenomenon for the Bilbao community and heavy metal contamination has existed there since the first iron smelters and foundries. The background levels of historical pollution provide a spiteful mask for the present-day contamination. Were there any attempt to prosecute polluters by sampling local sediments or groundwater, new industry could simply claim that the findings are contamination echoes of the past. CONTAMINATION IN BILBAO A search of available scientific literature on the contamination of the Bilbao area reveals a remarkable lack of published data. The sources that are available however are alarming, and the following excerpts reveal contamination in the workplace, the atmosphere, on land, water and in the human body. Cancer In May, 1990 on the initiative of the European Office of the World Health Organization (WHO), a report was published (hereafter referred to as the "WHO report") on health conditions in the towns on the Left Bank of the Bilbao estuary. The investigation, carried out by the Health and Consumption Department of the Basque Government and within the "Healthy Cities" programme of the WHO, is based on information from 1986 and 1987, and covers the five major towns of the Left Bank. These are the communities of Barakaldo, Sestao, Portugalete, Santurtzi and Trapaga, with a total population of 276,154 inhabitants (23% of the Basque country). The study establishes cancer as the first cause of death among men and as the second among women. It links the cases of cancer that cause death firstly to the conditions of the environment in the workplace, and secondly to environmental conditions in general. Tumorous diseases affect this Left Bank population in a proportion significantly higher than for the average population of the Autonomous Basque Community. A comparison of mortality rates in 1986 on the Left Bank with those of the Autonomous Community reveals that for the men on the Left Bank there is a rate of 271.85 per 100,000 inhabitants, whereas the Autonomous Community shows a much lower rate of 236.44 per 100,000. The total number of deaths of cancer in the region of investigation was 688 in 1986. Of these 438 were men (63.66%) and 259 women (36.34%). Among the men, cancer of the trachea, the bronchial tubes and the lungs prevails, followed by cancer of the stomach and bladder. Among the women, there is a major incidence of breast cancer with one woman in four living in the region contracting the disease (26.8%), followed by cancer of the womb and the stomach and lung. Occupational Tumours The study specifically looked at the health of the working population, choosing 19 big companies of the region with a total of 1088 workers. Not one of the companies investigated recognised a chemical risk on its premises. Nevertheless, the investigation established chemical risk by exposure to inert dust, dust of pneumoconiotic activity, metal fumes and vapours and substances with dermatological effects. The report makes a strong hypothesis that the working environment is the primary cause of mortality from tumours. The percentage of men that have died from cancer is considerably higher than that of women. Overall, the first cause of worker death among the men is from tumours, and the second cause is diseases of the circulatory system. Among women it is the other way around. Although the WHO report does not give the names of the companies investigated, since it deals with the most important companies of the region, we can safely assume that the majority of these are metallurgical in nature, with the number of men on the work floor being considerably higher than the number of women. Atmospheric Contamination The Left Bank has high levels of atmospheric pollution, coming primarily from industrial sources. The WHO report specifies that the industries located in the urban continuum of the Left Bank emit 14,340 tonnes per year of SO2, 9,635 tonnes of particles in suspension, 8,621 tonnes of carbon monoxide, and 2,091 tonnes of hydrocarbons. Of this volume, 97% of the SO2 and 97.1% of the particles in suspension is emitted by industry. Urban and Industrial Solid Wastes Urban waste currently totals around 600,000 tonnes per year and was dumped primarily on the Argalario dumpsite until 1988, and to the Artigas dump currently. According to the Council of Urbanism, 12.6 million tonnes of industrial waste is produced annually in the Basque provinces alone. Virtually all of this material is disposed of without any control whatsoever. In fact the government has counted an estimated 467 uncontrolled dumpsites in the Basque country. There are industrial dump sites next to population centres and close to river beds. Many of these dumps have been shown to be contaminating Bilbao area aquifers. In 1986 the total volume of all waste generated annually in the region was calculated to be: 600,000 tonnes-- urban waste 2,500,000 tonnes-- agricultural waste 12,500,000 tonnes-- industrial waste 15,600,000 tonnes TOTAL WASTE GENERATED The WHO report states: "the toxic and hazardous wastes generated by the industries of the zone that are found accumulated in dumpsites, leak into water sources and, given their composition, can constitute a grave risk to human health." The Ria Del Nervion - A Poisoned Estuary Since the beginning of regional industrialisation, the Ria del Nervion estuary has been the sewer for the industrial basins of Nervion, Ibaizabal, Kadagua and the tributary industrialised waterways of the AsŁa, Gobelas and Casta¤os rivers. Today there are still no sewage treatment plants, virtually no industrial pre-treatment and most of the untreated urban sewage and industrial discharges still go directly via pipelines into the rivers, estuary and sea. It is estimated that industrial discharges alone total about 500,000 cubic metres per day. A zero dissolved oxygen figure in parts of the Ria has been confirmed in various studies. Nitrogen wastes from industrial discharges consume vast amounts of oxygen, making the Ria anaerobic. At the moment the Ria is in itself a source of toxic atmospheric pollution, as methane and hydrogen sulphide gases emanating from anaerobic bacterial digestion, bubble regularly to the surface. The Casta¤os River has been known to catch fire. The Ria suffers from extreme acidity - so much so that it presents a problem in corroding the hulls of ships. An estimated 400 tonnes of acid wastes are dumped daily, and in combination with acid rain, have caused the heavy metals deposited in sediments or leached into the Ria from surrounding dumping sites to dissolve the toxic heavy metals into solution. Once dissolved they become biologically available and toxic to organisms. The sampling carried out by Greenpeace scientists at the organisation's Queen Mary and Westfield College unit, discussed in detail below, has found massive bottom sediment contamination by heavy metals and PAHs. About 80 tonnes of iron wastes containing heavy metals are dumped into the estuary each day. The metals are precipitated in the form of hydroxides. The sulphurous gases combined with iron, create ferrous salts which colour the water and sediments black. Levels of ammonia, phenols and cyanides are also elevated. Mercury contamination is detected in the bottom sediments as well as high levels of the extremely persistent, bioaccumulative and toxic pesticide lindane. Suspended solids from upriver mining activities as well as industrial discharges are also characteristic of the water quality. After this description of the Ria's chemical soup, it should not be a surprise that virtually all animal life in the estuary has been eliminated. Moreover, the anaerobic condition present in the Ria can facilitate the outgrowth of pathogenic faecal bacteria such as salmonella. Thus, estuarine waters, besides damaging human health by their own atmospheric emissions, present a bacteriological danger at all times to those who may come in contact with the "water". All of this effluvia then washes toward the coastal beaches of Arena, Ereaga and Plencia, making the bathing there extremely unhealthy. A panel of experts attending II Congreso Mundial Vasco and discussing the biological environment, concluded that the Ria del Nervion was "almost in a state of no-return". Soil and Sediment Contamination Some studies have shown elevated levels of heavy metals in sediments, water and biota in the outer harbour and beyond but to date, no studies have been published which give levels for the Ria itself or for soils around where much of the industry is situated. Greenpeace decided to sample sediments of the estuary, the AsŁa River, and the soil in AsŁa, where much of the recycling industry is situated. Heavy metals and PAH analysis was coordinated by the Greenpeace Queen Mary and Westfield College unit. The results of the study have been alarming and reveal that much of the soil around AsŁa, as well as sediments in the AsŁa and Ria del Nervion, would be considered hazardous wastes in countries like the Netherlands (see Annex I). Point source contamination of the AsŁa river by heavy metals and PAHs has obviously occurred, as levels of these contaminants in sediments are lowest (with the exception of chromium in sample A1) upriver of samples A2 and A3 (Tables 1 & 5, Annex I). The report stated that it was likely that these extremely high levels near the centre of AsŁa were the result of recent and heavy industrial point source discharges. The levels of heavy metals in the AsŁa River area adjacent to the industrial centre are astronomical. The levels of zinc, lead and cadmium are especially high in the sediment sample taken nearest the ASER plant (sample #2), although it is impossible to conclude that ASER is the primary source. Elevated levels of zinc, lead and cadmium are also found in high levels near the unloading docks for ASER's steel dust (sample #6). The study concluded that the city and environs of Bilbao are suffering from levels of contamination that are "alarmingly high" with an "obvious health risk" to the local population. WASTE IMPORTS The first time Bilbao became internationally recognised as a receiving community for hazardous wastes was in 1989 when the USA newspaper the Saint Louis Post-Dispatch discovered illegal shipments of lead-contaminated soils going to Bilbao for further processing by Ercosa and ASER. The waste broker, Triangle Metallurgical of Granite City, Illinois, had not bothered to wait for consent for the export from the US Environmental Protection Agency (EPA). The EPA had not given consent because they in turn had received no consent from the Spanish authorities for the shipment. The shipment was transported in violation of US law and arrived in Bilbao with no mention of hazard or contamination. The representative of Ercosa, Jose Antonio Boveda, said that he did not need permission from the Spanish government to receive hazardous waste. He told the journalist that in his opinion the load was not important and said: "You Americans, with your Environmental Protection Agency, you call everything toxic." The EPA subsequently fined Triangle Metallurgical $51,750 dollars for the violation. Reliable data on total waste importation into the region is difficult to obtain. Although probably an underestimation, the following figures have been obtained for 1989: TABLE I TOTAL KNOWN HAZARDOUS WASTE IMPORTS INTO THE BASQUE COUNTRY IN 1989 811,408 tonnes-- scrap iron waste 250,000 tonnes-- waste for extraction of precious metals 150,000 tonnes-- industrial sludges 50,000 tonnes-- pyrite ashes from Portugal 150,000 tonnes-- by-products from copper production 100,000 tonnes-- aluminum salt slags and scrap to Remetal 70,000 tonnes-- steel dust for ASER 1,581,408 tonnes TOTAL known waste imports (1989) TABLE II SOME WASTE IMPORTERS IN THE BILBAO REGION AND PRIMARY ACTIVITY ASER Steel dust recycling HIDRONOR Hazardous waste treatment and dumping in old mine. ORISPANIA Gold, silver, platinum, palladium recovery from computer scrap INDUMETAL Recovery of ferrous, non-ferrous metals and precious metals INDUMETAL RECYCLING Buying, selling and recycling of non-ferrous metals steel scrap SADER Hazardous waste collection and treatment METALQUIMICA DEL NERVION Metals extraction RONTEALDE Production of sulphuric acid from pyrite waste REMETAL Recycling of aluminum scrap and slags HALLEY METALS IBERICA Commerce in metals ECOSA Copper recycling PART II - ASER S.A. ASER - An Introduction In June 1989 Greenpeace blockaded a ship in Rotterdam Harbour carrying 1,000 tonnes of "zinc residues" bound for Sao Paulo, Brazil. At the same time Greenpeace discovered that a similar cargo had already left for Brazil just days before. Analysis of the material revealed high levels of toxic heavy metals. Further investigation showed that the material was very likely also contaminated with dioxins. After notifying Brazilian authorities of the impending arrival of the waste shipment, they discovered that the recycling plant due to receive the material did not have a licence to import hazardous waste. In fact, the plant was in continual violation of environmental and occupational health regulations. Many workers complained of illnesses and one death was even reported due to poor health conditions at the plant. The Brazilian authorities ordered the ship to return to Rotterdam without unloading. For many months the Dutch authorities did not know what to do with the returned waste, since the generating countries of Belgium, Denmark and Italy refused to take the wastes back. Finally after 15 months of deliberation, the toxic cargo was shipped to the ASER recycling plant in Bilbao, Spain. The ASER plant in Bilbao yearly receives 80,000 tonnes of this same "zinc oxide residue" for recycling. Much of it still comes from the very same sources that shipped it to Brazil in 1989. It was interesting to Greenpeace that a plant in Bilbao, Spain, seemed to be competing with the Third World for hazardous waste. We decided to investigate further. Greenpeace does not claim that the ASER plant in Bilbao is one of the worst polluters in Europe or even in Bilbao. It is not: we chose this plant as a case study because it is considered one of the best from that point of view. We reasoned, that if the best is operating without adequate regard for the environment, then certainly the whole recycling industry is deserving of greater scrutiny and regulation. ASER - "The Best" In March 1988, the ASER plant near Bilbao, Spain, was awarded an Environmental Action award by the European Commission as one of the 20 best businesses in the European Community (EC) with respect to the environment. The award was given for "the conservation of energy and the reduction of emissions of steel dusts, thus bettering the environment". La CompanĄa Industrial AsŁa-Erandio S.A., known commonly as ASER, is situated in the AsŁa valley on the banks of the AsŁa River in the township of Erandio, about four kilometres outside of Bilbao. The AsŁa River is a small stream whose water can show four or five colours in a day. ASER was founded on 10 May 1985 on an 18,000 square metre piece of land on the site and buildings of Induquimica - an old recycling foundry. ASER began operations in May 1987. It was established using ZUR (Zona de Urgente Reindustrializaci˘n) of the Nervi˘n area - a programme of economic assistance provided for the community. All of ASER's shares are in the possession of just three parties: Berzelius Umwelt-Service, Metalquimica del Nervion of Erandio, and Industrias Reunidas Minero-Metallurgicas (Indumetal) of AsŁa. ASER is majority owned (66%, up from 48% as of July 1990) by Berzelius Umwelt-Service the environmental arm of Germany's metals giant, Metallgesselschaft, which in turn is 30% owned by Daimler Benz (Mercedes Benz cars). ASER is part of the Rontealde Group, a holding company that consists of factories primarily dedicated to the treatment of metals waste. The Directors and President of ASER hold much influence in other companies of the group, particularly with Rontealde, Metalquimica, Indumetal Recycling, Cometal, Remetal, Halley Metals Iberica and Orispania, all of which are located near the Bilbao Estuary. Most of these companies are also heavy polluters particularly, of pyrite wastes and metals scrap residues. ASER is one of only three waste management firms in the Autonomous Basque Community that has been granted provisional authorisation as a waste management firm. From the beginning, Nestor Goikoetxea, an industrial engineer, has appeared as leader and spokesperson for the company in his capacity as General Manager. Goikoetxea was formerly the Vice-Director for the Environment of the Autonomous Basque Community. ASER employs 45 people. Promises, Promises From its founding, ASER has utilised an ambitious, well-designed public relations programme to sell its worth and goodwill to the local community. Numerous articles appeared immediately, touting the plant as a clean technology capable of resolving much of the endemic environmental problems of the region while producing no emissions - only harmless inert slag wastes. The articles cited the need to eliminate the massive amount of steel dust generated in northern Spain, which has at least a dozen large steel works and about 200 smaller ones, producing an estimated 80,000 tonnes of dusts per year. Currently, by all accounts, this material is simply dumped in piles near steel works to avoid higher production costs. Everything seemed to point to the need for this installation and it was logical at first that the public welcomed the project. The fact that this German technology was said to be the best available, and the fact that its highest official, Nestor Goikoetxea, was a person with a wide knowledge of environmental concerns, seemed to help guarantee a change for the better in a site and region completely degraded by pollution. What Is Wrong With This Picture? What has transpired since ASER began operation in 1987, however, has only darkened an already dirty picture. The founding of ASER was probably never based on the assumption that its source of materials would soon come from Spain. Market researchers for the plant would have known that it was not likely that Spanish steel mills would suddenly start paying ASER to take their wastes. Even if Spanish steel firms were forced to halt their direct dumping practices, it was known that for the foreseeable future, the top prices paid would come from abroad. Since pollution control devices which recover hazardous dusts have been required in northern European countries, 400,000 tonnes of steel dusts are accumulated annually. All that was needed was an area in Spain which was already devastated by environmental abuses from mining and metals industries, suffering from severe unemployment, willing to take them. Bilbao was the ideal location. As soon as the plant opened it was already getting more offers for wastes from abroad then it had the capacity to process. And today, not one of the environmental promises that has been announced to the media has been realised. THE WASTE - Where it comes from Sources The majority of ASER's waste input material comes neither from its area of economic influence nor its area of environmental impact. In 1988 it was stated that 95% of the waste coming to ASER originated abroad. While increasing amounts are coming from Catalonia, in 1991, according to ASER, 60% will still come from abroad. They list Germany, Denmark, Belgium, Ireland, the United Kingdom, Sweden and Austria as suppliers. These generators of the waste, or their brokers, pay ASER between 30 and 50 US dollars per tonne to take the waste. Costs for disposal in northern Europe run to around 120 to 200 US dollars per tonne, depending on the country and toxicity of the waste. Staalvalsevaerket -- One Generator In order to provide a more complete picture of the hazards endemic to in the entire steel recycling industry, it is interesting to take note of one particular generator of the steel dust that is exported to ASER. Staalvalsevaerket (Det Danske Staalvalsevaerk, or DDS) is a secondary steel mill that produces about 619,000 tonnes of steel per year from 635,000 tonnes of scrap and 90,000 tonnes of pig iron. The plant is placed right in the Roskilde Fjord on the shores of the Baltic Sea and has been dumping its slag wastes on the shoreline for years. The scrap, which includes old cars, appliances, farm machinery, etc., is smelted by electric arc furnaces (EAFs), and then rolled into steel plates and bars. The smelting process creates the vast majority of regional pollution as large quantities of gas and particulates are emitted, containing virtually all known heavy metals, and also organic compounds. In addition there are substantial volumes of waste waters. Total air and water emissions per year from the plant are estimated to be: Pb-- 8 tonnes Zn-- 38.9 tonnes Hg-- 198 kg Cd-- 362 kg PAHs-- 150 kg chlorobenzenes-- 16.9 kg chlorophenols-- 5.8 kg dioxin (TCDD) (Eadon method)-- 5.4 grammes The Danish Environmental Protection Agency (EPA) limit guidelines for lead and cadmium air emissions are often exceeded by as much as 50 times. For lead air emissions are exceeded by up to 240 times, for mercury up to 32 times, and for cadmium up to 162 times. Total amount of hazardous waste produced each year excluding slags is approximately 38,000 tonnes. The total amount of slag produced each year is 73,000 tonnes. The slag is contaminated with heavy metals which over the years have leached into the surrounding environment. High levels of lead and cadmium have been found in sediments in the fiord. Lead levels exceed Danish EPA guidelines by 55 times and cadmium 33 times. On the basis of analyses of mussels from some critical locations around the plant, the local health inspector published a warning stating that the shellfish were so highly contaminated with heavy metals as to be unfit for human consumption. In 1990, the health inspector also did a study of lead concentrations in the blood of children in the neighbourhood. His conclusion published in a memorandum in April of 1991, was that: "it is reasonable to assume that some of the infants and small children are so severely exposed to lead contamination that the recommended limit values are significantly exceeded." After this memorandum caused a great deal of scandal, the Health Inspector told Greenpeace: "We never intended to sound the alarm or anything. What we wanted to do was to say to the local population and to organisations, workers etcetera, you should be aware that in this area there is an increased load. And you should realise that there are a few particular sources which might be problematic. Many people work at the plant, not all of them at sites with elevated lead levels. But if you are employed at a place like this, you should be aware that you could take lead home with you and contaminate your family. This is important to keep in mind. Another thing is not to let small children crawl around in open areas with dirt surfaces where they might eat the dirt. And lastly, one should rinse vegetables thoroughly especially if they are for children's consumption. If you do these things, you can live safely and soundly in Frederiksv‘rk and otherwise enjoy the town." With all of the problems with environmental contamination at the plant, DDS is relieved that the filter dusts which in the past have presented considerable disposal problems for the plant are now shipped to ASER in Bilbao--out of sight, out of mind. As these hazardous wastes are bound for a recycling facility, there is very little control required by Danish authorities. Because this waste is exported for recycling and not for "disposal", DDS does not need to inform or involve the Danish national EPA. The analysis of heavy metals in the 10,000 tonnes per year of steel dust that is exported to ASER in Bilbao, Spain, is listed below: Cadmium-- 5.2 tonnes Chromium-- 11.0 tonnes Nickel-- 1.5 tonnes Zinc-- 1,600.0 tonnes Lead-- 370.0 tonnes Copper-- 32. tonnes Vanadium-- .8 tonnes Mercury-- .0048 tonnes The Danish EPA is still awaiting results of extensive dioxin and other organic chemical analysis of the filter dusts and emissions from the DDS plant. However a preliminary sample was taken in 1990, which indicated levels of TCDD dioxin equivalents of either 2.5 (Eadon model) or 3.8 grams (Nordic model) per thousand tonnes. If we assume the low figure, that would mean that about 25 grammes of dioxin (TCDD equivalents) are exported to ASER from Denmark every year. This figure compares to the 50 grammes of TCDD (toxic equivalents) which are estimated to be emitted from all of the waste incinerators in Denmark. This same analysis showed a total PAH (polycyclic aromatic hydrocarbon) level of 4.16 mg/kg or 42 kg exported to ASER from Denmark each year. [] TL: DUMPING BY ANOTHER NAME -- THE RECYCLING OF IMPORTED HAZARDOUS WASTES INBILBAO, SPAIN BY THE ASER COMPANY. SO: Greenpeace International (GP) DT: June 26, 1991 Keywords: toxics europe waste disposal hazardous waste trade spain business problems reports gp / [part 2 of 2] THE WASTE - What it is All products eventually become waste. Common consumer items of this century which contain high percentages of steel such as cars, refrigerators, steam radiators and so on, are smelted down in small steel mills to recover the steel. About 45% of all steel produced today is derived from scrap. Within the scrap, there are other materials present besides steel which enter the smelter process. The presence of heavy metal and organic chemical contamination makes the recycling of this secondary ferrous waste stream dangerous to the environment. "Steel Dust" In the 1970s all steel plants using electric arc furnaces (EAFs), including an increasing number of the "mini-steel plants" built to recycle secondary scrap steel, were required to install pollution control devices to recover dangerous dust emissions. As is the case with most end-of-the-pipe pollution collection systems, the recovered material still must go somewhere, and for the steel industry this toxic dust presents a serious hazardous waste disposal problem. The dust consists primarily of zinc, lead and other heavy metals, iron oxides, volatile compounds such as halides, polycyclic aromatic hydrocarbons (PAHs) and sulphur compounds, which are all precipitated and collected by the filters. The dust collection systems are primarily bag filters, and dust collected equals about 1.5% of the feed. All of these contaminants end up in the collected filter dusts known by the deceptive terms "steel dust", or (in the waste trade) "zinc residues" or "zinc oxide residues" or "zinc concentrate". As the majority of the waste dust consists of extremely fine particles, dumping this material is seen by regulators as dangerous without "pre-treatment" as it would be taken away readily by the weather. Leaching tests have shown that the alkalis as well as the heavy metals present as chlorides or sulphates, are water soluble and will readily contaminate groundwater with heavy metals as well as polycyclic aromatic hydrocarbons (PAHs). In recent years in the United States and most EC countries, gross contamination of groundwater from the dumping of non-ferrous (non-iron) metals wastes has necessitated legislation classifying steel dusts as hazardous wastes which must be sent to special landfills or to processing plants. In Denmark and Sweden, dumping the steel dust waste is now completely forbidden. Now these two countries export them to Spain rather than seek to eliminate the wastes at source. According to Berzelius, "since it is becoming more and more difficult to find and operate adequate dumping areas, disposal costs for such waste materials cannot be underestimated". According to Mr Goikoetxea, in 1988 ASER was paid 4,800 pesetas per tonne to take the waste. In other parts of Europe, particularly in Scandinavia, the costs for storage amounted to between 12,000 pesetas and 20,000 pesetas per tonne. Steel scrap is often very high in zinc content due to the widespread use of galvanised materials to prevent corrosion. Zinc concentrations from some of the secondary steel plants can be as high as 35%. When the zinc content is high enough to be economically recoverable, the collected steel dust from these steel plants is used to feed the Waelz process at plants such as ASER. Lead is recovered as well, but the significant profit is made from the zinc. Thus, it is understood that companies relying on zinc recovery such as ASER, will by necessity need to use wastes emanating from scraps contaminated by organic compounds. Organic Chemicals in "Steel Dust" It is the organic chemical component of this waste and its fate that is most often overlooked by regulators and metallurgists. According to company figures for the Badische Stahlwerke BSW scrap steel plant in Kehl, in southern Germany near Strasbourg, the percentage of organic contamination of the scrap is roughly 2%. Thus one million tonnes of processed scrap would include the burning of 20,000 tonnes of plastic parts, hydraulic oils, protective automobile coverings and so on. Even if efforts are made to separate plastics such as PVC (polyvinyl chloride) from car bodies, enough chlorine and hydrocarbons are present in the waste or process inputs, for dangerous halogenated hydrocarbons and PAHs to be formed in the smelting process. A Swedish study found 20 mg/kg (parts per million - ppm) of PAH in the Domnarvet electric arc furnace steel mill in Sweden. PAHs are a group of compounds of great environmental concern. PAHs include some of the most carcinogenic compounds known. The same study found 66 ćg/kg (parts per billion - ppb) of chlorobenzenes. But perhaps most frightening are the levels of dioxins and furans that are inevitably formed by the electric arc furnace (EAF) of steel mills processing scrap materials. Dioxins in Steel Dust Until recently nobody knew that perhaps the most deadly group of chemicals -- the polychlorinated dibenzo-p-dioxins and dibenzofurans known collectively as dioxins, were routinely being emitted from steel smelters. According to a 1989 Swedish study funded by the Swedish Steel Producers' Association, "the use of chlorinated compounds in iron and steel processes and the use of recycled scrap metal contaminated with cutting oils and plastics containing chlorine provides all the factors required for the formation of chlorinated aromatic compounds. The largest emissions (of dioxins and furans) were observed during the smelting scrap metal containing PVC plastics." In one study, samples were taken at four steel mills to determine the danger of exposure to workers. The study confirmed that the dioxin concentration in the mills followed the relative dust concentration. The filters were shown to capture 50-75% of all of the dioxins. Another study carried out in Sweden by the REFORSK foundation found levels in filter dust as high as 1.5 (ppb) of TCDD dioxin equivalent (this is a measure of the toxicity of the eight most toxic congeners of emitted dioxins and furans in terms of the most potent dioxin known as 2,3,7,8 TCDD). A sample taken of the filter dust at Staalvalsevaerket (DDS) steel works in Denmark (discussed later in this report) revealed al level of 2.5 ppb of dioxin TCDD equivalents (Eadon method) or 3.8 ppb (Nordic method). At Badische Stahlwerke in Kehl Germany, levels as high as 17.8 ppb were found. If we assume the low Staalvalsevaerket figure of 2.5 to be average for all imports from all sources, ASER will be receiving 200 grams of dioxin TCDD equivalents per year. We will discuss the fate of these dioxins in ASER's Waelz process later in the report. Badische Stahlwerke in Kehl - Dioxins to ASER In the Spring of 1990 revelations about dioxins produced at the Badische Stahlwerke AG (BSW) steelworks created a huge scandal in Kehl, Germany near Strasbourg. As early as March 1986 as part of a special investigation of the BSW plant in Kehl, an analysis was conducted of the steel dusts which revealed a very high dioxin and furan content of 17.8 ppb TCDD toxic equivalents. Following efforts to reduce dioxin formation, more tests were made in 1989 of dusts collected from four areas around the plant, by the L„nder Institute for Environmental Protection at the request of the Ministry of Environment. A peak value of 2 ppb TCDD equivalents was recorded in the dusts collected at the ash pellet filling area. The BSW plant produces and pelletises 30 tonnes of steel dusts daily, or 15,000 tonnes per year. As witness to the investigation, Dr. Klein stated: "They were subsequently loaded onto a covered truck and the material was then deposited in a container at the river docks. As soon as sufficient quantities had accumulated, the residue was transferred from the container to a ship and then it was gone." In previous years this highly contaminated ash had undergone further processing at ASER's mother plant in Duisburg owned and operated by Berzelius. After Berzelius was informed in April 1986 of the dioxin content of this material, they stopped accepting the pellets from BSW and instead began shipping them to ASER in Spain. They claim that this was due to the fact that the Duisburg plant had reached full capacity and could accept no more waste. The Duisburg plant now maintains that any dusts that exceed the legal limits will not be accepted. It is not stated where the wastes go when they exceed the legally allowable levels. However, tests were performed on emissions at the Duisburg Berzelius plant to determine the fate of the dioxins and furans. The tests showed that the Waelz process utilised there resulted in a slight increase in dioxin levels. A statement released by Berzelius dated 23 November 1990 stated that the pellets were still being processed in Duisburg until mid-1987. In the period that followed, the contaminated pellets were exported and being recycled by ASER in Bilbao, Spain. In these periods and by these waste metals brokerage firms, substantial shipments of dioxin-contaminated steel dusts were shipped from BSW to ASER in Bilbao: September 1987 - September 1988-- EUROMET September 1988 - December 1988-- BERZELIUS July 1989 - December 1989-- BERZELIUS December 1989 - July 1990-- EUROMET July 1990 - present-- BERZELIUS Berzelius denies that the wastes were sent to Spain because of the German dioxin scandal. However, the argument claiming full German capacity is weak given that Berzelius controls both plants and should have by now been able to redistribute capacity and send the BSW dust to their nearest facility. Instead of being processed in Germany these contaminated dusts continue to be shipped via rivers, through Rotterdam and on to Bilbao, to this day. Even though special permits have been given to Berzelius' shipper Lehntering Shipping, also owned by Metallgesallschaft, and former owner and operator of hazardous waste ocean incineration vessel, Vesta; and a state-owned French company known as Compagnie Fran‡aise de Navigation du Rhin, to handle dioxin-contaminated wastes on the river system, none of this material is shipped as hazardous wastes but as "pelleted zinc concentrate". Nobody warns the shippers and handlers of this material that they are actually carrying very dangerous cargo. In the past the very same barges, after a simple sweeping, were used to transport soy beans, grains and animal fodder. THE WAELZ PROCESS - What ASER does with the waste The Waelz process has been used for over three decades and was first introduced at the Berzelius Metallhtten GmbH plant in Duisburg, Germany. Currently in western Europe there are three Waelz plants in operation: the Berzelius plant in Duisburg, the ASER plant in Bilbao, and a plant in Ponte Nossa, Italy. Berzelius is currently constructing another plant in Noyelles- Godault, in northern France near Lille - a 50/50 joint venture with France's Metaleurope. The first Waelz plant was built in 1952 and was originally designed to recover zinc and lead from zinc retort residues and slags from lead shaft furnaces. But in the early 1970s new refinement technology led to less zinc in the lead smelting feedstock, so the plant was forced to look for substitute materials. They quickly turned to the vast quantities of steel dusts being recovered by pollution control devices. The Waelz process works by volatilisation of the metals and metal compounds in a rotary kiln and then reducing them to oxides. The metal content of the recovered "Waelz oxides" average about 52% zinc and 10% lead. These oxides are then made into briquettes and marketed for further smelting using the Imperial shaft furnace (ISF) to recover pure zinc lead and sometimes cadmium. These ISF plants are located in Bristol, England; Noyelles- Godault, France; Porto Vesme, Sardinia, Italy; Titov Veles, Yugoslavia; as well as in the USA. The buyers of ASER's briquettes include Fundiciones Pena Roya of France, CSL of the United Kingdom (UK), Nuovo Samin of Italy and Zletovo of Yugoslavia. The heat necessary to vaporise the metals is supplied by the burning of coke. In addition to the steel dust and the coke, sand is added in quantities equal to about 15.8% of the total input. All compounds with a sufficiently high vapour pressure are volatilised. Thus, 50% of the sodium and 67% of the potassium are transferred from the feed materials to the oxide. Chlorine and fluorine are mostly volatilised as well, as is about half of the tin and most of the cadmium. The arsenic and copper, however, are almost completely carried off by the slag. The copper content of the slag can be as much as 1%. THE NEW WASTE - What it is Besides producing zinc and lead oxides for sale which are by themselves contaminated with cadmium and other toxic chemicals, the Waelz process employed by ASER creates new wastes in the form of spillage, fugitive emissions, stack emissions, more filter dust collected by pollution control devices, and slags. All these pollution sources contain heavy metals and organic chemicals. We explore a few of these problem chemicals below. Heavy Metals - A Mass Balance Approach The acute toxicity of heavy metals has been well known for centuries. More recently it has become known that the symptoms of metal toxicity are usually nonspecific and accumulative and the effects are likely to be subclinical, going unnoticed. Metals such as lead range in toxicity all the way from causing death to a reduction of the body's ability to cope with other forms of stress. We investigate just two of the heavy metals of concern to the ASER story. TABLE III A BALANCE OF MASSES OF THE ASER PLANT EAF steel dust Waelz Oxide Slag Tonnes/year80,00025,00060,000 Zn 16-3650-600.2-0.4 Pb2-77-110.1-0.2 Cd0.03-0.10.1-0.2~0.01 Cu0.2-0.40.03-0.040.3-0.5 Sn0.2-0.30.2-0.40.1-0.2 As0.04-0.080.01-0.020.05-0.1 S total1.8-2.21.4-1.81.5-2.5 F0.2-0.40.4-0.80.1-0.2 Cl1-1.52-40.03-0.05 C1-20.2-0.85-10 FeO26-303-430-58 MnO4-50.6-0.85-6 CaO6-70.6-0.88-9 MgO2.5-3.00.4-0.53-4 BaO~ 0.01~ 0.01~ 0.1 Al2O30.4-0.60.1-0.152.5-3.5 SiO23-3.50.5-0.735-37 Na2O1.5-1.92-2.51.2-1.6 K2O1.2-1.52-2.50.7-0.9 moisture9-110.1-0.110-20 The above table was presented in a paper by Nestor de Goicoechea y Gandiaga (Industrial Engineer and Director of ASER). TABLE IV [for accurate presentation of this chart, please see the print copy] ANNUAL HEAVY METAL AND CHLORINE LOSSES TO THE ENVIRONMENT AT ASER Input in tonnes Recovery Rate Tonnes re- covered Tonnes lost in slag Tonnes, not ac- counted for Total tonnes lost to enviro. Zn 20,800 66% 13,750 1806 8707, 050 Pb3,60062.5%2,25090 1,2601,350 Cu2403.6%8.7518051.25231.25 Cd5272.1%37.568.514.5 As487.8%3.753014.2544.25 Sn20037.5%759035125 Cl1000 75%75024226250 The above figures are based on ASER's own data presented in Table III above. Median figures of the given range were used except where noted. Lead Environmental exposure to even low levels of lead has been associated with a wide range of metabolic disorders and neuropsychological deficits. It is now generally accepted that children are especially susceptible to the effects of lead and also are at greater risk of being exposed. The well-known toxic effects of lead in children include blood, brain and bone cell damage. Biochemical and neurological changes associated with lead toxicity have been observed in lead concentrations in blood as low as 60ćg litre-1. Workers exposed to lead fumes or lead compounds take in lead mainly by inhalation. On average about 30% of inhaled lead is absorbed into the body. Most of this will normally be excreted but the remainder is distributed primarily in blood and bones. Plant manager Nestor Goikoetxea stated that blood tests for lead were required every six months. The results of ASER's employee blood tests were not available for this study. The effects of lead on fish can be extreme, with toxicity beginning at around .1 mg/l. According to ASER's mass balance data, (see Table IV) they put 3,600 tonnes of lead into their plant each year. They have elsewhere claimed a recovery rate of 90%, but their own mass balance figures record a recovery rate of 62.5%. We cannot explain this discrepancy. According to ASER's data, 90 tonnes go into the slag, leaving approximately 1,260 tonnes unaccounted for - presumed lost each year in the immediate environment of the plant. The sum quantity of the slag and the unaccounted-for lead equals an amazing 1,350 tonnes of lead lost to the environment each year. Cadmium Cadmium is a natural by-product of zinc extraction, and is known to be extremely toxic. It has been shown to cause an increased number of deaths due to chronic bronchitis and lung cancer in exposed workers, which is especially serious for those persons who smoke cigarettes (because of the high absorption of cadmium from tobacco) or who are exposed to other potential carcinogens in the workplace such as arsenic, nickel, asbestos and PAHs. Other studies have recorded severe effects of cadmium inhalation on laboratory animals. Reproductive effects observed were loss of libido, lowered sperm count and total sterility. Other effects included renal tubular damage, placental and testicular necrosis, structural and functional liver damage, osteomalacia, testicular tumours, teratogenic malformations, anaemia, hypertension, pulmonary oedema, chronic pulmonary emphysema and induced deficiencies of iron, copper and zinc. Cadmium is extremely toxic to aquatic organisms. In Canada, recommended water quality objectives range as low as .0002 to .0004 mg/l total cadmium in order to protect certain aquatic life. According to ASER's data (see Table IV), they put 52 tonnes of cadmium into their plant each year. ASER claims that virtually all of the cadmium (90-99%) is volatilised in their process and goes into their briquette product. However, their own mass balance figures suggest a recovery rate of 72.1% with 6 tonnes reportedly going into the slag and 8.5 tonnes left unaccounted- for, amounting to a total loss to the environment of 14.5 tonnes. A Greenpeace sponsored sampling study discovered extremely high levels of cadmium in soils and sediments adjacent to the plant. All of the cadmium levels in the AsŁa River downstream or adjacent to the industries there show exceptionally high levels of cadmium (see Annex I). Although ASER claims to be releasing no waste waters, such levels seem to indicate contamination from a highly concentrated source of cadmium in addition to zinc, copper, and lead. These samples indicate levels so high that they would have been required to be removed and treated as hazardous waste in the Netherlands. The study showed that the soil levels of cadmium and other metals probably indicate a large amount of atmospheric deposition in the AsŁa Valley "probably arising from the metals recycling facilities." Elevated cadmium levels in soils are a cause for concern, since this metal is easily mobilised into crops. The community of AsŁa consists of numerous households interspersed in and around the factories. Many of these have vegetable gardens. Given the likelihood of biological uptake of cadmium and other metals, crops grown and consumed from these gardens could represent a serious health threat. ASER's briquettes are sold to smelters which may or may not be in the business of recovering cadmium. Most of the money is to be made in zinc recovery, and there is little incentive to isolate cadmium from the environment. One such smelter, owned by Commonwealth Smelting Ltd in Avonmouth, Bristol, UK, claims to be recovering cadmium as well as zinc and lead, but according to a study published by the British Ecological Society it is estimated to be discharging 6.1 tonnes of cadmium per year into the atmosphere or the Bristol channel. Dioxins and Furans In order to partially recover operational costs through zinc sales, and thus enhance overall profits, there is a great incentive for Waelz operators to import steel dusts with high concentrations of zinc. The highest zinc concentrations are found in secondary scrap steel production due to the use of zinc galvanisation on much of the former steel products. Unfortunately, this is the same source material which produces the dioxins and furans. Even low concentrations of dioxins are of great concern; the Centres for Disease Control (CDC) in Atlanta in the United States have recommended that 1 ppb of 2,3,7,8-TCDD in soil be regarded as the level for concern. This is usually the level at which clean-up work is initiated. The Fate of Dioxins in the Waelz process When asked whether he was aware that his input materials contained dioxins, Mr Nestor Goikoetxea stated that, "normally speaking, this is a very difficult subject given that the analysis of dioxins in Spain is not possible". He admitted that dioxins are present in some of the steel dusts emanating from secondary (scrap) processes. He further stated that the Waelz rotary kiln operating at 1200 degrees Celsius would destroy most of the dioxins and "at no time have we found levels above the permitted". However, tests performed by Berzelius on emissions at the Duisburg Berzelius plant to determine the fate of the dioxins and furans, revealed that the Waelz process utilised there resulted in a slight increase in input dioxin levels. The gases leaving the Waelz kiln are at a temperature of approximately 850-900ř C. This indicates kiln temperatures in the range capable of at least partly destroying those dioxins in the dust feed. However, as with high temperature incineration, it is likely that dioxin emissions can arise from re-formation in the post-combustion train. The temperature just before the electrostatic precipitator itself is 315-320ř C. It is well known that formation of dioxins and their precursors in an incinerator primarily occurs in the range of 300ř to 650ř C, as would be found between the Waelz kiln and the electrostatic precipitator. It has also been shown that dioxins and furans are formed in electrostatic precipitators. Scientists have explained the formation of dioxins on fly ash from municipal incinerators. Research indicates that the presence of the elements chlorine, copper, sodium, potassium and zinc in fly ash lead to increased dioxin formation. Clearly copper, chlorine, and zinc are present in the feedstock, and carbon, obviously essential, is provided as the process fuel and reducing agent. The chlorine volatilisation rate is given as 98%; in the volatilised state, it would thus be chemically available for dioxin synthesis reactions. Thus, all of the necessary ingredients exist to produce or "re-form" dioxins. Given these facts and the emerging realisation that dioxins are emitted from a wide range of high-temperature metallurgical processes, it must be regarded as inevitable that dioxins and other related compounds will be present in the work environment and emissions of any plant operating the Waelz process. Toxicity of Dioxin The toxicity of the dioxins and furans to humans has caused great controversy over the past decade. The extreme carcinogenic potency of 2,3,7,8-TCDD and related compounds in animals is well established. The majority of human epidemiological work, carried out on workers occupationally exposed to TCDD, have not found TCDD to be carcinogenic although some more recent work contradicts this. Some of the epidemiological studies which found TCDD not to have carcinogenic effects has been called into question as regards statistical validity. Most recently, an extensive re-analysis of epidemiological data collected on US workers has been published by the National Institute for Occupational Safety and Health (NIOSH) in the USA. This considers data for over 5000 workers involved in the manufacture of trichlorophenol and its derivatives. The study concluded that workers exposed for more than one year showed a 46% excess of all cancers combined. THE NEW WASTE - Where it goes Water Discharges - Spillage and Run-off Although ASER claims that no waste or run-off waters enter the river from its plant, samples taken of sediments in the AsŁa River have indicated elevations of heavy metals around the plant higher than those up or downstream (see Annex I). These extreme levels are probably attributable to point source discharges located in the entire conglomeration of secondary metallurgical industries in the AsŁa valley, including ASER. Although ASER states that they are building shelters for the primary materials so they will be protected from the weather, our visit to the plant in May 1991 indicated that construction had not yet begun. The unloading facilities on the Deusto Channel have been observed to be completely without barriers to windblown or rainwater run- off of crane or tractor dumped dusts or pellets. It is interesting to note that the portion of the highly contaminated canal catchment area represented by QMW sediment sample #6 (see Annex I) is almost the same profile as the constituents of the steel dust itself (see Table V below). TABLE V A COMPARISON OF STEEL DUST AND A SEDIMENT SAMPLE IN THE DEUSTO CHANNEL ASER Import Steel Dusts Deusto Channel Metaltonnes per yearProportion of all 4 metals mg/kg dry weight Proportion of all 4 metals Zn6,87083%5,26078% Pb1,26015.3%87613% Cu51.25.006%562.08% Cd8.5.001%53.6.008% Air Emissions According to ASER, their two chimneys are equipped with electrostatic precipitators and the emissions are always below the permitted levels. The normal emission rates given by ASER are: Total particulates: 50mg/N m3 Heavy Metals: Pb+Cr+Cu+Mn = 5 mg/Nm3 Ni+As=1 mg/Nm3 Cd=.1 mg/Nm3 Hg=.1 mg/Nm3 S02=300 mg/Nm3 However, what is conveniently left out of this chart are the total loading levels of heavy metals unaccounted-for (see Table IV) as well as the levels of organic reformation products such as dioxins and furans, discussed above. Any attempt to lower air emissions by using the electrostatic precipitators or other filtration will only succeed in shifting the wastes from air pollution to concentrated solid hazardous waste. Slag ASER receives some 80,000 tonnes of waste steel dust from its various European sources each year. Because 15.8% of the input is added sand, the quantity of the total input is 92,640 tonnes. Of this amount, about 60,000 tonnes ends up as slag. Thus, the total solid waste output is equal to 75% of the imported waste input. ASER refuses to call this waste. They refer to the slag as an "inert by-product sold for public works". The United States Environmental Protection Agency, however, calls it waste. In fact, from August 1991 the USEPA will call this material hazardous waste, and dumping it in a landfill there will be illegal. Leachate Test Tricks The so called "inert" slag consists of high levels of copper, arsenic, selenium, sulphur, iron, chromium and nickel bound in silicate form. Both ASER and Berzelius maintain that these compounds are not water soluble. And ASER now regularly has a consultant in Bilbao performing leachate tests just to prove how inert the slag is. The results of these tests for July 1990 were: Initial pH 8.1 Total Chrome, mg Cr/l < 0.1 Nickel, mg Ni/l < 0.2 Zinc, mg Zn/l < 0.1 Cadmium, mg Cd/l < 0.1 Lead, mg Pb/l < 0.2 Arsenic, mg As/l < 0.001 EC-50, (15min. 15řC) > 100,000 Besides the fact that the detection levels for chromium, nickel, and cadmium are higher than the levels proposed to be allowed by the USEPA for landfilling in the United States, it is remarkable that ASER's consultants have decided to conduct their tests at a Ph of 8.1 (alkaline conditions). It is a well known fact that heavy metals are much more easily leached by acids than by alkaline or neutral water. Environmental consultants from the Institut fr Oekologie und Politik GmbH (Oekopol, see Annex II) assert that, "due to air pollution by sulphur and nitrogen oxides, in many areas rain water often has a pH value of 4 or even less, ie. the rain is acidic. Therefore, elution tests performed in the laboratory are meaningless unless acidic conditions are maintained over the whole testing period." ASER's practice of testing in alkaline conditions is especially deceitful when it is well known that the ambient conditions in Bilbao and especially the nearby estuary are highly acidic. Oekopol also asserts that slags are subject to acid leaching for years, and thus in the long run acid rain levels will always exceed the buffering alkaline components of slags. A 24-hour laboratory test cannot possibly mimic field exposures for years and years. Weathering and chemical processes can render heavy metals more soluble. Finally, it is also now known that seawater or estuarine water has a much stronger leaching capacity than most test media used in the laboratory. Laboratory tests for aqueous leaching, known as elution tests, are supposed to imitate open field conditions. In recent years, however, a serious discussion has arisen over the question of whether such laboratory tests are accurate representations of what happens in nature. For reasons as illustrated in the relevant example above, a standard leaching test that used to be considered as "state-of-the-art" in Germany (DEV S4) is about to be totally abandoned. It is now suggested that slags be classified according to their total content of toxic chemicals rather than presumed leachability levels. Such a system of classification is about to be adopted in the German state of North-Rhine Westfalia. Thus the assertion that ASER's slags are inert must be abandoned in favour of a model that assumes that with time and with the aid of natural (for example, weathering) and unnatural (for example, acid rain) conditions, virtually all of the contaminants will enter the local Bilbao environment. Where the Slag goes When asked if they lacked public facilities to dispose of wastes, ASER replied in the negative. This is not surprising, since they have managed to dump it just about everywhere in the community without resistance. The slag which ASER claims is "sold for public works" has, since the plant has been operating, been dumped wherever it can possibly go. There are 467 uncontrolled dumpsites in the Bilbao area and ASER has used many of them. The primary illegal dumpsite is situated in the Arriagas lowlands close to the AsŁa River. One kilometre from the place where the AsŁa empties into the Bilbao estuary, the waste from ASER and others is forming a plateau of many tens of thousands of cubic metres. At the moment it covers a surface of roughly a couple of hectares with an approximate height of six metres above the original land. One or two tractors are permanently busy spreading out and levelling the thousands of tonnes of waste that arrive there daily from the various companies in the region. A second dumpsite is also close to the ASER factory and next door to Indumetal Recycling. Here the slag has been levelled in the same way with a tractor and covers about one hectare. A third place is the parking lots at the beaches of Plentzia and Gorliz on the Bay of Biscay, where the waste has been used as the bed underneath the asphalt. The approximate area is two hectares. Besides these locations, there is a long list of other places including fallow farmland that has been rented or run-down industrial areas, which are likewise receiving ASER's slags. Proprietors are apparently convinced by ASER's claims that the slag is inert. THE MONEY Imported Profits According to Mr R. Kola, of Berzelius Umwelt-Service, the Waelz process: "should not be considered as a way to recover zinc and lead. On the contrary it offers a feasible means of avoiding the necessity of dumping a waste material which is not suited for recycling in the steel industry...the recovery of valuable metals gives a contribution to the expenses." Clearly the real money at ASER is made by "disposing" of wastes from northern Europe. Mr Kola reports that plants of this type receive 30 to 50 US dollars per tonne of steel dust. It must be understood that this is the figure left after brokers and shippers such as Euromet, HTA or Berzelius have taken their profit for handling the waste. If we take a figure of 40 US dollars per tonne and the import of 80,000 tonnes as is claimed by ASER, we arrive at an annual income of $3,200,000 US virtually free of overhead. Everything that ASER does after that costs them money. The recovery of the zinc and lead makes a small amount back, but by the time this process is finished, their initial income has been greatly reduced. ASER reported a profit of only $950,000 US in 1990. ASER claims to have produced 15,000 tonnes of actual zinc each year and 4,000 tonnes of lead in 1990 which brought sales of approximately $ 15,000,000 US. This figure does not reflect the price of pure zinc, but represents the price of the Waelz oxide briquettes which still need further refining in an ISF smelter to extract the pure metal. Zinc prices play a very important role in the business. According to Berzelius, with a zinc content below 15%, processing the wastes in a Waelz kiln is not economically viable if the zinc price dips below $1,000 US per tonne. Below that point, it becomes a losing operation. Although zinc prices have plummeted in the last two years, they are still currently above $1,000 US per tonne. Using the above available figures, one can arrive at an abbreviated balance sheet: Initial income for "disposal service": $ 3,200,000 Gross sales of Waelz Oxide: 15,000,000 Total Expenses- 17,250,000 Profit $US 950,000 Clearly, if they had never put the material through any sort of process at all they would have made a great deal more money. Therefore the incentive is great for recyclers of this kind to import wastes and then never process them. The existence of a recycling plant would provide perfect "cover" to justify numerous shipments which could simply be dumped untreated as if the contents were processed slags. In addition, as is pointed out on many occasions by ASER, the direct dumping of steel dusts in Spain is common, and although technically illegal, is not a violation that is prosecuted. Greenpeace by no means wishes to suggest that this is actually taking place or that ASER would ever consider such a thing. Rather, we wish to point out to regulators that there is very little scrutiny or control to prevent such practices. In fact, it must be noted that this is quite similar to the ruse used by Minas Almad‚n y Arraynes near Madrid for years and years. In that case mercury wastes were taken in to increase the income of the mine, with a promise that they would be recycled. They never were. This was accomplished with the full knowledge of the Spanish government. The Brokers A great fight is being waged in Europe for control of the estimated 400,000 tonnes of highly profitable steel dusts. Now that the Eastern European borders have opened and Eastern Europe is increasingly adopting old western end-of-pipe pollution control technologies, the amount of steel dust is estimated to soon grow to 500,000 tonnes per year. Some of the principal waste brokers are Euromet, Handels Transport und Abfalverwertung (HTA), and Berzelius-Umwelt Service. Euromet was featured in the scandal which sent steel dusts to Brazil in the summer of 1989 (see introduction to section on ASER, above) as well as a scandal involving contaminated metals importation to Wath Recycling in the UK, also in 1989. Euromet also exported toxic mercury wastes to the Spanish company Minas de Almad‚n y Arrayanes S.A. HTA of Duisburg, Germany, was recently caught shipping these same steel dusts to Poland, despite the fact that Poland has a hazardous waste import ban. Poland had requested that HTA re- export these wastes back to Germany. The Dutch authorities likewise possess a pile of HTA wastes sitting in Rotterdam which was halted on its way to Poland. Recently the Dutch government has written letters to both the German Minister of Environment and to HTA stating that unless they bring the steel dust waste back to Germany, then they will carry it across the border by force. Berzelius, headquartered in Duesseldorf, is a very profitable and active company and plans to spend 500 million DM on new investments by 1995. It was the first so called environmental company to be offered publicly on the West German stock exchange in February 1990. Common shares sold initially at DM 330 and are now trading at DM 538. In August 1990 it was reported that Berzelius increased its holdings in major metals recycling facilities in the United States and Australia. Berzelius charges about US$85.40 per tonne to take steel dust wastes from European steel mills. And even though Berzelius is roughly twice as expensive as its competitors, it is rapidly gaining a monopoly in the trade and is using its superiority in capital to buy up the global Waelz capacity and then squeeze competitors out. Besides completing their FF 120 million, 70,000 tonne capacity plant near Lille, France for the Belgian, French and Dutch markets, their European expansionist plans include building Waelz plants in the United Kingdom, Poland and in Freiberg in Saxony, eastern Germany. HAZARDOUS WASTE TRADE AND THE LAW The Path of Least Resistance Toxic waste, if left to the free market, follows the path of least resistance. The transboundary movement of the hazardous bi- products of industrialisation is dictated by economic forces which drive wastes from the richer nations of the world toward those peoples who are often powerless to resist making the choice between poverty and poison. Waste is shipped to areas where disposal or processing costs are lower, largely due to weaker occupational and environmental protection legislation. This sad outcome is as true for wastes bound for recycling processes as it is for those wastes bound for "final disposal". Thus the waste trade scandalises heavily industrialised (OECD) countries by victimising less economically powerful countries (non-OECD). Within the EC, a similar pattern of hazardous waste movements from richer to poorer countries and communities can be seen developing and should be equally condemned. Even though national and regional self-sufficiency and waste prevention are the stated objectives of EC waste management policy, inappropriate "free trade" arguments tend to dominate real legislation. But it is the very Prevention Principle which is the underlying precept which must dictate all legislation on waste. It is also the underlying reason for preventing waste trade. Waste is transported in avoidance of the responsibility to prevent its generation. As long as cheap dumpsites can be found in poorer nations or communities, industry will have little incentive to prevent the waste from being produced in the first place. Pressures to Export In recent years, however, the body of environmental law has been geared towards end-of-pipe "pollution control" rather than pollution prevention. While heightened environmental concern in rich industrialised nations such as the northern EC states has hastened the adoption of increasingly strict and costly regulations for waste disposal, little progress has been made on implementing clean production methodologies. Meanwhile, the quantities of waste produced are expected to increase as new, more encompassing definitions of hazardous waste are being implemented into legislation, and collection services improve. For many industrialists, the combined effect of these factors has unfortunately led not to an increased effort to reduce wastes, but to an increased desire to export them. Existing Waste Trade "Control" Legislation Meanwhile, the door for this unscrupulous and environmentally costly trade remains open, as few rich nations have sought to prohibit hazardous waste exports, even to developing (non-OECD) countries. The global Basel Convention failed to prohibit waste trade to any region of the world with the exception of Antarctica. Rather than banning waste trade, The Basel Convention, current EC , and USA legislation consists merely of complicated notification and consent regimes requiring increased bureaucracy, and creating little incentive to decrease hazardous waste trade. Since the implementation of the EC Directive, USA legislation and the signing of the Basel convention, waste trade proposals and activities have not decreased but rather have become more sophisticated, citing "state-of-the-art" landfills, incinerators or recycling or re-use projects. Recycling Loopholes "The tendency to export solid waste classified as non-hazardous is increasing and beginning to pose environmental, health and diplomatic problems..." -- US Congressman Mike Synar. It must be recognised that most of the hazardous wastes in the United States are not regulated under US law, especially if they are metals scraps, sludge, slags or dusts bound for recycling facilities. Such wastes are not subject to the notification procedure mentioned above and may flow into Bilbao without authorisation from the US government. Likewise in Europe, ferrous metals are currently not regulated at all and non-ferrous metals wastes require only a streamlined shipping procedure whereby notification is made to the receiving government as the waste is exported. Although all EC member states and the US are planning to ratify the Basel Convention, US and EC proposals for legislation to implement the convention, as well as policy recommendations coming from the OECD, all seek to establish less stringent control procedures for recyclable wastes than those adopted in Basel. This is remarkable given the fact that the Basel Convention was deemed by many of the delegations that negotiated that treaty, to be a weak, minimalist document. The loopholes in legislation sought by the rich industrialised countries would apply to hazardous wastes bound for so-called recycling facilities. Currently the EC, USA and OECD are busy trying to set criteria to determine which hazardous waste streams or exported recycling operations would be subject to full Basel provisions and which would be exempt. These types of exemptions could spell the end to any attempt to prevent the hazardous waste trade. Recycling loopholes can be easily exploited by waste traders claiming a pretext or fate of "further use" to justify any transboundary waste movement schemes. More than 60% of current waste schemes documented by Greenpeace claim some sort of "further use" fate or pretext. This is done in avoidance of admitting the real reason for waste export - the high costs of disposal in northern Europe and the USA. As we have witnessed in the case of ASER, the real economic activity of many of these recycling facilities is that of a waste "disposal service" helping rich countries get rid of poisons at the expense of the poor. Even in "legitimate" recycling operations such as we have seen in ASER, many tonnes of very hazardous chemicals such as lead, cadmium and dioxins are dumped on the importing countries as residues from any recycling process. These materials are not recyclable yet they are allowed to sail through the gaping recycling loophole. Additionally, the transport of such hazardous waste remains risky and thus there is no justification for assuming less strict environmental concern or criteria. For these reasons Greenpeace maintains that it is indefensible to retain any recycling loopholes or double standards in regulations governing hazardous waste. "Non-Ferrous Metals" Prominent in the recycling debate is the issue of so-called "non- ferrous metals". There is a substantial lobby behind the "non- ferrous metals" recovery industry. In the past, this lobby was influential in exempting this category of hazardous waste from many of the provisions of hazardous waste trade legislation. Despite numerous environmental and political scandals over the "non-ferrous metals" recycling trade involving both the USA and EC nations, serious efforts are presently under way to exempt this type of waste in the new generation of waste trade legislation. It is remarkable that pollution control dusts from EAF steel mills such as that imported by ASER can be considered strictly "non-ferrous metals" waste when the waste is well known to be contaminated with dioxins, furans, chlorinated aromatics and PAHs. Given these constituents, along with heavy metals, it is even more remarkable that anybody would consider steel dust to be any less hazardous than other hazardous wastes and thus deserving of less strict procedures. And initiatives to exempt this - or any - hazardous waste stream from full environmental protection are clearly the result of politics, not science. The European Commission's Proposed Regulation In a critique published on 14 January 1991, Greenpeace denounced the European Commission's proposed waste trade regulation for failing to ban hazardous waste trade to countries outside the EC. The Community will still allow hazardous waste exports bound for recycling facilities. Greenpeace also denounced the EC proposal for establishing other recycling loopholes for intra-Community trade in hazardous wastes. The European Commission and Council have introduced the concept that waste should be handled by double standards, with one set of provisions for wastes bound for final disposal and a weaker set for those wastes which somebody claims can be recycled. Under the provisions of the proposed regulation, recycled wastes would not be subject to self-sufficiency principles, or the so- called "proximity principle" (which states that wastes should be managed as close to the production site as possible), a surety bond or the normal procedures of prior informed consent. As far as the EC is concerned, as long as one states that the waste is bound for recycling processes it can go virtually anywhere with a minimum of scrutiny and control. The Single European Market for Waste - 1993 After the formation of the single European market at the end of 1992 it will be very difficult to control waste trade. As the Treaty of Rome (which formed the European Community) and the Single European Act amending it, are both trade agreements and not environmental treaties, the transboundary movement of hazardous waste is viewed almost entirely from the perspective of "free trade". Thus hazardous waste, rather than being viewed as a societal liability, is seen as a commodity or service which must be freely traded. Apart from contradicting the established goal of national and regional self-sufficiency in waste management, this free trade fixation will make it extremely difficult for an EC Member State to legally prohibit hazardous waste imports and exports, forcing them to rely on environmental protection exemption clauses. Unless national governments take a strong political stand against such "single waste market" ideas now, they may find themselves defenceless against waste invasions and evasions after 1992. In fact, after 1992 the absence of border controls will make the enforcement of any kind of hazardous waste transport regulation become extremely difficult. Most importantly though, is the fact that, true harmonisation, and parity of all members of the community, both regulatory and economic, will not be realised for many years. Thus the poorer countries and regions of the Community - which include Greece, Spain, Portugal, Southern Italy and the former East Germany -can for the foreseeable future be expected to be on the receiving end of the economic hazardous waste pipeline. Already the disparity between northern and southern Europe has caused Environment Commissioner Carlo Ripa di Meana to suggest a "two stage Europe", where rather than automatically accepting the lowest common denominator for environmental regulations, two sets of standards will be applied for an interim period. This proposal is tantamount to an assurance that unless southern Europe protests loudly, they can expect the poisons of the north to flood their way. Spain Spain, meanwhile has still not implemented the 1984 EC Directive 84/631/EEC on the Transboundary Movement of Hazardous Wastes although they claim that they are complying with it. The fact that they have only just begun to comply with a seven-year-old Directive does not bode well for implementation of new EC legislation, nor for their graduation in the near future from "second class" Europe with respect to the environment. Spain in the Paris and Oslo Conventions and North Sea Conference It is interesting to note that while Spain is busy importing and dumping heavy metals into the Cantabric Sea, the non-ferrous metals copper, zinc, lead, arsenic, chromium, nickel, cadmium and mercury are at the top of the North Sea Conference's list of priority hazardous substances. Ministers agreed in the Hague Declaration to achieve a reduction in these inputs of 50% or more between 1985 and 1995. In contrast, the Paris Commission of which Spain is a participating country, has done nothing in the way of agreeing to binding legislation for any of these toxic metals, with the exception of cadmium and mercury. The Hague Declaration requested the Paris Commission (PARCOM) to regard the non-ferrous metal industry as a priority area for reducing pollution. Although Spain is not a North Sea Conference signatory state, at the 1990 PARCOM meeting the Spanish delegation offered to take the lead on non-ferrous metals within the Working Group on Industrial Sectors. Spain's past record of action within, PARCOM, however is not good. It has often placed reservations on decisions and recommendations and has frequently dragged its feet in providing information and data to the Commission. It did, however, participate in a 1985 baseline study of marine contamination, and the Spanish coast near Santander was found to be exceptionally polluted by cadmium, lead and zinc. CONCLUSION According to the Basque Country's Council of Urbanism, 12.6 million tonnes of industrial waste is produced annually in the Basque provinces alone. Virtually all of this material is disposed of without any control whatsoever. Until the Basque community can eliminate its waste problems, it is foolish to import more wastes into this region already drowning in its own effluent. The Basque country has the most to gain by leading the way in Europe by being the first region to declare self-sufficiency by waste elimination and the implementation of clean production methods. To begin this process they must plug the hazardous waste import "pipeline". The Basque people have long held concerns for their rights and autonomy. A clean healthy environment must also be recognised as a human right which must be struggled for like any other. The alleged choice between health and jobs is a myth perpetuated by profit margin analysts. A healthy economy and environment will be achieved when people demand it. The hopelessness that can pervade a horribly polluted area like Bilbao is a disease which can be healed by action. Even ecological disaster zones like the Ria del Nervion estuary can be cleaned up and the ecosystem restored. Waste production and discharge in the region can be dramatically reduced. Bilbao need not become the sacrificial ash heap for the rest of Europe. And the very first step in the healing process is to stop taking poisons from abroad, whether for dumping or recycling. The recycling of hazardous waste must be seen for what it is - a bandage on a waste disease. Recycling is not waste prevention. It is not clean production. When we resort to recycling we have already lost the major battle against waste - we have allowed it to be produced. Greenpeace recognises that recyclers cannot be blamed for the fact that the waste stream they process are contaminated hazardous chemicals. In fact most recyclers would prefer to process only non-hazardous waste stream. However many like ASER are making money from the service of "disposal" and are actually paid to receive waste because of their hazard. Greenpeace is not opposed to recycling as long as the processes used are non-hazardous, no pollutants are released to the environment, and the product is compatible with, and can be reintroduced safely into, the natural environment or looped back into the original process. However, our first concern must always be to prevent hazardous waste generation in the first place. As we have already noted, ASER is not one of the worst polluters in all of Europe or even Bilbao. But ASER is a serious polluter and an excellent reminder of the limitations of managing wastes after they have been produced. The end-of-the-pipe "solutions" of "pollution control" have merely served to collect or concentrate waste. And that waste - like the 400,000 tonnes of steel dusts caught annually in the pollution filters of Western Europe - has to go somewhere. Once such hazardous wastes are produced, any recovery methods are themselves going to be hazardous and wasteful. The steel cycle itself is revealed in this study to be an incredibly wasteful and polluting production process. The polluting extraction and refinement of ore; the overconsumption and use of non-reusable energy-inefficient cars and major appliances with built-in obsolescence; the lack of energy- and resource-efficient transport systems; the use of lead, chlorinated plastics, and other dangerous chemicals in our products - all conspire to create massive volumes of toxic waste. ASER alone produces wastes at the rate of more than 75% of the total volume of steel dusts it receives. The rest of the material, still toxic, is dumped in the environment or passed on to the ISF smelter which in turn dumps more than half of its input material into the environment. Each year, by its own data, ASER is estimated to be losing over 7,000 tonnes of zinc, 1,350 tonnes of lead, 44 tonnes of arsenic, and 14.5 tonnes of cadmium to the immediate environment. In addition, approximately 200 grams of dioxins (TCDD equivalents) are probably released into the environment from ASER each year. [end]