VGB POWERTECH 10 (2020) - International Journal for Generation and Storage of Electricity and Heat

Implementation of Basic Requirement in harmonized product standards VGB PowerTech 10 l 2020
Tab. 1. Limit values for content and concrete for
fly ash from co-combustion in Germany
(emission E64d) [16].
Parameter content concrete
leaching
[mg/kg] [mg/m 2 ]
antimony (Sb) 5.5
arsenic (As) 150 11
barium (Ba) 375
lead (Pb) 700 7.7
bromium (Br)
cadmium (Cd) 10 0.56
chromium VI (Cr) 6.6
Chromium, total(Cr) 600 7.7
cobalt (Co) 8.8
copper (Cu) 400 15.4
molybdenium (Mo) 38.6
nickel (Ni) 500 15.4
mercury (Hg) 5 0.22
selenium (Se)
thallium (Tl) 7 0.88
vanadium (V) 1,500 4.4*
zink (Zn) 1,500 63.9
tin (Sn)
chloride (Cl-) 27,5515
fluoride (F-) 826
sulfate (SO42-) 26,4495
PAK16 30
PCB6 0.5
PCDD/PCDF
* evaluation adjourned
** TE = toxicity equivalent
100 ng/
kgTE**
and not the constituent for producing concrete.
The so-called NL BSB Productcertificaat
(Dutch Building materials Decree product
certificate) is used in the market to prove
that the requirements of the decree [18]
are fulfilled. A product certificate can be
declared for the product (group) of one
company or for a cluster of companies with
the same product (group). The minimum
test frequency has to be derived based on
the k-concept (different from the k-value
for use of fly ash in concrete) or the gamma-scheme
[18].
It is obvious from Ta b l e 1 and Ta b l e 2
that the limit values for leachates from concrete
in the two countries are different.
But also the evaluation systems are different
as they were developed separately
with different background consideration
(place of evaluation, sorption capacity of
soils, …) .
The implementation of BWR 3 into harmonised
product standards requires:
––
Parameters, methods and limit values,
––
Evaluation scheme for auto control and
third party control.
Tab. 2. Limit values maximum leaching
inorganic compounds for bound applications
in NL (emission E64d) [18].
Parameter
concrete
leaching
[mg/m 2 ]
antimony (Sb) 8.7
arsenic (As) 260
barium (Ba) 1,500
lead (Pb) 400
bromium (Br) 670
cadmium (Cd) 3.8
chromium VI (Cr)
Chromium, total(Cr) 120
cobalt (Co) 60
copper (Cu) 98
molybdenium (Mo) 144
nickel (Ni) 81
mercury (Hg) 1.4
selenium (Se) 4.8
thallium (Tl)
vanadium (V) 320
zink (Zn) 800
tin (Sn) 50
chloride (Cl-) 110,000
fluoride (F-) 2,500
sulfate (SO42-) 165,000
It further requires producers to declare
the environmental performance of products
according harmonized product standards.
Based on the CPR [2], this can be
done by declared values or by classes with
the consequence that the customer finally
has to decide whether the product can be
used according national limit values. In
both cases the required parameters have to
be listed in the Declaration of Performance
(DoP) and CE-mark. The EC and
CEN prefer declared values or classes as
required by the CPR. The use of declared
values is also the easiest way to prepare a
standard. But placing a product on the
market is not the responsibility of the EC
as free trade is the overall aim. Therefore,
the consequences of such requirements
regarding perception of customers for
products on the existing and long term
served market is not sufficiently considered
by now. A list of trace parameter with
maximum declared values or with classes
based on minimum and maximum values
in the DoP and/or CE-mark will result
in confusion in the market, will not promote
free movement of goods and use of
secondary materials, and is finally against
competition for materials with testing
needs as not for all materials environmental
requirements exist. It is obvious that a
fly ash with a long list of environmental
parameters (F i g u r e 4 ) like arsenic, cadmium,
chromium, ... , will not be used
when the competing product does not need
such a declaration. The confusion or mistrust
will further grow if such a fly ash has
to place always NPD indicating that the
producer may not be willing to declare the
values or to perform such tests. Competing
construction products without testing
needs will be preferred as causing no additional
work for constructors regarding
environmental requirements and work
load to control whether declared values are
meeting national requirements.
Based on the requirements of existing environmental
regulations WG 4 has proposed
a system of categories to allow neutral information
on BWR3 in DoP and CE-mark
[19]. By this, a “category” is defined as “a
set or parameters, test procedures (as developed
by TC 351) and limit values to be
considered in a member state”. For each
type of requirement (organics, content,
leaching, concrete leaching) a category has
to be defined for requirements in a member
state leading to maximum three lines (organics,
content, concrete leaching) for declaring
environmental performance in
DoP and CE-mark. In member states without
respective environmental requirements
NPD (no performance determined – or better:
no test required) can be placed. This
process however requires the preparation
of a delegated act by the EC. As this is a
time consuming process which will lead
to a further postponement of the revision
work of the standard, WG 4 has also proposed
to consider the existing experience
in the countries where requirements for either
release into soil and ground or for
radioactivity have to be provided in a test
report which is considered “neutral”, and
in case of radioactivity also to be declared
by partly nuclide concentration or an
index.
Examples for the Declaration of Performance
and/or CE marking by the four options
“Declared values” , “Classes”, “Categories”
and “Existing Systems” are given in
F i g u r e 4 . It is obvious that the declaration
via declared values and classes leads
to a long list of parameters for environment
which are predominant to the few technical
parameters. The declaration via categories
and by existing systems however, allow
the information on environmental parameters
by a few lines only.
In June 2018, TC 104 has tasked WG 4 to
update the discussion paper on pros and
cons of the information systems by the systems
existing in the place of use. The updated
report was sent to TC 104 and other
TCs dealing with the revision of harmonized
product standard to develop a common
view for an acceptable solution on
environmental information in DoP and CEmark
for all construction products. It was
considered in a report of TC 104/WG14 on
health aspects for concrete and concrete
products provided as an input to TC 351/
WG1 which decided to deal with this issue
in a CEN Technical Report.
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