Technical Guidelines for the ESM of Dioxins and Furans
Wastes
Technical Guideline for Environmentally Sound Management of
Wastes Consisting of, Containing or Contaminated with
Polychlorinated Dibenzo-p-dioxins (PCDDs) and or Polychlorinated
Dibenzofurans (PCDFs) or both.
Comments from Germany: The title should read:“Technical
Guidelines for the Environmentally Sound Management of Wastes
consisting of, containing or contaminated with the polychlorinated
dibenzo-p-dioxins (PCDDs), polychlorinated dibenzofurans (PCDFs) or
unintentionally produced polychlorinated biphenyls (PCBs) or
hexachlorobenzene (HCB)”Rationale: see General technical
guidelines, para. 2e and PCB guidelines, para. 4.
Comments from the World Chlorine Council: TITLE:The present
title is slightly misleading due to the use of the word “and”. It
is of course intended that this guideline should apply to wastes
contaminated with either PCDDs or PCDFs or both – not only those
wastes contaminated with substances from both groups. Replace the
word “and” by “and/or”.
Prepared by:
The Australian Government Department of the Environment and
Heritage
Draft of 22 April 2005
Table of Contents
11.0Introduction
11.1Scope
21.2Description, production and use, and wastes
21.2.1Description
41.2.2Production and use
51.2.3Wastes
62.0Relevant provisions in the Basel and Stockholm
Conventions
62.1Basel Convention
112.2Stockholm Convention
143.0Provisions of the Stockholm Convention to be addressed
cooperatively with the Basel Convention
143.1Low PCDDs and PCDFs content
143.2Levels of destruction and irreversible transformation
143.3.Methods that constitute environmentally sound destruction
and disposal
143.3.1Destruction or irreversible transformation methods
143.3.2Other disposal methods when PCDDs and PCDFs content is
low
153.3.3Other disposal methods when destruction or irreversible
transformation does not represent the environmentally preferable
option
164.0Guidance on Environmentally Sound Management
164.1.1Basel Convention
164.1.2Stockholm Convention
174.1.3OECD
174.2Legislative and regulatory framework
174.3Waste prevention and minimisation
184.4Identification and inventories
184.4.1Identification
194.4.2Inventory
194.6Handling, collection, packaging, transportation and
temporary storage
194.6.1Handling
204.6.2Collection
204.6.3Packaging
204.6.4Labeling
214.6.5Transport
214.6.6Storage
234.7Environmentally sound destruction and disposal
234.7.1Pre-treatment
244.7.2Destruction and irreversible transformation methods
424.7.3Other disposal methods when the PCDDs and PCDFs content
is low
454.8Remediation of contaminated sites
454.9Health and safety
464.9.1High-volume, high-concentration or high-risk
situations
474.9.2Low-volume, low-concentration sites or low-risk
situations
474.10Public participation
51References
52Appendices
53Appendix 1. WHO TEFs for PCDDs, PCDFs and PCBs
54Appendix 2: Relevant documents and guidelines/references
Abbreviations and Acronyms
AOPAdvanced oxidation process
BCDBase catalysed destruction
COPConference of the Parties
DDTDichlorodiphenyltrichlroethane
Dichlorodiphenyltrichloroethane
(1,1,1-trichloro-2,2-bis(4-chlrophenyl 4-chlorophenyl)ethane)
ESMEnvironmentally sound management
GPCRGas phase chemical reduction
HASPHealth and Safety Plan
HCBHexachlorobenzene
LTTDLow-temperature thermal desorption
MSOMolten salt oxidation
OECDOrganization for Economic Cooperation and Development
PCBsPolychlorinated biphenyls
PCDDsPolychlorinated dibenzo-p-dioxins
PCDFsPolychlorinated dibenzofurans
POPsPersistent organic pollutants
SCWOSuper-critical water oxidation
SETSolvated electron technology
TCDD2,3,7,8-tetrachlorodibenzo-p-dioxin
TEFsToxic equivalency factors
TEQToxic equivalence
2,4,5-T2,4,5-trichlorophenoxyacetic acid
WHOWorld Health Organization
Comments from the World Chlorine Council: ABBREVIATIONS AND
ACRONYMS: Replace “Dichlorodiphenyltrichlroethane” by
“Dichlorodiphenyltrichloroethane” and replace “4 chlrophenyl” by
“4-chlorophenyl”.
Editor’s note
Throughout this draft:
Comments are written in italics
Proposed insertions are underlined
Proposed deletions are in strikethrough.
1.0Introduction1.1Scope
1.This Technical Guideline provides guidance for the
environmentally sound management (ESM) of wastes consisting of,
containing, or contaminated with polychlorinated dibenzo-p-dioxins
(PCDDs) and or polychlorinated dibenzofurans (PCDFs) or both in
accordance with: decisions V/8, V/26 and VI/23 of the Conference of
the Parties to the Basel Convention on the Control of Transboundary
Movement of Hazardous Wastes and Their Disposal; decisions OEWG-I/4
and OEWG-II/10 of the Open-ended Working Group of the Basel
Convention; resolution 5 of the Conference of Plenipotentiaries to
the Stockholm Convention on Persistent Organic Pollutants; and
decisions INC/6/8, INC/7/6 and INC/7/8 of the Stockholm Convention
Intergovernmental Negotiating Committee.
Comments from the World Chlorine Council: Paragraph 1: Replace
“and” by “and/or” in the title of the present guideline (see
comment above on the title).
2. The PCDDs and PCDFs are included in Annex C of the Stockholm
Convention (“Unintentional Production”) as POPs that are formed and
released unintentionally from anthropogenic sources.
Comments from the World Chlorine Council: Replace “Annex C” by
“Annex C of the Stockholm Convention”
3. Topics addressed in this guidance document for PCDDs and
PCDFs wastes include waste management, treatment, destruction and
disposal practices, including discarded/expired materials
contaminated with these chemicals, such as waste stockpiles; waste
products and articles; residues captured during production and
waste treatment processes; and materials in remediation sites (e.g.
contaminated soil, sediment and groundwater), where these sites
have been identified for cleanup.
4. This document should be used in conjunction with the General
Technical Guidelines for Environmentally Sound Management of Wastes
Consisting of, Containing or Contaminated with Persistent Organic
Pollutants. This document provides more information on the nature
and occurrence of PCDDs and PCDFs wastes for purposes of their
identification and management.
5. The Polychlorinated Biphenyls (PCBs) and Hexachlorobenzene
(HCB) are also listed under Annex C of the Stockholm Convention as
unintentionally produced POPs. However, these POPs were also
intentionally produced and their concentrations in wastes are
dominated by commercial production and application considerations,
which are the subject of other technical guidance documents.
However, while not the subject of the current guidance document,
the topics addressed here would also apply to wastes consisting of,
containing, or contaminated with unintentionally produced PCBs and
HCB.
Comments from Germany: The text should be extended to also cover
unintentionally produced polychlorinated biphenyls (PCBs) or
hexachlorobenzene (HCB)
Comments from the United Kingdom: We support the German proposal
to extend the guidelines to include unintentionally produced PCBs
and HCB. A comment to this effect is already made in para 5, but
this needs to be carried through the text. This will make the
guideline consistent with the cross-reference to it made in
paragraph 3 of the pesticide guideline. Also, an explicit
discussion of dioxin-like PCBs is required in the context of
measurement and definition of low POPs contents, as dioxin-like
PCBs are included in some definitions of 'TEQ'.
Comments from the World Chlorine Council: Paragraph 5: This is
very useful wording and should allow the guidelines on HCBs and
PCBs, in the interest of efficiency and clarity, to minimise any
text that relates specifically to unintentionally produced HCBs or
PCBs by cross-reference to the present guideline. However, there is
a bit of a problem inasmuch as the sources of unintentionally
produced HCBs (and to a lesser extent PCBs) are somewhat different
to those of PCDDs/PCDFs. There is a much wider range of potential
sources for PCDDs/PCDFs than for HCB. Is it possible to slightly
restructure the document so that the material in common for all
unintentionally produced POPs (principally the guidance on ESM) is
applied to all, but so that the material, inter alia n sources, is
stated to be specific to PCDDs/PCDFs?
1.2Description, production and use, and wastes
1.2.1Description
6. The PCDDs and PCDFs are tricyclic halogenated aromatic
hydrocarbons, comprising two benzene rings connected by two oxygen
atoms at adjacent carbons on each of the benzene rings in PCDDs and
by one oxygen atom and one carbon-carbon bond at adjacent carbons
in PCDFs, and at least one two (usually four to eight) chlorine
atoms substituted for hydrogen; the basic structures are shown in
Figure 1.
(A)
(B)
o
o
9
8
7
6
1
2
3
4
o
9
8
7
6
4
3
2
1
Figure 1. The structures of dibenzo-p-dioxins (A) and
dibenzofurans (B)
Comments from Argentina: Paragraph 6: Furan structural formula
in inverted. It has to be amended.
Comments from World Chlorine Council: Add “at adjacent carbons”
after “carbon-carbon bond” for consistency with the text on PCDDs.
Replace “at least one” by “at least two (usually four to eight)”.
Polychlorinated dioxins and furans by definition must contain at
least two chlorine atoms.In figure 1 the generic structural formula
for polychlorinated dibenzofurans has been inverted and, as a
result, the numbering of the carbon atoms reversed. The correct
figure for PCDFs is similar in orientation and numbering to that
for the PCDDs, i.e.
7. Both groups of chemicals may have up to eight chlorine atoms
attached at carbon atoms 1 to 4 and 6 to 9. Each individual
compound resulting from this is referred to as a congener. The
number and position of chlorine atoms around the aromatic nuclei
distinguish each specific congener. In total, there are 75 possible
PCDD congeners and 135 possible PCDF congeners. The most widely
studied of the PCDDs and PCDFs is
2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD).
8. Congeners containing one, two or three chlorine atoms are
thought to be of little toxicological significance. However, 17
congeners with chlorine atoms substituted in the 2, 3, 7 and 8
positions (i.e. in the lateral positions of the aromatic rings) are
thought to pose a health and environmental risk. Increasing
substitution from four to eight chlorine atoms generally results in
a marked decrease in potency.
9. The PCDDs and PCDFs have very low water solubility, high
octanol-water partition coefficients, low vapour pressure and
adsorb strongly to particles and surfaces and are resistant to
chemical and biochemical degradation under normal environmental
conditions. Thus, they are persistent in the environment and their
high fat solubility results in their bioconcentration into biota
and accumulation in the food chain. Almost all 210 individual PCDD
and PCDF congeners have been identified in emissions from thermal
and industrial processes and consequently they are found as
mixtures in environmental matrices such as soil, sediment, air,
plants and lower animals, although their low aqueous solubility
means they can hardly be detected in water and are largely immobile
in soils.
Comments from Germany: Para. 9: In line 2, insert “and
biochemical” after “chemical”.Rationale: Under normal environmental
conditions and if a degradation takes place at all, the biochemical
degradation of chemicals, mainly by microorganisms, plays an
important if not the dominant role.
10. When found in the environment, biological tissues and
industrial sources, the PCDDs and PCDFs are usually present as
complex mixtures and the different congeners vary significantly in
their toxicity. However, the potency of different dioxins can be
ranked relative to TCDD, the most toxic member of the dioxin class.
These rankings are known as toxic equivalency factors (TEFs).
11. The most recent review of TEFs was that of the WHO in 1998
(Van den Berg et al, 1998). This review has subsequently been
recognised by the United States Environmental Protection Agency (US
EPA) as being the most appropriate scheme for estimating the
toxicity of dioxin mixtures (US EPA, 2000). Under the WHO TEF
scheme shown in Appendix 1, TCDD is assigned a TEF of 1.0, and
other PCDDs and PCDFs have TEF values ranging from 1.0 down to
0.0001. To be included in the TEF scheme, a PCDD or PCDF must bind
to the cellular aryl hydrocarbon (Ah) receptor, elicit Ah
receptor-mediated biochemical and toxic responses, must be
persistent, and accumulate in the food chain (WHO, 1998). To
estimate the toxic potency of a given mixture of PCDDs and PCDFs,
the mass concentration of each individual component is multiplied
by its respective TEF, and the products are summed to represent the
TCDD toxic equivalence (TEQ) of the mixture. The WHO TEF scheme
also includes those PCBs congeners that are considered to exhibit
dioxin-like characteristics for which the WHO has also developed
toxicity equivalency factors to TCDD ranging from 0.1 down to
0.00001.
Comments from Canada: WHO-TEQ and I-TEQ, Paragraph 11 and
Appendix 1: We are of the view that the Technical Guideline should
elaborate on the I-TEQ as well as the WHO-TEQ given that the former
is widely used internationally. I-TEQ is a toxic equivalent factor
"consistent with accepted international standards" as per the
Stockholm Convention text on WHO-TEQ in Annex C Part IV paragraph 2
which promotes but does not insist on exclusive use of the WHO-TEQ.
Note: we will try to send relevant information on I-TEQ
shortly.
Comments from the World Chlorine Council: Paragraph 11:In the
final sentence, replace “which the WHO” by “,for which the
WHO”.
1.2.2Production and use
12. The PCDDs and PCDFs have never been intentionally produced
or used commercially except in very small quantities for analytical
and research purposes.
13. The PCDDs and PCDFs are regarded as trace contaminants in a
number of chemical products and they are formed as by-products
during various industrial, chemical and combustion processes. They
are formed as undesirable waste products during industrial
processes where carbon-containing organic material is incinerated
in the presence of chlorine. The PCDDs and PCDFs are regarded as
trace contaminants in a number of chemical products. They may also
be formed as unintended by-products in certain industrial and
combustion processes where heating takes place under conditions of
poor mixing and at relatively low temperatures. They may thus be
formed as unintended and undesirable waste products during certain
processes where carbonaceous material is heated in the presence of
organic or inorganic chlorinated substances (including sodium
chloride, i.e. common salt). These processes include the
manufacture of chemicals including chlorophenols and herbicides
like 2,4,5-trichlorophenoxyacetic acid (2,4,5-T), and in combustion
or incineration processes such as waste incinerators and fossil
fuel power plants.
Comments from Argentina: The mentioned thermal processes are not
the only ones, having the potential for formation and release of
these pollutants. Citing Stockolm Convention “...Polychlorinated
dibenzo-p-dioxins and dibenzofurans, hexachlorobenzene and
polychlorinated biphenyls are unintentionally formed and released
from thermal processes involving organic matter and chlorine as a
result of incomplete combustion or chemical reactions…”. A
reference should be made to the BAT/BEP Draft Guidance/Guidelines,
regarding the favourable conditions for releasing and de novo
synthesis.
We suggest replacing “in combustion or incineration processes
such as waste incinerators and fossil fuel power plants” by “in
combustion processes under specific conditions (e.g. temperature,
residence time, humidity, catalyst presence, etc.)”
Comments from the World Chlorine Council: Paragraph
13:PCDDs/PCDFs are only formed in industrial, etc.
thermal/incineration/combustion processes under conditions of poor
mixing and low temperature – and even then not always. Chlorine is
never present as such in wastes – the reference should be to
organic or inorganic chlorinated substances.
Replace the first two sentences of the paragraph by the
following:
“The PCDDs and PCDFs are regarded as trace contaminants in a
number of chemical products. They may also be formed as unintended
by-products in certain industrial and combustion processes where
heating takes place under conditions of poor mixing and at
relatively low temperatures. They may thus be formed as unintended
and undesirable waste products during certain processes where
carbonaceous material is heated in the presence of organic or
inorganic chlorinated substances (including sodium chloride, i.e.
common salt). “
In the last sentence, replace “waste incinerators” by “waste
incinerators (when poorly designed, or when operated at inadequate
temperatures and/or insufficient residence times)”. Not all waste
incinerators necessarily generate dioxins.
14. The PCDDs and PCDFs also enter the environment from
non-industrial and natural sources including domestic wood and
waste burning, uncontrolled forest fires, vehicle emissions and
tobacco smoke.
Comments from Germany: Para. 14: In line 2, delete
“uncontrolled”.Rationale: Controlled forest fires may also release
PCDDs and PCDFs.
1.2.3Wastes
15. Types of products, containers and wastes that may consist
of, contain or be contaminated with PCDDs and PCDFs include:
Solids
· Contaminated soils and sediments (sites contaminated by:
pesticide use of certain pesticides including ‘Agent Orange’;
treated wood; open burning and chemical industries);
· Contaminated rock and mine aggregates (excavated bedrock,
gravel, rubble, slag, spent shale);
· Contaminated sludge (containing industrially produced solids,
chemicals and liquids);
· Contaminated solid waste (paper, metal products, plastic, auto
shredder fluff, painted objects, demolition debris etc.);
· Combustion fly and bottom ashes (incinerators, power plants,
kilns, refineries);
· Drained equipment with liquid residues (electrical, hydraulic
or heat transfer equipment, engines, pesticide application);
· Drained containers with liquid residues (oil drums, plastic
drums, pesticide bottles, storage tanks);
· Contaminated wood (PCB painted, pesticide impregnated);
Liquids
· Contaminated oils (contained within or drained from
electrical, hydraulic, engine or heat transfer equipment);
· Certain pesticide formulations (herbicides, wood
preservation);
· Mixed organic liquid wastes (paints, oils, solvents); and
· Contaminated process water (industrial effluent, pollution
control scrubbers and curtains, quench waters, sewer).
· Landfill effluents
Comments from European Federation of Waste Management and
Environmental Services: 1.2.3 Wastes, liquids: Remove pollution
control scrubbers and curtains. Rationale: Dioxins are hydrophobic
(not water soluble) and are therefore only found in the solid
residues of waste treatment. Do not include landfill effluent, as
proposed by Germany, as a source of dioxins. Rationale: same as
above.
Comments from Germany: Para. 15: Under the heading “Liquids”,
add the following new indent at the end:Landfill effluents
Rationale: Landfill effluents may be contaminated by PCDDs/PCDFs.
Example: In 1988, such effluents of the German landfill
Hamburg-Georgswerder have been decontaminated.
Comments from the World Chlorine Council: Paragraph 15: In the
first bullet under “solids”, replace “pesticide use” by “the use of
certain pesticides”. Most pesticides do not generate dioxins.In the
second bullet under “liquids”, replace “pesticide formulations” by
“certain pesticide formulations”. Most pesticides do not generate
dioxins.This paragraph is correctly stated to apply to PCDDs/PCDFs.
Most of these sources are not relevant for HCB and PCBs (see §5
above); this should maybe be made more explicit.
16. In addition, Part II & III of Annex C of the Stockholm
Convention lists source categories that have the potential for
formation and release of PCDDs and PCDFs to the environment, see
section 2.1 (“Basel Convention”) and section 2.2 (“Stockholm
Convention”) of this guidance document.
Comments from Canada: 1.2.3 Wastes list - paragraph 16 - Should
not only mention the Stockholm Convention list of wastes in section
2.2 but also refer to the Basel Convention list of wastes in
section 2.1.
2.0Relevant provisions in the Basel and Stockholm
Conventions
Comments from the World Chlorine Council: General: Section 2.0:
This section remains inconsistent in many places with the text of
the Conventions. All – or at least most – of this section should be
removed, as suggested both by the Secretariat to the Basel
Convention and by the USA in comments that were excluded by the
consultants from consideration. This topic needs to be on the
agenda for OEWG-3. The general principles should be:
- Include in the guideline only material that cannot readily be
accessed elsewhere. It is reasonable to assume that readers,
particularly regulators (who, we understand, are the primary
intended audience) have access to the texts of the Conventions and
their annexes.
- Where reference is made to either of the Conventions, their
text should be cited verbatim. These treaty texts were negotiated
with great care and at great length. The subtleties of the text may
not be immediately apparent to those not involved in those
negotiations, but are important. It is not the rôle of the
guideline to interpret the Conventions – this would usurp the
authority of the relevant Conference of the Parties, and could lead
to great confusion. There are many examples of this, still, in the
present draft. Many of the detailed comments that follow could be
dealt with most simply by the deletion of Section 2 of the
guideline
2.1Basel Convention
17. Article 2 (“Definitions”), paragraph 1 defines wastes as
“substances or objects which are disposed of or are intended to be
disposed of or are required to be disposed of by the provisions of
national law”. A stockpile of a material would, therefore, be
considered a waste if it is intended for disposal or disposal is
required by national law. Paragraph 8 defines ESM of hazardous
wastes or other wastes as “taking all practicable steps to ensure
that hazardous wastes or other wastes are managed in a manner which
will protect human health and the environment against the adverse
effects which may result from such wastes”.
18. Article 4 (“General Obligations”), paragraph 2 (a) through
(d) contain key provisions of the Basel Convention pertaining to
ESM, waste minimisation, and waste disposal practices that protect
or minimise adverse effects on human health and the environment.
Paragraph 8 further elaborates that “Each Party shall require that
hazardous wastes or other wastes, to be exported, are managed in an
environmentally sound manner in the State of import or elsewhere.
Technical guidelines for the environmentally sound management of
wastes subject to this Convention shall be decided by the Parties
at their first meeting.” This technical guidance document is
intended to provide a more precise meaning to ESM in the context of
PCDDs and PCDFs wastes, including which treatment, destruction and
disposal methods are appropriate for these waste streams.
19. Article 1 (“Scope of the Convention”), paragraph 1(a)
determines a “hazardous waste” that is subject to the Convention as
a waste that belongs to any category contained in Annex I
(“Categories of Wastes to be Controlled”), unless it does not
possess any of the characteristics listed in Annex III (“List of
Hazardous Characteristics”).
20. Annex I lists categories of wastes to be controlled that are
presumed to exhibit an Annex III hazardous characteristic, which
includes: H6.1 “Poisonous (Acute)”; H11 “Toxic (Delayed or
Chronic)”; and H12 “Ecotoxic”. The waste categories that may
consist of, contain or be contaminated with PCDDs and PCDFs wastes
include:
Waste Streams:
Y2Wastes form the production and preparation of pharmaceutical
products
Y4Wastes from the production, formulation and use of biocides
and phytopharmaceuticals
Y5Wastes from the manufacture, formulation and use of wood
preserving chemicals
Y6Wastes from the production, formulation and use of organic
solvents
Y8Waste mineral oils unfit for their originally intended use
Y9Waste oils/water, hydrocarbons/water mixtures, emulsions
Y10Waste substances and articles containing or contaminated with
polychlorinated byphenyls (PCBs) and/or polychlorinated terphenyls
(PCTs) and/or polybrominated biphenyls (PBBs)
Y11Waste tarry residues arising from refining, distillation and
any pyrolytic treatment
Y12Wastes from production, formulation and use of inks, dyes,
pigments, paints, lacquers, varnish
Y13Wastes from production, formulation and use of resins, latex,
plasticizers, glues/adhesives
Y14Waste chemical substances arising from research and
development or teaching activities which are not identified and/or
are new and whose effects on man and/or the environment are not
known
Y18Residues arising from industrial waste disposal
operations
Wastes having as constituents:
Y39Phenols; phenol compounds including chlorophenols
Y41Halogenated organic solvents
Y43Any congenor of polychlorinated dibenzo-furan
Y44Any congenor of polychlorinated dibenzo-p-dioxin
Y45Organohalogen compounds other than substances referred to in
this Annex (e.g. Y39, Y41, Y42, Y43, Y44).
Comments from the World Chlorine Council: Paragraph 20: If this
section is retained it requires some editorial work – perhaps by
the Secretariat to the Basel Convention and the Interim Secretariat
to the Stockholm Convention. Some of the categories included seem a
little strange and some reference should be provided for the view
that certain “Y numbers” may consist of, or be contaminated with,
PCDDs/PCDFs. In general, it would seem wiser to restrict comment to
the categories described in the Stockholm Convention. Examples of
categories where the occurrence of PCDDs/PCDFs seems on the whole
to be unlikely are: Y2, Y4, Y12, Y13 and Y14. If certain Y
categories are to be picked out, it would probably be more useful
to stick to categories at least consistent with Annex C of the
Stockholm Convention.
While it is recognised that this paragraph is intended to key
into the Basel Convention, a much better list of relevant wastes is
in fact given in §53 below.This paragraph is correctly stated to
apply to PCDDs/PCDFs. Most of these sources are not relevant for
HCB and PCBs (see §5 above); this should maybe be made more
explicit.
21. List A of Annex VIII contains wastes that are “characterized
as hazardous under Article 1, paragraph 1(a)” and “their
designation on this Annex does not preclude the use of Annex III to
demonstrate that a waste is not hazardous”. List B of Annex IX
contains wastes that “will not be wastes covered by Article 1,
paragraph 1(a), unless they contain Annex I material to an extent
causing them to exhibit an Annex III characteristic”. The following
wastes are applicable may contain or be contaminated with to PCDDs
and PCDFs:
A1090Ashes from the incineration of insulated copper wire
A1100Dusts and residues from gas cleaning systems of copper
smelters
A11501Precious metal ash from incineration of printed circuit
boards not included on list B
A11802Waste electrical and electronic assemblies or scrap
containing components such as accumulators and other batteries
included on list A, mercury-switches, glass from cathode-ray tubes
and other activated glass and PCB-capacitors, or contaminated with
Annex I constituents (e.g., cadmium, mercury, lead, polychlorinated
biphenyl) to an extent that they possess any of the characteristics
contained in Annex III (note the related entry on list B
B1110)3
A2030Waste catalysts but excluding such wastes specified on list
B
A2040 Waste gypsum arising from chemical industry processes,
when containing
Annex I constituents to the extent that it exhibits an Annex III
hazardous
characteristic (note the related entry on list B B2080)
A2060Coal-fired power plant fly-ash containing Annex I
substances in concentrations sufficient to exhibit Annex III
characteristics (Note the related entry on list B B2050)
A3010Waste from the production or processing of petroleum coke
and bitumen
A3020Waste mineral oils unfit for their originally intended
use
A3030Wastes that contain, consist of or are contaminated with
leaded anti-knock compound sludges
A3040Waste thermal (heat transfer) fluids
A3050Wastes from production, formulation and use of resins,
latex, plasticizers, glues/adhesives excluding such wastes
specified on list B (note the related entry on list B B4020)
A3070Waste phenols, phenol compounds including chlorophenol in
the form of liquids or sludges
A3090Waste leather dust, ash, sludges and flours when containing
hexavalent chromium compounds or biocides (note the related entry
on list B B3100)
A3100Waste paring and other waste of leather or of composition
leather not
suitable for the manufacture of leather articles containing
hexavalent
chromium compounds or biocides (note the related entry on list B
B3090)
A3110 Fellmongery wastes containing hexavalent chromium
compounds or
biocides or infectious substances (note the related entry on
list B B3110)
A3140Waste non-halogenated organic solvents but excluding such
wastes specified on list B
A3150Waste halogenated organic solvents
A3160Waste halogenated or unhalogenated non-aqueous distillation
residues arising from organic solvent recovery operations
A3170Wastes arising from the production of aliphatic halogenated
hydrocarbons (such as chloromethane, dichloro-ethane, vinyl
chloride, vinylidene chloride, allyl chloride and
epichlorhydrin)
A3180:wastes, substances and articles containing, consisting of
or contaminated with polychlorinated biphenyl (PCB),
polychlorinated terphenyl (PCT), polychlorinated naphthalene (PCN)
or polybrominated biphenyl (PBB), or any other polybrominated
analogues of these compounds, at a concentration level of 50 mg/kg
or more4
A3190Waste tarry residues (excluding asphalt cements) arising
from refining, distillation and any pyrolitic treatment of organic
materials
A4010Wastes from the production, preparation and use of
pharmaceutical products but excluding such wastes specified on list
B
A4030Wastes from the production, formulation and use of biocides
and phytopharmaceuticals, including waste pesticides and herbicides
which are off-specification, out-dated5, or unfit for their
originally intended use
A4040Wastes from the manufacture, formulation and use of
wood-preserving chemicals6
A4070Wastes from the production, formulation and use of inks,
dyes, pigments, paints, lacquers, varnish excluding any such waste
specified on list B (note the related entry on list B B4010)
A4100Wastes from industrial pollution control devices for
cleaning of industrial off-gases but excluding such wastes
specified on list B
A4110Wastes that contain, consist of or are contaminated with
any of the following:
· Any congenor of polychlorinated dibenzo-furan
· Any congenor of polychlorinated dibenzo-p-dioxin
A4130Waste packages and containers containing Annex I substances
in concentrations sufficient to exhibit Annex III hazard
characteristics
A4140Waste consisting of or containing off specification or
out-dated chemicals corresponding to Annex I categories and
exhibiting Annex III hazard characteristics
A4150Waste chemical substances arising from research and
development or
teaching activities which are not identified and/or are new and
whose
effects on human health and/or the environment are not known
A4160Spent activated carbon not included on list B (note the
related entry on list B B2060).
Note that mirror entry on list B (B1160) does not specify
exceptions.
2 This entry does not include scrap assemblies from electric
power generation.
3 PCBs are at a concentration level of 50 mg/kg or more.
4 The 50 mg/kg level is considered to be an internationally
practical level for all wastes. However,
many individual countries have established lower regulatory
levels (e.g., 20 mg/kg) for specific wastes.
5 “Outdated” means unused within the period recommended by the
manufacturer.
6 This entry does not include wood treated with wood preserving
chemicals.
.
Comments from Argentina: We suggest the addition of following
potential sources: A1990, A2030, 2040,A3100, A3110, A4150. (see
Stockolm Convention: “Part III of Annex C lists source categories
that may have the potential for the formation and release of
unintentionally produced POPs”)
Comments from Germany: Paras. 20 and 21: The text of the entries
should be checked; in particular any footnotes for the A entries
should be inserted.
Comments from the World Chlorine Council: Paragraph 21: It is
not clear why wastes listed in Annex IX, i.e. List B, are likely to
contain POPs. As List B is intended to be a list of wastes that are
not covered by Article 1(a) of the Convention. Admittedly they
could be covered by Article 1(a) if they contain sufficient of an
Annex I material that they exhibit an Annex III characteristic, but
this is not necessarily the case for any particular waste. This is
a complex subject, still under active discussion under the Basel
Convention. It would be better to omit references to List B and to
list B categories in this paragraph. In fact the particular List B
wastes specifically mentioned (B3060 and B4020) are not
particularly likely to contain significant amounts of a POP. Best
of all, the whole of section 2 should be deleted as recommended
above and by several other commentators.If the section is to be
retained, replace “are applicable to” in the final sentence of the
chapeau by “may contain or be contaminated with”.Among the
categories that seem unlikely members of the “A list” are A3030,
A3050, A3090, A3140, A3160, A4010, A4070, A4130 and A4140. While it
is recognised that this paragraph is intended to key into the Basel
Convention, a much better list of relevant wastes is in fact given
in §53 below.This paragraph is correctly stated to apply to
PCDDs/PCDFs. Most of these sources are not relevant for HCB and
PCBs (see §5 above); this should maybe be made more explicit.
22. Disposal is defined by a broad range of options specified in
Section A of Annex IV (“Disposal Operations”), “which do not lead
to the possibility of resource recovery, recycling, reclamation,
direct re-use or alternative uses”. Those that are suitable for
PCDDs and PCDFs wastes include:
D9physico-chemical treatment not specified elsewhere in this
Annex which results in final compounds or mixtures which are
discarded by means of any of the operations in Section A, (e.g.,
via evaporation, drying, calcination, neutralization, precipitation
etc.)
D13Blending or mixing prior to submission to any of the
operations in Section A
D14Repackaging prior to submission to any of the operations in
Section A
D15Storage pending any of the operations in Section A.
Comments from the World Chlorine Council: Paragraph 22 is
correctly stated to apply to PCDDs/PCDFs. Most of these sources are
not relevant for HCB and PCBs (see §5 above); this should maybe be
made more explicit.
23. The disposal options also features two destruction options
that may occur in practice for PCDDs and PCDFs wastes:
D10Incineration on land
D11Incineration at sea.
24. Several of the Annex IV disposal options entail long-term
storage of hazardous wastes that may occur in practice for PCDDs
and PCDFs wastes:
D3Deep injection, (e.g., injection of pumpable discards into
wells, salt domes or naturally occurring repositories, etc.)
D5Specially engineered landfill, (e.g., placement into lined
discrete cells which are capped and isolated from one another and
the environment, etc.)
D12Permanent storage (e.g., emplacement of containers in a mine,
etc.).
25. Section A of Annex IV also lists disposal operations that
are clearly unsuitable for wastes containing PCDDs and PCDFs, owing
to their toxicity, persistence and potential for bioaccumulation,
these include:
D2Land treatment, (e.g., biodegradation of liquid or sludgy
discards in soils, etc.)
D4Surface impoundment, (e.g., placement of liquid or sludge
discards into pits, ponds or lagoons, etc.)
D6Release into a water body except seas/oceans
D7Release into seas/oceans including sea-bed insertion
D8Biological treatment not specified elsewhere in this Annex
which results in final compounds or mixtures which are discarded by
means of any of the operations in Section A.
26. Section B of Annex IV (“Operations which may lead to
resource recovery, recycling, reclamation, direct re-use or
alternative uses”) “encompasses all such operations with respect to
materials legally defined as or considered to be hazardous wastes
and which otherwise would have been destined for operations
included in Section A”. The list of disposal methods that may occur
in practice for PCDDs and PCDFs wastes includes:
R1Use as a fuel (other than in direct incineration) or other
means to generate energy
R7Recovery of components used for pollution abatement
R9Used oil re-refining or other reuses of previously used
oil.
Comments from Germany: Delete paragraphs 22-26.Rationale:
Content does not fit under the heading of the chapter.
Environmentally sound disposal is addressed in the General
technical guidelines in chapter G.
Comments from the World Chlorine Council: Paragraphs 22 to 26:
It is unclear whether this attempted listing of certain disposal
operations and recovery, etc. operations is of any value in the
present guideline. If these paragraphs are to be retained a more
critical analysis may be required.
2.2Stockholm Convention
27. The objective of the Stockholm Convention as stated in
Article 1 “is to protect human health and the environment from
persistent organic pollutants”.
28. For POPs that are unintentionally generated as the result of
human activity Article 5 (“Measures to reduce or eliminate releases
from unintentional production”) stipulates that each party shall
take “measures to reduce the total releases derived from
anthropogenic sources of each of the chemicals listed in Annex C,
with the goal of their continuing minimization and, where feasible,
ultimate elimination”. The PCDDs and PCDFs, along with PCBs and
HCB, are listed and described in Annex C (“Unintentional
Production”). For a more detailed description of the PCDDs and
PCDFs see section 1.2.1 (“Description”) of this guidance
document.
29. Provisions pertaining to ultimate disposal of POPs waste are
set out in Article 6 (“Measures to reduce or eliminate releases
from stockpiles and wastes”). Article 6.1(a) applies to:
(i)Stockpiles consisting of or containing chemicals listed
either in Annex A or Annex B; and
(ii)Products and articles in use and wastes consisting of,
containing or contaminated with a chemical listed in Annex A, B or
C.
30. Article 6.1(d) on waste handling and disposal stipulates
that each Party shall take appropriate measures so that such
wastes, including products and articles upon becoming wastes,
are:
(i)Handled, collected, transported and stored in an
environmentally sound manner;
(ii)Disposed of in such a way that the persistent organic
pollutant content is destroyed or irreversibly transformed so that
they do not exhibit the characteristics of persistent organic
pollutants or otherwise disposed of in an environmentally sound
manner when destruction or irreversible transformation does not
represent the environmentally preferable option or the persistent
organic pollutant content is low, taking into account international
rules, standards, and guidelines, including those that may be
developed pursuant to paragraph 2, and relevant global and regional
regimes governing the management of hazardous wastes;
(iii)Not permitted to be subjected to disposal operations that
may lead to recovery, recycling, reclamation, direct reuse or
alternative uses of persistent organic pollutants; and
(iv)Not transported across international boundaries without
taking into account relevant international rules, standards and
guidelines.
31.
32. Part II of Annex C lists industrial source categories that
have the potential for comparatively high formation and release of
unintentionally produced POPs, including PCDDs and PCDFs, these
categories include:
(a)Waste incinerators, including co-incinerators of municipal,
hazardous or medical waste or of sewage sludge;
(b)Cement kilns firing hazardous waste;
(c)Production of pulp using elemental chlorine or chemicals
generating elemental chlorine for bleaching;
(d)The following thermal processes in the metallurgical
industry:
(i)Secondary copper production;
(ii)Sinter plants in the iron and steel industry;
(iii)Secondary aluminium production;
(iv)Secondary zinc production.
33. Part III of Annex C lists source categories that may have
the potential for the formation and release of unintentionally
produced POPs, these include:
(a)Open burning of waste, including burning of landfill
sites;
(b)Thermal processes in the metallurgical industry not mentioned
in Part II;
(c)Residential combustion sources;
(d)Fossil fuel-fired utility and industrial boilers;
(e)Firing installations for wood and other biomass fuels;
(f)Specific chemical production processes releasing
unintentionally formed persistent organic pollutants, especially
production of chlorophenols and chloranil;
(g)Crematoria;
(h)Motor vehicles, particularly those burning leaded
gasoline;
(i)Destruction of animal carcasses;
(j)Textile and leather dyeing (with chloranil) and finishing
(with alkaline extraction);
(k)Shredder plants for the treatment of end of life
vehicles;
(l)Smouldering of copper cables;
(m)Waste oil refineries.
34. Part V of Annex C provides general guidance on best
available techniques and best environmental practices to Parties on
preventing or reducing releases of unintentionally produced POPs
and stipulates that “priority should be given to the consideration
of approaches to prevent the formation and release of these
chemicals”. Useful measures could include:
(a)The use of low-waste technology;
(b)The use of less hazardous substances;
(c)The promotion of the recovery and recycling of waste and of
substances generated and used in a process;
(d)Replacement of feed materials which are persistent organic
pollutants or where there is a direct link between the materials
and releases of persistent organic pollutants from the source;
(e)Good housekeeping and preventive maintenance programmes;
(f)Improvements in waste management with the aim of the
cessation of open and other uncontrolled burning of wastes,
including the burning of landfill sites. When considering proposals
to construct new waste disposal facilities, consideration should be
given to alternatives such as activities to minimize the generation
of municipal and medical waste, including resource recovery, reuse,
recycling, waste separation and promoting products that generate
less waste. Under this approach, public health concerns should be
carefully considered;
(g)Minimization of these chemicals as contaminants in
products;
(h)Avoiding elemental chlorine or chemicals generating elemental
chlorine for bleaching.
Comments from the World Chlorine Council: Paragraphs 27 to 33:
It would be better – and no lengthier – to cite the Convention
rather than to attempt a paraphrase, if these paragraphs are really
deemed necessary. It would be better still to drop the whole
section. At the very least it should be made clear which parts of
the text are citations of Convention text and which are
paraphrases.
3.0Provisions of the Stockholm Convention to be addressed
cooperatively with the Basel Convention
35. Article 6.2 of the Stockholm Convention stipulates that “the
Conference of the Parties shall cooperate closely with the
appropriate bodies of the Basel Convention”. Article 6.2(c)
stipulates that this cooperation will include “work to establish,
as appropriate, the concentration levels of the chemicals listed in
Annexes A, B and C in order to define the low persistent organic
pollutant content referred to in paragraph 1 (d)(ii)”, outlined in
section 2.2 (“Stockholm Convention”) of this guidance document. The
low POPs content will serve as a “trigger” for the provision within
Article 6.1(d)(ii) requiring that the POPs content of these wastes
be destroyed or irreversibly transformed, except where destruction
or irreversible transformation does not represent the
environmentally preferable option.
3.1Low PCDDs and PCDFs content
36. As per paragraph 2 (c) of the Open-ended Working Group
decision II/10 the issue of methodology for further definition of
low POP content will be addressed in a separate part of the
document.
Comments from the World Chlorine Council: Paragraph 35bis:
Insert a new paragraph 35bis with the same text as paragraph
35.This paragraph should also consider the nature (i.e. physical
form) of the waste, as well as POPs concentration, etc.
3.2 Levels of destruction and or irreversible transformation
Comments from the World Chlorine Council: Title: Replace “and”
by “or”.
3.3.Methods that constitute environmentally sound destruction
and disposal3.3.1Destruction or irreversible transformation
methods
37. Section 4.7.2 (“Destruction and irreversible transformation
methods”) of this guidance document contains a description of
several methods of destruction or irreversible transformation.
38. The applicability of these methods to a particular PCDDs and
PCDFs waste will depend upon the definition of low PCDDs and PCDFs
content and level of destruction or irreversible transformation.
For example, when the waste has a concentration greater than the
low PCDDs and PCDFs content, only those destruction or irreversible
transformation methods capable of achieving the proposed levels
should be utilised, unless destruction or irreversible
transformation does not represent the environmentally preferable
option. Further considerations are outlined in section 4.7.2.
3.3.2 Other disposal methods when PCDDs and PCDFs content is
low
39. Section 4.7.3 (“Other disposal methods when the PCDDs and
PCDFs content is low”) of this guidance document contains a
description of several methods of disposal.
40. The applicability of these methods to a particular PCDDs and
PCDFs waste will depend upon the concentration of PCDDs and PCDFs
in the waste, and the definition of low PCDDs and PCDFs content.
These methods may also be utilised in situations where destruction
or irreversible transformation does not represent the
environmentally preferable option. Further considerations are
outlined in section 4.7.3.
3.3.3Other disposal methods when destruction or irreversible
transformation does not represent the environmentally preferable
option
41. The conditions and cases where destruction or irreversible
transformation of PCDDs and PCDFs waste with a concentration above
the established low PCDDs and PCDFs content does not represent the
environmentally preferable option should be defined by evaluating
the experiences of the different environmental management
techniques (e.g., environmental impact assessment, life-cycle
assessment, risk assessment). In each case, the appropriate waste
management operation and ESM disposal option(s) should be
described, including as these apply to waste type and quantity and
the competent authority of the State concerned has subsequently
authorised the alternative disposal operation and informed the
Secretariat of the Basel Convention of its authorisation and
justification for it.
42. Examples of wastes containing or contaminated with PCDDs and
PCDFs where destruction or irreversible transformation may not
represent the environmentally preferable option include:
· non-leachable contaminated solids (demolition waste,
auto-shredder fluff, cable sheaths);
· in-situ “low-level” contaminated soil and bedrock;
· solid wastes from thermal processes including fly and bottom
ashes;
· waste linings and refractories; and
· solid wastes from waste management facilities, off-site waste
water treatment plants and the preparation of water intended for
human consumption and water for industrial use.
Comments from Argentina: Examples of wastes containing or
contaminated with PCDDs and PCDFs where destruction or irreversible
transformation may not represent the environmentally preferable
option include:
- solid wastes from thermal processes including fly and bottom
ashes;
- waste linings and refractories; and
- solid wastes from waste management facilities, off-site waste
water treatment plants and the preparation of water intended for
human consumption and water for industrial use.
It is not clear why ireversible transformation may not represent
the environmentally prefereble option and which is the alternative
option to avoid land and water contamination from disposal, or
which are the alternative treatment, for the three mentioned
cases.
Comments from Confederation of European Waste-to-Energy Plants
(CEWEP): Paragraph 41:First bullet, the term ‘auto-shredder fluff’
should either be excluded or it should be defined clearly what is
to be understood under this term. As to our understanding,
auto-shredder fluff can be destroyed through waste
incineration.
Comments from the World Chlorine Council: Paragraphs 34 to 41:
It would be better – and no lengthier – to cite the Convention
rather than to attempt a paraphrase, if these paragraphs are really
deemed necessary. It would be better still to drop the whole
section. At the very least it should be made clear which parts of
the text are citations of Convention text and which are
paraphrases
4.0Guidance on Environmentally Sound Management
Comments from the World Chlorine Council: Insert new
second-level heading “4.1” titled “General Considerations” if
paragraphs 42 to 48 are to be retained.
4.1General Considerations
4.1.1Basel Convention
43. Environmentally Sound Management (ESM) of hazardous wastes
or other wastes is described in Article 2.8 as “taking all
practicable steps to ensure that hazardous wastes or other wastes
are managed in a manner which will protect human health and the
environment against adverse effects which may result from such
wastes.”
44. Article 4.2(b) requires that each Party take appropriate
measures to ensure the availability of adequate disposal facilities
for the environmentally sound management of hazardous or other
wastes, that shall be located, to the extent possible, within it,
while 4.2(c) requires each Party to ensure that persons involved in
management of these wastes take the necessary steps to prevent
pollution arising from such management and, if pollution does
occur, to minimize the consequences for human health and the
environment.
45. ESM is also the subject of the 1999 Basel Declaration on
Environmentally Sound Management, adopted at the fifth meeting of
the COP to the Basel Convention. The Declaration calls on the
Parties to enhance and strengthen their efforts and cooperation to
achieve environmentally sound management, including through
prevention, minimization, recycling, recovery and disposal of
hazardous and other wastes subject to the Basel Convention, taking
into account social, technological and economic concerns; and
further reduction of transboundary movements of hazardous and other
wastes subject to the Basel Convention.
46. One of the main vehicles for the promotion of ESM is the
preparation and dissemination of technical guidance documents such
as this one and its “parent” document titled General Technical
Guideline for Environmentally Sound Management of Wastes Consisting
of, Containing or Contaminated with Persistent Organic
Pollutants.
Comments from the World Chlorine Council Basel Convention:
Paragraphs 42 to 45: It is not clear that reiteration of Basel
Convention material is useful in this guideline as it is readily
accessible elsewhere. If these paragraphs are to be retained they
should be edited by the Secretariat to the Basel Convention for
consistency with the original source documents.
4.1.2Stockholm Convention
47. The term “environmentally sound management” is not defined
within the Stockholm Convention. Environmentally sound methods for
waste destruction or irreversible transformation and disposal are
to be determined by the COP in cooperation with the appropriate
bodies of the Basel Convention (as per Article 6.2(b) of the
Stockholm Convention).
48. Parties should consult Interim guidance for developing a
national implementation plan for the Stockholm Convention (UNEP,
2003) as well as the other guidance documents listed in the
Bibliography.
Comments from the World Chlorine Council Stockholm Convention:
Paragraphs 46 to 47: It is not clear that reiteration of Stockholm
Convention material is useful in this guideline as it is readily
accessible elsewhere. If these paragraphs are to be retained they
should be edited by the Interim Secretariat to the Stockholm
Convention for consistency with the original source documents.
4.1.3OECD
49. The Organization for Economic Cooperation and Development
also promotes ESM through its “Core Performance Elements” (OECD,
2003; OECD, 2002).
Comments from the World Chlorine Council: OECD: Paragraph 48: It
is not clear whether this material from one regional economic
organisation is of sufficient global relevance to merit inclusion
in a UN document. Consider deletion of these paragraphs.
4.2Legislative and regulatory framework
50. Elements of a regulatory framework applicable to PCDDs and
PCDFs include:
· Enabling environmental protection legislation (sets release
limits and environmental quality criteria);
· Hazardous materials and waste transportation requirements;
· Specifications for containers, equipment, bulk containers and
storage sites;
· Specification of acceptable analytical and sampling
methods;
· Requirements for hazardous waste destruction technologies,
waste management facilities and landfills;
· General requirement for public notification and review of
proposed government regulations, policy, certificates of approval,
and licenses and inventory information and national emissions
data;
· Requirements for identification and remediation of
contaminated sites;
· Requirements for health and safety of workers; and
· Other potential legislative controls (waste prevention and
minimization, inventory development, emergency response).
· Requirements for hazardous waste destruction technologies,
waste management facilities and landfills; regulations about
restrictions on open burning and domestic wastes destruction and
ash disposal (including agriculture and farming wastes).
Comments from Argentina: We suggest adding:Requirements for
hazardous waste destruction technologies, waste management
facilities and landfills; regulations about restrictions on open
burning and domestic wastes destruction and ash disposal (including
agriculture and farming wastes).
Comments from the World Chlorine Council: Paragraph 49: This is
a helpful model of the text that could equally form this section in
the other “daughter” guidelines.
4.3 Waste prevention and minimisation
51. Both the Basel and Stockholm Conventions advocate waste
avoidance and minimisation. This guidance document recommends that
PCDDs and PCDFs be destroyed, irreversibly transformed or disposed
of in an ESM manner (as applicable to concentration of the PCDDs
and PCDFs and the matrix in which the PCDDs and PCDFs occurs) as
quickly as possible and that these wastes not be recycled or
recovered for re-use.
52. Efforts undertaken to reduce the formation and release of
PCDDs and PCDFs are likely to also reduce the generation and
release of unintentionally produced PCBs and HCB that are generated
by the same processes. The reader is referred to the Standardized
Toolkit for the Identification and Quantification of Dioxins and
Furans available from UNEP Chemicals. A Stockholm Convention Expert
Group is also in the process of preparing additional guidance on
best available techniques and best environmental practices for
reducing and eliminating releases of Annex C substances.
Comments from the World Chlorine Council: This is a helpful
model of the text that could equally form the basis for this
section in the other “daughter” guidelines.
4.4Identification and inventories
4.4.1Identification
53. The PCDDs and PCDFs are may be formed as undesirable waste
products during industrial processes where carbon-containing
organic material is incinerated heated in the presence of chlorine.
These processes include the manufacture of chemicals including
chlorophenols and herbicides like 2,4,5-T, and in certain
combustion or incineration processes such as waste incinerators and
fossil fuel power plants.
Comments from the World Chlorine Council: Identification and
inventories:Paragraph 52: In the first sentence, replace “are
formed” by “may be formed” and replace “incinerated” by “heated”.
In the second sentence, replace “and in combustion” by “and in
certain combustion”.
54. PCDDs and PCDFs may be found in the following industries,
equipment and locations:
· Painted objects, such as wood, concrete and wallboard
· Waste incinerators incineration
· Cement kilns
· Pulp and paper production
· Metallurgical industries
· Fossil fuel-fired utility and industrial boilers
· Production of certain pesticides production
· Motor vehicles
· Drained equipment with liquid residues (electrical, hydraulic
or heat transfer equipment, engines, pesticide application)
· Drained containers with liquid residues (oil drums, plastic
drums, pesticide bottles, storage tanks)
· Mixed organic liquid wastes (paints, oils, solvents)
· Contaminated wood
· Contaminated soils, sediments, rock and mine aggregates
· Contaminated solid waste
· Contaminated sludge
· Contaminated oils (contained within or drained from
electrical, hydraulic, engine or heat transfer equipment)
· Contaminated process water (industrial effluent, pollution
control scrubbers and curtains, quench waters, sewer)
Comments from the World Chlorine Council: Paragraph 53:The list
should be restricted to the major cases where PCDDs/PCDFs are
really likely to be found. Better still it should be replaced by
the lists from Annex C of the Stockholm Convention – except that
these may already have been cited in earlier sections (unless these
are deleted in accordance with our recommendations). So it seems
doubtful whether any listing really needs repeating here! If a
listing here is to be retained, then the following more specific
comments apply:- The first bullet seems very general – while there
may be cases where painted objects contain or give rise to PCDD
contamination, this would seem to be a very small minority.- The
second bullet should read, “waste incineration” (as an industry)
rather than “waste incinerators” (as equipment) as the
contamination with PCDDs/PCDFs is as (or more) likely to be found
in ancillary equipment and locations than the incinerator itself.-
The seventh bullet should read “production of certain pesticides”.-
The eighth bullet (“motor vehicles”) is so general as to be of
limited value and should perhaps be deleted.
4.4.2Inventory
55. A national inventory of PCDDs and PCDFs is necessary to
establish a baseline quantification of these unintentionally
produced POPs. The baseline can be used to establish an action plan
and track progress for the reduction and where feasible the
elimination of these substances.
Comments from Argentina: 4.4.2 Inventory: We suggest to make a
reference to the Standardized Toolkit proposed methodology
56. The development of a national inventory requires the
long-term commitment of the national government and a sound
administrative process for collection of information on an ongoing
basis, storage of the information in a computer database and
preparation of useful reports regarding the progress of reduced
release or elimination.
57. Article 5 and Annex C of the Stockholm Convention require
Parties to prepare an inventory of current and projected releases
of unintentionally produced POPs. Typically, this is done on an
annual release basis. Annex C lists the source categories that must
be considered in the inventory, see section 2.2 (“Stockholm
Convention”) of this guidance document.
4.6Handling, collection, packaging, transportation and temporary
storage
58. Handling and movement are critically important steps as
there is as much or more risk of a spill, leak or fire during
handling and transport (e.g., in preparation for storage or
destruction) than during the normal operation of the equipment. In
addition, movement of hazardous wastes is carefully regulated under
international agreement and national laws. Internationally, the
Basel Convention: Manual for Implementation (UNEP, 1995), the
International Maritime Dangerous Goods Code (IMO, 2002), the
International Air Transport Association Dangerous Goods Code and
the United Nations Transport of Dangerous Goods Code should be
consulted to determine specific requirements for transport and
transboundary movement of hazardous wastes.
4.6.1Handling
59. Handling of PCDDs and PCDFs wastes should be done with the
objective of minimising releases to the environment and
contamination of additional materials. Recommended practices for
this purpose include:
· inspecting containers for leaks, holes, rust, high
temperature;
· handling wastes at temperatures below 25 °C, if possible, due
to the increased volatility at higher temperatures;
· ensuring that spill containment measures adequate to contain
liquid wastes if spilled;
· placing plastic sheeting or absorbent mats under containers
before opening containers if the surface of the containment area is
not coated with a smooth surface material (paint, urethane,
epoxy,
· removing the liquid wastes either by removing the drain plug
or by pumping with a peristaltic pump and Teflon or silicon
tubing;
· using dedicated pumps, tubing and drums to transfer liquid
wastes;
· cleaning up any spills with cloths or paper towels;
· triple rinsing of contaminated surfaces with a solvent such as
kerosene; and
· treating all absorbents, disposable protective clothing,
plastic sheeting PCDDs and PCDFs waste when appropriate.
60. Staff should be trained in the appropriate methods for
handling hazardous wastes.
4.6.2Collection
4.6.3Packaging
61. The PCDDs and PCDFS wastes that are being collected must be
prepared for storage, transport and/or destruction. For
liquid-filled equipment that is made to be opened or drained, the
liquid should be removed and placed in double-bung steel drums.
Regulations governing transport often specify containers of certain
quality (e.g., 16-gauge steel coated inside with epoxy). Therefore,
the containers used for storage should meet transport requirements
in anticipation that they may be transported in the future. The
procedure for removing the liquid is the same as described in
Section 4.6.1 (“Handling”) except that inspection and repair of
damage to the equipment is not necessary. After draining, equipment
should be re-sealed.
62. Large, drained equipment may be stored as is, or may be
placed inside a large container (over-pack drum) or heavy plastic
“wrap” if leakage is a concern. Small pieces of equipment should be
placed in drums with an absorbent material placed or poured in
under and around the pieces of equipment. Numerous small pieces of
equipment may be placed in each drum, so long as an adequate amount
of absorbent material is present in the drum. Loose absorbents may
be purchased from safety suppliers. Sawdust, vermiculite or peat
moss may also be used.
63. Drums and equipment may be placed on pallets for movement by
forklift truck and for storage, keeping them off the ground will
reduce the chance of rusting and of contamination by spillage of
other stored materials. Equipment and drums should be strapped to
the pallets prior to movement.
4.6.4Labeling
64. All drums, containers and equipment containing or
contaminated with PCDDs and PCDFs should be clearly labelled with
both a hazard-warning label and a label that gives the details of
the equipment or drum. The details include the contents of the drum
or equipment (exact counts of equipment or volume of liquid), the
type of waste, and the name and telephone number of the responsible
person.
4.6.5Transport
65. Transportation of dangerous goods and wastes is regulated in
most countries and the transboundary movement of wastes is
controlled by the Basel Convention. The Basel Convention requires
notification and consent for movement of wastes. See the General
Technical Guidance document for key provisions for movement of
wastes in the Basel Convention.
66. Persons transporting wastes within their own country should
be qualified and/or certified as a shipper of hazardous materials
and wastes. Persons proposing to ship hazardous wastes across an
international border should notify their national regulatory agency
of their intent and follow national and international
standards.
4.6.6Storage
67. Many countries have adopted PCB waste storage regulations or
have developed guidance documents for PCB storage. Most do not have
specific storage regulations or guidance for PCDDs and PCDFs
wastes. However, it can be assumed that the storage procedures
should be identical to those for PCBs waste since their properties
and toxicity are virtually the same. While recommended practice
varies somewhat from country to country, there are many common
elements to safe storage of these wastes. The following recommended
practices are based on the most current and best-available
practice:
· storage sites inside multi-purpose buildings should be in a
locked dedicated room or partition that is not in an area of high
use;
· outdoor dedicated storage buildings or containers (often
shipping containers are used) should be inside a lockable fenced
enclosure;
· PCDDs and PCDFs wastes should not be stored on or near
“sensitive sites” (e.g., hospitals or other medical care
facilities, schools, residences, food processing facilities, animal
feed storage or processing facilities, agricultural operations, or
facilities located near or within sensitive environmental
sites);
· if transfer to another location or immediate destruction is
not possible, then the storage site should be a dedicated storage
building situated as far away from the high-traffic and operational
areas of the property as possible;
· PCDDs and PCDFs wastes may be stored together, but should not
be stored with any other materials, including other types of
hazardous wastes;
· storage rooms, buildings and containers should be ventilated
to the outside air or should be completely sealed to prevent escape
of volatile contaminants:
· ventilating a site to the outside air is considered when
exposure to vapours for those who work in the site is a concern,
and
· completely sealing a site so that no vapours can escape to
outside air is considered when environmental concerns are paramount
and there is minimal entry into the site;
· dedicated buildings or containers should be in good condition
and made of hard plastic or metal;
· the roof of dedicated buildings or containers and surrounding
land should be sloped so as to provide drainage away from the
site;
· dedicated buildings or containers should be set on asphalt,
concrete or durable (e.g., 6 mm ml) plastic sheeting;
· floors should be steel, concrete or durable (e.g., 6 ml mm)
plastic sheeting, concrete should be coated with a durable
epoxy;
· storage sites should have a fire alarm system;
· storage sites inside buildings should have a fire suppression
system, preferably a non-water system;
· if the fire suppressant is water, then the floor of the
storage room should be curbed and the floor drainage system should
have it’s own collection system such as a sump;
· liquid wastes should be placed in containment trays or a
curbed, leak-proof area with a containment volume of 125%;
· curbing or sides of the containment must be high enough, or
the wastes kept back from the edge of the curbing far enough, that
a leak in any drum or container would not “jet” over the edge of
the curb or side;
· contaminated solids, contaminated debris, contaminated
clothing, spill cleanup material and contaminated soil, should be
stored in containers, such as barrels or pails, steel waste
containers (lugger boxes) or in specially constructed trays or
containers.;
· large volumes of soil or other contaminated material may be
stored in bulk in dedicated shipping containers, buildings or
vaults as long as they meet the safety and security requirements as
described herein;
· complete inventory of the PCDDs and PCDFs wastes in the
storage site should be created and kept up to date as waste is
added or disposed;
· a copy of the inventory should be kept on site, another copy
kept in the corporate offices, and a copy filed with the emergency
response plan;
· the outside of the storage site should be labelled as a PCDDs
and PCDFs waste site;
· all containers of materials in the site should be labelled
with hazard labels that clearly indicate the contents of the
container;
· the site should be subjected to routine inspection for leaks,
degradation of container materials, vandalism, integrity of fire
alarms and fire suppression systems and general status of the
site;
· rusting or degrading drums or equipment bodies should be
placed inside larger “overpack” drums instead of attempting to
transfer the fluid to a new container;
· drums or pallets should not be stacked more than two high and
only if this can be done safely (i.e., the drums are
stackable);
· the site should have an emergency response plan and a copy of
this should be reviewed and kept on file by the local fire
protection agency; and
· the site should have a health and safety plan if PCDDs and
PCDFs wastes are not dealt with in the master health and safety
plan for the property, company or agency.
Comments from Germany: Para. 66: Duplication with the General
technical guidelines should be avoided.In the tenth bullet, insert
“steel” before “concrete or durable” and replace “ml” by
“mm”Rationale: Steel floors are also suitable because they are
resistant against chemicals mentioned here, are not porous and easy
to clean.
Comments from the World Chlorine Council: Paragraph 66:While
there is no objection per se to the text of this paragraph, it does
seem rather daunting. This raises the question whether recipients
of this guidance, e.g. developing countries, might be deterred from
doing anything by a counsel of perfection? We should maybe discuss
whether the list of recommended practices could be condensed and
prioritised?
4.7Environmentally sound destruction and disposal
4.7.1Pre-treatment
68. This section presents the most common pre-treatments that
may be required for the proper and safe operation of the
destruction technologies described later in Section 4.7.2
(“Destruction and irreversible transformation methods”).
4.7.1.1Adsorption/Absorption
69. Sorption is the general expression for both absorption and
adsorption processes. Sorption is a pre-treatment method that uses
solids for removing substances from gaseous gases or liquids
solutions. Adsorption involves the separation of a substance
(liquid, oil) from one phase and its accumulation at the surface of
another (activated carbon, zeolite, silica, etc.). Absorption is
where a material transferred from one phase to another
interpenetrates the second phase to form a solution (e.g.,
contaminant transferred from liquid phase into activated
carbon).
Comments from the World Chlorine Council: Paragraph 68: What is
meant by “gaseous solution”? Delete “gaseous” and replace by
“gases”. What is meant by “liquid solution”? Delete “liquid
solution” and replace by “liquids”.
70. The following pre-treatment technologies may be used to
concentrate contaminants and separate them from aqueous wastes. The
concentrate and the adsorbent or absorbent will require destruction
treatment. In comparison with oil water separation, sorption
pre-treatments should produce wastewater, which that meets
discharge criteria. There are several sorption technologies
commercially proven and developed.
Comments from the World Chlorine Council: Paragraph 69: In the
penultimate sentence, replace “wastewater, which” by “wastewater
that”.
4.7.1.2Dewatering
71. Dewatering is a pre-treatment approach that partially
removes water from the wastes to be treated. Dewatering can be
employed for destruction technologies that are not suitable for
aqueous wastes. For example, over a certain temperature and
pressure environment, water can react explosively with molten salts
or sodium. There are several dewatering technologies commercially
proven and developed. Depending on the nature of the contaminant,
resulting vapours may require condensation or scrubbing and/or
further treatment.
4.7.1.3Oil/Water Separation
72. Some process technologies are not suitable for aqueous
wastes while others are not suitable for oily wastes. Oil/water
separation can be employed in these situations to separate the oily
phase from the water. Both the water and the oily phase may be
contaminated after the separation and both may require treatment.
Several oil/water separation technologies are commercially proven
and developed.
4.7.1.4pH Adjustment
73. Some treatment technologies are most effective in a defined
pH range and in these situations, caustic alkali, acid or CO2 are
often used to control pH levels. Some technologies may also require
pH adjustment as a post-treatment step. Several pH adjustment
technologies have been commercially proven.
Comments from the World Chlorine Council: Paragraph 72: Replace
“caustic” by “alkali”. There does not appear to be any reason why
the alkali used to neutralise a low pH waste should necessarily be
caustic soda (or caustic potash).
4.7.1.5Screening
74. Screening as a pre-treatment step can be used to remove
debris from the waste stream or for technologies that may not be
suitable for both soils and solid wastes. There are several
screening technologies commercially proven and developed.
4.7.1.6Shredding
75. Some technologies are only able to process wastes within a
certain size limit. For example, some will handle POP contaminated
solid wastes only if less than 200 microns in diameter. Shredding
can be used in these situations to reduce the waste components to a
defined diameter. Other destruction technologies require slurries
to be prepared prior to waste injection into the main reactor.
There are several shredding technologies commercially proven and
developed.
4.7.1.7Solvent Washing
76. Electrical equipment such as capacitors and transformers
cannot be treated by many of the destruction technologies described
above but solvent washing can be successful. This technology has
also been used successfully for the treatment of contaminated soil.
There are several technologies commercially proven and developed to
remove PCDDs and PCDFs from soil.
4.7.1.8Thermal Desorption
77. Low-Temperature Thermal Desorption (LTTD), also known as
low-temperature thermal volatilisation, thermal stripping, and soil
roasting, is an ex-situ remedial technology that uses heat to
physically separate volatile and semi-volatile compounds and
elements (most commonly petroleum hydrocarbons) from contaminated
media (most commonly excavated soils). Such processes have been
used for the decontamination of the non-porous surfaces of
electrical equipment such as transformer carcasses that formerly
contained PCB-containing dielectric fluids. There are several such
technologies commercially proven and developed. Depending on the
nature of the contaminant, resulting vapours may require
condensation or scrubbing and might require further treatment.
4.7.2 Destruction and irreversible transformation methods
78. This section describes and comments on commercially
available technologies for the destruction or irreversible
transformation of PCDDs and PCDFs wastes, followed by
recommendations.
77bis.These technologies require highly trained personnel.
Regular maintenance and services, and intensive control procedures,
including analytical facilities, are necessary.
Comments from Argentina: 4.7.2 Destruction and irreversible
transformation methods:
We suggest harmonization with BAT/BEP Draft Guidance, -or simply
make a reference to this draft for some thermal technologies that
are more fully described- taking in consideration temperature,
oxygen content, residence time, for thermal destruction and
avoidance of reforming. It should make reference to POP General
Guidelines or another UNEP Guidances for those technologies already
fully detailed (such as those for incineration and
co-incineration). This draft should only considerate those not
previously described for these pollutants. eg. plasma arc
decomposition, gas phase chemical reduction, etc.
Comments from Canada:
- Greater details on the degree of commercialization and
economics should be provided for each technology as per the
Technical Guidelines on PCB, PBB and PCT Wastes
- The destruction and irreversible transformation methods should
refer to the General Technical Guideline as per the PCB Technical
Guidelines. We believe that it would be important that the document
states, with reference, methods that do not apply to PCDD and PCDF,
such as Alkali metal reduction.
- Technologies with destruction efficiencies of 90% and 95% are
questionable especially with respect to high concentration wastes.
While technologies such as In-situ vitrification (section. 4.7.2.6)
are recommended in the General Guidelines, the POP-specific
guidelines such as this one should make an effort to indicate how
the higher destruction efficiencies can be obtained for the
specific POP-waste in question.
- The destruction efficiency qualifier "very high" should be
reserved for 99.9999% or perhaps 99.99% and greater destruction
efficiency.
Comments from the World Chlorine Council:
a.Verification of manufacturers’ / licensors’/ claims
This is the core section of the entire guideline and merits very
careful analysis and verification against actual practical
experience as opposed to manufacturers’ or licensors’ claims. The
section could usefully make use of a wider range of sources. One
examples of a source that appears not to have been consulted
(because statements are made that are at variance with these
sources) is: UNIDO – Demonstration of viability and removal of
barriers that impede adoption and effective implementation of
available non-combustion technologies for destroying persistent
organic pollutants (a whole series of documents from the Technical
Advisory Group to UNIDO). WCC does not necessarily endorse any of
the information from UNIDO, but believes that it forms an important
contribution to the corpus of information on the topic of
destruction methods for POPs and merits critical analysis alongside
other sources.
In addition, WCC believes that in the interests of transparency
all claims made about the various technologies should be capable of
independent verification. This implies, as a minimum, that for each
technology there is a clear statement of:
- Examples of commercially operating plants and their
location.
- How long these plants have been in continuous operation.
- Their actual operating (as opposed to design) capacity.
- Their destruction and removal efficiency (DRE) measured across
the entire system with a clear statement of the POPs concentration
in the input waste stream to which this applies.
- Their consumption of utilities (water, energy).
- The types of waste (chemical nature, physical form,
concentration) for which they have been proven in practice.
- The nature of any residues and their fate, e.g. techniques for
disposal of residues.
- The nature of any pollution abatement measures that are
required in operation.
- The costs per tonne of waste and/or per tonne of POP, with an
indication as to whether there is potential for this to reduce as
the technology matures.
- The nature (and costs) of any intellectual property rights
(e.g. licences under patents) required.
Where this information is not available, it would be sensible to
conclude that the technology is not yet really commercialised (see
point (b) below), as any purchaser of the technology would need all
of this information (and more) before proceeding.
b.State of commercialisation:
Some technologies are described as commercialised on the
strength of a single recently operating medium-scale plant, while
others have numerous full-scale plants that have been on operation
over considerable periods of time in many countries. Some further
qualitative distinction needs to be made between new and
well-established technologies both because of the implications for
reliable and safe operation, and because any cost comparisons will
be weighted against new technologies that have not yet progressed
down the techno-economic ‘learning curve’.
c.Intellectual property rights and their implications
Several of the technologies discussed appear to have a single
(i.e. monopoly) supplier who holds intellectual property rights
(e.g. patents) and would wish to license the technology. It is
important for governments to know whether there is competition (and
thus some measure of market control of prices) between technology
suppliers, and whether (and on what terms and at what cost)
licences are required.
Paragraph 77bis:Insert a paragraph 77bis – see comment below
under paragraph 92.
4.7.2.1Advanced oxidation process (AOP)
79. AOP increase the rate of oxidation through the use of highly
reactive chemical oxidisers. The technology will destroy hazardous
organic chemicals in water. Different process combinations like
Ultraviolet (UV)/ozone, UV/hydrogen peroxide or UV with ozone and
peroxide exist. UV/oxidation processes combine the use of UV and
chemical oxidizers such as ozone (O3) and hydrogen peroxide (H2O2)
to destroy organic compounds. The UV light reacts breaks down with
the H2O2 to form hydroxyl radicals (OH·). These hydroxyl radicals
will react with the contaminants to form CO2, H2O and residual ions
radicals such as Cl•.
Comments from the World Chlorine Council: UV light is not a
substance and thus does not “react”. Replace “reacts with” by
“breaks down”. It seems unlikely that a radical reaction, such as
that described, would generate ions. Replace “residual ions such as
Clˉ ” by “residual radicals such as Cl• ”
80. AOP is a proven technology and is commercially available
(Rayox, Ultrox, etc.). AOP can reduce PCB in water, aqueous
solutions and groundwater to acceptable discharge standards. The
Perox Pure process has been successfully applied in over 80 sites
throughout the United States, Canada and Europe. The results show a
destruction efficiency of 95% for PCB in contaminated groundwater.
The technology is only applicable to water and aqueous solutions.
It is not suitable for organic solids, oily phases and organic
liquids.
Comments from the World Chlorine Council: “Proven technology” –
state number of operating plants and give examples of specific
locations and operating capacities. State whether there is any
operating experience with POPs other than PCBs. State whether the
technology is suitable for medium- to high-concentration wastes as
well as for “groundwater” (i.e. a low concentration waste). WCC
understands that the technology is only suitable for the
destruction of low concentration aqueous wastes. The UNIDO task
group does not appear to list this option in its initial screening
matrix of non-combustion POPs destruction technologies; it seems
important to know why not. What does this imply as to the
suitability and/or state of commercialisation of the
technology?
Remove reference to PCBs in ground water and provide reference
for use with PCDDs/PCDFs – if this technology is to be retained as
an option.
81. Free product and highly turbid waste streams tend to lower
the UV reactor’s efficiencies. Waste streams should be relatively
free of heavy metal ions, insoluble oil or grease to minimise the
potential for fouling of the UV quartz sleeves. No by-products
should be released to the environment with this technology,
although possible air emission problems with ozone (as the
oxidiser) have been encountered in some UV/oxidation systems. There
appears to be medium risk to the environment and humans. This
technology requires high energy levels. Ozone is highly unstable
and tends to decompose to oxygen. Ozone must be produced on-site.
Peroxide is the main chemical product required. The process
requires high performance construction materials and highly
qualified technical personnel. Preventive maintenance is very
important. There is a high hazard level associated with operation
of this technology, however, the actual risk may be low with the
implementation of a proper health and safety plan. Considering the
complexity of the technology, the need for highly qualified
personnel and high potential risk for worker exposure, AOP is not
recommended in areas remote from industrial regions. However, AOP
is recommended for destruction of low and high concentration POPs
wastes in industrial regions. However, AOP can be recommended as an
option for the destruction of low concentration aqueous PCB wastes,
for example in contaminated groundwater, in industrial regions.
Comments from the World Chlorine Council: Paragraph 80: Last
sentence – no evidence is presented to support the statement that
the technology is suitable for “high concentration” POPs wastes.
Even if the technology is retained in this section, on the basis of
the information provided in the draft the last sentence should be
deleted and replaced by “However, AOP can be recommended as an
option for the destruction of low concentration aqueous PCB wastes,
for example in contaminated groundwater, in industrial
regions”.
4.7.2.2 Base catalysed mediated decomposition (BCD)
Comments from the World Chlorine Council: While the technology
described is conventionally known as “Base-catalysed Decomposition”
(BCD), we understand that the “proprietary catalyst” is in fact
gradually consumed in the process and requires replenishment. This
does not