UNITED

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UNEP/CHW/OEWG/4/

Draft technical guidelines for the environmentally sound management of wastes containing or contaminated with unintentionally produced polychlorinated dibenzo-p-dioxins (PCDDs), polychlorinated dibenzofurans (PCDFs), polychlorinated biphenyls (PCBs) or hexachlorobenzene (HCB)

POST-OEWG 4 Version: 15 July 2005

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Table of Contents

61.0Introduction

61.1Scope

71.2Description, production and use, and wastes

71.2.1Description

81.2.2Production and use

91.2.3Wastes

102.0Relevant provisions in the Basel and Stockholm Conventions

102.1Basel Convention

152.2Stockholm Convention

173.0Provisions of the Stockholm Convention to be addressed cooperatively with the Basel Convention

173.1Low PCDDs and PCDFs content

173.2Levels of destruction and irreversible transformation

173.3.Methods that constitute environmentally sound destruction and disposal

173.3.1Destruction or irreversible transformation methods

183.3.2Other disposal methods when PCDDs and PCDFs content is low

183.3.3Other disposal methods when destruction or irreversible transformation does not represent the environmentally preferable option

184.0Guidance on Environmentally Sound Management

194.1.1Basel Convention

194.1.2Stockholm Convention

194.1.3OECD

194.2Legislative and regulatory framework

204.3Waste prevention and minimisation

204.4Identification and inventories

204.4.1Identification

224.4.2Inventory

224.6Handling, collection, packaging, transportation and temporary storage

224.6.1Handling

234.6.2Collection

234.6.3Packaging

234.6.4Labeling

234.6.5Transport

234.6.6Storage

254.7Environmentally sound destruction and disposal

254.7.1Pre-treatment

274.7.2Destruction and irreversible transformation methods

414.7.3Other disposal methods when the PCDDs and PCDFs content is low

444.8Remediation of contaminated sites

444.9Health and safety

444.9.1High-volume, high-concentration or high-risk situations

454.9.2Low-volume, low-concentration sites or low-risk situations

464.10Public participation

49References

50Appendices

51Appendix 1. WHO TEFs for PCDDs, PCDFs and PCBs

52Appendix 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”.

1.0Introduction

1.1Scope

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 wastes1.2.1Description

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 Unintentionally production

[two chapters: unintentionally production

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. The disposal options also features two destruction options that may occur in practice for PCDDs and PCDFs wastes:

D10Incineration on land

D11Incineration at sea.

23. 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.).

24. 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.

25. 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.

2.2 Stockholm Convention

26. The objective of the Stockholm Convention as stated in Article 1 “is to protect human health and the environment from persistent organic pollutants”.

27. 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.

28. 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.

29. 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.

30. 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.

31. 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.

32. 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

33. 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

34. 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 disposal

3.3.1 Destruction or irreversible transformation methods

35. Section 4.7.2 (“Destruction and irreversible transformation methods”) of this guidance document contains a description of several methods of destruction or irreversible transformation.

36. 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

37. 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.

38. 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.

3.3.3 Other disposal methods when destruction or irreversible transformation does not represent the environmentally preferable option

39. 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.

40. 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

41. 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.”

42. 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.

43. 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.

44. 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

45. 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).

46. 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

47. 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

48. 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

49. 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.

50. 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.

4.4 Identification and inventories

4.4.1Identification

51. 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”.

52. PCDDs and PCDFs may be found in the following industries, equipment and locations:[to include HCB, PCB]

· 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

53. 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

54. 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.

55. 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

56. 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

57. 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.

58. Staff should be trained in the appropriate methods for handling hazardous wastes.

4.6.2Collection

4.6.3Packaging

59. 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.

60. 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.

61. 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.

4.6.4 Labeling

62. 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.

4.6.5 Transport

63. 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.

64. 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

65. 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

4.7.1 Pre-treatment

66. 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

67. 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”.

68. 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

69. 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

70. 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

71. 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

72. 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

73. 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

74. 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

75. 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

76. 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)

77. 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• ”

78. 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.

79. 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 conform to the accepted definition of a “catalyst” as a substance that changes the kinetics of, but is not consumed in, a chemical reaction. A better name would be “Base-mediated Decomposition”.

80. BCD treats liquid and solid wastes in the presence of a reagent mixture consisting of a high boiling point hydrocarbon, sodium hydroxide and a proprietary catalyst. When heated, the reagent produces highly reactive atomic hydrogen, which reacts with organochlorines and other wastes. The residues produced from decomposition are an inert carbon residue and sodium salts. After the reaction, solid residues are separated from the residual oil by gravity or centrifugation. The oil and catalyst may be recovered for reuse. The operation of this process can be either on a continuous or batch basis. In practice, the contaminated liquid is pumped into a heated reactor containing the hydrocarbon oil, sodium hydroxide and the catalyst, the resulting reaction is rapid. For solid waste treatment, the waste needs to be premixed with the catalyst and fed into a heated thermal desorption unit. Depending on the waste matrix, other types of pre-treatment may also be required, including shredding, screening and dewatering.

Comments from the World Chlorine Council:

a.BCD cannot treat solids (or soils) directly (cf. UNIDO assessment). In the first sentence replace “liquid and solid” by “liquid”. It is true that solid wastes can, depending on the waste matrix, be pre-treated (e.g. by shredding, screening, etc.) – this is correctly stated in the final sentence of the paragraph. UNIDO agrees that the process has been commercialised and has promise for certain waste streams. The UNIDO Task Group has, however, asked the (sole) technology provider to supply details on:

- Chemical characterisation and details of the reactions involved.

- Quantities of mineral oils used in pre-treatment and