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Technical Guidelines for the ESM of PCB, PCT and PBB Wastes

Technical Guideline for Environmentally Sound Management of Wastes Consisting of,

Containing or Contaminated with Polychlorinated biphenyls (PCB),

Polychlorinated terphenyls (PCT), and Polybrominated biphenyls (PBB)

22 February 2004 Draft


Table of Contents1.0 Introduction.............................................................................................................................1

1.1 Scope.......................................................................................................................................1

1.2 Description, production, use and wastes.................................................................................1

1.2.1 Description..............................................................................................................................1

1.2.2 Production...............................................................................................................................2

1.2.3 Use..........................................................................................................................................3

1.2.4 Wastes.....................................................................................................................................4

2.0 Relevant provisions in the Basel and Stockholm Conventions...............................................5

2.1 Basel Convention....................................................................................................................5

2.2 Stockholm Convention............................................................................................................6

3.0 Provisions of the Stockholm Convention to be addressed cooperatively with the Basel Convention..............................................................................................................................7

3.1 Low PCB content....................................................................................................................7

3.2 Levels of destruction and irreversible transformation............................................................7

3.3. Methods that constitute environmentally sound destruction and disposal..............................7

3.3.1 Destruction or irreversible transformation methods...............................................................7

3.3.2 Other disposal methods when PCB content is low.................................................................7

3.3.3 Other disposal methods when destruction or irreversible transformation does not represent the environmentally preferable option....................................................................................8

4.0 Guidance on Environmentally Sound Management (ESM)...................................................8

4.1.1 Basel Convention....................................................................................................................8

4.1.2 Stockholm Convention............................................................................................................9

4.1.3 OECD......................................................................................................................................9

4.2 Legislative and regulatory framework....................................................................................9

4.3 Waste prevention and minimization.....................................................................................10

4.4 Identification and inventories...............................................................................................10

4.4.1 Identification.........................................................................................................................10

4.4.2 Inventory...............................................................................................................................11

4.5 Sampling, analysis and monitoring.......................................................................................11

4.5.1 Sampling...............................................................................................................................11

4.5.2 Analysis.................................................................................................................................13

4.5.3 Monitoring............................................................................................................................14

4.6 Handling, collection, packaging, transportation and storage................................................14

4.6.1 Handling................................................................................................................................14

4.6.2 Collection..............................................................................................................................15

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4.6.3 Packaging..............................................................................................................................15

4.6.4 Labelling...............................................................................................................................16

4.6.5 Transport...............................................................................................................................16

4.6.5 Storage..................................................................................................................................16

4.7 Environmentally sound destruction and disposal.................................................................18

4.7.1 Pre-treatment.........................................................................................................................18

4.7.2 Destruction and irreversible transformation methods...........................................................19

4.7.3 Other disposal methods when the PCB content is low.........................................................28

4.8 Remediation of contaminated sites.......................................................................................30

4.9 Health and safety...................................................................................................................30

4.9.1 High-volume, high-concentration or high-risk situations.....................................................30

4.9.2 Low-volume, low-concentration sites or low-risk situations................................................31

4.10 Emergency response.............................................................................................................32

4.11 Public participation...............................................................................................................32

Appendix 1: Synonyms and trade names for PCB, PCT and PBB............................................................34

Appendix 2: References.............................................................................................................................35

Appendix 3: Bibliography..........................................................................................................................36

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Abbreviations and AcronymsABS acrylonitrile butadiene styreneAOP Advanced oxidation processBCD Base catalyzed decompositionCOP Conference of the PartiesDNAPLS dense non-aqueous phase liquidsESM Environmentally sound managementGC gas chromatographyGPCR Gas phase chemical reductionHASP Health and Safety PlanMS mass spectrometry MSO Molten salt oxidationPBB Polybrominated biphenylPCB Polychlorinated biphenyls PCDD polychlorinated dibenzo-p-dioxinsPCDF Polychlorinated dibenzofuransPCT Polychlorinated terphenyls POP Persistent organic pollutantppm parts per millionSET Solvated electron technology SCWO Super-critical water oxidationWHO World Health Organization

Units of measurementmg/kg: Milligram(s) per kilogram. A measure of the concentration of an analyte in a given solid medium.

Corresponds to parts per million (ppm) by weight.

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1.0 Introduction

1.1 Scope1. This document supersedes the Basel Convention’s Technical Guidelines on Wastes Comprising or Containing PCB, PCT and PBB (Y10), February 1997.

2. This Technical Guideline provides guidance for the environmentally sound management (ESM) of wastes in accordance with decisions V/8 and VI/23 of the Conference of the Parties (COP) to the Basel Convention on the Control of Transboundary Movement of Hazardous Wastes and Their Disposal, I/4 and II/10 of the Open-ended Working Group of the Basel Convention (OEWG), and INC-6/5 and INC-7/6 of the Stockholm Convention on Persistent Organic Pollutants Intergovernmental Negotiating Committee for an International Legally Binding Instrument for Persistent Organic Pollutants.

3. Along with PCB, this Technical Guideline addresses PCT and PBB, as a class or category of substances owing to similarities in the physio-chemical and toxicological properties of these substances. Topics addressed include waste management, treatment, destruction and disposal practices. Please note that neither PCT nor PBB are subject to the Stockholm Convention.

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 Pollutant. This document provides more detailed information on the nature and occurrence of PCB, PCT and PBB wastes for purposes of identification and their management.

1.2 Description, production, use and wastes

1.2.1 Description1.2.1.1 PCB5. Commonly known as chlorobiphenyls, PCB is a group of halogenated aromatic hydrocarbons (arenes) characterized by the biphenyl structure (two phenyl rings (C6H5)2) and at least two chlorine atom substituted for hydrogen. The chlorine atoms can be attached at any of ten available sites. In theory there are 209 congeners, although only about 130 congeners have actually been found in chemical formulations (Holoubek, 2000). Typically 40% to 60% of the 10 possible substitution sites are occupied with chlorine atoms (four to six chlorine atoms) (Environment Canada, 1988). The higher chlorinated PCB congeners are virtually insoluble in water and very resistant to thermal and biological degradation.

6. PCB includes 12 compounds for which the World Health Organization (WHO) has developed toxicity equivalency factors since they exhibit dioxin-like toxicity (2,3,7,8-tetrachlorodibenzo-p-dioxin).

1.2.1.2 PCT7. PCT is also a group of halogenated hydrocarbons. PCT is very similar in chemical structure to PCB, except that they contain three phenyl rings instead of two. PCT can therefore have up to 14 chlorine atoms attached. The number of possible congeners of PCT is very large, however only a few occur in commercial products. PCT have very similar chemical and physical properties to PCB. They are virtually insoluble in water and very resistant to thermal and biological degradation. One difference is that PCT tend to have less volatility (higher boiling point) than PCB.

1.2.1.3 PBB8. PBB are chemically identical to PCB, except that bromine atoms are substituted for hydrogen on the phenyl rings instead of chlorine. As with PCB, there are 209 possible congeners of PBB. However, only a few occur in commercial products (Melber et al, 1994). They are solids or waxy substances at room

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temperature. They are virtually insoluble in water and very resistant to thermal and biological degradation.

1.2.2 Production1.2.2.1 PCB9. PCB have excellent dielectric properties, longevity, non-flammability, and resistance to thermal and chemical degradation. For this reason, prior to national bans, they were manufactured for use in electrical equipment, heat exchangers, hydraulic systems, and several other specialized applications.

10. Principal manufacture occurred from 1930 up to the late 1970s in the United States; 1974 in China (China State Environmental Protection Agency, 2002); the early 1980s in Europe, and 1993 in Russia (AMAP, 2000); and from 1954 to 1972 in Japan.

11. PCB were generally manufactured as mixtures of congeners, for example as progressive chlorination of batches of biphenyl until a certain target percentage of chlorine by weight was achieved. The manufactured PCB were rarely used at full strength. For example, they were added in small quantities to ink, plastics, paints and carbon paper or were used in formulations up to 70% PCB in hydraulic fluid, transformer fluid and heating fluids. At room temperature, the majority of them are oily liquids or waxy solids.

12. Prominent trade names of PCB products included those listed below. (See Appendix 1 for a more detailed list of PCB trade names and synonyms and Section 4.4 considerations regarding precautions to take when utilizing trade names in inventory exercises.)

Apirolio (Italy)Aroclor (US) Clophen (Germany)Delor (Czechoslovakia)Elaol (Germany)Fenchlor (Italy)Kanechlor (Japan)Phenoclor (France) Pyralene (France) Pyranol (US) Pyroclor (US)Santotherm (Japan)Sovol (USSR)Sovtol (USSR)

13. In the Aroclor series a four-digit number follows the word “Aroclor”. The first two digits of the number are either “10” or “12”. The number “12” indicates a “normal” Aroclor while the number “10” indicates a distillation product of an Aroclor. The second two digits of the four digit code indicate the percent chlorine in the mixture by weight. Therefore Aroclor 1254 contains approximately 54% chlorine by weight.

14. Commercial PCB products were sold for their industrial properties rather than for their chemical composition (International Programme on Chemical Safety (IPCS), 1992). They contained a number of impurities, were not guaranteed to have a specific PCB content, and were often mixed with solvents, such as tri- and tetrachlorobenzenes. Those PCB mixed with tri- and tetrachlorobenzenes were called “askarel.” Contaminants in commercial mixtures include polychlorinated dibenzofurans (PCDF) and chlorinated naphthalenes. Studies have found from 0.8 mg/kg to 40 mg/kg of PCDF in commercial mixtures (IPCS, 1992). PCB is also formed unintentionally in some thermal and chemical processes. For example, the combustion of chlorine-containing organic material and some processes for the chemical

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production of ethylene dichloride may produce PCB.

15. It is estimated that the worldwide cumulative production of PCB was 0.75 – 2 million tonnes.

1.2.2.2 PCT16. PCT were manufactured in much smaller quantities than PCB and were given the same, or very similar, trade names. They were used for the same sorts of applications as PCB, although most were used in waxes, plastics, hydraulic fluid, paint and lubricants (Jensen & Jørgensen, 1983). In the US Aroclor series terphenyls are indicated by the digits 54 in the first two spaces of the four digit code (IPCS, 1992), e.g. Aroclor 5432, 5442 and 5460.

17. Examples of trade names are:

Aroclor (US) Kanechlor KC-C. (Japan)

18. PCT were produced in the United States, France, Germany, Italy and Japan until the early 1980s when all production is thought to have ceased. The total cumulative worldwide production is estimated to have been 60,000 tonnes between 1955 and 1980 (UNECE, 2002). See Appendix 1 for examples of trade names and discussion in Section 4.4 of trade names in inventory identification.

1.2.2.3 PBB19. Information on the production of PBB is scarce. It is estimated that at least 11,000 tonnes of PBB were cumulatively produced worldwide but production figures from some countries known to have produced PBB are not available (IPCS, 1994). PBB were manufactured in the United States until 1979, in Germany until the mid-1980s, and in France until at least the mid-1990s. It is reported that PBB were still being marketed in Western Europe in 1998. PBB may still be in production in Asia (Lassen et al., 1999).

20. The first PBB compound produced was hexabromobiphenyl, which was commercially known as “FireMaster®” in the United States. Firemaster® was produced from 1970 to 1974. Analysis has shown that Firemaster® contained up to 80% hexa- and up to 25% heptabromobiphenyl. In France, a commercial mixture of PBB was sold as “Adine 0102.” In Germany, highly brominated PBB were produced and sold as “Bromkal 80-9D.” See Appendix 1 for examples of trade names and discussion in Section 4.4 of trade names in inventory identification.

1.2.3 Use1.2.3.1 PCB21. PCB were used in a very wide variety of applications in both industrial and consumer products. The WHO categorized the uses as completely closed, nominally closed and open ended (IPCS, 1992). The uses included:

completely closed systems: electrical transformers, electrical capacitors (including lamp ballasts), electrical switches, relays and other, electrical cables, and electric motors and magnets (very small amounts);

nominally closed systems: hydraulic systems, and heat transfer systems (heaters, heat exchangers); and

open-ended systems:

plasticizer in PVC, neoprene, and other artificial rubbers;

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ingredient in paint and other coatings; ingredient in ink and carbonless copy paper; ingredient in adhesives; pesticide extender; ingredient in lubricants, sealants and caulking material; fire retardant in fabrics, carpets, polyurethane foam, etc.; and lubricants (microscope oils, brake linings, cutting oils, other lubricants).

22. While electrical transformers containing PCB are defined as a “completely closed” application, industrial practices caused these PCB to be transferred to other types of equipment, thus creating additional points of contact with the environment. A common practice was to “top up” or recharge non-PCB (mineral oil) transformers with PCB when no other fluid was available.

23. PCB oils were also added to or disposed with non-PCB fluids such as heating/cooling fluid, hydraulic fluid, brake fluid, engine oil, and off-specification fuels. There are numerous anecdotal reports of employees in electrical utilities using PCB fluids to wash their hands and taking PCB fluids home for use in home heaters, hydraulic systems, and motors (as a lubricant). Since most fluorescent lamp ballasts made before PCB were banned contained PCB, most homes and businesses that installed fluorescent lamps unknowingly acquired PCB.

1.2.3.2 PCT24. PCT were used in almost exactly the same applications as PCB but in much smaller amounts, however little is known about remaining quantities because inventories have not been developed (UNECE, 2002). It is known that very little PCT was used in electrical equipment (Danish Environmental Protection Agency, 2002).

1.2.3.3 PBB25. The principal use of PBB was as a fire retardant. PBB were added to acrylonitrile butadiene styrene (ABS) plastic (10% PBB), coatings, lacquers and polyurethane foam (IPCS, 1994; Melber et al, 1994).

1.2.4 Wastes26. PCB, PCT and PBB wastes are found in a number of physical forms including:

oils consisting of, containing or contaminated with PCB and PCT (dielectric fluids, heat transfer fluids, hydraulic fluids, motor oil);

equipment containing or contaminated with PCB and PCT (capacitors, circuit breakers, electric cables, electric motors, electromagnets, heat transfer equipment, hydraulic equipment, switches, transformers, vacuum pumps, voltage regulators);

liquid waste contaminated with PCB, PCT or PBB (paints, solvents, varnishes);

fire suppression equipment containing or contaminated with PBB;

end-of-life vehicles containing PCB (only very old cars);

demolition wastes containing PCB (painted materials, resin-based floorings, sealants, sealed glazing units);

soils and sediments contaminated with PCB, PCT or PBB;

rock and aggregates (e.g., excavated bedrock, gravel, rubble) contaminated with PCB, PCT or PBB;

sludge contaminated with PCB, PCT or PBB;

solid waste contaminated with PCB, PCT or PBB (paper, metal products, glass, plastic, auto

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shredder fluff, painted objects, fly ash); and

water contaminated with PCB, PCT or PBB (pumped groundwater, process water, firefighting water).

27. Note that the categories above mainly apply to PCB, which were produced in much larger quantities than PBB or PCT and have been stored as wastes awaiting destruction. PBB and PCT are rarely found in large bulk situations and therefore do not have the potential to form large amounts of waste.

2.0 Relevant provisions in the Basel and Stockholm Conventions

2.1 Basel Convention28. 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 of the Basel Convention defines environmentally sound management 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.”

29. Article 4 (“General Obligations”), paragraph 2, subparagraphs (a) through (d) contain key provisions of the Basel Convention pertaining to environmentally sound management, waste minimization, and waste disposal practices that protect or minimize 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 PCB, PCT and PBB wastes, including which treatment, destruction and disposal methods are appropriate for these waste streams

30. Article 1 (“Scope of Convention”) outlines the waste types subject to the Basel Convention. Article 1 paragraph 1(a) of the Basel Convention contains a 2-step process for determining if a “waste” is a “hazardous waste” subject to the Convention. First, the waste must belong to any category contained in Annex I (“Categories of Wastes to be Controlled”). Second, the waste must posses at least one of the characteristics listed in Annex III (“List of Hazardous Characteristics”).

31. Annex I lists some of the wastes that may consist of, contain or be contaminated with PCB, PCT and PBB, these include:

Y10 Waste substances and articles containing or contaminated with polychlorinated biphenyls (PCB) and/or polychlorinated terphenyls (PCT) and/or polybrominated biphenyls (PBB)

Y18 Residues arising from industrial waste disposal operations

32. Wastes contained in Annex I are presumed to exhibit an Annex III hazardous characteristic—which include H11: “Toxic (Delayed or Chronic)”; H12 “Ecotoxic”; and H6.1 “Poisonous (Acute)”—unless, through “national tests,” they can be shown to not exhibit the characteristics. National tests may be used until such time as the hazardous characteristics of Annex III are fully defined.

33. List A of Annex VIII describes wastes that are “characterized as hazardous under Article 1, paragraph 1(a)” although “their designation on this Annex does not preclude the use of Annex III to demonstrate that a waste is not hazardous.” The B list of Annex IX lists 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 to PCB, PCT and PBB:

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A1180 Waste electrical and electronic assemblies or scrap (excluding those from electric power generation) containing components that include PCB-capacitors

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 more

34. The footnote to A3180 states that 50 mg/kg is considered to be an internationally practical level for all wastes, although some countries have established lower regulatory levels (e.g., 20 mg/kg) for specific wastes.

35. Annex VIII’s List A and Annex IX’s List B also include a number of wastes or waste categories that have the potential to include PCB, PCT or PBB owing to past applications of these substances, such as waste thermal (heat transfer) fluids (A3040); fluff–light fraction from shredding (A3120); waste mineral oils (A3020); wastes from production, formulation and use of resins, latex, plasticizers, glue/adhesives (A3050); waste halogenated or unhalogenated non aqueous distillation residues arising form organic solvent recovery operations (A3160); and, as regards unintentionally generated PCB, spent sorbents. Inorganic wastes are also described that could potentially be contaminated with these substances (including as taken up form the environment), such as wastes arising from agro food industries that include, for example, fish waste (B3060).

2.2 Stockholm Convention36. The general objective of the Stockholm Convention as stated in Article 1 (“Objective”) is to protect human health and the environment from persistent organic pollutants.

37. The Stockholm Convention differentiates between two categories of PCB:

1. intentionally produced PCB whose production and use are to be eliminated in accordance with the provisions of Annex A;

2. unintentionally produced PCB, whose total releases derived from anthropogenic sources are to be minimized and, where feasible, ultimately eliminated.

38. 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;

39. Annex A, Part II (“Polychlorinated biphenyls”), paragraph (a) taking into account the 2025 target for removal of PCB liquids requires that Parties make determined efforts to identify, label, and remove from use equipment in accordance with the following priorities:

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equipment containing greater than 10% PCB and volumes greater than litres; 0.05% PCB and volumes greater than 5 litres; 0.005% PCB and volumes greater than 0.05 litres.

40. Annex A, Part II, paragraph (e) calls upon each Party to “Make determined efforts designed to lead to environmentally sound waste management of liquids containing polychlorinated biphenyls and equipment contaminated with polychlorinated biphenyls having a polychlorinated biphenyls content above 0.005 per cent, in accordance with paragraph 1 of Article 6, as soon as possible but no later than 2028, subject to review by the Conference of the Parties.”

41. Annex A, Part II, paragraph (g) further obligates each Party to provide a progress report on elimination of PCB every five years. The COP will review the reports at five year intervals, or other period, as appropriate.

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

3.1 Low PCB content42. Recognizing the wide range of values proposed, and the need to establish a practical and enforceable low PCB content, it is recommended to use the following provisional values at this time:

50 mg/kg (ppm) for PCB both in solid and in liquid.

43. As per paragraph 2(c) of the OEWG decision II/10 the issue of methodology for further definition of low PCB content will be addressed in a separate document.

3.2 Levels of destruction and irreversible transformation42. As per paragraph 2(b) of the Open-ended Working Group decision II/10 the definition of level of destruction and irreversible transformation will be addressed within a separate document.

3.3. Methods that constitute environmentally sound destruction and disposal

3.3.1 Destruction or irreversible transformation methods43. Section 4.7.2 contains a description of several methods of destruction or irreversible transformation.

44. The applicability of these methods to a particular PCB waste will depend upon the definition of low PCB content and level of destruction or irreversible transformation. For example, when the waste has a PCB concentration greater than the low PCB content, only those destruction or irreversible transformation methods capable of achieving the proposed levels should be utilized, 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 PCB content is low45. Section 4.7.3 contains a description of several methods of disposal.

46. The applicability of these methods to a particular POP waste will depend upon the concentration of concentration of POP in the waste, and the definition of low POP content. These methods may also be utilized in situations where destruction or irreversible transformation does not represent the environmentally preferable option. Further considerations are outlined in section 4.7.3.

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

47. The conditions and cases where destruction or irreversible transformation of PCB waste with a concentration above the established low PCB 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 authorized the alternative disposal operation and informed the Secretariat of the Basel Convention of its authorization and justification for it.

48. Examples of wastes containing or contaminated with PCB where destruction or irreversible transformation may not represent the environmentally preferable option include those listed below:

non-leachable contaminated solids (demolition waste, auto-shredder fluff, cable sheaths), in-situ “low-level” contaminated soil and bedrock, solid wastes from thermal processes, waste linings and refractories, solid construction and demolition wastes, 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.

4.0 Guidance on Environmentally Sound Management (ESM)[This draft has retained section 4.2 as per the Table of Contents circulated for comment on November 7, 2003. Note that the Basel Secretariat suggests removal of this section.]

4.1.1 Basel Convention49. Environmentally sound management (ESM) of hazardous wastes or other wastes is described in Article 2, paragraph 8 of the Basel Convention 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.”

50. Article 4, subparagraph 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 subparagraph 2(c) requires each Party to ensure that persons involve 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.

51. 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.

52. 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 “umbrella” document titled General Technical Guideline for Environmentally Sound Management of Wastes Consisting of, Containing or Contaminated with Persistent Organic Pollutants.

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53. Parties planning or reviewing their national ESM programme should consult the Basel Convention 2003 guidance document Preparation of a National Environmentally Sound Plan for PCB and PCB-Contaminated Equipment: Training Manual.

4.1.2 Stockholm Convention54. 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 6.2 (b) of the Stockholm Convention).

55. 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.

4.1.3 OECD56. The Organization for Economic Cooperation and Development also promotes ESM through its “Core Performance Elements” (OECD, 2003).

4.2 Legislative and regulatory framework57. Elements of a regulatory framework applicable to PCB, PCT and PBB could include the following:

enabling environmental protection legislation (sets release limits and environmental quality criteria);

prohibitions on the manufacture, sale, import and export (for use) of PCB, PCT and PBB;

phase-out dates for PCB that remain in service, inventory or storage;

hazardous materials and waste transportation requirements;

specifications for containers, equipment, bulk containers and storage sites;

specification of acceptable analytical and sampling methods for PCB, PCT and PBB;

requirements for waste management, destruction and disposal facilities;

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).

58. The timing of the phase-out of PCB (and to a lesser extent PCT and PBB) will likely be the most critical legislative concern for most countries, given that most nations already have some form of legislative framework dealing with PCB.

4.3 Waste prevention and minimization59. Both the Basel and Stockholm Convention advocate waste avoidance and minimization, while PCB compounds are targeted in the Stockholm Convention for complete phase-out. PCB, PCT and PBB

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should be taken out of service and destroyed/irreversibly transformed or disposed of in an ESM manner (as applicable to concentration of the POP and the matrix in which the POP occurs) as quickly as possible and that these wastes not be recycled or recovered for re-use.

60. Quantities of waste containing these compounds can be minimized through isolation and source separation in order to prevent mixing and contamination of other waste streams. For example PCB in electrical equipment, painted materials, resin-based floorings, sealants and sealed glazing units can contaminate large amounts of demolition waste if not separated prior to demolition.

61. Efforts should also be made to reduce and eliminate releases of unintentionally produced PCB, PCT and PBB and thereby minimize wastes contaminated with these substances. Efforts undertaken to reduce the incidental generation and releases of polychlorinated dibenzo-p-dioxins (PCDD) and PCDF will also reduce the generation and release of unintentionally produced PCB 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 in the process of preparing additional guidance on best available techniques and best environmental practices for reducing and eliminating releases of Annex C substances.

4.4 Identification and inventories

4.4.1 Identification62. PCB, PBB or PCT are typically may be found in the following industries, equipment and locations (if constructed before approximately 1980):

electric utilities (generation stations and transmission companies; PCB in transformers, capacitors, switches, regulators, etc.);

communications equipment (PCB in capacitors and transformers, PBB in plastic housings and cables) ;

components (mainly the ABS plastic housing) of business machines (PBB);

government, industrial, office and apartment buildings; schools, hospitals (for PCB and PBB in electrical equipment; PBB in fire suppressing systems);

fire suppressant systems and bulk fire suppressant products (PBB and PCT);

fluorescent light ballasts (PCB);

sealants and caulking used on exterior and interior building surfaces (PCB);

painted objects, such as wood, concrete and wallboard (PCB, PBB, PCT);

insulation in underground electrical cables (PCB);

joints and valves of gas and oil pipelines, and the condensate that forms in pipelines (PCB, PCT);

ships (electrical equipment, communications equipment, hydraulic equipment, fire suppresants) (PCB, PBB, PCT);

aircraft (electrical equipment, communications equipment, hydraulic equipment, fire suppressants: PCB, PBB, PCT);

barrels (storage of PCB, PBB, PCT);

mineral oil and other waste oils that may have become contaminated with PCB;

oil filled heaters (PCB);

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auto-shredder residue (fluff) (mainly PCB, possibly PBB and PCT);

soil and groundwater (contaminated by spills);

sediment (contaminated by spills);

dirt and gravel roads (contaminated when used PCB oil sprayed for dust control); and

recycled liquid paint (PCB, PBB, PCT).

63. It is important to note that even experienced technical persons may not be able to determine the nature of an effluent, substance, container or piece of equipment by its appearance or markings. PCB equipment, for example, was typically not labelled as to the type of dielectric fluid contained within. Experienced inspectors may be able to determine the original contents from other information on the nameplate, or by using guidance manuals such as Guidelines for the Identification of PCB and Materials Containing PCB (UNEP, 1999), or by contacting the manufacturer.

64. When identifying PCB, PCT and PCCs common trade names outlined in Appendix 1 may be useful.

4.4.2 Inventory65. A national stockpile inventory of PCB, PBB and PCT is necessary to establish a baseline quantity of these substances. The baseline can be used to establish an action plan and track progress for phase-out of these substances. Stockpile inventories also assist with regulatory and health and safety inspections, aw well as preparation of emergency response plans.

66. The development of a national inventory requires the long-term commitment of the national government, cooperation of PCB, PBB and PCT owners, 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 phase-out and destruction. In some cases, government regulations may be required to ensure that PCB, PBB and PCT owners report their holdings and cooperate with government inspectors.

67. A complete inventory of all PCB, PBB and PCT is impossible to compile, mainly because of dispersive uses of these chemicals (use in inks, plasticizers, paint, flame retardants in small components, lubricants, etc.).

4.5 Sampling, analysis and monitoring[This draft has retained section 4.5 as per the Table of Contents circulated for comment on November 7, 2003. Note that UNEP Chemicals suggests removal of this section.]

4.5.1 Sampling68. In this document “sampling” refers to the taking of a sample of gas, liquid or solid for later analysis either in the field or in a laboratory.

69. The types of matrices that are sampled for analysis of PCB, PCT and PBB are shown below.

Liquids:

water (surface water, rainwater, groundwater, soil pore water, drinking water, industrial process water, effluent water, condensate);

askarel (PCB) liquid from transformers or other equipment or in bulk storage; mineral oil from transformers contaminated with PCB or in bulk storage; waste motor oil and other waste oils, fuels and organic liquids; liquid fire suppressants and retardants (PBB);



biological liquids (blood, urine); and liquids collected from spills or from free-product subsurface recovery systems at

contaminated sites.

Solids:

solid or semi-solid PCB, PCT and PBB products; containers or equipment (rinse or wipe sample); soil, sediment, rubble, compost; paint chips, pieces of caulking and sealant, plastic chips, pieces of wire and cable, auto-

shredder “fluff,” mixed solid wastes; tissues or fabric used in the collection of wipe samples; filter materials; solids extracted from a liquid or sludge (suspended solids, precipitates, coagulated solids,

filtered material); solids from industrial or destruction processes (fly ash, bottom ash, slag, still bottoms,

other residues); ice, snow and other frozen materials; plant materials and food; and biological solids (whole animals, tissues, faeces).

Gases:

product or waste gases in containers; stack gases from industry and treatment processes; volatile emissions from products, wastes, processes and contaminated sites; soil and groundwater gases; air (ambient, personal breathing, confined space); and biological gases (exhaled air, gases released by organisms).

70. Elements of sampling for PCB, PCT and/or PBB that should be undertaken in all cases include the following:

researching the site and/or materials to be sampled;

planning the sampling programme to ensure representative samples are obtained;

obtaining the sample supplies and preparing for the field or laboratory work;

laying out the sample locations and equipment at the site;

reviewing and revising the sample plan in the field if necessary; and

collecting the sample(s):

placing the sample in the sample container, labeling the sample, preserving the sample, cleaning the sampling equipment for next sample, completing the sample submission and, if applicable, chain of custody forms, documenting the sampling work (notes, photographs, videos), transporting the sample to the analytical equipment (field or laboratory), and transferring the samples to the custody of the analytical personnel.

71. There are numerous types of sampling equipment including custom made samplers. Virtually any sample method is acceptable if the above-listed sampling steps are followed.



4.5.2 Analysis72. Analysis in this section refers to the determination of physical, chemical or biological properties of a material using documented, peer-reviewed and “accepted” laboratory methods.

73. Each nation should identify, through guidance documents or legislation, standard methods that are required to be used for each POP chemical and the matrices in which the use of the method must be used.

74. The methods specified should cover all aspects of the analytical process for each type of sample that could be collected, as per the list of sample materials in Subsection 4.5.1. The steps in analysis are some or all of the following:

sample handling and storage;

sample preparation (drying, weighing, grinding, chemical digestion, etc.);

extraction of contaminants (organic solvent extraction, leachate production);

dilution or concentration of sample or extract;

calibration of equipment;

the actual analytical or bioassay test method;

calculation or determination of result; and

reporting of result.

75. There are numerous methods available for each step of the process. The key for any nation is to adopt standard methods and then require the use of them by commercial, government and research laboratories. In very general terms the methods available for chemical analysis for PCB (UNEP, 1999) are the following:

Thin-layer chromatography – typically for soils and oils; not the most precise method

Gas-liquid chromatography/electron capture – typically for air samples

Packed-column gas chromatography (GC)/electron capture – typically for oil samples that may be high-concentration PCB (from equipment and spills)

Capillary column GC – for solids and liquids contaminated with PCB

GC/Hall electrolytic conductivity detector – for oils and liquids; less precise than GC/electron capture

GC/mass spectrometry (MS) – for determining individual PCB isomers. May not be able to detect low concentrations

Thermal extraction/GC/MS – for soils, sludges and solids; this is an alternative to solvent extraction prior to GC/MS analysis

76. Certification and testing of laboratories is another important aspect of a national analytical programme. All laboratories must be able to meet certain quality standards as set and tested by government, an independent body such as ISO or an association of laboratories.

4.5.3 Monitoring77. In this section “monitoring” refers to the measurement of PCB, PCT and/or PBB in the environment or in humans or from known or suspected sources to the environment or evaluation of the effects of PCB, PCT and/or PBB on the environment, human health, societies and economies.



78. Monitoring for PCB is well established globally and nations that have PCB monitoring programmes should continue or expand them to meet the requirements of the Stockholm and Basel Conventions.

79. Monitoring programmes for PCT and PBB have, in general, not been established by national governments, although some research studies have been carried out. The scientific evidence to date does not indicate that PCT and PBB in the environment are a significant environmental and human health threat. However, there have not been sufficient studies to make a definitive statement about the risk they pose. Nations should implement initial monitoring studies for PBB and PCT, possibly in cooperation with other nations, and then determine whether further monitoring is necessary and the scope of that monitoring.

80. Environmental monitoring for PCB, PCT and PBB should focus on key “marker” species in which they are known to bioaccumulate and have toxic effects. Examples of the species that fall into this category for PCB are gulls, eagles, peregrine falcon, fish-eating ducks, cormorants, seals, fish-eating whales, dolphins, polar bear, mink, otters, salmon, and cod.

81. Research and monitoring results should be published in government reports or scientific journals or be submitted to the Basel or Stockholm Secretariat for incorporation into an international publication.

82. For more specific information on monitoring activities that could be carried out see the General Technical Guidelines for Environmentally Sound Management of Wastes Consisting of, Containing or Contaminated with Persistent Organic Pollutants.

4.6 Handling, collection, packaging, transportation and storage83. 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.

4.6.1 Handling84. Handling of PCB, PCT and PBB wastes should be done with the objective of minimizing 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 25oC, if possible, due to the increased volatility at higher temperatures;

ensuring that spill containment measures are in good shape and 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 (not used for any other purpose);

cleaning up any spills with cloths or paper towels;

triple rinsing of contaminated surfaces with a solvent such as kerosene to remove all of the residual PCB, PCT or PBB; and

treating all absorbents, disposable protective clothing, plastic sheeting as PCB, PCT or PBB waste when appropriate.

85. Staff should be trained in the correct methods for handling hazardous wastes.

4.6.2 Collection86. A significant amount of the total national inventory of PCB, PCT and PBB may be held in small quantities by small business owners and homeowners, for example, in PCB fluorescent light ballasts, other small electrical devices, heat exchangers and heaters containing PCB or PCT fluid, PBB in fire suppression systems, small containers of pure products, and assorted small, unmanaged “stockpiles” on occupied or unoccupied land. It is difficult for small quantity owners to dispose of these materials. For example, the regulatory situation may require that they be a registered waste generator, logistical considerations may prevent of discourage pick up (e.g., no industrial waste pick-up allowed/available in a residential neighbourhood), and costs may be prohibitive. National, regional or municipal governments may wish to consider establishing collection stations for these small quantities so that each small-quantity owner does not have to make individual transport and disposal arrangements.

87. Collection depots and/or collection times for PCB, PCT and/or PBB should be separate from those for all other wastes. It is not advisable to mix PCB, PCT and PBB with other wastes as they may contaminate the other wastes and cause them to become PCB, PCT or PBB waste.

88. It is imperative that collection depots not become long-term storage facilities for PCB, PCT and PBB. The risk of environmental and human health impairment is higher for a large stockpile of wastes, even if properly stored, than from small quantities scattered over a large area.

4.6.3 Packaging89. PCB, PBB and PCT wastes must be packages prior to storage or transport. Liquid wastes should be 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, containers used for storage should meet transport requirements in anticipation that they may be transported in the future.

90. 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 whether drained or not, should be placed in drums with an absorbent material. Numerous small pieces of equipment may be placed in one drum, so long as an adequate amount of absorbent material is present in the drum. Loose absorbents may be purchased from safety suppliers or sawdust, vermiculite or peat-moss may also be used.

91. Drums and equipment may be placed on pallets for movement by forklift truck and for storage. Equipment and drums should be strapped to the pallets prior to movement.

4.6.4 Labelling 92. All drums, containers and equipment containing or contaminated with PCB, PCT or PBB should be clearly labelled with both a hazard warning label and a label that gives the details of the equipment or drum. The details includes 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 93. 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 prior informed consent for movement of wastes. See the General Technical Guidance document for key provisions for movement of wastes in the Basel Convention.

94. 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.

4.6.5 Storage95. Many countries have adopted PCB storage regulations or have developed guidance documents for PCB storage. Most do not have specific storage regulations or guidance for PCT and PBB. However, it can be assumed that the storage procedures should be similar to PCB since the properties and toxicity of PCT and PBB are similar. 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;

PCB, PCT and PBB 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;

PCB, PCT and PBB 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 by humans;

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 mil) plastic sheeting

floors should be concrete or durable (e.g., 6 mil) 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, such as lamp ballasts, small capacitors, other small equipment, 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 PCB, PCT and PBB 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 PCB, PCT and/or PBB 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 PCB, PCT and/or PBB are not dealt with in the master health and safety plan for the property, company or agency.

4.7 Environmentally sound destruction and disposal

4.7.1 Pre-treatment96. 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.



4.7.1.1 Adsorption / Absorption

97. 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 or liquid 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).

98. These 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 meets discharge criteria. There are several sorption technologies commercially proven and developed.

4.7.1.2 Dewatering

99. Dewatering is a pre-treatment approach that partially removes water from the wastes to be treated. Dewatering can be employed for destruction technologies which 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.

4.7.1.3 Oil / Water Separation

100. Some process technologies are not suitable for aqueous wastes, 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.

4.7.1.4 pH Adjustment

101. Some treatment technologies are most effective in a defined pH range and in these situations, caustic, 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.

4.7.1.5 Screening

102. 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.

4.7.1.6 Shredding

103. 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.

4.7.1.7 Solvent Washing

104. 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 PCB, PCDD and PCDF from soil.

4.7.1.8 Thermal Desorption



105. Low-Temperature Thermal Desorption (LTTD), also known as low-temperature thermal volatilization, 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 methods106. This section describes and comments on commercially available technologies for the destruction or irreversible transformation of PCB, followed by recommendations.

4.7.2.1 Advanced oxidation process (AOP)

107. AOP increase the rate of oxidation through the use of highly reactive chemical oxidizers. 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 with the H2O2 to form hydroxyl radicals (OH). These hydroxyl radicals will react with the contaminants to form CO2, H2O and residual ions such as Cl-.

108. 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.

109. 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 minimize 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 oxidizer) 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 instable 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 high hazard levels 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 PCB wastes in industrial regions.

4.7.2.2 Base catalyzed decomposition (BCD)110. 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.

111. This is a proven technology that has undergone commercialization since 1993 in both the United States and other countries. The destruction efficiency of the BCD process for the treatment of DDT, dieldrin, PCB, PCDD and PCDF is high (99.9999%). As mentioned above, both liquids and solids can be treated. This process can treat from 100 kg/h to 20 t/h for solid wastes on a continuous basis and from 1 to 5 t/batch with 2 to 4 batches a day for solids on a batch basis. For liquid waste, the capacity is typically 4500 to 9000 litres with 2 to 4 batches a day. Higher concentrations in the waste require longer reaction time.

112. The possible configuration of the technology ranges from modular to transportable units as well as fixed plants. As with other technologies using chemical products in large quantities, some skilled operators and a well-defined safety procedure are required. Further analysis of the material may be required since the contaminants may become concentrated in the condensate. There have been measurable discharges of PCDD and organochlorines to the atmosphere for the older plants but this problem has been addressed through the use of new hydrogen donors. Air emissions can be further reduced through the usage of gas scrubbing units. This technology could be used with highly qualified personnel and management and strict safety and inspection procedures combined with an excellent maintenance program. This technology could be recommended for use in all areas, for low and high PCB concentrations, in the described matrices.

4.7.2.3 Cement kiln co-incineration113. Cements kilns are rotary ovens used to produce a clinker from lime, sand, clay and other materials. Temperatures reach 1450°C in a cement kiln and the combustion gases stay above 1200°C for five to six seconds destroying most POPs in the process. The usage of large quantities of lime (in excess) ensures that traces of sulphur and chlorine acids are neutralized. Dust produced during the process is reintroduced into the process, therefore no solid wastes should be produced.

114. Numerous pilot plant trials in the United States and France, by cement producers and private waste management firms, have demonstrated destruction efficiencies above 99.99%. This technology can be used to destroy all POP wastes in the form of non-aqueous liquids and sludges. Powders can be destroyed if converted into a slurry form. Cement kiln incineration is not suitable for soils.

115. For destruction in cement kilns, wastes must be blended with a fuel suited to the cement process itself. Under proper conditions, the risk to the environment and humans should be minimal. Upsets in the process may cause incomplete combustion resulting in polluting emissions. Highly qualified technical personnel are necessary to operate the system. There is medium hazard levels associated with the operation of this technology, however the actual risk should be low with the implementation of a health and safety plan. Although the technology is commercially available and high destruction efficiencies have been demonstrated, it should only be used in cement plants that can demonstrate adequate kiln temperature control.

4.7.2.4 Gas phase chemical reduction (GPCR)116. GPCR is based on a gas-phase thermo-chemical reaction at a high temperature (approx. 850°C) between hydrogen and organic compounds. The organic compounds are reduced by the hydrogen to methane, hydrogen chloride (if the waste is chlorinated) and minor amounts of low molecular weight hydrocarbons in the GPCR reactor. The reduced gases are then scrubbed to remove the particulates and acid before being stored for reuse as a fuel. The process can operate without any external hydrogen supply if the methane produced is converted back to hydrogen. Depending upon the waste matrix, either a vaporizer or a thermal desorption unit will be required to convert the POP waste into a gas phase.

117. The GPCR process has been developed, patented and commercialized by Eco-Logic in Canada. A full-scale plant was operating in Kwinana, Australia, but has since been shut down. The technology is



under full-scale and pilot-scale applications in Canada, the United States, and the Slovak Republic. Destruction efficiencies of 99.9999% have been measured for aldrin, dieldrin, HCB, DDT, PCB, PCDD and PCDF. This process is flexible and can be applicable to bulk solids, contaminated soils/sediments, and liquids including oils.

118. The benefits of this technology are the high efficiency of the process (low emissions) and the range of matrices and contaminants that can be treated. Some limitations have been identified, for example, pre-treatment can be limiting factor in the case of large equipment to be decontaminated. Treatment of waste containing arsenic and mercury produces highly toxic arsenic and mercury compounds. Also, some by-products are generated which need to be disposed of (used liquor and solid residues). This technology could be considered as ‘high tech’ meaning that skilled operators would be required to operate such a plant. The principle raw materials and ancillaries required for this process are electricity, hydrogen (at least during start-up), water and caustic. Even though mobile units are available; this technology remains mainly as large fixed plants. GCPR technology is recommended for destruction of low and high concentration PCBs in the described matrices, in both industrial and non-industrial regions.

4.7.2.5 Incineration

Large-scale fixed incinerators

119. Large-scale fixed incinerators use heat from fuel combustion or electrical input to cause thermal decomposition of organic contaminants through cracking and oxidation reactions at high temperatures (usually between 760 to 1550°C). The organic contaminants are primarily converted into carbon dioxide and water vapour. Other products of incineration can include nitrite oxides, nitrates, and ammonia (from nitrogen-containing wastes); sulfur oxides and sulfate (from sulfur-containing wastes); and halogen acids, HCB, PCB, PCDD and PCDF (from halogenated wastes). The nature and quantity of by-products depends on the control of the incineration operations. Some post-treatment may be required, including gas scrubbing, waste-water treatment and proper treatment of ashes, slag and scrubber residues. Also off-gas treatment may be needed to neutralize the acidic gas incinerating halogenated substances.

120. This technology is widely commercialised and has been used for many years. The reported destruction efficiency of this process is over 99.99%. Their capacities vary, typically ranging from 1.5 to 7 t/h for larger units. These incinerators can handle solids and liquids, as well as contaminated soil, materials, containers and packed waste. Incinerators can destroy all types of POP waste. In general, incineration is not considered suitable for large volumes of aqueous low concentration POP wastes.

121. In the last few years public opinion has started to change regarding incinerators. PCDD, PCDF, PCB and HCB can be formed and released in stack gases and solid residues. The formation and release of unintentional POPs is influenced by the incinerator design and control technology. Some companies have restrictions regarding wastes containing heavy metals such as mercury or other specific elements like iodine, which is another limitation to be considered. These incinerators require highly trained personnel. Regular maintenance and services, and intensive control procedures, including analytical facilities, are necessary. A continuous supply of fresh water, large quantities of chemicals for the scrubber and a reliable supply of electricity and fuel are needed. Gas scrubbers are required with a good control/treatment of the other residues (ash, etc.). This technology is recommended for high and low concentration PCB waste destruction, in the described matrices, in industrial regions.

Mobile incinerators122. Usually, mobile incinerators are large units with a rotary kiln and air pollution control devices.

123. This technology is widely commercialized and has been used to clean hazardous waste dumps in the United States. Destruction and removal efficiencies can be up to 99.999% with units meeting most air emissions standards. Capacities of the smaller models range from 2 to 20 tons/day. Mobile incinerators



are capable of destroying large amounts of soil, aqueous solutions, sludge, oil, organic liquids and solids. It is not generally considered suitable for large volumes of water containing low concentrations of POPs.

124. Mobile incinerators require large quantities of fresh water, large quantities of chemicals for the scrubber, a reliable supply of electricity and highly trained staff. Like large-scale incinerators, it should be considered that a gas scrubber is required with good control/treatment of the other residues like ashes and so forth. There may be limits to the maximum chlorine content of POP wastes that can be incinerated. With proper gas scrubbing and proper treatment of by-products, the mobile incinerator is recommended for large volumes and high concentration PCB waste in all areas for the described matrices. Nonetheless, the applicability of this method to PCB should be reviewed on a case-by-case basis.

Small-scale fixed incinerators

125. The principle of incineration for small-scale fixed facilities is the same as for the large-scale fixed incinerators with a few differences relative to capacity (10 to 100 kg/h), number of combustion chambers, afterburner and gas scrubber requirements. The simplest small-scale model has only a single chamber without an afterburner and/or gas scrubber. The models without an afterburner and gas cleaning devices are definitively not suitable for the destruction of large quantities of waste POPs or any wastes containing chlorine, phosphorus, sulphur or nitrogen. The lack of such proper control devices creates a high risk of severe air pollution particularly when organochlorine compounds are incinerated. Many models do not reach the temperatures required for destruction, which further aggravates the risk. For these reasons small-scale fixed incinerators are not recommended.

4.7.2.6 In-situ vitrification

[Note that the WCC asks if this is really destruction technology]

126. In-situ vitrification uses electricity to melt contaminated soil or wastes at high temperature. The organic pollutants are destroyed by pyrolysis and inorganic compounds are immobilized within the vitrified glass. Large graphite electrodes are inserted into the soil. Electricity arcs from one electrode to another through the soil. Temperatures reached vary from 1400 to 2000°C. The heat reduces the soil into a molten form. The electrodes move deeper as the ground liquefies and continue to melt the soil until the maximum depth is reached. The estimated achievable depth is 30 feet. The electricity is then shut off and the soil solidifies into glass. The organic pollutants are reduced into gases that are collected and transported for treatment.

127. The in-situ vitrification technology is commercially available (Geomelt, Geosafe). The soil should have sufficient amount of glass-forming materials (silicon, aluminum oxides) and metals. The technology has been applied on matrices contaminated with chlordane, dieldrin, DDT, HCB, hepachlor, PCB, PCDD and PCDF. Destruction efficiencies have been reported between 90 and 99.99%. This technology can be applied to both low and high strength waste materials. The technology is suitable for a wide range of soil, dewatered sludge, sediment, and wastes. Permeability and density tests should be performed for each site to determine suitability.

128. The vitrification process is limited by the length of the electrodes and the availability of power. Volatile organic compounds and combustion products can escape from the off-gas treatment system. The soil should be dried prior to melting to prevent the release of dangerous gases. Overall risk to the environment and humans associated with use of this technology is low, considering that an off-gas treatment system should prevent leaks. Electrodes, a transformer, off-gas collection hood, off-gas treatment system and water are the required materials. This technology is portable. There appears to be medium hazard levels associated with operation of this technology, however the actual risk should be low with the implementation of a health and safety plan. This technology is recommended for low and high concentration PCB, for the described matrices, for all regions.



4.7.2.7 Molten salt oxidation (MSO)129. MSO is a flameless reaction that oxidizes the organic substances at temperatures between 700 and 1000°C. The oxidizer (air/oxygen) is added to the waste stream and fed into the reaction chamber beneath the surface of an alkaline molten salt bath. Hot gases rise through the molten salt bath and the salt scrubs acids from the gases. Organic materials are converted into carbon dioxide, nitrogen and water vapour. Metals and other inorganic materials are captured and held in the salt bath. Solid wastes should be dewatered and shredded as a pre-treatment before being injected with air under the surface of the molten salt bath. Oily or liquid phase wastes should be water-free prior to destruction.

130. MOE is a proven destruction technology. Very high destruction efficiencies (>99.9999%) are reported for liquid PCB, PCB-containing solids, HCB, and chlordane. This technology is suitable for high concentration wastes. This technology should only be used for destruction of the following waste types: oily phase, organic liquids and solids. Because water can react explosively with molten salts, MSO is not suitable for water and aqueous solutions. MSO is not suitable for inorganic waste, especially for soil. Inorganic constituents will form metal oxides and slag that may be hazardous and require special disposal.

131. The pre-treatment system may produce contaminated water and require further treatment. Salt residues may contain heavy metals and inorganic contaminants that will require disposal. Volatile organic compounds (VOCs) can also react explosively, therefore VOC concentrations in waste should be controlled. The process requires a high level of energy, water, salt and oxygen. There appears to be a low risk for generation and release of unintentional POPs. There appears to be medium hazard levels associated with the operation of this technology, however the actual risk should be low with the implementation of a health and safety plan. Highly qualified technical personnel are necessary to operate the system. Portable systems utilizing this technology could not be identified. The applicability of this technology for remote areas could be limited due to electricity requirements and chemical product transportation. Therefore technology is recommended for high concentration PCB waste destruction, in the described matrices, within industrial regions.

4.7.2.8 Plasma arc decomposition132. Plasma arc technology directs an electric current between two electrodes through a low pressure gas to create a plasma. The waste is injected into the plasma at a temperature that can reach 3000 to 15000°C. Chlorinated organic compounds are transformed into their elemental states and recombined into mineral gases. Plasma arc decomposition is available through two processes, but only the plascon process has been demonstrated with PCB waste.

Plascon133. In the second process (Plascon), the waste is injected with argon into a plasma arc. The mixing temperature is in excess of 3000°C during which the organic material is pyrolysed. The resulting products include gases consisting of argon, carbon dioxide, water vapour and an aqueous solution of inorganic sodium salts.

134. The Plascon process is a commercially available method. The technology should achieve very high destruction efficiencies (99.00%). The process has been demonstrated successfully for liquid PCB.

135. A pre-treatment to transform waste into a slurry will be required for solid waste. A high level of energy is required. It appears that there should be low risk to the environment considering that process control interlocks are provided to prevent the release of incompletely treated waste, in the case of power failure. Highly qualified technical personnel are necessary to operate the system. Considering the process technology (high temperature), there appears to be high hazard levels associated with the operation of this technology, however the actual risk should be low with the implementation of a health and safety plan.. Although the technology is commercially available and high destruction efficiencies have been



demonstrated, it is not recommended for industrially remote areas. It is recommended, however, for usage in industrial areas for high concentration PCB, in the matrices described.

4.7.2.9 Sodium reduction

136. Sodium reduction uses dispersed metallic sodium at low temperature to destroy PCB. The sodium reacts with the chlorine atoms in the PCB to form sodium chloride and non-halogenated biphenyls.

137. Sodium reduction technology appears to be mostly used for PCB removal from oil transformers. Destruction efficiency of this technology has not been reported. However, this technology has been demonstrated to meet regulatory criteria in Europe, United States, Canada, South America, Australia and Japan for PCB transformer oil treatment. This technology can also be applied to transformers and capacitors if these are previously ground up to fine pieces.

138. There is little information available regarding residue characteristics. When used for in-situ treatment of transformer oils, all PCB contained within the porous internals may not be destroyed. Large amounts of sodium are required. Supply, storage and handling of sodium may present challenges in industrial remote areas. This technology is recommended for low concentration PCB, in the matrices described within industrial areas.

4.7.2.10 Solvated electron technology (SET)

139. SET process is a method of reducing halogenated hydrocarbons in a mixture of sodium or other alkali metal in liquid ammonia. As sodium dissolves in ammonia, it decomposes into sodium ions (Na+) and electrons (e-.). The solvated electrons in the solution act as powerful reducing agents removing the halogens (primarily chlorine) from organic molecules and reducing other contaminants. The solvated electron reaction is highly exothermic. In application, contaminated materials are placed into a sealed treatment vessel and mixed, at room temperature, with the solvated electron solution where the contaminants are rapidly dehalogenated. Ammonia is recovered for further use in a separation vessel and by a condenser. Depending on the matrices treated, pre-treatment and/or post-treatment may be required. Possible pre-treatments are water removal, crushing, screening and washing, among others. Possible post-treatments include pH adjustment and ammonia recovery.

140. Commodore Applied Technology Inc has commercialized the SET technology (although the company has apparently been de-listed from the American Stock Exchange in February 2003 for financial reasons). The reported efficiencies of this technology are rated as high depending on the treated contaminants and matrices. The SET technology has been used to destroy the following contaminants: DDT, dieldrin, HCB, PCB, PCDD and PCDF. This process is flexible as it can handle various matrices: soils, sediments, sludges, oils, non-aqueous liquids and concrete, among others. SET is not suitable for waste containing significant quantities of water. The reported capacity for this process is 10 tons/day for the commercial unit.

141. The SET process has a number of limitations that need to be considered before using this technology:

insufficient amounts of reagents could lead to only partial decomposition of the target contaminants;

excess amounts of reagents would leave traces of sodium in the matrix;

handling and storing large quantities of anhydrous ammonia and sodium pose serious health and safety issues;

the SET reaction is highly exothermic which can present a problem for a large-scale plant;

the process can create toxic by-products;



pressure relief valves and permits for accidental venting of ammonia could be required when processing large amount of materials;

the SET solution is highly corrosive; and

soils cannot be treated in-situ.

142. Most metals will be corroded in the SET reactor, therefore the internals of the reactor should be of inert materials like glass or ceramics. The benefits of this technology are the high efficiency of the process, the range of contaminants that can be treated as well as the type of matrices that can be processed. This process is also available in mobile units which can present an advantage. The number of pre-treatment and post-treatment steps that can be required need to be taken into consideration. The limitations listed above also raise serious concerns, especially regarding health and safety issues with the ammonia and sodium, which can be toxic and dangerous if not handled by highly qualified personnel in combination with exhaustive security procedures. For these reasons, this technology is not recommended.

4.7.2.11 Super-critical water oxidation (SCWO)

143. SCWO destroys organic wastes using an oxidizer in water at temperatures and pressures above the critical point of water (374°C and 220 bars). Products from the process include CO2, water and inorganic salts or acids. At the outlet of the SCWO reactor, the effluent is cooled, depressurized and separated into gaseous and liquid streams.

144. A SCWO commercial-scale plant has recently begun operating in Japan. This technology has been tested with chlordane, PCB and PCDD, however no data is available on destruction efficiencies. This technology is suited for water and aqueous solutions, sludge, oily phase and organic liquids, soil and solid-phase wastes (<200 microns). Solids can be shredded in the pre-treatment stage if they are too large. The system is suitable for low and high concentration POP waste with less than 20% organic content.

145. Hydrochloric acid can be formed by the oxidation of halogenated compounds. Post-treatment may be required. The acid can cause corrosion of the reactor and processing system. Furthermore, neutralization of these acids produces salts, which can form solid precipitates. Electricity, water and oxygen are required. The process requires specialized materials, e.g., titanium, that can withstand corrosion by chlorine ions at high temperatures and pressures. Such materials are expensive and may not be available within developing nations, but should be available within developed nations. Because of the combination of high temperatures and pressures employed, the potential hazards to workers associated with this technology are high. However, with proper safety measures the actual risk to workers may be low. Dioxin formation can be high if reaction conditions are not optimized; however with adequate process control the actual risk may be low. These systems were considered “highly transportable”. Based on these considerations, SCWO is suitable for low and high concentration PCB destruction (with less than 20% organic content) in the described matrices, for use within industrialized regions and where care is taken to assure optimum operating conditions.

4.7.2.12 TiO2 Enhanced Photocatalysis

146. Organic compounds, such as organochlorine pesticides, can be completely degraded in an aqueous environment by UV irradiation in the presence of oxygen and TiO2 based photocatalysts. The solution to be treated is placed into the reactor with TiO2 as a photocatalyst. The photocatalyst is made out of titanium dioxide (0.1 to 0.5% by weight) on glass micro-spheres, which are immobilized on a fixed support or on the reactor wall for easy separation once the reaction is completed. If this is not done, the reactor has to be supplemented by liquid-solid separation as a post-treatment step. Once the solution to be treated is in the reactor with the catalyst, the irradiation process starts (UV source between 300 to 360 nm) and contaminants are quickly degraded.



147. This technology is commercially available (Purifics, Photo-Cat). It has been used to treat PCB, PCDD and PCDF in soil, water and aqueous solutions and sludge to acceptable discharge standards. Purifics’ installations, permitted by the US EPA, have been successfully applied throughout the world. Destruction efficiency of 99.99% has been demonstrated for PCB. This technology has been demonstrated for aqueous liquids and soil with low and high concentration POP wastes.

There do not appear to be any by-products to the environment from this technology. This technology is available on skids and the installations are compact. There appears to be low risk to the environment associated with usage of this technology. Considering the process technology, there is low risk to workers operating this technology. This technology is not ideal for larger operations, but is can be used for small scale treatment. Considering the proven destruction efficiency and the low potential risk for worker exposure, this technology is recommended for low and high concentration PCB in the matrices described, within all areas.



4.7.2.13 Recommendations

148. All of the technology recommendations made in the text of this guidance document have been summarized in Table 1 below, and aggregated according to their recommended use.

Table 1: Summary of Recommended TechnologiesHigh Concentration POP Waste Low Concentration POP Waste

Industrial Areas Industrially Remote Areas Industrial Areas Industrially Remote

Areas

Soils

Aqu

eous

Sol

utio

ns

Sedi

men

t / S

ludg

e

Oil

& O

rgan

ic

Solid

s

Soils

Aqu

eous

Sol

utio

ns

Sedi

men

t / S

ludg

e

Sedi

men

t / S

ludg

e

Oil

& O

rgan

ic

Soils

Aqu

eous

Sol

utio

ns

Sedi

men

t / S

ludg

e

Oil

& O

rgan

ic

Solid

s

Soils

Aqu

eous

Sol

utio

ns

Sedi

men

t / S

ludg

e

Oil

& O

rgan

ic

Solid

s

AOP X XBCD X X X X X X X X X X X X X X X X X X X XCement kiln co-incineration X1 X1 X1 X1 X1 X1 X1 X1

GPCR X X X X X X X X X X X X X X X XIncinerators (large scale fixed) X2 X2 X2 X2 X2 X2 X2 X2 X2 X2

Incinerators (mobile) X2 X2 X2 X2 X2 X2 X2 X2 X2 X2 X2 X2 X2 X2 X2 X2 X2 X2 X2 X2

In-situ vitrification X X X X X X X XMSO X XPlascon X XSodium Reduction X XSCWO X3 X3 X3 X3 X4 X3 X3 X3 X3 X4

TiO2 enhanced photocatalysis X X X X X X X X X X X X X

1. Only for cement plants that can demonstrate good kiln temperature control2. Using an existing facility with proper gas scrubbing and treatment of by-products3. If <20% organic content4. If <20% organic content and solid waste <200 microns in diameter


Environment Canada Technical Guidelines for the ESM of PCB, PCT and PBB Wastes

4.7.3 Other disposal methods when the PCB content is low149. Disposal is not an acceptable alternative for wastes with a high PCB content. In such instances, the destruction methods capable of achieving the required level of destruction and irreversible transformation should be used (except when destruction is not an environmentally acceptable option).

150. In general PCB liquid wastes irregardless of concentration should be destroyed (except where they occur in small quantities, as discussed below).

4.7.3.1 Hazardous waste landfill151. Modern hazardous landfills are equipped with two or three liners (clay or plastic), gas and leachate collection systems, and leak detection systems. Hazardous waste landfills should be a component of integrated hazardous waste management facilities. The operation permit should include specifications as to the definition of hazardous wastes to be accepted, concentration limits that differentiate hazardous from non-hazardous waste, and provisions for continuous and long-term monitoring of gas/leachate releases, and for gas/leachate collection and treatment. The operation permit should include a plan for the closure and permanent maintenance of the secure landfill.

152. The following PCB wastes are suitable for hazardous waste landfills:

PCB in solid matrices with a bulk concentration and leachate concentration below regulatory limits;

PCB in semi-solid form that are suitable for and have undergone immobilization prior to landfilling;

solid residues (fly ash, bottom ash, slag, scrubber sludge, treated soil, treated metals, etc.) from PCB treatment systems;

residue remaining after destruction of liquid PCB, once the residue has been tested to be non-hazardous; and

small quantity PCB wastes (e.g., fluorescent light ballasts containing PCB).

153. The following should be considered in the selection of hazardous waste landfill for PCB waste disposal:

placement in a hazardous waste landfill should be considered only when destruction or treatment of the PCB wastes is not available or extremely difficult for the particular waste matrix, for small quantities or low-concentration wastes;

hazardous waste landfills must be of modern, secure design; are required to provide on-going monitoring, collection and treatment of captured gas/leachate; and have a permanent mechanism for monitoring and maintenance; and

PCB waste that is to be placed in a landfill should first be immobilized. Some PCB wastes are deemed to be, in essence, already immobilized, e.g., contaminated painted materials, plastics, auto shredder fluff, and may be placed directly into a secure landfill.

4.7.3.2 Immobilization by fixation or solidification 154. Immobilization is a treatment method that attempts to prevent contaminants from moving out of the solid matrix of the parent material. This is done either by chemically binding the contaminants to the solid particles (fixation) or physically preventing the contaminants from moving out of the matrix (solidification). In some cases a combination of physical and chemical



immobilization is used. After this type of treatment, the material usually requires placement in a hazardous waste landfill.

155. All PCB wastes of low to moderate contamination levels in solid or semi-solid form are suitable for immobilization.

156. The following should be considered in the selection of immobilization for PCB waste disposal:

treatability tests should be performed to determine if the waste is suitable for fixation or solidification;

immobilized material should be resistant to weathering and freeze-thaw cycles; and

an agreement should be in place with a suitable facility for the disposal of the immobilized waste before proceeding with immobilization.

4.7.3.3 On-site containment157. This option involves building a permanent disposal cell or landfill on site for the disposal of contaminated equipment, products, soil, sediment, rock, sludge or other solid waste materials that are found on or under the surface of a property. There are two distinct ways to achieve the objective. One is to excavate the contaminated material (soil, debris, buried drums or equipment) and place it in a hazardous waste landfill, which is then capped. The other is to leave the material in place and build a barrier wall around it. Barrier walls may be made of steel sheet piles, grout curtains or slurry walls. This option is considered a “risk management’ strategy. It should only be considered when the risk associated with application of this technique is less that the risk incurred by excavating, transporting, and destroying or disposing of the material by other means. This option may be used as a way to manage a high-risk situation until another alternative can be found for the PCB wastes.

158. PCB in soil, rubble, sediment, rock and other solid matrices are suitable for on-site containment.

159. The following should be considered in the selection of on-site containment for PCB waste disposal:

it may be difficult or impossible in some geologic settings to fully contain the wastes and/or control groundwater contamination;

this technique is not suitable for high-concentration PCB wastes, liquid PCB wastes or situations where risk assessment shows that there is a higher risk with containment than with off-site disposal; and

mechanisms for on-going monitoring and maintenance should be implemented.

4.7.3.4 Permanent storage in salt mines 160. Permanent storage in salt mines facilities, can represent a lower risk to the environment and human health than surface disposal sites if they are located in geologically safe settings and are operated and maintained in the same manner similar to modern hazardous waste landfills. Salt mines offer a “pre-made” disposal space they can be economically developed and operated. The PCB wastes remains accessible and is stored in containers or in the original equipment (e.g., transformers).

161. Any type of PCB waste is suitable for disposal in abandoned mines, provided that waste is contained in leak-proof, corrosion-proof containers with secondary containment.

162. The following should be considered in the selection of permanent storage in salt mines for PCB waste disposal:



caverns or tunnels used for disposal are unused, not adjacent to active mining operations and not likely to ever be opened for mining again;

caverns or tunnels are located in a geologic formation that is well below the zone of available groundwater in the area, or a formation that is completely isolated (by impermeable rock or clay layers) from water bearing zones; and

caverns and tunnels are located in a geologic formation that is extremely stable and not within an earthquake zone.

4.8 Remediation of contaminated sites163. The identification and assessment of contaminated sites is a fairly well developed science, although the results of site assessments are often open to interpretation. Many government agencies and standards associations recommend a phased approach to the identification and assessment of contaminated sites.

164. Contaminated site criteria are used as general targets in the site remediation. They are developed by government agencies using risk assessment techniques. Since contaminants are directly in contact with the environment, these criteria tend to be considerably lower than the hazardous waste or control criteria for PCB, PCT and PBB. In addition many jurisdictions recognize that the criteria for site clean-up will vary depending on the site location and use. Typically a distinction is made between industrial land (highest criteria), residential land and agricultural or park land (lowest criteria). Separate criteria should be developed or adopted for soil, sediment and groundwater.

165. Site-specific risk assessment can also be used to develop the clean-up targets for the site. The results of a site-specific risk assessment may show that clean-up criteria should be higher, or lower, than the generic criteria developed by the regulatory agency. Risk assessments must be carried out by qualified toxicologists with training or certification in conducting environmental and/or human health risk assessments.

4.9 Health and safety166. A health and safety plan for an individual facility should be developed by a trained health and safety professional with experience in PCB, PBB and/or PCT management. In general there are three main ways to protect workers from chemical hazards (in order of preference):

1. Keep the worker away from all possible sources of contamination

2. Control the contaminants so that the possibility of exposure is minimized

3. Protect the worker using personal protective equipment.

167. All health and safety plans should adhere to the above principles and recognize local or national labour standards.

4.9.1 High-volume, high-concentration or high-risk situations168. Situations with high-volume, high-concentration or high-risk PCB, PBB or PCT situations include:

waste handling areas; storage sites; treatment, destruction and disposal areas;



and contaminated sites with high concentration of PCB, PCT or PBB at or near the surface.

169. At a minimum, the following should be included in PCB, PCT and PBB health and safety plans for high volume/high concentration:

the Health and Safety Plan (HASP) should be in writing, with a copy posted posted at each site containing PCB, PCT, or PBB;

each worker who is to have access to the “exclusion” zone (see below) should read the HASP and sign that they have read and understood it;

the HASP may be written to encompass all hazards at a site but should have a section or chapter specifically detailing procedures for PCB, PCT and/or PBB;

workers should only be present in an area containing PCB, PCT or PBB (the exclusion zone) when necessary for the servicing or inspection of equipment or stored materials;

workers entering an exclusion zone should have appropriate health and safety and operational training for chemical, physical and biological hazards;

health and safety training should be performed annually;

PCB, PCT and PBB exclusion zones should be routinely monitored for these contaminants in air;

when appropriate, workers entering an exclusion zone should wear appropriate respiratory protection and PCB-, PCT-, PBB-impermeable fabric should cover the entire body (i.e., coveralls with hood, face-shield, gloves and boot covers or a full-body suit);

spill cleanup kits and personal decontamination materials should be present in all areas containing PCB, PCT or PBB;

workers who are, or are expected to be, routinely entering PCB, PCT or PBB exclusion zones or working with these substances should be medically monitored including a baseline medical examination;

where PCB, PCT or PBB are to be handled in an open system, or where it is reasonably expected that the protective clothing of a worker may contact PCB, PCT or PBB, a “contaminant reduction” zone should be established where workers can be decontaminated and remove their protective equipment; and

the HASP and general work procedures should be reviewed at least annually and revised if necessary to enhance safety and health at the site.

4.9.2 Low-volume, low-concentration sites or low-risk situations170. The recommended health and safety practice in Section 4.9.1 do not apply to sites that contain PCB, PCT and/or PBB in amounts or concentrations that are not seen as acute or chronically hazardous to human health and the environment. There is no clear definition of low concentration or low volume situations and “low-risk” must be determined by comparing contaminant levels with government guidelines or by conducting a site specific risk assessment. Some examples of low-risk situations to worker health and safety include:



commercial storage or inventory rooms that contain small quantities of products (i.e. pesticides) that are to be used in acceptable application situations;

facilities that unintentionally generate and release PCB, PCT or PBB in very low concentrations with respect to human exposure limits; and

contaminated sites with low levels of PCB, PCT or PBB.171. Despite the low risk situation, some health and safety measures should be taken to minimize exposure, including health and safety training of personnel who are likely to come into contact with PCB, PBB or PCT.

4.10 Emergency response[This draft has retained section 4.11 as per the Table of Contents circulated for comment on November 7, 2003. Note that the United States suggests removal of this section.]

172. Emergency response plans should be in place for PCB, PBB and PCT that are in-service, in storage, in transit and at a disposal or destruction site. While the emergency response plans will vary for each situation, there are some common elements. The main elements of an emergency response plan are:

planning of possible emergency situations and possible responses;

training of personnel in response activities including simulated response exercises;

maintaining mobile spill response capabilities or retaining the services of a specialized firm for spill response;

notification of fire department, police and other government emergency response agencies of the location of PCB, PBB and PCT and the routes of transport;

installation of mitigation measures such as fire extinguishing systems, spill containment, fire-fighting water containment, spill and fire alarms and fire walls;

installation of emergency communication systems including signs indicating emergency exits, telephone numbers, alarm locations and response instructions;

installation and maintenance of emergency response “kits” containing sorbents, personnel protective equipment, portable fire extinguishers, and first aid supplies; and

integration of local plans with regional, national and global emergency plans if appropriate.

173. Specific actions that can be taken in the event of a spill, leak or fir can be found in Preparation of a National Environmentally Sound Management Plan for PCB and PCB-Contaminated Equipment (UNEP, 2003) and in other manuals dealing with emergency response.

4.11 Public participation174. Parties to the Basel or Stockholm Convention should have an open public participation process. The reader is referred to the General Technical Guideline for more detailed information on the requirements of these Conventions.

175. Parties developing new or revised policies or regulations regarding PCB, PCT and PBB should have an open process for soliciting comment from any and all person or groups. This means that a general invitation to comment is given through regular media outlets, the internet, or direct invitation. The individuals and groups who should be considered for direct invitation to



comment are:

Individual citizens who have expressed interest

Local citizens’ groups (including local environmental groups) for local issues

Special groups, mainly women,children and the least-educated (as specified in the Stockholm Convention)

Environmental groups (regionally, nationally or globally organized)

Individual industries and businesses with a “stake” in the process (i.e. electrical utilities, heavy industry, hazardous waste management firms, electrical equipment manufacturers)

Business associations

Trade unions and associations

Professional associations

Other levels of government

176. A public participation process may have several phases of public participation. The public and interest groups may be consulted before any changes or programs are considered, during the process of developing policy and after each of the draft policy documents is prepared. Comments may be invited in person, in writing or through an internet web-site.

177. An example of public consultation regarding the development of POPs management plans can be found in the Australian document A Case Study of Problem Solving Through Effective Community Consultation (Australia Department of Environmental Health, 2000).



Appendix 1: Synonyms and trade names for PCB, PCT and PBB

Chemical Some Synonyms and Trade Names a

Polychlorinated biphenyls (PCB)

Aceclor, Adkarel, ALC, Apirolio (Italy), Arochlor, Arochlors, Aroclor/Arochlor(s) (US), Arubren, Asbestol, Ask/Askarel/Askael, Auxol, Bakola, Biphenyl, Biphenyl, Chlorinated, Chlophen, Chloretol, Chlorextol, Chlorfin, Chlorinal/Chlorinol, Chlorinated biphenyl, Chlorinated diphenyl , Chlorobiphenyl, Chlorodiphenyl, Chlorphen, Chorextol, Chorinol, Clophen/Clophenharz (Germany), Cloresil, Clorinal, Clorphen, Decachlorodiphenyl, Delor, Delorene , Diaclor, Dicolor, Diconal, Diphenyl, chlorinated, DK, Duconal, Dykanol, Educarel, EEC-18, Elaol (Germany), Electrophenyl, Elemex, Elinol, Eucarel, Fenchlor (Italy), Fenclor, Fenocloro, Gilotherm, Hydol, Hyrol, Hyvol, Inclor, Inerteen, Inertenn, Kanechlor (Japan), Kaneclor, Kennechlor, Kenneclor, Leromoll, Magvar, MCS 1489, Montar, Nepolin, NoFlamol, No-Flamol, Non-Flamol, Olex-sf-d, Orophene, PCB, PCB, PCB's, Pheaoclor, Phenochlor, Phenoclor, Plastivar, Polychlorinated biphenyl, Polychlorinated biphenyls, Polychlorinated diphenyl, Polychlorinated diphenyls, Polychlorobiphenyl, Polychlorodiphenyl, Prodelec, Pydraul, Pyraclor, Pyralene (France), Pyranol (US), Pyroclor (US) Phenoclor (France), Pyronol, Safe-T-Kuhl, Saf-T-Kohl, Saf-T-Kuhl, Santosol, Santotherm (Japan), Santovac, Solvol, Sorol, Soval, Sovol (USSR), Sovtol, Terphenychlore, Therminal, Therminol, Turbinol

PCT Aroclor (US), Clophen Harz (W), Cloresil (A,B,100), Electrophenyl T-50 and T60, Kanechlor KC-C(Japan). Leromoll, Phenoclor, Pydraul

PBB Adine 0102, BB-9, Berkflam B10, Bromkal 80, Firemaster BP-6, Firemaster FF-1, Flammex B-10, hbb, hexabromobiphenyl, HFO 101, obb, BB-8, Berkflam B10

a The list of trade names is not intended to be exhaustive.



Appendix 2: ReferencesAustralia Department of Environmental Health, 2000. A Case Study of Problem Solving Through

Effective Community Consultation. Available at www.deh.gov/au/industry/chemicals/scheduled-waste/commuinty-consultation.html

AMAP, 2000. Multilateral Co-operative Project on Phase-out of PCB Use and Management of PCBcontaminated Wastes in the Russian federation – Phase I: Arctic Monitoring and Assessment Programme. Oslo, Norway.

China State Environmental Protection Agency, 2002. Terms of Reference: Development of a PCB Inventory Methodology and a Draft Strategy on PCB Reduction and Disposal in China (Draft). Document prepared for the World Bank, Beijing, China.

Environment Canada, 1988. Polychlorinated Biphenyls (PCB) – Fate and Effects in the Canadian Environment. Environment Canada report EPS 4/HA/2, May, 1988.

Jensen, A.A. and Jørgensen, K.F, 1983. Polychlorinated terphenyls (PCT) uses, levels and biological effects. Sci. Total Environ. 27:231-250.

Holoubek, I., 2000. Polychlorinated Biphenyls (PCB) World-Wide Contaminated Sites. Downloaded from http://www.recetox.chemi.muni.cz/PCB/content173.htm.

IMO, 2002. International Maritime Dangerous Goods Code. Avaliable at www.imo.org

IPCS, 1992. Environmental Health Criteria 140: Polychlorinated Biphenyls and Polychlorinated Terphenyls. Published by UNEP, ILO and WHO, Geneva.

IPCS, 1994. Environmental Health Criteria 152: Polybrominated Biphenyls. Published by UNEP, ILO and WHO, Geneva.

Lassen, C., Løkke, S. and Andersen, L.I. 1999. Brominated flame retardants – substance flow analysis and assessment of alternatives. Environmental Project No. 494, Danish EPA, Copenhagen. Available at www.mst.dk/udgiv/Publications/1999/87-7909-416-3/html/default_eng.htm

OECD, 2003. Core Performance Elements of the Guidelines for Environmentally Sound Management of Wastes. Available at www.oecd.org

UNECE, 2002. Report on Production and Use of PCT (draft). Prepared for the UNECE Expert Group on POPs.

UNEP, 1995. Basel Convention: Manual for Implementation. Available at www.basel.int

UNEP, 1999. Guidelines for the identification of PCB and materials containing PCB. Available at www.chem.unep.ch

UNEP, 2003. Interim guidance for developing a national implementation plan for the Stockholm Convention. Available at www.pops.int

UNEP, 2003. Standardized Toolkit for the Identification and Quantification of PCDD and PCDF. Available at www.pops.int


http://www.pops.int/

http://www.pops.int/

http://www.chem.unep.ch/

http://www.basel.int/

http://www.oecd.org/

http://www.mst.dk/udgiv/Publications/1999/87-7909-416-3/html/default_eng.htm

http://www.imo.org/

http://www.deh.gov/au/industry/chemicals/scheduled-waste/commuinty-consultation.html


Appendix 3: BibliographyIFCS, 2001. Framework for the Management of PCB. Available at www.who.int/ifcs

Rahuman, M.S.M. Mujeebur; Luigi Pistone; Ferruccio Trifirò and Stanislav Miertu, 2000. Destruction Technologies for Polychlorinated Biphenyls (PCBs). Available at www.unido.org

UNEP, 1998. Inventory of World-Wide PCB Destruction Capacity. Available at www.chem.unep.ch

UNEP, 1999. Guidelines for the Identification of PCB and Materials Containing PCB. Available at www.chem.unep.ch

UNEP, 2000. Survey of Currently Available Non-Incineration PCB Destruction Technologies. Available at www.chem.unep.ch

UNEP, 2001. Destruction and Decontamination Technologies for PCB and Other POPs Wastes Part I. Available at www.basel.int

UNEP, 2001. Destruction and Decontamination Technologies for PCB and Other POPs Wastes Part II. Available at www.basel.int

UNEP, 2001. Destruction and Decontamination Technologies for PCB and Other POPs Wastes Part III. Available at www.basel.int

UNEP, 2002. PCB Transformers and Capacitors - From Management to Reclassification and Disposal. Available at www.chem.unep.ch

UNEP, 2002. PCB Inventory Form. Available at www.chem.unep.ch

UNEP, 2003. Preparation of a National Environmentally Sound Management Plan for PCB and PCB-contaminated Equipment in the Context of the Implementation of the Basel Convention. Available at www.basel.int











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