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Comments on

General Technical Guidelines for Environmentally Sound Management (ESM) of Wastes Consisting of, Containing or Contaminated with Persistent Organic Pollutants (POPs),

First Draft

Prepared by Pat Costner Greenpeace International12 September 2003

Page1 1.2 Scope

This document is designed to provide guidance for:1. Environmentally sound management of POPs when they are deemed to be wastes

according to the provisions of the Stockholm and Basel conventions;2. Unintentional releases to the environment of POPs generated from waste

treatment and disposal (destruction) operations; and3. Waste avoidance and minimization to reduce the amount of POPs needing to be

managed as wastes at the end of their life-cycle.

Comment: In the second point – “Unintentional releases to the environment of POPs generated from waste treatment and disposal (destruction) operations”, the word “Unintentional” indicates that the only releases of by-product POPs that will be addressed are those that are accidental (e.g., fugitive emissions) and that intentional releases from waste disposal treatment and destruction (e.g., process gases that are deliberately released to the air, solid residues that are deliberately placed in landfills, etc.) are not considerations. This would be incompatible with the goals of the Stockholm Convention and would not constitute ESM of POPs wastes. Further, this point also appears to equate “waste treatment and disposal” with “destruction” even through several well-known waste treatment and disposal technologies have minimal or no destruction capability.

Suggestion: Replace the second point with the following

Selection of technologies for the environmentally sound management of POPs wastes and their general capabilities including their potential for meeting the requirements of the Stockholm Convention.

1 POPs wastes, or other wastes contaminated with POPs wastes, captured (not released to the environment) in production processes are addressed by this document (i.e., applicable to item 1 in the paragraph immediately before this paragraph).

Comment: The sentence above indicates that this document does not address ESM of soils, sediments, industrial wastes deposited in ponds, pits

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and piles, etc. that are, by their contents, POPs wastes and, as such may be required under the Stockholm Convention to undergo destruction/irreversible transformation or ESM. Given the rather extensive discussions throughout this document of POPs-contaminated soils, sludge, etc. that cannot be construed to be “POPs waste, or other wastes contaminated with POPs wastes, captured (not released to the environment) in production processes,” this is obviously not the case.

Suggestion: Delete this sentence.

2 This document does not address unintentional releases to the environment of POPs from industrial production processes (i.e., releases to air, water, soil/sediment). Releases to air of unintentionally generated POPs from industrial processes would be a component of guidance on best available techniques (BAT) and best environmental practices (BEP) under the Stockholm Convention. Please note, at the discretion of the Stockholm Convention, Conference of the Parties (COP), BAT and BEP guidance might also address certain waste treatment and disposal operations (i.e. applicable to item 2 above), in which case, consistency will need to be sought between this guidance document and applicable BAT and BEP guidance.

Comment: With respect to the first sentence above, other than the two lists of source categories of unintentionally produced POPs, the only industrial production process that is addressed in this document is cement production in which POPs wastes are co-fired. Further, the only releases of POPs from industrial processes that can be accurately defined as “unintentional” are so-called “fugitive emissions.” Use of the latter term avoids the confusion of “unintentional releases” with key terms such as “unintentionally byproducts,” “unintentionally generated POPs,” etc. With regard to the second sentence, it is important to note that the Stockholm Convention addresses releases of POPs that are both intentionally and unintentionally generated not only to air but also to water, land, products and wastes. The Convention also sources other than industrial production. With regard to the third sentence, as discussed at some length in this document, BAT and BEP for POPs waste treatment and disposal is given substantial, detailed consideration in the Stockholm Treaty

Suggestion: Either delete the first sentence or rephrase as follows:“This document does not address fugitive emissions of POPs from industrial production processes.” Rephrase the second sentence as follows:“Releases to air, water, land, products and wastes of POPs from industrial processes and other human activities are to be addressed in guidance on best available techniques (BAT) and best environmental practices (BEP) under the Stockholm Convention.” Rephrase the third sentence as follows:“The Stockholm Convention INC6 established an Expert Group to develop guidance on best available techniques (BAT) and best environmental practices (BEP) for reducing and/or eliminating formation and release of unintentional byproduct POPs from source categories of these POPs, which includes some waste treatment and disposal technologies and practices, such as waste incineration.”

3 While POPs wastes (depending on the POP, concentration and matrix, including a product or article, in which it occurs) may not present an immediate risk of exposure to those coming into physical contact with the waste, improper disposal of a POPs waste will lead to releases of POPs to the environment with subsequent potential for exposure.



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Comment: Since POPs-contaminated soils, sediments, etc., are important sources of exposure, they deserve mention here. Also since improper disposal of a POPs waste can lead to release not only of the POPs in that waste but also the generation of unintentional by-product POPs, this too deserves mention.

Suggestion:While POPs wastes (depending on the POP, concentration and matrix, including products, soils, sediments, etc, in which the POP occurs) may not present an immediate risk of exposure to those coming into physical contact with the waste, improper disposal of a POPs waste will lead to releases of POPs and, in certain cases, to the generation and release of newly formed unintentional by-product POPs to the environment with subsequent potential for exposure.

3 2.2. Stockholm Convention: When a POP is a waste

Comment: It would be helpful if the title of this section were more inclusive.

Suggestion: 2.2. Stockholm Convention: When a POP or a material containing one or more POPs is a waste

3 Article 6 of the Stockholm Convention (“Measures to reduce or eliminate releases from stockpiles and wastes”) is the central article pertaining to wastes in the convention. The article describes and applies to three categories of POPs wastes:

1. POPs wastes per se. Examples include POPs that were intentionally manufactured but which are now prohibited, deregistered, or, if covered by a use exemption, have expired or been taken out of use.

2. By-product wastes, i.e., products and articles consisting of, containing or contaminated with a chemical listed in Annex A, B or C upon becoming wastes; and

3. Stockpiles consisting of or containing chemicals listed either in Annex A or Annex B once they are deemed to be waste.

Comment: In regulatory, scientific and related communities, “by-product” is the term commonly used for dioxins, furans and other unintentionally produced POPs. Applying this same term to wastes containing any of the priority POPs can lead to needless confusion.

Suggestion: Rephrase the second bullet above as follows:

2. Wastes, such as products and articles consisting of, containing or contaminated with any of the twelve prioritized POPs .

5 Article 5 (measures to reduce or eliminate releases from unintentional production) in

paragraph (c) calls on the Parties to promote development and, where appropriate, requires the use of substitute or modified materials, products and processes to prevent the formation and release of chemicals listed in Annex C. Application of this provision will result in waste prevention and minimization, for example via pre-treatment of process waters to concentrate wastes and remove the POPs from wastewater prior to

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its discharge.

Comment: The example given above – the removal POPs from wastewater prior to discharge – has no apparent relationship to the Stockholm Convention’s requirement of alternative materials, products and processes to prevent formation and release of by-product POPs. Article 5 addresses reducing or eliminating releases of unintentional POPs rather than wastes in general. A more appropriate example is needed.

Suggestion: Replace the second sentence as follows:

Application of this provision will result in reducing or eliminating the formation and release of unintentionally produced POPs, for example via substituting chlorine-containing products with chlorine-free products when such products may undergo combustion during disposal.

5 2.4 Stockholm Convention provisions for prevention of releases and implications for wastes

Comment: Since this entire section addresses only the unintentionally POPs, it will be less confusing to indicate this in the title. Also, the phrase “implications for wastes” has no apparent relationship to the contents of this section. However, a significant portion of the section is devoted to BAT.

Suggestion: Rephrase title as follows:

2.4 Stockholm Convention provisions for prevention of releases of unintentional POPs

5 Paragraph (d) of Article 5 addresses facility-based approaches (Best Available Techniques and Best Environmental Practices) that can be taken to reduce releases of unintentional POPs generated by industrial sources and processes that generate by-products. Annex C provides two lists of sources of releases of the POPs, the Part II Annex C list being those with potential for comparatively high formation of these POPs. The Part III list provides examples of other sources that may also generate releases of these substances.

Comment: Article 5(d) actually requires that BAT be either promoted or required, depending on the circumstances specified and according to the timetable specified, and it requires promotion of BEP. Descriptions of BAT and BEP are presented in Annex C, Part V: General Guidance on best available techniques and best environmental practices. For example, in Annex C, Part B: Best Available Techniques, paragraph (b) specifies as follows, for example: “When considering proposals to construct new facilities or significantly modify existing facilities using processes that release chemicals listed in this Annex, priority consideration should be given to alternative processes, techniques or practices that have similar usefulness but which avoid the formation and release of such chemicals.” Since alternative processes, techniques or practices that have similar usefulness but do not form and release unintentional POPs are defined as BAT in the Stockholm Convention, it is not accurate to say that paragraph (d) of Article 5(d) addresses facility-based BAT and BEP for reducing unintentional POPs releases by industrial sources and processes that generate by-products. Suggestion: Rephrase as follows:



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Paragraph (d) of Article 5 requires Parties either to promote or to require BAT and BEP to reduce the formation and release of unintentional byproducts from industrial and other human activities. Annex C provides two lists of sources of unintentional POPs. One list, Part II, identifies sources that have the potential for comparatively high releases, while Part III is an indicative list of other potential sources. Annex C Part V also identifies BAT and BEP in some detail with the stipulation that, when considering proposals for new facilities or significant modification of existing facilities, Parties must give priority consideration to alternative processes, techniques or practices that have similar usefulness but do not form and release unintentional POPs.

5 BAT utilized to reduce releases from the listed sources aim at achieving greater efficiency not only with regard to destruction of POPs, but, with respect to releases, and capture of a greater proportion of POPs generated, such as dioxins and furans that may form in stack gases. More efficient capture of unintentional POPS will result in higher concentration of these POPs in wastes (ash; sludge; carbon filters) and potentially a volume of waste that must be subsequently destroyed or managed in an environmentally sound manner.

Comment: See comment immediately above. It is apparent that the authors of the report either failed to see or grasp the content of Annex C Part V.

Suggestion: The primary aim of BAT used to reduce or eliminate formation and releases from sources of unintentionally produced POPs is replacement of processes, techniques and practices that generate and release these POPs with those that do not. Until these non-POP-generating alternatives are fully in place, BAT also aim to reduce formation and release of unintentionally produced POPs by, for example, replacing feed materials that are POPs or are linked to release of POPs, making process changes that reduce or eliminate releases, modify process designs to improve combustion and reduce POPs formation, etc. Interim BAT also include using improved flue-gas cleaning, which will result in higher concentrations of unintentionally produced POPs in wastes (ash; sludge; carbon filters) and, consequently, the need for further treatment of such wastes.

5 The first two sources listed in Part II (italicized below for emphasis) are used to destroy POPs (although cement kilns may be designed to burn hazardous wastes as an fuel, rather than having the destruction as a primary purpose). Other end-of-life-cycle disposal or recycling operations which can lead to unintentional realises of POPs are italicized in the Part III list.

Comment: The first sentence is unclear in its meaning and/or purpose and its content is erroneous. For example, all waste incinerators are not used to destroy POPs nor are all waste co-incinerators used to destroy POPs. Cement kilns are designed to produce cement clinker; their design can be modified to burn wastes. In addition, while the Part II list is a `closed’ list, Part III is not, as shown by the exact language of the Stockholm Treaty: “may also be untentionally formed and released from the following source categories, including” [emphasis added]. The Part III list contains several unintentional POPs sources that can be characterized as end-of-life-cycle disposal or recycling operations other than those that have been italicized. The purpose served by using such

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italics is, in any case, not at all clear.

Suggestion: Remove the italics from both lists and rephrase the above paragraph as follows:

The Stockholm Convention presents two lists of source categories of unintentionally produced POPs: Part II, which identifies those source categories that have the potential for high formation and release of these POPs, and Part III, which is an indicative list of other source categories.

7 Annex C, Part V, describes general prevention measures relating to both best available techniques and best environmental practices for industrial sources with high Annex C POPs formation potential. Priority should be given to consideration of approaches to prevent the formation and release of chemicals, including:

3 The promotion of the recovery and recycling of waste and of substances generated and used in processes. 4 Improvements in waste management with the aim of the cessation of open and other uncontrolled burning of wastes, including the burning of landfill sites.

When considering proposals to construct new waste disposal facilities, consideration should be given to alternatives, such as activities to minimize the generation of municipal and medical waste, including resource recovery, reuse, recycling, waste separation and promoting products that generate less waste. Under this approach, public health concerns should be carefully considered.

General considerations for BAT are listed in Annex C, Part 5, B.

Comment: The first sentence indicates that BAT and BEP described in Annex C, Part V applies only to Part II source categories. This is not correct. Annex C, Part V “provides general guidance to Parties on preventing or reducing releases of the chemicals listed in Part I.” I.e., the BAT and BEP described in Annex C, Part V applies to source categories in both Part II and Part III. Moreover, it is not clear what purpose is served by the selection of only two of the eight measures related to BAT and BEP given in Annex C, Part V, section A. Similarly, it would seem to be important to include the specific BAT presented in Annex C, Part V, section B, especially the one item that is to be given priority consideration: “When considering proposals to construct new facilities or significantly modify existing facilities using processes that release chemicals listed in this Annex, priority consideration should be given to alternative processes, techniques or practices that have similar usefulness but which avoid the formation and release of such chemicals.” The specific information on BAT and BEP that is presented in Annex C would seem to be considerably more useful than the general definitions given in Article 5(f).

Suggestion: Replace the definitions from Article 5(f) with all of Annex C, Part V.

8 The Basel Convention observes in a footnote to A3180 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.

Comment: To avoid confusion, it should be made clear that A3180 is “Wastes, substances and articles containing, consisting of or contaminated with polychlorinated biphenyl (PCB), polychlorinated terphenyl (PCT),



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polychlorinated naphthalene (PCN) or polybrominated biphenyl (PBB), or any polybrominated analogues of these compounds, at a concentration level of 50 ng/kg or more.” Consequently, the footnote to A3180 is relevant to wastes containing PCB, PCT, PCN, PBB or any polybrominated analogues. It is incorrect to characterize the 50 ng/kg as applying to other POPs.

Suggestion: Rephrase as follows:

With regard to PCBs, the Basel Convention observes in a footnote to A3180 that 50 mg/kg is considered to be an internationally practical level for PCBs in all wastes, although some countries have established lower regulatory levels (e.g., 20 mg/kg) for specific wastes.

9 For example, trace concentrations is generally reported in units of micrograms per liter (ug/L) or per kilogram (ug/kg), but can also be expressed in concentration values ranging from the milligram per liter (mg/L) or per kilogram (mg/kg) down to the nanogram per liter (ng/L) or per kilogram (ng/kg).

Comment: For the dioxins and furans, trace concentrations are reported in picograms per kilogram.

Suggestion: Modify wording as follows:

For example, trace concentrations is generally reported in units of micrograms per liter (ug/L) or per kilogram (ug/kg), but can also be expressed in concentration values ranging from the milligram per liter (mg/L) or per kilogram (mg/kg) down to the picogram per liter (pg/L) or per kilogram (pg/kg).

9 Trace concentration values, as the term applies to Annex A and B listed in the Stockholm Convention, can therefore be reasonably defined as values that are close to the limit of detection (LD) for a given analytical tool and methodology.

Comment: The same can be said of the POPs listed in Annex C.

Suggestion: Modify the wording as follows;

Trace concentration values, as the term applies to the POPs listed in Annex A, B and C of the Stockholm Convention, can therefore be reasonably defined as values that are close to the limit of detection (LD) for a given analytical tool and methodology.

10 As per Article 6.2 (c) of the Stockholm Convention, concentration levels are to be established for each of the POPs so as to “define” the low POPs content, which will then serve as a “trigger” for invocation of Article 6.1(d) (ii). As previously discussed (section 2.3 of this document), Article 6.1(d) (ii) requires that wastes above the LPCC be destroyed or irreversibly transformed (except where destruction or irreversible transformation does not represent the environmentally preferable option), taking into account international rules, standards and guidelines.

Comment: This is the first appearance in the text of the acronym “LPCC” and It would be helpful to include its exact meaning in the text. It seems likely that

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the “LPC” means “low POPs content” and the second “C” may be “concentration”.

Suggestion: Modify the second sentence as follows (if accurate):

As previously discussed (section 2.3 of this document), Article 6.1(d) (ii) requires that wastes containing any of the POPs at levels above their respective Low POPs Content Concentrations (LPCCs) be destroyed or irreversibly transformed (except where destruction or irreversible transformation does not represent the environmentally preferable option), taking into account international rules, standards and guidelines.

10 Application of LPCCs may not be the best option for determining waste disposal options in all circumstances, for example where analytical capacity is weak or application of the LPCC would be counter-productive (e.g., when collection and destruction of very small quantities of wastes are impractical). In instances where analytical capacity is weak, alternatives to use of LPCCs might be considered that would achieve the same objectives of an LPCC (for which some examples are provided in section 3.3). It will also be important to take into consideration the circumstances of individual nations. For example, farmers in developed nations may be accustomed to and have adequate facilities and capacity for sequestering small expired quantities of an acutely hazardous pesticide pending collection. The majority of farmers in developing nations may not have capacity for safe storage and even a small quantity of a pesticide waste could pose a risk (owing to accessibility) not only to the farmer but the farmer’s family and children playing in the vicinity.

Comment: Given the specific language of the Stockholm Convention, alternatives to determining low levels of POPs would not appear to be an option given the Stockholm Treaty language. In addition, the last three sentences in this paragraph address storage of POPs wastes and, as such, are not relevant to the issue of establishing low POPs content.

Suggestion: Delete this paragraph.

11 -- concentration-dependent toxicological observations in humans (inclusive of benchmarks that take children and elderly into account)

Comment: The Stockholm Treaty is concerned both with human health and the environment, as shown by the following statement, which appears in the chapeau of the Stockholm Treaty – “Determined to protect human health and the environment from the harmful impacts of persistent organic pollutants”. I.e., the effect of POPs on other organisms is also of concern. Moreover, this bullet point suggests that experimental evidence, including studies involving laboratory animals, and documentation of effects on birds, wildlife, domestic animals, fish, etc. may not be taken into consideration. Further it suggests that observations on the effects on the developing foetus and nursing infant are not to be considered.

Suggestion: Reword as follows:

-- concentration-dependent toxicological observations in experimental animals, fish, birds, wildlife and humans (inclusive of benchmarks that take the developing fetus, nursing infant, children and elderly into account).

11 Examples of concentrations are provided that are used to place limitations on disposal options for POPs or to classify wastes, which then has a bearing on disposal or use. (Additional details are provided in Appendix 4.) These examples are drawn



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from international guidance or national legislation that utilize methodologies similar to the components in 3.2 (taking into account variables in data, receiving environment, etc.). Examples of approaches that offer an alternative to establishment of LPCCs in specific circumstances are also noted for some POPs categories. As discussed in the previous section, an international body of experts should ultimately propose LPCCs for the consideration of the Stockholm COP.

Comment: Refer to earlier comment on “Application of LPCCs …”, p. 10.

Suggestion: Delete the last two sentences.

11 As discussed in the previous section, an international body of experts should ultimately propose LPCCs for the consideration of the Stockholm COP.

Comment: We were unable to find such a discussion in any earlier section of this document. However, Annex III of the Basel Convention includes a list of hazardous characteristics, including H11 Toxic (Delayed or Chronic), which includes “Substances or wastes which, if they are inhaled or ingested or if they penetrate the skin, may involved delayed or chronic effects, including carcinogenicity,” and H12 Ecotoxic, which includes “Substances or wastes which if released present or may present immediate or delayed adverse impacts to the environment by means of bioaccumulation and/or toxic effects upon biotic systems.” Both of these characteristics are currently under consideration by the Basel Convention Open Ended Working Group (OEWG) with comments due by September 30 on the draft scoping paper tabled by the US at the last OEWG meeting on H11 (UNEP/CHW/OEWG/1/INF/8). This draft document includes delineation of waste constituent categories and de minimis concentrations in waste, i.e., those concentrations below which the waste is not considered as an H11 waste. In summary, an international body of experts is currently developing guidance for de minimis, or low, levels of toxic chemicals including the currently listed POPs.

Suggestion: Reword this sentence as follows:

De minimis, or low levels of toxic chemicals, including those POPs currently listed by the Stockholm Convention, are currently being developed by the Basel Convention Open Ended Working Group. When completed the resulting values can be submitted for consideration by the Stockholm Convention.

12 Contaminated equipment (capacitors and transformers, and other equipment containing liquid stocks): The most pressing concern as regards PCB wastes is destruction of the most toxic PCB congeners which, owing to manufacturing history of PCBs, are present in liquids that were or continue to be used in electrical capacitors and transformers.

Comment: Many of the same toxic PCB congeners present in liquids in capacitors and transformers are known also to occur as unintentional byproducts of various industrial processes. Consequently, it may be more accurate to convey that the most pressing concern is destruction of the largest identifiable stores of PCBs.

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Suggestion: Reword as follows:

Contaminated equipment (capacitors and transformers, and other equipment containing liquid stocks): The most pressing concern as regards PCB wastes is destruction of the largest identifiable stores of PCBs which, owing to manufacturing and use history of PCBs, are present in liquids that were or continue to be used in electrical capacitors and transformers.

12 Cleanup treatment and disposal options may be specified (such as incineration for wastes above 50 mg/kg) but may also be determined on a site-by-site basis taking into account reductions achievable with best available technology.

Comment: It should also be acknowledged here that, with the entry into force of the Stockholm Convention, it may be necessary to revisit regulations specifying incineration for the disposal of certain PCB wastes since waste incinerators are included among the source categories of unintentional POPs.

Suggestion: Either delete the phrase “(such as incineration for wastes above 50 mg/kg)” or modify as follows: Cleanup treatment and disposal options may be specified, such as incinera-tion for wastes above 50 mg/kg. However, entry into force of the Stockholm Convention may necessitate revisiting regulations that require the use of a particular technology rather than the attainment of an appropriate level of de-struction/irreversible transformation of PCB wastes, especially since waste in-cinerators are a source category of potentially large releases of unintentional POPs.

13 There is no WHO ADI for PCBs

Comment: in 1998, WHO established a Tolerable Daily Intake for dioxins, furans and dioxin-like PCBs of 1-4 pg TEQ/kg bw/day, accompanied by the recommendation that every effort should be made to reduce exposure to the lower end of this range.i

Suggestion: While WHO have not established a TDI or ADI for total PCBs, they have established an ADI of 1-5 pg TEQ/kg bw/day for dioxins, furans and dioxinlike PCBs combined.

13 (Many developing nations have small or no stocks of banned POPs, hence regulation has focused on import/export and remediation of contaminated sites relative to POPs rather than destruction.)

Comment: This statement is sufficiently controversial as to require substantiation.

Suggestion: Provide documentation to support this statement or delete it.

13 As previously noted, the Basel Convention observes that 50 mg/kg is used internationally to establish a level above which the waste must be treated as hazardous. Some countries use 50 mg/kg as the concentration at which contaminated soil must be remediated (for example, Australia). It could be that 50 mg/kg (ppm) for all POPs (except dioxins/furans) is a pragmatic compromise on the basis of precautionary and feasibility considerations (subject to the consideration of the Basel and Stockholm COPs ). However, the toxicity of the pesticide POPs even at low concentrations, their high volatility, their action upon the central nervous system (the purpose for which they were designed), might lend one to believe that more rigid, low concentration standards would be more protective of human health and the



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environment.

For example, the concentration values above which these pesticide POPs cannot be stored in a landfill under the US EPA Universal Waste Rule are all below 1 mg/kg or 1 ppm, except toxaphene, for which the non-wastewater concentration is 2.6 mg/kg. Other applicable examples include:

Comment: As previously commented, it should be made clear that A3180 is “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 polybrominated analogues of these compounds, at a concentration level of 50 ng/kg or more.” Consequently, the footnote to A3180 is relevant to wastes containing PCB, PCT, PCN, PBB or any polybrominated analogues. It is incorrect to characterize the 50 ng/kg as having been deemed acceptable for all POPs under the Basel Convention. It is also incorrect to say that Australia uses 50 mg/kg as the concentration at which Australia requires soil remediation of any contaminant. Australia uses standard risk assessment for determining remediation levels. ii, iii, iv

Suggestion: Delete the first two sentences of the first paragraph then combine and rephrase the last sentence and the first sentence of the second paragraph as follows;

The language of the Stockholm Convention as well as the toxicity of the pesticide POPs even at low concentrations, their high volatility, and their action upon the central nervous system reflect the need for establishing low concentration standards that are fully protective of human health and the environment. For example, the concentration values above which these pesticide POPs cannot be stored in a landfill under the US EPA Universal Waste Rule are all below 1 mg/kg or 1 ppm, except toxaphene, for which the non-wastewater concentration is 2.6 mg/kg. Other potentially applicable examples include:

13 For example, the concentration values above which these pesticide POPs cannot be stored in a landfill under the US EPA Universal Waste Rule are all below 1 mg/kg or 1 ppm, except toxaphene, for which the non-wastewater concentration is 2.6 mg/kg. Other applicable examples include:

Comment: It would be more helpful and more accurate to describe these US EPA criteria properly (i.e., as the US EPA Universal Treatment Standards (at 40 CFR 268.48) and to point out that these technology-based standards can be found in Appendix 4 of this document. To make the information more

i Van Leeuwen F., Younes, M., 1998. WHO revises the tolerable daily intake ( TDI) for dioxins. Organohalogen Cpds. 38:295-298.ii National environment protection measure for the assessment of site contamination. Adelaide: National Environment Protection Council, 1999.iii Environmental health risk assessment. Guidelines for assessing human health risks from environmental hazards. Canberra: Department of Health and Ageing, 2002.iv Toxicity assessment guidelines for carcinogenic soil contaminants. Canberra: National Health and Medical Research Council, 1999.

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accessible, it would be most helpful to assign table numbers with explanatory titles to each of the tables of data in Appendix 4.

Suggestion: Rephrase as follows, assign table numbers and explanatory titles to each of the tables of data in Appendix 4, and include the attached table (Comparison of US EPA Technology-Based and Health/Risk-Based Hazardous Waste Standards) in Appendix 4:

For example, under the US EPA Universal Treatment Standards, contaminated soils, cleanup of spills at hazardous waste facilities and so-called “characteristic wastes” must be treated to achieve low levels of the listed POPs prior to placement in landfills or other land disposal. These low POPs levels are technology-based standards (best demonstrated available technology, BDAT). As shown in Table X in Appendix 4, these levels are less than 0.3 mg/kg (parts per million) in non-wastewater (usually solid) residues for all pesticide POPs except toxaphene, which has a standard of 2.6 mg/kg. The low level concentration for PCBs is 10 mg/kg and 6 ug/kg (parts per billion) for total dioxins and furans.

US EPA has also proposed health/risk-based “exit” levels for the listed POPs as well as other contaminants in wastes that have undergone treatment. As shown in Table Y in Appendix 4, the health/risk-based standards for the listed POPs in non-wastewater are, with the exception of chlordane, considerably lower than the technology-based low levels. As indicated in Table Y, some of the health/risk-based standards are set at the lowest limit that can be reliably measured within acceptable limits of precision and accuracy using appropriate methods.

Other potentially applicable examples include:

14 Obsolete stockpiles: The FAO has noted that the only currently available disposal option for obsolete stocks contaminated with organochlorines, and also containers that have been used for such pesticides, is incineration at very high temperatures.

Comment: First this statement is fully extraneous to the subject matter of this section of the document, which is low POPs concentration. Further, it is important to know the source of this statement, particularly the date and the exact phrasing of the FAO position. In this regard, the following statement was made by Dr. Alemayehu Wodageneh, Chief Technical Advisor, Plant Production and Protection Division, FAO: " The FAO/ UNEP/ WHO guidelines on disposal of bulk quantities of stocks indicate that the preferred means of disposal at the moment is high temperature incineration. It would be useful to use alternative methods of disposal than incineration and this is the ultimate desire of FAO. " (A. Wodageneh, letter to Andreas Bernstorff, November 20, 2000) It is also important to note that high temperature incinerators are listed by the Stockholm Convention as a source category of potentially high formation and release of unintentionally produced POPs.


14 The 50 mg/kg international standard for waste noted in the Basel Convention could be used as the level at which HCB contaminated wastes must be destroyed. However, examples of other options that could be considered and concentrations used in specific circumstances are noted below.

Comment: As previously acknowledged in this document and commented upon earlier, the source of the misconception that 50 mg/kg is an international



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standard for waste was given as a footnote to A3180, which is “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 polybrominated analogues of these compounds, at a concentration level of 50 ng/kg or more.” Consequently, the footnote to A3180 is relevant to wastes containing PCB, PCT, PCN, PBB or any polybrominated analogues. It is incorrect to characterize the 50 ng/kg as having been deemed by the Basel Convention as acceptable for all POPs.

Suggestion: Delete this first sentence and reword the second sentence as follows:

Examples of potentially relevant low level concentrations are noted below;

15 The US Universal Waste Rule requires that solid wastes contaminated with HCB must be treated to 10 mg/kg prior to disposal in a landfill

Comment: As commented earlier, it would be more helpful and more accurate to describe these US EPA criteria properly (i.e., as the US EPA Universal Treatment Standards (at 40 CFR 268.48) and to point out that this technology-based standard as well as the proposed health/risk-based standard can be found in Tables X and Y of Appendix 4 of this document. Also again, to make the information more accessible, it would be most helpful to assign table numbers with explanatory titles to each of the tables of data in Appendix 4.

Suggestion: The US EPA Universal Treatment Standard, a technology-based standard, requires that HCB in contaminated materials, including soils, cleanup of spills at hazardous waste facilities and so-called “characteristic wastes” must be treated to reduce the HCB content to 10 mg/kg prior to placement in landfills or other land disposal. US EPA has proposed a health/risk-based standard for HCB wastes of 0.072 mg/kg, which is the lowest limit that can be reliably measured using appropriate methods.

15 Contaminated soil: Germany’s concentration limits for soil contaminated with HCB range from 4 mg/kg (playgrounds) to 200 mg/kg (industrial sites). These values are based on an estimation of the transfer of these chemicals into plants used for food production and, in the case of playgrounds, uptake by children while playing.

Comment: Are these action levels, i.e., is treatment required for soils containing HCB at higher concentrations than those given?

Suggestion: Modify the first sentence to explain what kind of concentration limits these are.

15 Contaminated soils: A preliminary literature search indicates that levels in con-

taminated soil vary considerably based on country and within a country, on use.

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For example, Germany has a contaminated soil concentration of 40 mg/kg for playgrounds, 80 mg/kg for residential areas and 200 mg/kg for industrial areas. Australia requires remediation of soils contaminated at 400 mg/kg.

Comment: Are the levels referred to in the first sentence action levels, i.e., contamination levels that trigger remedial action?

Suggestion: Modify the first sentence to explain what kind of concentration limits these are.

15 Specific guidance for establishing of an LPCC will need to take into consideration the extreme toxicity of these POPs at very low concentrations and the analytical rigour and high costs involved in measuring these POPs.

Comment: This specific guidance should also provide information on the precision, accuracy, availability and lower costs of bioanalytical methods, such as the CALUX cellular bioassay, which is based on the mechanism of toxicity of dioxin for estimating TEQ contamination with dioxin-like chemicals. This system has been developed with a rapid method of sample extraction and processing and application of the extract to living cells that respond to dioxin-like chemicals. This method has been applied to and validated for use with the full spectrum of environmental matrices, for example, the FAO/WHO Codex Committee on Food and Additives and Contaminants recently noted the validation of CALUX method for foods and food additives.v This method has also been used in conjunction with a new low-cost air sampling device for stack sampling and analysis.vi The UK’s Royal Commission on Environmental Pollution notes that “promising bioassay techniques include in vitro reporter gene assays, such as the receptor-mediated chemical-activated luciferase expression ( CALUX) assays. These assays are now as sensitive as traditional chemical analysis techniques and have been successfully used as broadspectrum assays in several studies.” vii A review by Behnisch et al. (2001) describes international activities using bioassays/biomarkers to measure dioxins and dioxin-like compounds in processes including thermally treated waste, wastewater treatment, landfill leachate treatment, commercial PCB mixtures; in environmental matrices (air, water, soil); and in humans and wildlife.viii

Suggestion: Modify as follows:

Specific guidance for establishing an LPCC will need to take into consideration the extreme toxicity of these POPs at very low concentrations. Conventional chemical methods of analysis are very costly and developing countries often do not have the necessary capacity. However, bioanalytical methods that are similar in rigor but markedly lower in cost are now in widespread use.



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16 The 201 dioxins and furan congeners are measured in terms of their TEQ (Toxic Equivalency Quotient) as calculated in comparison to the most toxic dioxin congener, 2,3,7,8,-TCDD. There are 30 dioxin, furan and PCB congeners that are particularly toxic because of their TEQ, including seven polychlorinated dibenzo-p-dioxins, 10 polychlorinated dibenzofurans, and 13 polychlorinated biphenyls, for which the World Health Organisation has established dioxin toxic equivalents.

Comment: In addition to the typographical error in the number of congeners (210 rather than 201), this paragraph incorrectly implies that all 210 congeners have toxicological properties similar to those of 2,3,7,8-tetrachlorodibenzo-p-dioxin. It also presents a definition of TEQ that is inconsistent with the broadly accepted definition. I.e., TEQ is not “Toxic Equivalency Quotient” but is simply “toxic equivalent”.ix Also it is neither correct nor helpful to say that these POPs “are particularly toxic because of their TEQ.” Nor is it correct or helpful to say that the World Health Organisation established dioxin toxic equivalents. The World Health Organisation established the most widely accepted and used toxic equivalency factors (TEFs) for dioxins, furans and dioxin-like PCBs.x


There are 210 dioxin and furan congeners. However, only seven of the dioxins and 10 of the furans are regarded as toxicologically important ultratoxins. The World Health Organization has assigned to each of these 17 congeners, as well as 13 PCB congeners, a toxic equivalency factor (TEF) based on each congener’s potency relative to that of the most potent of the dioxins and furans, 2,3,7,8-tetrachlorodibenzo-p-dioxin. By multiplying the mass concentration of each congener by its TEF, the concentration of a mixture of dioxins, furans and dioxin-like PCBs is expressed in toxic equivalents (TEQ).

16 The toxicity of these POPs is several orders of magnitude higher than for the Stockholm Annex A and B POPs; hence contaminant concentrations in national inventories are typically measured in much smaller amounts than for the other POPs, i.e., grams TEQ/year (or picograms/gram or picograms/Litre with respect to daily and monthly emissions, and as nanograms I-TEQ/kg in dry mass). These measurements as reflected in national legislation are derived in various ways, such as:

v Codes Committee on Food Additives and Contaminants, 2002. Position Paper on Dioxins and Dioxin-Like PCBs, Including Methods of Analysis for Dioxins and Dioxin-Like PCBs. Joint FAO/WHO Food Standards Programme. Thirty-fourth Session, Rotterdam, The Netherlands, 11-15 March 2002.vi Clark, G., Chu, M., Rayfield, B., Stone, J., Cooke, M., 1999. A novel low-cost air sampling device (AmbStack sapler) and detection system (CALUX bioassay) for measuring air emissions of dioxin, furan and PCB on a TEQ basis tested with a model industrial boiler. Organohalogen Cpds. 40: 79-82.vii Royal Commission on Environmental Pollution, 2003. Chemicals in Products: Safeguarding the Environment and Human Health. Twenty-fourth Report. Presented to Parliament by Command of Her Majesty June 2003. London, UK.viii Behnisch, P., Hosoe, K., Sakai, S., 2001. Combinatorial bio/chemical analysis of dioxin and dioxin-like compounds in waste recycling, feed/food, humans/wildlife and the environment. Environment International 27: 495-519.

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Comment: As noted in the general comments, the term “emission” and its derivates should be replaced by the term “release” or its derivatives unless referring specifically to releases to air in which case the term “air emission” or its derivates should be used.

Suggestion: Modify the first sentence as follows:

These POPs are among the most potent toxic chemicals known to science. Their potency is several orders of magnitude higher than, for example, the pesticides listed by the Stockholm Convention. In national inventories their releases are typically measured in much smaller amounts than for the other POPs, i.e., grams TEQ/year (or picograms/gram or picograms/Litre with respect to daily and monthly releases, and as nanograms I-TEQ/kg in dry mass).

16 Wastes contaminated with these substances are a source of releases to the environment, for example, through direct releases to air when sewage sludge is spread on land, via aqueous waste discharges, such as acid and alkali wastewaters, and leachate from landfills (if not captured).

Comment: Wastes containing unintentional POPs are not a source of releases. They are releases unless captured and treated to destroy their POPs content. Since the spreading of sewage sludge cannot be construed to be a direct release to air of Annex C POPs, perhaps what was meant was “direct release to soil”. Also there are other potentially far more important sources of releases that deserve mention here (see, for example, the next comment).

Suggestion: Reword the sentence as follows:

Unless captured and treated to destroy their POPs content, wastes containing unintentional POPs are considered to be POPs releases. For example, when POPs-contaminated sewage sludge is spread on soils, this is a direct release of POPs to the soils and when POPs-contaminated wastes from industrial processes, such as the manufacture of certain pesticides, are placed in pits, piles and ponds, this is a direct release of POPs to the environment.

16 Solid and semi-solid residue, such as ash, slag, dust and sludge generated from various processes, including the source categories listed in Annex C, parts II and III, may, when taken together, as well as for some sectors individually, constitute a significant contribution to national releases where such residue is not contained, although more data is needed to determine the extent of releases attributable to wastes from each category.

Comment: Whether contained or not, wastes such as those listed in this sentence are included in most if not all national and regional inventories. See, for example, the European Union inventory of dioxin releases to land and waterxi as well as UNEP’s Dioxin Toolkit, which was produced for and is being used by countries and regions to prepare their inventories of releases to the

ix van den Berg, M., 1998. Human Risk Assessment and TEFs: Draft Working Paper for the WHO-ECEH/IPCS Consultation on Assessment of the Health Risk of Dioxins: Re-evaluation of the Tolerable Daily Intake. Icp EHH 019 VD98.2/X, Geneva, 20 May 1998.x Van den Berg, M., Birnbaum, L., Bosveld, A., Brunström, B., Cook, P., Feeley, M., Giesy, J., Hanberg, A., Hasegawa, R., Kennedy, S., Kubiak, T., Larsen, J., van Leeuwen, F., Liem, A., Nolt, C., Peterson, R., Poellinger, L., Safe, S., Schrenk, D., Tillitt, D., Tysklind, M., Younes, M., Wærn, F., Zacharewski, T., 1998. Toxic Equivalency Factors (TEFs) for PCBs, PCDDs, PCDFs for humans and wildlife. Environ. Health Perspect. 106: 775 – 792.



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environment of dioxins and furans .xii Also existing inventories show such wastes to be major contributors to estimates of national releases. See, for example, when data from the EU inventory of dioxin releases to airxiii and that for releases to land and water are combined, it can be shown that 30% of total dioxin releases in the EU can be attributed to wastes from pesticide production and 20% to municipal waste incinerator ashes.

Suggestion: Rephrase this sentences as follows:

Solid and semi-solid residue, such as ash, slag, dust and sludge generated from various processes, including the source categories listed in Annex C, parts II and III, may, when taken together, as well as for some sectors individually, constitute a significant contribution to national releases. For example, in the European Union, some 20 percent of total releases of dioxins and furans are attributed to municipal waste incinerator ash.

16 It is difficult to make accurate comparisons among inventories based on how information is reported and characterization of what constitutes a waste. For example, a particular residue, such as ash, may be considered a product in its own right or as a material incorporated into other products, with varied designations in national law depending on the sector; hence a “re-used” residue may not be reflected in an inventory as a waste or as a release.

Comment: It is not obvious that a discussion of the limitations or lack thereof of inventories is a meaningful contribution to the topic under discussion, which is, broadly, “State of development in POPs concentrations,” and specifically the state of development in concentrations of unintentional POPs. It would be more useful simply to make reference to, for example, the EU inventories and UNEP’s Dioxin Toolkit.


16 Taking these considerations into account, the 50 mg/kg definition of a waste will not be adequate for these POPs as a level that triggers destruction of waste. Germany has proposed 50 μg/TEQ/ kilogram (equivalent to 50 ppb of TCDD TEQ) as an LPCC.

Comment: With regard to the first sentence, as previously acknowledged in this document and commented upon earlier, the source of the misconception that 50 mg/kg is an international standard for waste was given as a footnote to A3180, which is “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 polybrominated analogues of these compounds, at a concentration level of 50 ng/kg or more.” Consequently, the footnote to A3180 is relevant to wastes containing PCB, PCT, PCN, PBB or any polybrominated analogues. It is incorrect to characterize the 50 ng/kg as having been deemed by the Basel Convention as acceptable for all POPs.

With regard to the second sentence, can documentation please be provided for this statement that Germany has proposed an LPCC of 50 μg TEQ/ kilo-gram, as well as an accompanying description of the context including when,

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by whom and to whom was this proposal made and what is the matrix, waste, soils, etc.? Moreover, other, considerably more stringent low level concentra-tions for dioxins and/or other unintentional POPs in wastes have been estab-lished and/or proposed by other countries.

Suggestion: Delete the first sentence and either delete the second sentence or fully explain the source and context and include here levels established and/or proposed by other countries.

17 Where analytical capacity to measure is lacking: Obtaining accurate measurement of dioxins and furans at extremely low concentrations requires highly sophisticated analytical capacity and involves considerable cost per sample..

Comment: As noted in an earlier comment, it is essential also to provide information on the precision, accuracy, availability and lower costs of bioanalytical methods, such as the CALUX cellular bioassay, which is based on the mechanism of toxicity of dioxin for estimating TEQ contamination with dioxin-like chemicals. This system has been developed with a rapid method of sample extraction and processing and application of the extract to living cells that respond to dioxin-like chemicals. This method has been applied to and validated for use with the full spectrum of environmental matrices, for example, the FAO/WHO Codex Committee on Food and Additives and Contaminants recently noted the validation of CALUX method for foods and food additives.xiv This method has also been used in conjunction with a new low-cost air sampling device for stack sampling and analysis.xv The UK’s Royal Commission on Environmental Pollution notes that “promising bioassay techniques include in vitro reporter gene assays, such as the receptor-mediated chemical-activated luciferase expression ( CALUX) assays … These assays are now as sensitive as traditional chemical analysis techniques and have been successfully used as broadspectrum assays in several studies.” xvi A review by Behnisch et al. (2001) describes international activities using bioassays/biomarkers to measure dioxins and dioxin-like compounds in processes including thermally treated waste, wastewater treatment, landfill leachate treatment, commercial PCB mixtures; in environmental matrices (air, water, soil); and in humans and wildlife.xvii

Suggestion: Rephrase and add further information as follows:

Obtaining accurate measurement of dioxins and furans at extremely low concentrations has historically required highly sophisticated analytical capacity and involved considerable cost per sample. However, bioanalytical methods that are similar in rigor but markedly lower in cost are now in available and in widespread use.

xi Wenborn, M., King, K., Buckley-Golder, D., Gascon, J. A., 1999. Dioxin emissions to land and water in Europe. AEAT-4703. Available from < http:// www. europa. eu. int/ comm/ environment/ dioxin>.



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17 For nations that lack analytical capacity, the limit of detection could be the low POPs content concentration, so as to ensure that wastes that could be significantly contaminated with Annex C POPs will not be excluded from provisions of Article 6.1 (d) (ii) because of inability to accurately detect typically low concentrations of these substances in waste.

Alternatively, decisions regarding wastes destined for destruction could be based on the type of waste stream and loading of such waste, taking into account the typical concentrations that can be achieved for the waste stream in various matrices utilizing best available techniques

Comment: If a nation lacks analytical capacity, the limit of detection would be infinitely large and so, consequently, the low POPs content concentration would be infinitely large. This would mean that all POPs-contaminated wastes would be excluded from the provisions of Article 6.1 (d)(ii). If a nation had access only to very poor or insensitive analytical methods, the limit of detection would be very high and so, consequently, the low POPs content concentration would be very high. This would mean that POPs-contaminated wastes that might, because of their quantity, be major contributors to the nation’s estimated releases would be excluded from the provisions of Article 6.1 (d)(ii). In summary, this is a very unsound suggestion. The second sentence is incompatible with the requirements of the Stockholm Convention.

Suggestion: Delete these sentences.

17 3.4 Guidance on establishing terms “ destruction” and “irreversible transformation”

Comment: The subject under discussion would be clearer if this heading were simplified.

Suggestion:

xii United Nations Environment Programme, 2001. Standardized Toolkit for Identification and Quantification of Dioxin and Furan Releases. Geneva, Switzerland: UNEP Chemicals.xiii Quass, U., and Fermann, M. 1997. Identification of Relevant Industrial Sources of Dioxins and Furans in Europe (The European Dioxin Inventory), Final Report, No. 43. Landesumweltamt Nordrhein-Westfalen: Essen, Germany.xiv Codes Committee on Food Additives and Contaminants, 2002. Position Paper on Dioxins and Dioxin-Like PCBs, Including Methods of Analysis for Dioxins and Dioxin-Like PCBs. Joint FAO/WHO Food Standards Programme. Thirty-fourth Session, Rotterdam, The Netherlands, 11-15 March 2002.xv Clark, G., Chu, M., Rayfield, B., Stone, J., Cooke, M., 1999. A novel low-cost air sampling device (AmbStack sapler) and detection system (CALUX bioassay) for measuring air emissions of dioxin, furan and PCB on a TEQ basis tested with a model industrial boiler. Organohalogen Cpds. 40: 79-82.xvi Royal Commission on Environmental Pollution, 2003. Chemicals in Products: Safeguarding the Environment and Human Health. Twenty-fourth Report. Presented to Parliament by Command of Her Majesty June 2003. London, UK.xvii Behnisch, P., Hosoe, K., Sakai, S., 2001. Combinatorial bio/chemical analysis of dioxin and dioxin-like compounds in waste recycling, feed/food, humans/wildlife and the environment. Environment International 27: 495-519.

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3.4 Guidance on destruction and irreversible transformation

17 The objective of destruction is to eliminate the POPs molecule (as determined by a non detect or limit of detection measurement).

Irreversible transformation means POPs no longer exhibit the characteristic of a POP, hence, regardless of how waste that has been irreversibly transformed is disposed of, it cannot in the future release POPs.

Comment: These two sentences provide neither clear, understandable explanations of destruction and irreversible transformation nor a context for the discussion of these terms.

Suggestion: Replace these two sentences with the following:

Article 6, paragraph 1(d)(iii) of the Stockholm Convention requires that wastes containing the listed POPs are “[d]isposed 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;”

17 3.5 Guidance on establishing levels of destruction

Article 6.2(a) as previously noted directs the Stockholm COP to work with the appropriate bodies of the Basel Convention to establish levels of destruction and irreversible transformation necessary to ensure that the characteristics of POPs are not exhibited.

The level of destruction could be based on what is currently achievable for the particular POP utilizing best available techniques (BAT) and best environmental practices (BEP). To determine what is achievable, existing BAT could be assessed using a common set of criteria developed and applied by an international experts body and periodically revisited in light of new techniques and practices as these become commercially available, taking into account inventory and general features (concentration, condition, etc.) of waste stocks awaiting destruction as these are applicable to BAT and BEP for destruction.

Comment: It would add considerable clarity to include in this section the exact language of Article 6.2(a): “Establish levels of destruction and irreversible transformation necessary to ensure that the characteristics of persistent organic pollutants as specified in paragraph 1 of Annex D are not exhibited.” The defining criterion of this requirement is ensuring that POPs characteristics are not exhibited. However, there is no discussion in this or any other section of this document that addresses this criterion. The key questions that must be answered with regard to this criterion are -- What is required to ensure that POPs characteristics are not exhibited?

and



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How can it be determined that this requirement – no POPs characteristics – is met?

The answer to the first question is that destruction/irreversible transformation of the POPs content of the wastes must be effectively 100 percent. I.e., destruction/irreversible transformation must be carried out so that no detectable levels of POPs remain, since, by definition, one molecule of a POP will exhibit POPs characteristics.1 Consequently, the answer to the second question is that the outputs from the destruction/irreversible transformation processes must be analyzed to ascertain that no POPs can be detected. This means that the guidelines must address the methods of sampling and analysis that will be relied upon to establish that effectively 100 percent destruction/irreversible transformation has been achieved.


As previously noted, Article 6.2(a) of the Stockholm Convention directs the Stockholm COP to work with the appropriate bodies of the Basel Convention to “[e]stablish levels of destruction and irreversible transformation necessary to ensure that the characteristics of persistent organic pollutants as specified in paragraph 1 of Annex D are not exhibited.” To ensure that POPs characteristics are not exhibited, it is necessary that POPs are destroyed and/or irreversibly transformed until they are no longer detectable, i.e., with effectively 100 percent efficiency.

Achieving this level of destruction can be based on best available techniques (BAT) and best environmental practices (BEP), which are defined and generally described by the Stockholm Convention. The Convention also requires that certain BAT -- alternative processes, techniques and practices that have similar usefulness but which avoid the formation and release of unintentional POPs – are given priority consideration when considering proposed new facilities or significant modifications to existing facilities. The Stockholm Convention BAT/BEP Expert Group is drawing up BAT/BEP guidelines for the identified source categories for unintentionally produced POPs, which include some technologies, such as waste incinerators and cement kilns, that are used or have been proposed for use for the disposal of POPs wastes. However, these BAT/BEP guidelines are directed specifically toward the reduction or elimination of formation and release of unintentionally produced POPs.

BAT/BEP for the destruction/irreversible transformation of POPs wastes could be assessed using a common set of criteria, such as those criteria presented by UNIDO: xviii

“The technologies used for destroying stockpiles of persistent organic pollutants (POPs) must meet the following fundamental performance criteria:

Destruction efficiencies of effectively almost 100 percent for the

1 Webster's Revised Unabridged Dictionary (1913) offers the following definition of molecule: “the smallest part of any substance which possesses the characteristic properties and qualities of that substance, and which can exist alone in a free state.”

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chemicals of concern: The determination of 100 percent destruction efficiency is necessarily based on findings of extremely low concentrations of the chemicals of concern, approaching zero in any and all residues, or outflow streams using the most sensitive analytical techniques available worldwide. …

In order to better attain the abovementioned goal, priority is recommended for technologies that imply containment of all residues and out flowing streams for screening and, if necessary, reprocessing. This is to ensure that no chemicals of concern or other harmful compounds, such as newly formed POPs or other hazardous substances, are released to the environment. Technologies, which may require uncontrolled releases (e.g. relief valve from high-pressure vessels) or environmental spreading of POPs, even at hardly detectable levels (e.g. incineration processes with high gaseous mass flow released to atmosphere), should be carefully scrutinized and possibly avoided.”

Additional criteria that have been developed include the following: xix

capability of treating a variety of wastes with varying constituents with minimal pre-treatment of waste;

secondary waste stream volumes that are significantly smaller than the original waste stream volumes and which contain no toxic reaction by-products;

complete elimination of organic contaminants; off gas and secondary waste composition; cost; and risk.

These and other relevant criteria could be compiled and evaluated by an international body of experts and periodically revisited in light of new techniques and practices as these become commercially available, taking into account inventory and general features (concentration, condition, etc.) of waste stocks awaiting destruction as these are relevant to BAT and BEP for destruction.

18 The technologies assessed could include the following “core” technologies for treatment of POPs and POPS-bearing media to determine their appropriateness and performance with respect to destruction (see appendix 6 for a brief overview of waste treatment processes):

5 High Temperature/Residence Time Incineration6 Wet-Feed Cement Kiln Co-Incineration7 Pyrolysis and Molten Metal Pyrolosis8 Advanced Oxidation Processes9 Solar-Mediated Photo-Chemical Oxidation10 SubCritical and SupraCritical Oxidation and Hydrolysis11 Electro-Chemical Oxidation12 Molten-Salt Oxidation13 Plasma Arc Decomposition14 High Temperature Chemical Reduction/Dehalogenation15 Solvated Electron Reduction



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Comment: First, the list above includes technologies that were apparently selected for their potential for achieving destruction/irreversibly transformation whereas this guidance is supposed to be guidance for the environmental sound management of POPs wastes. I.e., this document should also include guidance for the environmentally sound management of POPs wastes having “low” levels of POPs. This would include, for example, techniques or technologies for long-term isolation or containment of low level POPs wastes, e.g., engineered landfills, aboveground storage, vitrification, cement solidification, etc. In addition, this document should include guidance for techniques/technologies that concentrate and capture POPs from low level wastes for subsequent destruction/irreversible transformation, as mentioned in Appendix 6, e.g., electro-osmosis, thermal desorption, etc. Second, the above list, which includes 11 technologies, should be made compatible with Appendix 6, which includes 13 technologies. The technologies listed should be grouped and named more appropriately and listed alphabetically to avoid the appearance of favoritism toward any particular technology or technologies. Also, as shown below, several additional technologies should be included.

Suggestion:

The technologies assessed could include the following “core” technologies for treatment of POPs and POPS-bearing media to determine their appropriateness and performance with respect to destruction/irreversible transformation (see appendix 6 for a brief overview of waste treatment processes):

16 Ball milling17 Gas-phase Chemical Reduction (Hydrogenation)18 Oxidation Processes Advanced Oxidation Processes

› Electro-Chemical Oxidation› Molten metal oxidation› Molten salt oxidation› Solar-Mediated Photo-Chemical Oxidation› SubCritical and SupraCritical Oxidation and Hydrolysis

Incineration, high temperature/residence time› Cement kiln modified for co-firing hazardous waste› Dedicated hazardous waste incinerators

19 Plasma Arc Decomposition20 Pyrolysis

- Molten metal pyrolysis

xviii Rahuman, M., Pistone, L., Trifiro, F., Miertus, S., 2000. Destruction technologies for polychlorinated biphenyls (PCBs). Presented at the Expert Group Meeting on “Clean Technologies for the Reduction and Elimination of POPs”, International Centre for Science (ICC-UNIDO), Trieste, Italy, 4-5 May 2000.xix Schwinkendorf, W., McFee, J., Devarakonda, M., Nenninger, L., Fadullon, F., Donaldson, T., and Dickerson, K., 1995. Alternatives to Incineration: Technical Area Status Report. Prepared for the Mixed Waste Integrated Program. U.S. Department of Energy, Office of Technology Development, Washington, D.C., April 1995.

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- Molten salt pyrolysis21 Sodium dispersion 22 Solvated Electron Reduction

17 The concentrated waste media—either a spent sorbent, an extract, a concentrate, a precipitate, or a free phase product—would then be subjected to one of the incineration, co-incineration, oxidative, reductive or dehalogenation technologies as presented above.

Comment: As pointed out in the comment above, if it deemed necessary to list technologies, it is more appropriate to list them in alphabetical order to avoid the appearance of favoritism.


The concentrated waste media—either a spent sorbent, an extract, a concentrate, a precipitate, or a free phase product—would then be subjected destruction/irreversible transformation or, if POPs content is low, other methods of environmentally sound management.

18 The following factors could be taken into account for the application of BAT and BEP for hazardous waste disposal operations:… When a technology is selected and applied for destruction of POPs, an audit or

assessment of the receiving environment in the facility area should be conducted during destruction operations so as to verify via field measurements whether releases that are occurring are significant and pose a health risk to the surrounding population.

The potential for releases to the environment could also be taken into account when siting a destruction facility. This could be more important for countries where food sources are localized given the exposure pathway for dioxins and furans. These risks should be weighed against the risks of exposure that can occur from continued storage of wastes.

…

Comment: First, the guidance document should be consistent throughout that it addresses POPs wastes, not hazardous wastes in general. The suggestion of “an audit or assessment of the receiving environment in the facility area … during destruction operations … so as to verify … whether releases that are occurring are significant and pose a health risk to the surround population” has some merit. However, it, in effect, an ex post facto measure that should not be regarded in any way as a substitute for thorough, continuous monitoring of all facility outputs, including fugitive emissions, for POPs releases and appropriate measures, including a facility shutdown to identify and eliminate the cause of such releases. The suggestion that destruction/irreversible transformation facilities that release POPs are not only acceptable but are more acceptable in some locations than others is incompatible with the requirements of the Stockholm Convention.

Suggestion: Omit the bullet “The potential for releases …” and modify the other bullet as follows:

The following factors could be taken into account for the application of BAT and BEP for techniques and technologies for the environmentally sound management of POPs wastes:…



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When a technology is selected and applied for destruction of POPs, an audit or assessment of the receiving environment in the facility area should be conducted during destruction operations to supplement data obtained through continuous monitoring of all potential points of POPs release at the facility in identifying and eliminating all POPs releases from the facility.

19 3.7 Guidance on determining when destruction or irreversible transformation does not represent the environmentally preferable option

Where utilization of BAT to destroy a particular POP or POPs would result in release concentrations and/or loadings of unintentional POPs that pose an unacceptable health risk, alternatives might be examined using a health-based risk assessment methodology to determine whether a management option, such as interim storage utilizing best environmental practices, poses less risk than the destruction or irreversible transformation option(s). For example, releases based on concentrations or loading might be deemed acceptable where the receiving environment contains dioxins and furans at background levels might not be acceptable where the receiving environment is already contaminated above background levels. In some instances the only choice may be between “the lesser of two evils.” For example, community X decides that the PCBs in sediment that are poisoning fish on which people depend and which also represent a substantial loss in tourism dollars, and potentially the community’s drinking water, are deemed to pose an unacceptable risk owing to their bioavailability and concentration, in contrast to generation of dioxins and furans where releases, if they do occur, are estimated to be less significant in terms of exposure risks relative to acceptable daily intake, maximum residue limits in food, etc. In other instances, removal and safe packing, labelling and interim storage of a contaminant may be deemed preferable to immediate destruction, pending availability of a suitable technology, and assuming the storage follows best practices in all respects, including as regards security and taking into account the siting and nature of the facility with respect to “acts of god” such as flooding, hurricanes, lightning, etc. In some instances the nature of the waste (other substances with which it is mixed, lack of uniformity, etc.) may preclude use of a particular technology.

As previously noted, there may be instances where the quantity of a waste is so small that destruction (based again on feedstock rates required for destruction technologies, as well as difficulties with collection, handling, packing and transport) does not constitute the best approach.

Comment: The first paragraph seems unduly difficult to comprehend. With regard to the first sentence, it is difficult to conceive of a technique/technology that is BAT that would have unacceptably high releases of unintentional POPs. A technique/technology that has unacceptably high releases of unintentional POPs would not be considered BAT by definition. Assuming that “but” is the missing word, the second sentence suggests that polluting an unpolluted area is preferable to polluting a polluted area. The reasoning behind this is not at all clear, especially when the pollutants under discussion are unintentional POPs (dioxins and furans), releases of which the Stockholm Treaty aims to continuously minimize and, where feasible ultimately to eliminate.

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With regard to the third and fourth sentences, which explore a “lesser of evils” situation, the two apparent “evils” facing ‘community X” are 1) PCBs in sediments that threaten fish, livelihoods and potentially drinking

water, and2) dioxins and furans released by the technology used to destroy/irreversibly

transform the PCBs in the sediment. The threat to human health and the environment of the dioxins and furans is posited as being less problematic than and consequently preferable to the threat of the PCBs to fish, livelihoods and potentially drinking water. No rationale is given for the use of a PCB remediation technology that releases dioxins and furans when technologies are available that do not release dioxins and furans.

Suggestion: Delete the first through fourth sentences and modify as follows:

Removal and safe packing, labeling and interim storage of a contaminant may be deemed preferable to immediate destruction, pending availability of a suitable technology. This assumes that the storage follows best practices in all respects, including security and taking into account the siting and nature of the facility with respect to “acts of god” such as flooding, hurricanes, lightning, etc. In some instances the nature of the waste (other substances with which it is mixed, lack of uniformity, etc.) may preclude use of a particular technology.

As previously noted, there may be instances where the quantity of a waste is so small that destruction (based again on feedstock rates required for destruction technologies, as well as difficulties with collection, handling, packing and transport) does not constitute the best approach. However other methods of environmentally sound management can be employed.

19 Waste minimization is achieved through adoption of best available techniques and best environmental practices that prevent pollution rather than attempting to mitigate pollution after it is created. Pollution prevention that minimizes wastes, including use of alternative processes and products that do not incorporate POPs, is always preferable to generation of POPs and POPs wastes.

Comment: With regard to the first sentence, the terms “waste” and “pollution” are not synonymous. In the second sentence, the term “incorporate” does not fully encompass the scope of the Stockholm Convention with respect to POPs in the context of pollution prevention and waste minimization.

Suggestion: Minimization of POPs waste is achieved through BAT and BEP that avoid the generation of POPs waste rather than attempting to dispose of it after it is created. Avoiding and minimizing POPs waste by using alternative materials, processes and products that neither contain POPs nor lead to the formation of POPs is always preferable to the generation of POPs and POPs wastes.

20 Guidance on BAT and BEP is currently under development for some Annex C sources of POPs by an Expert Group of the Stockholm Convention.

Comment: The Expert Group is addressing only BAT/BEP for reducing and/or eliminating formation and release of unintentionally produced POPs.


Guidance on BAT and BEP for preventing and/or reducing the formation and



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release of unintentionally produced POPs from some Annex C source categories is currently under development by an Expert Group of the Stockholm Convention. General guidance in this regard is presented in Annex C, Part V of the Convention.

20 The Basel Convention embodies several key principles with respect to environmentally sound management of waste that are articulated in the 1994 Framework Document on Preparation of Technical Guidelines for the environmentally Sound Management of Wastes Subject to the Basel Convention:

23 The self-sufficiency principle by which countries should ensure that the disposal of waste generated within their territory is undertaken there by means which are compatible with environmentally sound management, recognizing that economically sound management of some wastes outside of national territories may also be environmentally sound. 24 The proximity principle by which the disposal of hazardous wastes must take place as close as possible to their point of generation, recognizing that economically and environmentally sound management of some wastes will be achieved at specialized facilities located at greater distances from the point of generation.25 The Source Reduction Principle by which the generation of wastes should be minimized in terms of its quantity and its potential to cause pollution. This may be achieved by using appropriate plant and process design.

Comment: The Basel Convention’s “Guidance Document on the Preparation of Technical Guidelines for the Environmentally Sound Management of Wastes Subject to the Basel Convention proffers several other key principles that are equally important and some of which are acknowledged in the Stockholm Convention. xx

Suggestion: Modify the above as follows:

The Basel Convention embodies several key principles with respect to environmentally sound management of waste that are articulated in the “Guidance Document on the Preparation of Technical Guidelines for the Environmentally Sound Management of Wastes Subject to the Basel Convention”:

Principles to be considered in the Development of Waste and Hazardous Waste Strategies

Below are a number of principles that many countries have used to varying extents in developing their waste management strategies. These principles are not absolute and are not meant to replace the principles agreed to in the Basel Convention, nor to define "environmentally sound management." They are presented as principles that merit consideration and that some countries have found useful.

(a) The Source Reduction Principle - by which the generation of waste should be minimized in terms of its quantity and its potential to cause pollution. This may be achieved by using appropriate plant and process designs;

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(b) The Integrated Life-cycle Principle - by which substances and products should be designed and managed such that minimum environmental impact is caused during their generation, use, recovery and disposal;

(c) The Precautionary Principle - whereby preventive measures are taken, considering the costs and benefits of action and inaction, when there is a scientific basis, even if limited, to believe that release to the environment of substances, waste or energy is likely to cause harm to human health or the environment;

(d) The Integrated Pollution Control Principle - which requires that the management of hazardous waste should be based on a strategy which takes into account the potential for cross media and multi-media synergistic effects; (e) The Standardization Principle - which requires the provision of standards for the environmentally sound management of hazardous wastes at all stages of their processing, treatment, disposal and recovery;

(f) The Self-sufficiency Principle (to be considered with (g) and (h)) - by which countries should ensure that the disposal of the waste generated within their territory is undertaken there by means which are compatible with environmentally sound management, recognizing that economically sound management of some wastes outside of national territories may also be environmentally sound;

(g) The Proximity Principle (to be considered with (f) and (h)) - by which the disposal of hazardous wastes must take place as close as possible to their point of generation, recognizing that economically and environmentally sound management of some wastes will be achieved at specialized facilities located at greater distances from the point of generation;

(h) The Least Transboundary Movement Principle (to be considered with (f) and (g) - by which transboundary movements of hazardous wastes should be reduced to a minimum consistent with efficient and environmentally sound management;

(i) The Polluter Pays Principle - by which the potential polluter must act to prevent pollution and those who cause pollution pay for remedying the consequences of that pollution;

(j) The Principle of Sovereignty - under which every country shall take into account political, social and economic conditions in establishing a national waste management structure. A country may, for example, ban the importation of hazardous wastes into its territory in accord with its national environmental legislation;

(k) The Principle of Public Participation - under which States should ensure that in all stages, waste management options are considered in consultation with the public as appropriate, and that the public has access to information concerning the management of hazardous wastes.

22 Regulatory provisions for post-destruction concentrations of POPs in different matrices could be specified based on what is achievable using best available techniques and best environmental practices.

Comment: It is essential to acknowledge here the requirements of the Stockholm Convention with respect to destruction/irreversible transformation.



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The Stockholm Convention requires that POPs wastes other than those that contain low levels of POPs undergo destruction/irreversible transformation so that POPs characteristics are no longer exhibited, i.e., no POPs can be detected. However, regulatory provisions for post-destruction concentrations of POPs in low level POPs wastes could be specified based on what is achievable using best available techniques and best environmental practices.

23 Legislation and regulations should include provisions for public access to information and public awareness raising as per provisions of the Stockholm and Basel conventions as these apply to POPs.

Comment: This statement does not reflect the emphasis or the extent of public participation as it is described in relationship to the Basel and Stockholm Conventions. As acknowledged in the Basel Convention Guidance cited above:

“…States should ensure that in all stages, waste management options are considered in consultation with the public as appropriate, and that the public has access to information concerning the management of hazardous wastes”; and

as acknowledged in Article 10 1(d) of the Stockholm Convention, “Each Party shall, within its capabilities, promote and facilitate:… Public participation in addressing persistent organic pollutants and their

health and environmental effects and in developing adequate responses, including opportunities for providing input at the national level regarding implementation of this Convention;”

Suggestion: Legislation and regulations should include provisions for public participation and input in all stages of decisionmaking in the management of POPs wastes, public access to information concerning the management of POPs wastes, and public awareness raising on the health and environmental effects of POPs, including opportunities for input at the national level regarding implementation of the Stockholm Treaty.

23 5.2 How to Identify POPs as wastes

Comment: The “as” is superfluous.


5.2 How to Identify POPs wastes

23 POPs wastes are generated as a result of industrial production processes, blending and formulation, application and handling. Wastes occur in solid form, liquid form (aqueous, semi-aqueous, solvent-based, and emulsions) and in vapour phase (in

xx Guidance Document on the Preparation of Technical Guidelines for the Environmentally Sound Management of Wastes Subject to the Basel Convention. http://www.basel.int/meetings/sbc/workdoc/framewk.htm#Principles

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gaseous form, as a liquid dispersion, or adsorbed onto atmospheric pollutants).

Comment: POPs wastes are also generated as a result of human activities other than industrial production processes, blending and formulation, application and handling. See, for example, the Stockholm Convention, Annex C, Part III source categories.

Suggestion: Modify the paragraph above as follows:

POPs wastes are generated and otherwise created as a result of a broad range of human activities, e.g., industrial production of chemicals, pesticides and consumer goods and the use and handling of these products; waste disposal via dedicated combustion facilities such as incinerators; accidental fires involving buildings, vehicles, landfills, etc.; open burning of municipal, household and agricultural wastes; etc. POPs wastes occur as solids, semi-solids, liquids (aqueous, semi-aqueous, solvent-based, and emulsions) and gases (actual gases, aerosols, or adsorbed onto airborne particulates).

23 Wastes are generated in the following situations:

Comment: This is not a definitive list and should not be presented as such.

Suggestion: POPs waste are generated in many ways, such as …

23 Industrial process waters and wastewaters (including rinses, shower water, etc.), solid residues (ash, dust); industrial and municipal sludge, etc., may be described in national legislation as waste. However, they may also be characterized as discharges or releases to the environment (effluent discharges, for example), and as products where POPs content is low (for example, sludge utilized in land farming and ash that is contaminated below the low POPs content concentration that is incorporated into other products).

Comment: This paragraph introduces a new, complicating factor – another category of “low POPs content”. This “low” POPs content is not the same as the “low” POPs content that is to be established for each of the POPs to determine whether a POPs waste is to undergo destruction/irreversible transformation (unless destruction/irreversible transformation is not environmentally preferable) or to undergo other environmentally sound disposal methods. More important, however, is the fact that the Stockholm Convention, Article 6, paragraph 1(d)(iii) specifies that POPs wastes, including products and articles upon becoming wastes, are … “[n]ot permitted to be subjected to disposal operations that may lead to recovery, recycling, reclamation, direct reuse or alternative uses of persistent organic pollutants;”


Industrial process waters and wastewaters (including rinses, shower water, etc.), solid residues (ash, dust); industrial and municipal sludge, etc., may be described in national legislation as waste. They may also be characterized as discharges or releases to the environment (effluent discharges, for example), and as products where POPs content is below certain levels (for example, sludge utilized in land farming and incinerator ash that is incorporated into other products). With regard to the latter, however, the Stockholm Convention expressly prohibits the recovery, recycling, reclamation, direct reuse or alternative uses of POPs.

23 Familiarity with process sectors and waste streams that generate or utilize POPs will



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assist managers to identify POPs wastes.

Comment: It would also be helpful to remind readers of the Stockholm Convention’s lists of source categories of unintentionally produced POPs.


Familiarity with process sectors and waste streams that generate or utilize POPs will assist managers to identify POPs wastes. The lists of source categories of unintentionally produced POPs provided in the Stockholm Convention will assist not only industrial managers but also managers in other sectors as well as the general public to identify POPs wastes.

24 5.3 Overview of approaches for waste prevention, minimization and recycling Comment: With regard to this title, the Stockholm Convention prohibits the recycling of POPs wastes. With the exception of the second sentence, this section seems to be a generic description of waste prevention, minimization and recycling. As such, it needs to undergo substantial revision so that it is more specific to POPs wastes.

Suggestion: Modify the title as follows and add more information on alternative processes, such as alternative management of municipal, medical and household wastes, and alternative pulp bleaching, such as oxygen-based bleaching; alternative materials (materials that are not linked to the generation of unintentional POPs) such as non-chlorinated plastics; etc.; etc.

5.3 Overview of approaches for preventing and minimizing POPs wastes

24 Waste prevention has as its objective avoidance of waste creation. Alternatives (process design; substitute materials) are used to avoid generation of POPs and hence of POPs wastes.

Comment: This could be phrased somewhat more clearly.


Preventing POPs wastes -- avoiding the generation of POPs wastes – is the first and most important step in the overall environmentally sound management of POPs wastes. Primary measures for preventing POPs wastes include the use of alternatives -- alternative products that are not POPs or are not linked to the generation of POPs during their lifecycles, alternative processes that do not generate unintentional POPs, alternative practices that do not involve the use or generation of POPs, etc.

24 5.3 Waste treatment

Comment: The purpose of this segment is not clear. If it is intended as a generic overview of waste treatment, it is not entirely germane to this document. If it is intended as an overview of technologies for POPs waste

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treatment, it needs to be retitled and revised by, for example, including a detailed discussion of the Stockholm Convention requirements for POPs waste treatment.

Suggestion: Modify the title as follows:

5.4 POPs waste treatment

24 Waste treatment involves the application of any process that changes the physical, chemical, or biological character of a waste to make it less of a threat to the environment. Treatment can neutralize the targeted waste; recover energy or resources from the waste; render the waste less hazardous; and/or make the waste safer to store, transport, or dispose. Pre-treatment is any process that will improve the performance and/or economics and/or safety of the ensuing waste treatment process. Post–treatment is any process that will complement the performance of the waste treatment process in meeting overall defined process objectives, either when applied to the main waste stream being processed or to any side streams (continuous, intermittent, occasional, accidental) that might be generated during treatment.

Comment: This needs to be revised so that it applies to POPs wastes.


In general, waste treatment involves the application of any process that changes the physical, chemical, or biological character of a waste to make it less of a threat to the environment. Treatment can neutralize the targeted waste; recover energy or resources from the waste; render the waste less hazardous; and/or make the waste safer to store, transport, or dispose. Pre-treatment is any process that will improve the performance and/or economics and/or safety of the ensuing waste treatment process. Post–treatment is any process that will complement the performance of the waste treatment process in meeting overall defined process objectives, either when applied to the main waste stream being processed or to any side streams (continuous, intermittent, occasional, accidental) that might be generated during treatment.

Treatment for POPs wastes has very specific objectives, depending on the concentrations of POPs in the wastes. When POPs levels are above certain threshold concentrations that are to be established, the POPs wastes must undergo1) treatment that destroys or irreversibly transforms the POPs so that POPs

characteristics are no longer exhibited, i.e., so that the POPs are below the limits of detection; or

2) if destruction/irreversible transformation is not environmentally preferable, treatment by other environmentally sound disposal methods.

When POPs levels in wastes are below the “low” threshold concentrations, the wastes also must undergo treatment by other environmentally sound disposal methods.

25 Treatment technologies are generally defined in terms of chemical, physical, physical-chemical, and biological with/without enzymatic processes. Waste treatment can be pursued in the following states: liquid (lowest energy matrix), vapour, supercritical, and plasma (fourth-state of matter - highest energy matrix). Increasing energy states generally translate into increasing treatment costs.

Comment: There are a variety of classification systems for treatment technologies. Also at least one treatment technology, ball milling, takes place in the solid state.



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Treatment technologies for wastes, including POPs wastes, can be broadly categories as chemical, physical, physical-chemical, and biological processes. These processes can take place in all states: solid, liquid, gaseous, supercritical, and plasma. Treatment costs generally are lowest for treatment in the solid state and highest for plasma.

25 Oxidation of POPs may result in the creation of other POPs when the reactions have not been allowed to proceed to absolute completion and hence down to mineral elements (water, carbon dioxide, mineral acids, and mineral “salts.”) These events will occur not only during treatment, especially given the recent advances in analytical chemistry, but more importantly are likely to occur during process upsets, start-up, shut-down, process fine tuning/optimization, and maintenance-related operations.

Comment: The first sentence is not entirely accurate.

Suggestion: Oxidation of the currently listed POPs, including combustive oxidation in incinerators, industrial processes (e.g., iron sintering and similar metals production) and cement kilns, can be accompanied by the formation and release of unintentionally produced POPs. Formation of unintentional POPs occurs primarily as post-combustion gases cool down as they move to and through air pollution abatement systems. Formation of these POPs is known to increase during process upsets, start-ups and shutdowns as well as during process fine tuning/optimization and during some maintenance-related operations.

25 Treatment of POPs-bearing wastes might only necessitate, in certain cases, a partial conversion to ensure that their persistency characteristics have been eliminated.

Comment: The Stockholm Convention specifies that destruction/irreversible transformation of POPs wastes must ensure that POPs characteristics are no longer exhibited. Besides persistence, other POPs characteristics are listed in Annex D of the Stockholm Convention. While it seems likely that treatment that eliminates persistence will also eliminate the other POPs characteristics, the implication here that persistence is the only POPs characteristic is both inaccurate and confusing. Also, biological treatment of POPs wastes is not yet so widespread as to be described accurately as “conventional”.

Suggestion: Treatment of POPs wastes need not entail complete mineralization, i.e., complete decomposition to, for example, water, carbon dioxide, and hydrogen chloride. For example, the sodium dispersion technology dehalogenates, i.e., removes chlorine, and may leave the underlying molecular structure intact.

27 5.6 Inventories

Comment: This section is incomplete without a discussion of the Stockholm Convention requirements for inventories, including inventories of sources and estimated releases of unintentionally produced POPs.

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Suggestion: Add a segment on the Stockholm Convention requirements for inventories, including inventories of sources and estimated releases of unintentionally produced POPs. The UNEP Chemical’s Dioxin Toolkit provides a template for such national and regional inventories.

27 5.7 Analytical sampling and monitoring

Capacity with regard to sample collection and preparation, laboratory analysis, and data interpretation are important to obtaining accurate information with respect to POPs wastes, including concentrations in wastes. Monitoring the receiving environment (air, water, soil/sediment; wildlife) and food source is important in identifying and characterizing contaminated site wastes.

Comment: It is also crucially important to monitor all outputs of treatment technologies and techniques for undestroyed POPs and unintentionally produced POPs.

Suggestion: Capacity with regard to sample collection and preparation, laboratory analysis, and data interpretation are important to obtaining accurate information with respect to POPs wastes, including concentrations in wastes. It is also crucial for monitoring the gaseous, liquid and solid outputs of POPs waste treatment, pre-treatment, storage, and containment/isolation technologies, including landfills, to identify and quantify undestroyed POPs and unintentionally produced POPs. Monitoring the receiving environment (air, water, soil/sediment; wildlife) and food source is important in identifying and characterizing contaminated site wastes.

27 Criteria-based approaches set maximum allowable contaminant concentrations for contaminants in various matrices that must be attained post-remediation. These may include concentrations to be attained in water or fish.

Comment: It is also common to set maximum allowable contaminant concentrations for matrices other than water or fish.

Suggestion: Criteria-based approaches set maximum allowable contaminant concentrations for contaminants in various matrices that must be attained post-remediation. These may include concentrations to be attained in air, water, soils, sediment, fish, etc.

28 26 Methods that constitute environmentally sound disposal, including monitoring and assessment.– Destruction and irreversible transformation– Other disposal in an environmentally sound manner

Other disposal when the POP content is low Other disposal when destruction or irreversible transformation does not represent

the environmentally preferable option.

Comment: The two bullet points under “Other disposal in an environmentally sound manner” are unnecessary and may lead to needless repetition. These are only the conditions that determine whether POPs wastes undergo destruction/irreversible transformation or other environmentally sound disposal. They are not categories of POPs waste disposal as suggested by the current configuration.



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Suggestion: Delete the two bullet points under “Other disposal in an environmentally sound manner”.

28 27 Analytical methods28 Public awareness

Comment: Sampling protocols are also essential. Public awareness should be replaced by public participation, as specified in Basel Convention Guidance and in the Stockholm Convention.

Suggestion: Modify as follows:29 Sampling protocols for wastes, treatment residues (gaseous, liquid and solid), environmental media (air, water, soil, sediments, vegetation), and potentially impacted organisms (blood, tissue, breastmilk, etc.) 30 Analytical methods appropriate for all of the above.31 Public participation

29 The discussion of destruction and ESM options should take FAO, Crop Life International, UNITAR, UNEP, Basel and ILO guidance into account as these are applicable to POPs pesticides (for example, one would not recommend a triple wash procedure for POPs containers or burial of POPs pesticides).

Comment: It seems essential also to consider the requirements of the Stockholm Convention. Further it is inappropriate to give special consideration to Crop Life International, a special interest group for industries involved in pesticide manufacture and use, xxi unless, of course, similar consideration is also given to guidance from Greenpeace and other environmental non-governmental organizations.


The discussion of destruction/irreversible transformation and other ESM options should take the Stockholm Convention, FAO, UNITAR, UNEP, Basel and ILO guidance into account as these are applicable to POPs pesticides (for example, one would not recommend a triple wash procedure for POPs containers or burial of POPs pesticides).

30 6.2.3 Dioxins and Furans

Suggestion: This section should also include a list of those processes and activities that have been identified those in which formation of dioxins and furans occurs, e.g., the Stockholm Convention, Annex C, Part II and Part III, the European Union inventories for dioxin releases to air and water and land, etc.

30 Products and articles that are known on occasion to be contaminated with dioxins and furans (and concentration information, where available) should be listed.

Comment: This listing should also include those products and articles that are suspected to be contaminated with dioxins and furans on occasion.

xxi CropLife International, http://www.gcpf.org/website/pages/Who_are_we.aspx

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Suggestion: Products and articles that are known or suspected to be contaminated with dioxins and furans (and concentration information, where available) should be listed.

30 The types of wastes known to be contaminated with dioxins and furans should be listed and toxicity discussed as information is available.

Comment: This listing should be more inclusive and, since toxicity has already been listed in the first paragraph, it is redundant here.

Suggestion: The types of wastes known or suspected to be contaminated with dioxins and furans should be listed.

35 Appendix 4: Examples of concentration action levels

Suggestion: Include in this appendix the three attached tables

Table 1: Health/Risk-Based Exit Levels Proposed in Hazardous Waste Identification Rule –64 FR 66344Table 2: Comparison of Technology-Based and Health/Risk-Based Hazardous Waste StandardsTable 3: POPs Risk Data from IRIS*

Also assign table numbers to all tables in Appendix 4 and retitle the table currently titled “Universal treatment standards” to “US EPA Universal Treatment Standards” and change the explanatory text under the title to the following:Under the US EPA Universal Treatment Standards, contaminated soils, cleanup of spills at hazardous waste facilities and so-called “characteristic wastes” must be treated to achieve low levels of the listed POPs prior to placement in landfills or other land disposal. These low levels are technology-based standards (best demonstrated available technology, BDAT).

41 Appendix 6: Technology Overview

Suggestion: These technologies should be reorganized and presented in the order suggested earlier:

32 Ball milling33 Gas-phase Chemical Reduction (Hydrogenation)34 Oxidation Processes Advanced Oxidation Processes

› Electro-Chemical Oxidation› Molten metal oxidation› Molten salt oxidation› Solar-Mediated Photo-Chemical Oxidation› SubCritical and SupraCritical Oxidation and Hydrolysis

Incineration, high temperature/residence time› Cement kiln modified for co-firing hazardous waste› Dedicated hazardous waste incinerators

35 Plasma Arc Decomposition36 Pyrolysis

- Molten metal pyrolysis- Molten salt pyrolysis



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37 Sodium dispersion 38 Solvated Electron Reduction

Summary information should be included for ball milling and sodium dispersion technologies. Also, it is apparent that a common error throughout these technology summaries is the mistaken characterization of reported destruction and removal efficiencies (DREs) as destruction efficiencies (DEs). Each such characterization should be verified and, if necessary, corrected.

41 High Temperature and High Residence Time IncinerationIncineration has been one of the most applied concentrated waste treatment technology for the disposal of a number of organic contaminants either as ”neat“ products or as semi-aqueous matrices (evaporative incineration). Incineration is a highly complex, high temperature oxygen-based destructive treatment. The waste is fed into the incinerator under controlled conditions and at specific addition point(s): high temperatures (1200 C), high retention times (2 seconds), in the presence of excess oxygen (in excess of 103 % of chemical oxygen demand) volatilize and oxidize the contaminants into innocuous substances. Though a variety of designs are available, most incinerators are fitted with rotary kilns, dual combustion chambers equipped with an afterburner, quench tower and air pollution control systems. Removal efficiencies of up to 99.9999% are reported: these figures are achieved with proper design, optimum feeds, and „flawless“ operation. In reality, due to the highly complex design and operational requirements of such units, operational performance is variable, and process upsets not uncommon.

Comment: There are several important errors and omissions in this synopsis that require correction:

Suggestion: Modify as follows:In the Stockholm Convention, waste incinerators are identified as having the potential for comparatively high formation and release of unintentionally produced POPs. Incineration has been one of the most applied waste treatment technologies, due largely to the historic role of fire in the evolution of society. In recent times, primarily since the mid-20th century, increasingly highly engineered systems have been designed and built for the disposal by combustion of many types of wastes in gaseous, liquid and solid form. Modern incinerators are highly complex, high temperature oxygen-based systems. The waste is fed into the incinerator under controlled conditions and at specific addition point(s): high temperatures (optimally 1200 C), high retention times (optimally 2 seconds), in the presence of excess oxygen (in excess of 103 % of chemical oxygen demand). Ideally, organic contaminants, such as the listed POPs, are volatilized and oxidized to form carbon dioxide, hydrogen chloride, and water. In practice, however, some fraction of the POPs will escape destruction and partitions into the post-combustion gases, pollution control residues and bottom ash or slag. In addition, incompletely combusted components undergo reactions in post-combustion areas of the incinerators, particularly the air pollution control systems, to form unintentional POPs. Though a variety of designs are available, most incinerators are fitted with rotary kilns, dual combustion chambers equipped with an afterburner, quench tower and air pollution control systems. Few determinations have been made of the destruction efficiencies (DEs) achieved by hazardous waste

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incinerators. However, one such study found that DEs ranged from 97.5 to 99.9% at the same time that destruction and removal efficiencies (DREs) as high as 99.9999% were reported. xxii (See Appendix 5 for explanations of DEs and DREs). These DEs and DREs were achieved with proper design, optimum feeds, and „flawless“ operation and they do not necessarily reflect DEs and DREs achieved during routine operations, start-ups, shutdowns, process upsets, etc. Due to the highly complex design and operational requirements of such units, operational performance is variable, and process upsets not uncommon.

41Wet-Feed Cement Kiln Co-Incineration In the wet-feed cement kiln co-incineration process, the feed material is slurried and is fed directly into the mid-section of the kiln where it is exposed to initial temperatures close to 1100 C and increasing to 1400 c -1500 C as the volatilized compounds travel further down the kiln. Significantly higher retention times (> 3 x) than those observed in high temperature/residence time incinerators characterize cement kilns. Theoretically, highly alkaline conditions in a cement kiln are ideal for decomposing chlorinated organics down to chlorides and other mineral compounds/salts: the limestone used to make cement provide a natural scrubbing action inside the kiln that can effectively capture chlorine. However, overall destruction efficiencies for conventional designs tend to be orders of magnitude lower than that achieved in properly engineered and operated high temperature and retention time incinerators: this is likely attributed to the single-chamber design of cement kilns. In contrast, all modern incinerators are dual-chambered to achieve higher destruction efficiencies. New design of cement kilns appears to address this issue. No solid residues requiring other means of consideration are generated by wet-feed cement kilns since all residues are tightly bound within the product: this is in contrast to incinerators, and is an attribute in favour of cement kilns. Similarly to high temperature/residence time incinerators, the operation of a cement kiln is highly complex. Operational parameters are numerous, and fluctuations in destruction performances -either relying on coal, coke, petroleum hydrocarbons/oils, and percent level blends of chlorinated organics wastes as „fuel“ - will always an operational reality. Consequently, destruction efficiencies as high as 99.999% can be achieved, under „optimum“ conditions.

Comment: There are several important errors and omissions in this synopsis and there are several controversial statements that require substantiation, such as the contention that “[n]o solid residues requiring other means of consideration are generated by wet-feed cement kilns since all residues are tightly bound within the product.” Further, products that contain unintentional POPs such as cement containing cement kiln dust that commonly contains unintentionally produced POPs, is a concern of the Stockholm Convention.

Suggestion: Wet-Feed Cement Kiln Co-Incineration The Stockholm Convention identifies cement kilns that co-fire hazardous waste as having the potential for comparatively high formation and release of unintentionally produced POPs. With regard to the co-fired wastes, the UN-ECE Working Group on Strategies and Review Task Force notes that the concentration of “chlorides and chlorinated compounds (as a precursor for PCDD/F formation)’ are “major parameters that may influence residue characteristics and process technology.”xxiii Unintentionally produced POPs have been found or can be expected to occur in all of the process outputs of cement kilns, including the clinker. For example, Denmark has reported dioxin levels of 5.1 to 17.8 ng I-TEQ/kg in clinker.xxiv According to the US EPA, the



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stack gases and cement kiln dust from cement kilns that co-fire hazardous waste contain markedly higher levels of unintentional POPs than cement kilns that do not burn hazardous waste.xxv In the wet-feed cement kiln co-incineration process, the feed material is fed into the mid-section of the kiln where it is exposed to initial temperatures close to 1100 C and increasing to 1400 c -1500 C as the volatilized compounds travel further down the kiln. Significantly higher retention times (> 3 x) than those observed in high temperature/residence time incinerators characterize cement kilns. Theoretically, highly alkaline conditions in a cement kiln are ideal for decomposing chlorinated organics down to chlorides and other mineral compounds/salts: the limestone used to make cement provide a natural scrubbing action inside the kiln that can effectively capture chlorine. However, overall destruction efficiencies for conventional designs tend to be orders of magnitude lower than that achieved in properly engineered and operated high temperature and retention time incinerators: this is likely attributed to the single-chamber design of cement kilns. In contrast, all modern incinerators are dual-chambered to achieve higher destruction efficiencies. New design of cement kilns appear to address this issue. Releases of unintentionally produced POPs in stack gases of cement kilns with state-of-the-art air pollution control are reportedly well below the European standard of 0.1 ng TEQ/m3. However, cement kilns commonly have an alkali bypass exhaust gas and it is not clear that either the air pollution control systems or unintentional POPs concentrations in these stack gases are the same as those of the main exhaust stack. Concentrations of unintentional POPs may be quite high in cement kiln dust. In the U.S., some 64% of CKD is recycled back into the kiln and the remainder, which is generated at the rate of about 40 kg/ton of clinker, xxvi is primarily buried in landfills.xxvii Holcim, one of the world’s largest cement producers, sold or landfilled 29 kg CKD per tonne clinker in 2001.xxviii In Europe, CKD is commonly added directly to the product cement.xxix Recycling CKD directly to the kiln generally results in a gradual increase in alkali content of generated dust that may damage cement kiln linings, produce inferior cement, and increase particle emissions.xxx Similarly to high temperature/residence time incinerators, the operation of a cement kiln is highly complex. Operational parameters are numerous, and fluctuations in destruction performances -either relying on coal, coke, petroleum hydrocarbons/oils, and percent level blends of chlorinated organics wastes as „fuel“ - will always an operational reality. Destruction and removal efficiencies as high as 99.999% have been reported, under „optimum“ conditions. However, little information is available on the destruction efficiencies of cement kilns that co-fire hazardous waste.

44 Ecologic Chemical Reduction ProcessThe ECO LOGIC Process involves the gas-phase hydrogen-mediated chemical reduction of chlorinated organics at temperatures of 850 °C or greater.

Comment: This process is actually called and is most commonly referred to as Gas Phase Chemical Reduction.

xxii Costner, P.1998. Correlation of chlorine input and PCDD/PCDF emissions at a full-scale hazardous waste incinerator. Organohalogen Cpds. 36: 147 - 152

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Gas Phase Chemical ReductionGas phase chemical reduction (GPCR) involves the gas-phase hydrogen-mediated chemical reduction of chlorinated organics at temperatures of 850 °C or greater.

xxiii UN-ECE, 2001. Executive Summary of the Status Report on the Management of By-Products/Residues Containing Heavy Metals and/or Persistent Organic Pollutants. EB/AIR/WG.5/2001/9. Convention on Long-Range Transboundary Air Pollution, Working Group on Strategies and Review Task Force, Geneva, 24-27 September 2001.xxiv Hansen, E., 2000. Substance Flow Analysis for dioxins in Denmark. Environmental project No. 570. Copenhagen, Denmark: Danish Environmental Protection Agency.xxv USEPA, 1994. Estimating Exposure to Dioxin-Like Compounds. Office of Research and Development. EPA/600/6-88/005Ca,b,c. Washington, D.C.xxvi WISE, 2002. Waste Generation: Indicator: Volume of Cement Kiln Dust Produced and Reused. http://www.pepps.fsu.edu/WISE/xxvii U.S. Environmental Protection Agency, Draft Exposure and Human Health Reassessment of 2,3,7,8-Tetrachlorodibenzo-p-Dioxin (TCDD) and Related Compounds, Part I: Estimating Exposure to Dioxin-Like Compounds, Chapter 5: Combustion Sources of CDD/CDF: Other High Temperature Sources, EPA/600/P-00/001Bb, Washington, D.C., September 2000xxviii Holcim, Environmental Performance, p. 17. www.holcim.comxxix Lohse, J., Wulf-Schnabel, J., 1996. Expertise on the Environmental Risks Associated with the Co-Incineration of Wastes in the Cement Kiln "Four E" of CBR Usine de Lixhe, Belgium. Hamburg, Germany: Okopol. http://www.oekopol.de/Archiv/Anlagen/CBRBelgien.htmxxx U.S. Environmental Protection Agency, 1998. Technical Background Document on Ground Water Controls at CKD Landfills. Draft. Washington, D.C.: Office of Solid Waste, U.S. Environmental Protection Agency.

http://www.oekopol.de/Archiv/Anlagen/CBRBelgien.htm

http://www.epa.gov/ncea/pdfs/dioxin/part1/volume2/chap5.pdf

http://www.epa.gov/ncea/pdfs/dioxin/part1/volume2/chap5.pdf

http://www.pepps.fsu.edu/WISE/



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Table 1: Health/Risk-Based Exit Levels Proposed in Hazardous Waste Identification Rule –64 FR 66344

POP Exit Levels from MCLs* Exit Levels from Toxicity Benchmarks*Waste water

mg/L**Nonwastewater mg/kg Waste water

mg/L**Nonwastewater mg/kg

Totalsmg/kg**

Leachmg/L**

Totalsmg/kg**

Leachmg/L**

Aldrin 0.000034† 0.0006† 0.000034† 0.000034† 0.0006† 0.000034†

Chlordane 0.00004† 0.098 0.036 0.00004† 0.098 0.00016

DDT 0.000081† 0.0032 0.0054 0.000081† 0.0032 0.0054

Dieldrin 0.000059 0.0018 0.54 0.000059 0.0018 0.54

Dioxins & Furans

1.000x10-8† 8.000x10-9 5.400x10-7 1.000x10-8† 8.000x10-6 1.000x10-8†

Endrin 0.073 0.26 24 0.073 0.26 32

Heptachlor 0.00004† 8 0.00004† 8

Hexachloro-benzene

0.0016† 0.072† 0.018 0.0016† 0.072† 0.0016†

Mirex/Kepone#

0.016† 0.097† 0.016† 0.016† 0.097† 0.016†

PCBs 0.0005† 0.04† 0.009 0.0005† 0.04† 0.0005†

Toxaphene 0.0013† 0.03† 6 0.0013† 0.03† 0.11

*Columns 1, 2, and 3 represent the exit levels that were derived by using an MCL benchmark for drinking water ingestion & using toxicity benchmarks for all other routes of exposure. Columns 4, 5 and 6 represent the exit levels that were derived by using toxicity benchmarks for all routes of exposure.**In order to qualify for exit from hazardous waste status, total constituent concentrations in both wastewaters and nonwastewaters must be at or below the exemption levels given in this table. In addition, all leachable constituents must be below the levels given in the “Leach” column. †EQC = Exemption Quantitation Critiera: lowest limit that can be reliably measured within acceptable limits of precision and accuracy during routine laboratory operating conditions using appropriate methods. 60 FR 66344, 66377, Dec. 21, 1995. # Mirex is a pesticide that was used in the United States to control fire ants. Its use has been banned since 1978. The EPA has identified Mirex as a hazardous waste but has not set any limits for its treatment and disposal or for its allowability in drinking water. Kepone is a decomposition product of Mirex. Agency for Toxic Substances and Disease Registry. EPA has set treatment standards for hazardous wastes containing kepone, and these are the values in the table. Agency for Toxic Substances and Disease Registry.

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Table 2: Comparison of Technology-Based and Health/Risk-Based Hazardous Waste Standards

POP Health-Based Residue Concentration Limits (currently stayed), mg/kg

Health/Risk Based Proposed Exit Levels(proposed rule)

Technology-Based Standards (in effect): Treatment Stds for Hazardous wastes 40 CFR 268.40 and Universal Treatment Standards40 CFR 268.48

Waste Non-water waste-mg/L water

mg/kg

Waste water mg/L

Nonwastewater

Totals Leach**mg/kg mg/L

Aldrin 0.00002 0.000034* 0.0006* 0.000034* 0.021 0.066Chlordane 0.0003 0.00004* 0.098 0.036/

0.000160.0033 0.26

DDT 0.001 0.000081* 0.0032 0.0054 0.0039 0.087Dieldrin 0.00002 0.000059 0.0018 0.54 0.017 0.13Dioxins & Furans

6 x 10-8 1.000x10-8* 8.000x10-9

5.400x10-7/ 1.000x10-8

0.000063 0.001

Endrin 0.0002 0.073 0.26 24/32 0.0028 0.13Heptachlor 0.00008 0.00004* 8 0.0012 0.066Hexachloro-benzene

0.0002 0.0016* 0.072* 0.018/0.0016*

0.055 10

Mirex/Kepone#

N/A 0.016* 0.097* 0.016* 0.0011 0.13

PCBs 0.00005 0.0005* 0.04* 0.009/0.0005*

0.10 10

Toxaphene 0.005 0.0013* 0.03* 6/0.11 0.0095 2.6

*EQC = lowest limit that can be reliably measured within acceptable limits of precision and accuracy during routine laboratory operating conditions using appropriate methods. 60 FR 66377, Dec. 21, 1995. **When two numbers are given separated by a “/”, the first number was derived using an MCL benchmark for drinking water ingestion and toxicity benchmarks for all other routes of exposure, and the second number was derived using toxicity benchmarks for all routes of exposure.# Mirex is a pesticide that was used in the United States to control fire ants. Its use has been banned since 1978. The EPA has identified Mirex as a hazardous waste but has not set any limits for its treatment and disposal or for its allowability in drinking water. Kepone is a decomposition product of Mirex. Agency for Toxic Substances and Disease Registry. EPA has set treatment standards for hazardous wastes containing kepone, and these are the values in the table. Agency for Toxic Substances and Disease Registry.

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Table 3: POPs Risk Data from IRIS*

POP Cancer risks Non-cancer risks

Oral Slope factor = unit cancer risk1

per mg/kg-day

Drinking water unit risk2

per mg/L

Drinking water concentration at 10-6 riskmg/L

Air Unit Risk

per mg/m3

Air concentration at 10-6 riskmg/m3

Oral RfD3

mg/kg-day

Inhalation RfC4

mg/m3

Aldrin 1.7 x 10 4.9 x 10-1 2 x 10-6 4.9 2 x 10-7 3 x 10-5 no data

Chlordane

3.5 x 10-1 1x 10-2 1 x 10-4 1 x 10-1 1.0 x 10-5

5 x 10-4 7 x 10-4

DDT5 3.4 x 10-1 9.7 x 10-3 1 x 10-4 9.7 x 10-2

1 x 10-5 5 x 10-4 no data

Dieldrin 1.6 x 10 4.6 x 10-1 2 x 10-6 4.6 2 x 10-7 5 x 10-5 no data

Dioxin6 6.2 x 10+3 1.8 x 10+2 6 x 10-9 1.3 x 10+3

8 x 10-10

no data no data

Endrin inconclusive7

inconclusive inconclusive

inconclusive

inconclusive

3 x 10-4 no data

Heptachlor

4.5 1.3 x 10-1 8 x 10-6 1.3 8 x 10-7 5 x 10-4 no data

Hexachloro-benzene

1.6 4.6 x 10-2 2 x 10-5 4.6 x 10-1

2 x 10-6 8 x 10-4 inadequate data

Mirex/Kepone no data no data no data no data no data 2 x 10-4 no data

PCBs8 4 x 10-2 1 x 10-2 1 x 10-4 1 x 10-1 1 x 10-5 inadequate data

no data

Toxaphene

1.1 3.2 x 10-2 3 x 10-5 3.2 x 10-1

3 x 10-6 no data no data

*IRIS = Integrated Risk Information System – database maintained by EPA. website: http://www.epa.gov/iris/

The EPA table in Appendex A of Hazardous Characteristic H11 – Toxic (Delayed or Chronic) UNEP/CHW/OEWG/1/INF/8 uses the term “unit cancer risk” for the parameter that is labeled “oral slope factor” in the IRIS database. This was determined by comparing the unit cancer risk stated in the table for benzene (5.5 x 10-2 per mg/kg/d) with the oral slope factor for benzene given in IRIS (5.5 x 10-2 per mg/kg/d).

1Slope Factor: An upper bound, approximating a 95% confidence limit, on the increased cancer risk from a lifetime exposure to an agent. This estimate, usually expressed in units of proportion (of a population) affected per mg/kg/day, is generally reserved for use in the low-dose region of the dose-response relationship, that is, for exposures corresponding to risks less than 1 in 100. IRIS Glossary of terms.2 Unit Risk: The upper-bound excess lifetime cancer risk estimated to result from continuous exposure to an agent at a concentration of 1 µg/L in water, or 1 µg/m3 in air. The interpretation of unit risk would be as follows: if unit risk = 1.5 x 10-6 µg/L, 1.5 excess tumors are expected to develop per 1,000,000 people if exposed daily for a lifetime to 1 µg of the chemical in 1 liter of drinking water. IRIS Glossary of terms.3 Reference Dose (RfD): An estimate (with uncertainty spanning perhaps an order of magnitude) of a daily oral exposure to the human population (including sensitive subgroups) that is likely to be

http://www.epa.gov/iris/



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without an appreciable risk of deleterious effects during a lifetime. It can be derived from a NOAEL, LOAEL, or benchmark dose, with uncertainty factors generally applied to reflect limitations of the data used. Generally used in EPA's noncancer health assessments. IRIS Glossary of terms.4 Reference Concentration (RfC): An estimate (with uncertainty spanning perhaps an order of magnitude) of a continuous inhalation exposure to the human population (including sensitive subgroups) that is likely to be without an appreciable risk of deleterious effects during a lifetime. It can be derived from a NOAEL, LOAEL, or benchmark concentration, with uncertainty factors generally applied to reflect limitations of the data used. Generally used in EPA's noncancer health assessments. IRIS Glossary of terms.5 DDT = p,p’-dichlorodiphenyltrichloroethane6 dioxin = hexachlorodibenzo-p-dioxin mixture7 Endrin: “oral administration of endrin did not produce carcinogenic effects in either sex of two strains of rats and three strains of mice.” Other studies have been less conclusive, so EPA has classed endrin as Group D: not classifiable as to human carcinogenicity – IRIS website8 PCBs: IRIS gives two values for the oral slope factor: 4 x 10-2 per mg/kg-day = lowest risk and persistence; central-estimate slope factor; and 2.0 per mg/kg-day = high risk and persistence; upper bound slope factor.

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If POPs waste has a POPs content that is at or below established “low POPs content” waste

Other environmentally sound disposal methods

Destruction orirreversible

transformationprocesses

If destruction/irreversible transformation is not environmentally preferable

Waste with no detectable POPs

orWaste with “lw” POPs

content or

Waste with POPs

POPs waste

If POPs waste has a POPs content that is at or below established “low POPs content” waste

Other environmentally sound disposal methods

Destruction orirreversible transformation

processes

If destruction/irreversible transformation is not environmentally preferable



orWaste with “low”

POPs content or

Waste with POPs content less than established “low”

POPs content

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