German comments, 31 January 2003
German comments
on the
Draft Technical Guidelines for Environmentally Sound Management of
Persistent Organic Pollutant Wastes
of October 2002 prepared by SENES Consultants
General Comment on disposal technologies
In the Executive Summery (page E-3) and in Chapter 4 (page 4-5 and chapters 4.5.1 and
4.5.3) the technologies landfilling and deep well injection are mentioned and described.
Both methods are seen as incompatible with "environmentally sound management". Therefore
"deep well injection" and "engineered landfill" should be excluded as disposal methods for
waste containing persistent organic pollutants and therefore the chapters 4.5.1 and 4.5.3
should be deleted from the guideline.
Engineered landfills are methods of temporary containment rather than a permanent solution
to the problem of POP wastes. It is doubted that permanent isolation from the biosphere can
be guaranteed by these facilities. The requirements of the Stockholm Convention are not met
by this kind of methods.
It is noted that according to Article 2 of the European Directive (96/59/EC) on the disposal of
polychlorinated biphenyls and polychlorinated terphenyls (PCB/PCT), "disposal" means only
the operations D8 "Biological treatment", D9 "Physico-chemical treatment", D10
"Incineration on land", D12 "Permanent storage (e.g. emplacement of containers in a mine,
etc1.)" and D15 "Storage pending any of the operations in this Annex, excluding temporary
storage, pending collection, on the site where it is produced" provided for in Annex II of the
EC Waste Framework Directive.
The German comments of 23 September 2002 are recalled, namely on the structure of Chapter
4.0. Based of these comments, the title of chapter 4.5 should be amended to read like
“Technologies for otherwise disposal in an environmentally sound manner”
and the title of chapter 4.7 should be amended to read like
“Technologies for the remediation of contaminated sites”.
Under Chapter 4.6 “Pre-treatment technologies”, also a chapter on “Storage pending any of
the other operations in these guidelines” should be included.
Specific Comments
Chapter 1.3.3.1 "Dioxins and Furans"
In the last sentence of para 2 it is correctly stated: "PCBs are the most significant potential
source of furans, a fact that underlies the concern about accidental burning of PCBs."
But it is missing that PCBs due to the production process contain considerable amounts of
furans, therefore the sentence should be amended as follows:
“PCBs are the most significant potential source of furans. Technical PCB mixtures are due to
their production processes severely contaminated by polychlorinated dibenzofurans (as well
as by polychlorinated naphthalenes).”
1
which means only in safe, deep, underground storage in dry rock formations and only for equipment
containing PCBs and used PCBs which cannot be decontaminated
...
German comments, 31 January 2003
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Table 3.1, POTENTIAL PCB WASTE CATEGORIES FOR NATIONAL
INVENTORY, page 3-7
In Table 3.1, column 1 concerning the Construction and demolition waste the text in brackets
should be corrected as follows:
(including European Waste List Groups: 17 04, 17 05 and 17 09)
A complete list of wastes which may contain PCBs is contained in Annex 1 below.
Chapter 3.3.3 "Disposal of Pesticide Containers"
The handling instructions described in this chapter are not clear and not practical at all. People
would have high health risk and the environment could be contaminated by pesticides.
Therefore the whole chapter should be redrafted according to the recommendations made by
pesticide industry. For further information, see www.croplife.org.
Chapter 4.4.3 "Electrochemical Oxidation"
The use of this technology for the destruction of chlorine containing POPs is questioned,
because when chloride ions or organic chlorides are present, Ag(I) precipitates as AgCl which
results in a stop of the electrochemical process2.
Chapters 4.4.4 "Molten Materials Processes" and 4.4.6 “Plasma Arc Systems"
In both processes the possible formation of PAHs has to be taken into account, therefore the
respective process parameters such as an introduction of oxygen or water steam are of
importance.
Chapter 4.5.2 "Long-Term-Storage"
The definition of "long term storage" is not clear and can cause decisions which lead to
environmental problems. It should be clearly described which wastes can be stored under
which conditions.
Chapter 4.5.4 "In-situ Vitrification"
Concerning the organic pollutants, the "In-situ Vitrification-Process" is a destruction method
and not a "sequestration" and should therefore be shifted to the chapter "Technologies for
destruction and/or irreversible transformation of POPs wastes".
The high temperatures used in the "In-situ Vitrification-Process" result in the formation of
pyrolysis-products like Polycyclic Aromatic Hydrocarbons (PAHs) and therefore the same
methods of flue gas purification used in pyrolysis or waste incineration have to be used.
Depending on how the process is conducted, the organic substances are destroyed or, due to
the temperature gradient around the electrodes, only evaporated and redistributed.
2
GRAHAM S. PEARSON und RICHARD S. MAGEE: "IUPAC Technical Report CRITICAL EVALUATION OF
PROVEN CHEMICAL WEAPON DESTRUCTION TECHNOLOGIES" Pure Appl. Chem., Vol. 74, No. 2, pp. 187–
316, 2002
...
German comments, 31 January 2003
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Chapter 4.6.3
The heading of this chapter cites a reference [71] which indeed is correct because this chapter
was included based on a German comment. For practical reasons the cited reference should be
replaced by the follwing:
a) Neupert, Dirk: "Clean-up time! PCB-filled transformers - environmental threat and
commercial opportunity", ABB Review, issue 2/2002 Zurich, Switzerland, 2002
b) Reinwald, Eckhard et al.: "Test of a step by step process for recovery of metals from
PCB-cooled capacitors and transformers", Research and Development Project for the
German Federal Environmental Agency, reference number 1460517, Berlin/Germany,
October 1997
In the last para. of this chapter the first sentence should be amended as follows:
“The entire cleaning process is handled in a closed-circuit system, avoiding hazardous
emissions.”
Chapter 4.7.1 “Bioremediation”
This chapter enumerates all potential methods of bioremediation. This may be misinterpreted
by the readers. Therefore only successfully used methods should be mentioned in this chapter.
Chapter “Technologies Under Development” p. 4-25
This Chapter should get a separate Chapter No. such as 4.7bis, if it is meant to cover
technologies under development related to chapters 4.4-4.7.
Under this heading, technologies which have achieved a certain state but cannot yet be used in
large scale processes should be mentioned, e. g.:
Sodium-process
In contrast to the Solvated-Electron-Process in which the sodium is dissolved in liquid
ammonia, the sodium-process3 uses molten sodium dispersed in hot oil (150° C) for the
dechlorination. In a pilot project this process has been applied successfully to the treatment
of polychlorinated dioxins containing effluents from a landfill site in Hamburg/Germany.
Tribochemical Methods
Tribochemical methods use mechanically activated chemical processes. Polyhalogenated
compounds like PCBs can be reductively dehalogenated by a base metal such as Mg, Al,
Fe, Na and a hydrogen donor at room temperature, ambient pressure and in a short time in
one single operational key step using a ball mill (rotating mill, vibratory mill, vibrating
mill) as a mechano-chemical dehalogenation reactor. No harmful emissions to the
environment have to be expected.
3
Survey of Currently Available Non-Incineration PCB Destruction Technologies, First Issue, August 2000, UNEP
Chemicals
...
German comments, 31 January 2003
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Annex 1
Table:
08
08 01
08 01 17*
12
12 01
12 01 16*
13
Chapters, groups and waste codes of European Waste List for wastes
potentially containing PCBs
WASTES FROM THE MANUFACTURE, FORMULATION, SUPPLY AND USE (MFSU)
OF COATINGS (PAINTS, VARNISHES AND VITREOUS ENAMELS), ADHESIVES,
SEALANTS AND PRINTING INKS
wastes from MFSU and removal of paint and varnish
wastes from paint or varnish removal containing organic solvents or other dangerous substances
WASTES FROM SHAPING AND PHYSICAL AND MECHANICAL SURFACE
TREATMENT OF METALS AND PLASTICS
wastes from shaping and physical and mechanical surface treatment of metals and plastics
waste blasting material containing dangerous substances
13 01
13 01 01*
OIL WASTES AND WASTES OF LIQUID FUELS (EXCEPT EDIBLE OILS, AND
THOSE IN CHAPTERS 05, 12 and 19)
waste hydraulic oils
hydraulic oils, containing PCBs
13 03
13 03 01*
waste insulating and heat transmission oils
insulating or heat transmission oils containing PCBs
16
16 01
16 01 09*
WASTES NOT OTHERWISE SPECIFIED IN THE LIST
end-of-life vehicles from different means of transport (including off-road machinery) and
wastes from dismantling of end-of-life vehicles and vehicle maintenance (except 13, 14, 16 06
and 16 08)
components containing PCBs
16 02
16 02 09*
16 02 10*
wastes from electrical and electronic equipment
transformers and capacitors containing PCBs
discarded equipment containing or contaminated by PCBs other than those mentioned in 16 02 09
17
17 04
17 04 10*
CONSTRUCTION AND DEMOLITION WASTES (INCLUDING EXCAVATED SOIL
FROM CONTAMINATED SITES)
metals (including their alloys)
cables containing oil, coal tar and other dangerous substances
17 05
17 05 03*
soil (including excavated soil from contaminated sites), stones and dredging spoil
soil and stones containing dangerous substances
17 09
17 09 02*
other construction and demolition wastes
construction and demolition wastes containing PCB (for example PCB-containing sealants, PCBcontaining resin-based floorings, PCB-containing sealed glazing units, PCB-containing capacitors)