Explanatory Note

ANZECC's directions
The National Strategy for the Management of Scheduled Waste, endorsed in 1993 by the Australian and New Zealand Environment and Conservation Council, requires that scheduled waste management plans (including the one for HCB waste):

The process to develop this HCB waste management plan started on 13 August 1994 with a public call for submissions, advertised nationally and in local Sydney newspapers. This was then followed with two rounds of "face to face" public consultation. Comprehensive reports on these consultations have been prepared and are available from the Waste Management Secretariat.

In preparing the HCB waste management plan, objectives (b) and (d) have been met with the exception of the requirement for notifiable quantity provisions which are not needed for this type of scheduled waste. Regarding objective (c), dates have been set for the disposal of HCB waste although the parts of this objective relating to cessation of the generation of HCB waste and use of articles containing HCB waste are not relevant as ICI Australia Operations Pty Ltd closed down the manufacturing process that generated HCB waste in 1991.

The role of risk assessment in preparing this plan
Risk assessment methods for chemicals can be applied to situations where human beings or the environment are exposed to those chemicals. The risk can be estimated from a combination of the inherent hazard of the chemical (the toxicity) and the likelihood of exposure to that chemical.

It is difficult to apply this approach to industrial chemicals in containers or equipment, such as is the case for HCB waste. The lack of exposure data relating to the intentional release of HCB waste in the environment makes it particularly difficult to estimate risk to the non-human environment. Thus, the National Advisory Body and the Scheduled Wastes Management Group did not find it possible to apply a formal risk assessment method to ICI's HCB waste because of the numerous possible scenarios involving HCB waste and the limited information on the synergistic effects of the components of HCB waste or on how to use this information in setting management provisions.

As was the case for the PCB management plan, the National Advisory Body and the Scheduled Wastes Management Group have adopted a relative risk management approach and the stored HCB waste is to be destroyed as soon as possible (within 10 years). For the Car Park Waste, a detailed risk assessment is to be prepared and, in the mean time, ICI Australia Operations Pty Ltd will look at applying in situmethods to remediate those wastes.

Implementing the plan
This management plan has been submitted to ANZECC for endorsement and following this it will be considered for implementation by the NSW Government. The plan will be given effect through NSW and, where applicable, other Commonwealth, State and Territory policy and statutory instruments. As such, the hexachlorobenzene waste management plan represents guidance to governments.

The future- EIS on any technology selected
After ICI Australia Operations Pty Ltd has selected the technology to be used, an environment impact assessment will be undertaken. NSW planning legislation requires that the public be given the opportunity to comment on this assessment and any proposal to build a plant at the Botany site.

Review process
The plan will be subject to periodic review. After selection of the technology, this management plan will be reviewed for suitability. Then, after an appropriate time, and not later than five years, the management plan will be reviewed in the light of experience gained. Any new information or risk assessment methods which may have an impact on the management provisions in the plan, particularly information on human health effects and environmental toxicology of HCB, will be examined as part of these reviews.

Role of the community
The proposed Community Participation and Review Committee is expected to play an important role in both reviews of the management plan and in making a contribution to the public review of any environment impact assessment.

Professor Ian Rae
Chair, National Advisory Body and Scheduled Wastes Management Group

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1. Definitions

In this management plan:

1.1 "ADG Code" means the Australian Code for the Transport of Dangerous Goods by Road and Rail, published by the Commonwealth Government (as amended from time to time);

1.2 "ANZECC" means the Australian and New Zealand Environment and Conservation Council;

1.3 "approved" means approved by EPANSW or other relevant agency;

1.4 "car park waste" means the approximately 45 000 cubic metres of a mixture of sand and coal ash containing 0.18% of HCB and other chlorinated materials, interred under a paved area on the premises;

1.5 "Community Participation and Review Committee" means a committee of representative stakeholders;

1.6 "congeners" means a group of chemicals which have the same basic structure;

1.7 "destruction" means processed to a point where there are no longer any special treatment or disposal requirements;

1.8 "dioxins" means those congeners listed in Appendix B and, for the purposes of this plan, includes furans;

1.9 "dioxin equivalent concentration" means the concentration of a congener multiplied by its dioxin equivalency factor (Appendix B provides details);

1.10 "EPANSW" means the Environment Protection Authority, New South Wales;

1.11 "HCB" means hexachlorobenzene and has the chemical formula C6Cl6;

1.12 "HCBD" means hexachlorobutadiene and has a chemical formula C4Cl6;

1.13 "ICI" means ICI Australia Operations Pty Ltd, 16- 20 Beauchamp Road, Matraville NSW 2019 and includes any subsequent entity arising from reorganisation or sale of the company;

1.14 "licence" means a licence issued by EPANSW or other relevant agency;

1.15 "management plan" means a plan approved by ANZECC for the management and disposal of specific categories or a combination of categories of scheduled wastes;

1.16 "NATA" means the National Association of Testing Authorities;

1.17 "National Strategy" means the Draft National Strategy for the Management of Scheduled Waste (Nov. 1992), supplemented and amended by the Scheduled Wastes Working Group Report to the Australian and New Zealand Environment and Conservation Council (Version B, May 1993);

1.18 "NHMRC" means the National Health and Medical Research Council;

1.19 "other chlorinated compounds" includes compounds such as hexachloroethane (C2Cl6), octachlorostyrene (C8Cl8), perchlorethylene (C2Cl4);

1.20 "premises" means the land occupied by ICI or any entity controlling the premises known as 16 - 20 Beauchamp Road, Matraville NSW 2019; and

1.21 "scheduled HCB waste" means all waste materials in Appendix A or any liquid, sludge or solid (including waste articles and containers) containing fifty milligrams per kilogram or more of HCB occurring in or on the premises or having migrated from the premises.

2. Scope of this Management Plan

2.1 This plan shall be known as the HCB Waste Management Plan and is approved by ANZECC for the management of scheduled HCB waste in accordance with the National Strategy.

2.2 This plan is only for scheduled HCB waste occurring in or on the premises or having migrated from the premises.

2.3 This plan does not cover HCB from any other source, such as agricultural use of chemicals. This will be subject to the organochlorine pesticides management plan.

2.4 Provisions of this management plan set out deadlines for completion of particular actions.

2.5 This management plan will be given effect through New South Wales legislation.

2.6 This plan does not cover HCB investigated in the ICI Botany Groundwater Stage II Survey August 1996¹. The report was a separate study carried out by ICI under EPANSW supervision. Stage III of this work is the implementation of the remediation. Contaminated groundwater is covered by separate legislation.

2.7 If scheduled HCB waste other than that detailed in Appendix A is found or generated as the result of any clean up process, it will be covered by the provisions of this plan.

3. HCB Analyses

3.1 Analyses shall be carried out by laboratories which are accredited and registered by NATA or approved equivalents in Australia or similar approval bodies in other countries. Laboratories carrying out HCB analyses shall incorporate quality assurance and quality control programs in accordance with the requirements of NATA or approved equivalents in Australia, or similar approval bodies in other countries.

3.2 Where analyses are required for regulatory purposes, the quality assurance program shall incorporate periodic check analyses by an independent laboratory.

3.3 Analytical methods which meet the requirements of NATA or of approved equivalents in Australia or similar approval bodies in other countries shall be used for HCB analyses.

3.4 Analytical data on HCB which have been obtained by nonNATA registered laboratories may be used for indicative purposes, including during the trialing of technologies. Such data shall be identified.

3.5 Sampling methods approved by NATA or approved equivalents in Australia or similar approval bodies in other countries shall be used.

3.6 Analyses for dioxins and furans shall report the results as the sum of the dioxin equivalent concentrations of the congeners in Appendix B.

4. Storage, Handling and Transport

4.1 Scheduled HCB waste shall be kept under the authority of, and in accordance with, the conditions of a licence issued by EPANSW which incorporates the following requirements:

4.2 Scheduled HCB waste shall be handled in accordance with the requirements of EPANSW and WorkCover NSW.

4.3 Scheduled HCB waste shall be stored in accordance with the requirements of applicable dangerous goods legislation and other relevant legislation, which in the case of liquid waste, includes the Australian Standard AS1940 Storage and Handling of Flammable and Combustible Liquids.

4.4 Scheduled HCB waste shall be stored and transported in containers that are clearly labelled to describe the type of waste matrix and the HCB concentration. If scheduled HCB waste is to be transported off site this shall be done in accordance with the National Guidelines for the Management of Wastes (National Manifest and Classification System) - July 1994 and other relevant regulatory requirements.

5. Emergency Procedures

5.1 ICI shall, in consultation with EPANSW and emergency services, develop and maintain emergency fire procedures for storage and destruction of scheduled HCB waste. A training, testing and review program shall be implemented for these procedures.

5.2 ICI shall develop emergency containment and clean up procedures for the accidental release of scheduled HCB waste into the environment.

5.3 Clean up of all releases of scheduled HCB waste shall be done in accordance with the relevant environment protection authority and other statutory requirements.

5.4 Requirements detailed in Sections 5.1 and 5.2 shall be developed in consultation with the community (see Section 10).

6. Destruction and Disposal of Scheduled HCB Waste

6.1 Scheduled HCB waste, with the exception of the car park waste which is dealt with in Section 7, shall be destroyed by a target date of 2006 (See Section 8).

6.2 ICI shall submit an implementation plan for the destruction of scheduled HCB waste within six months of being formally requested to do so by EPANSW, following the acceptance of the plan by ANZECC.

6.3 Given the perceived hazards of transporting scheduled HCB waste, it is considered preferable for destruction of the waste to take place at the premises. This will be reviewed following selection of the destruction technology. The final decision on the destruction site shall be subject to further community consultation.

6.4 Where scheduled HCB waste is destroyed, this shall be done in a facility(ies) approved and licensed by the relevant environment protection authority in accordance with the National Protocol for the Approval/Licensing of CommercialE­Scale Facilities for the Treatment of Schedule X Wastes (July 1994).

6.5 Where proposals arise to export the waste (or part of the waste) for disposal overseas they will be dealt with under the amendments to the Hazardous Waste (Regulation of Exports & Imports) Act 1989⁵.

6.6 The licence (see Section 6.4) for the destruction facility shall include, but not necessarily be limited to, discharge standards for the following constituents, where they are present:

6.7 The following levels set in the licence (see Section 6.4) shall not be less stringent than those specified below:

6.8 The relevant environment protection authority shall set limits for discharge of dioxins in liquids and solids from the destruction facility.

6.9 No dilution of HCB waste shall be allowed in order to meet the specified effluent or residue levels.

6.10 Monitoring shall be frequent in the early stages of destruction of HCB waste but this may be adjusted once confidence is gained that the operation is effective. Samples shall be analysed for dioxins (see Section 6.6) at least every three months during the first year of destruction and, depending on the results, the frequency may be adjusted. Monitoring shall be reported to the relevant environment protection authority and the Community Participation and Review Committee.

6.11 Any destruction facility constructed on the premises under this plan shall be decommissioned and removed from the premises after the scheduled HCB waste is destroyed.

6.12 A destruction facility on the premises shall not be used to destroy any waste that has not originated from the premises.

7. Car Park Waste

7.1 The car park waste shall be remediated as soon as possible and preferably in situ, provided that it does not preclude future destruction options, it is environmentally acceptable and it is cost effective. To this end, ICI shall examine the application of in situ remediation methods at the same time as it prepares a risk assessment of the car park waste.

7.2 ICI shall complete the following work in relation to the car park waste within two years of the plan being adopted by ANZECC, or sooner if that is possible:

7.3 ICI shall regularly report on progress and results of the work to be carried out under Section 7.1 to EPA NSW and the Community Participation and Review Committee at a frequency that is agreed by those bodies.

7.4 Within six months of the risk assessment being finalised, ICI shall prepare an action plan to manage the car park wastes that must be acceptable to EPANSW. This shall be done in consultation with the Community Participation and Review Committee. This action plan shall be based on the findings of the risk assessment and will take into account findings from the exploration of potential enhancements of the natural bioremediation process obtained under S 7.1.3.

8. Time Lines for the Management, Destruction and Disposal of Scheduled HCB Waste

*Given the perceived hazards of transporting scheduled HCB waste, it is considered preferable for destruction of the waste to take place at the premises. This will be reviewed following selection of the destruction technology. The final decision on the destruction site shall be subject to further community consultation.

9. Reporting

9.1 Following endorsement of the HCB waste management plan, ICI shall report at least annually to EPANSW in a public document on progress made in the management (including storage) and destruction of HCB waste.

9.2 With input from Community Participation and Review Committee, ICI shall report to the community on progress in selecting the technology, the trialing of any selected technology, records required to be kept in accordance with this management plan and any other relevant matters; this shall be done through a newsletter that is produced at least quarterly from the time of endorsement of the management plan until the waste has been destroyed and the destruction facility dismantled.

10. Community Participation and Access

10.1 There shall be ongoing public participation and review when this management plan is implemented.

10.2 A Community Participation and Review Committee shall be established to provide a forum for discussing the implementation of the plan and this Committee shall consider any matter that is within the scope of the plan. The role of the Community Participation and Review Committee shall be to receive, request and distribute information; consult the local community; participate in relevant processes; and review and advise EPANSW and ICI on relevant proposals, including monitoring and implementation of the management plan. The Community Participation and Review Committee shall include representatives of local community groups, relevant independent experts and local government. It shall be set up by the Chair of the National Advisory Body in conjunction with the National Advisory Body. Appendix C details a non-exclusive list of functions for the Committee.

10.3 Approval and licensing of any destruction facility shall undergo a public participation and review process.

10.4 Information and/or reports relating to inspection, storage, spillages, emergency planning, transport, destruction, monitoring and disposal shall be considered by the Community Participation and Review Committee and be made publicly accessible. This includes but is not limited to the requirements detailed in Sections 4.1.8, 5.1 and 5.2 of this plan.

10.5 Reports on any emergencies shall be provided to the Community Participation and Review Committee at the first opportunity.

11. Review Period

11.1 This management plan shall be reviewed after the choice of destruction technology has been made and in parallel with the preparation of an Environment Impact Assessment. During this review, further consideration shall be given to the car park waste. In any case, review periods for the management plan shall not be greater than five years.

References

The following documents were integral to the development of the HCB Waste Management Plan. All were prepared on behalf of ANZECC. Unless otherwise specified, the authors were the Scheduled Wastes Management Group and the National Advisory Body. All are obtainable from:

Waste Management Secretariat
40 Blackall Street
BARTON ACT 2600
Telephone: 1800 657 945 (free call)
Facsimile: (06) 274 1230

Draft HCB Waste Management Plan and Supporting Document: A report prepared by Professor Ben Selinger of ANUTECH Pty Ltd, November 1995.

HCB Waste Background and Issues Paper: A report prepared by Professor Ben Selinger of ANUTECH Pty Ltd, July 1995.

Hexachlorobenzene (HCB) Waste Management Plan (Draft Final), April 1996.

Summary Report of the HCB Consultation Panel on Major Outcomes from HCB Public Consultations 5 December 1995: HCB Consultation Panel supported by the Waste Management Secretariat, April 1996.

Summary Report of the HCB Consultation Panel on Major Outcomes from HCB Public Consultations 16 May 1996: HCB Consultation Panel supported by the Waste Management Secretariat, October 1996.

HCB Timing Review: A report prepared by CMPS&F Environmental, May 1996.

More comprehensive lists of references on HCB are contained in the HCB Background and Issues Paper.

Appendix A

Scheduled HCB waste

Quantities and analysis of scheduled HCB waste stored at the premises:

(a) Approximately 8000 tonnes of HCB waste with minor amounts of other chlorinated materials stored in lined 200 litre drums;

(b) Approximately 45 000 cubic metres of a mixture of sand and coal ash containing HCB and other chlorinated materials, interred under a paved car park area containing approximately 0.18% of HCB and other chlorinated materials;

(c) Approximately 755 tonnes of tar solids containing HCB and other chlorinated materials stored in concrete tanks and 200 litre drums containing about 0.3% of HCB;

(d) Approximately 24 tonnes of char containing HCB and other chlorinated materials stored in 200 litre drums containing approximately 0.4% of HCB;

(e) Approximately 65 tonnes of effluent sludge containing HCB and other chlorinated materials stored in 200 litre drums containing approximately 0.08% of HCB; and

(f) Approximately 55 tonnes of spent activated carbon containing HCB and other chlorinated materials stored in 200 litre drums containing approximately 0.003% of HCB. (HCB concentration is below the 50 mg/kg threshold limit but the concentrations for other compounds are not available.)

Appendix B

Dibenzopdioxins and dibenzofurans

Constituent		Dioxin equivalency factor
2,3,7,8E­tetrachlorodibenzopdioxin		1
1,2,3,7,8E­pentachlorodibenzopdioxin		0.5
1,2,3,4,7,8E­hexachlorodibenzopdioxin	)
1,2,3,7,8,9E­hexachlorodibenzopdioxin	)	0.1
1,2,3,6,7,8E­hexachlorodibenzopdioxin	)
1,2,3,4,6,7,8E­heptachlorodibenzopdioxin		0.01
octachlorodibenzopdioxin		0.001
2,3,7,8E­tetrachlorodibenzofuran		0.1
2,3,4,7,8E­pentachlorodibenzofuran		0.5
1,2,3,7,8E­pentachlorodibenzofuran		0.05
1,2,3,4,7,8E­hexachlorodibenzofuran	)
1,2,3,7,8,9E­hexachlorodibenzofuran	)
1,2,3,6,7,8E­hexachlorodibenzofuran	)	0.1
2,3,4,6,7,8E­hexachlorodibenzofuran	)
1,2,3,4,6,7,8E­heptachlorodibenzofuran	)
1,2,3,4,7,8,9E­heptachlorodibenzofuran		0.01
octachlorodibenzofuran		0.001

NOTE

International Toxicity Equivalency Factors are assigned to individual dioxins and furans on the basis of how toxic they are in comparison with the toxicity of 2,3,7,8tetrachlorodibenzopdioxin, the most potent dioxin. This contaminant has been assigned the value of 1.0 (NATO, 1988a^*). By comparison, animal and cell tests show that 2,3,7,8tetrachlorodibenzofuran is approximately oneE­tenth as toxic as 2,3,7,8tetrachlorodibenzopdioxin. Consequently, its toxic equivalent value is 0.1. International Toxicity Equivalency Factors have been developed for those dioxins and furans that contribute most to the toxicity of a complex mixture, which are those that have chlorines in at least the 2,3,7 and 8 positions. The toxicity is decreased from that of 2,3,7,8tetrachlorodibenzopdioxin in a predictable manner for those dioxins or furans which have either fewer or more chlorines than this compound, and/or which have chlorines in positions 1,4,6 or 9. Of the 210 dioxins and furans, 17 contribute most to the toxicity of a complex mixture and are of the greatest concern. This does not mean that the remaining 193 dioxins and furans are not toxic, but merely that they contribute comparatively little to the toxicity of a complex mixture.

^* NATO, 1988a. International Toxicity Equivalency Factor (IE­TEF) method of risk assessment for complex mixtures of dioxins and congeners.

Appendix C

Community Participation and Review Committee

To address the community's request to become involved in the issues relevant to the HCB waste held by ICI at its Botany site, a Community Participation and Review Committee will be formed under the management plan. This Committee shall consider any matter that is within the scope of the plan that may affect the community's health or the environment.

As a starting point, the following list of possible issues should be discussed by the Community Participation and Review Committee. This list is based on requirements in the management plan and on issues raised in oral and written comments made through the HCB waste public involvement process.

1. Reports on:

• redrumming activities
• inspections of HCB waste
• audits
• destruction results
• monitoring activities
• incidents.

2. Information on new technologies being considered and preferred siting options.

3. Emergency planning.

4. Investigations into the car park waste and its treatment.

5. Notification of intended movements of the HCB waste (for example, the export of waste for trials or import back to the site of any residues from those trials).

6. Monitoring compliance with emission standards.

7. Review activities.

8. The need for an awareness campaign to accompany notification requirements of the plan.

This list is provided for guidance only and should not be seen either as complete or as a means of restricting issues for consideration by the Community Participation and Review Committee.

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¹ A Woodward-Clyde report prepared for ICI Australia Engineering Pty Ltd. (Note: the survey contains six parts.)

² "N.O.S." means not otherwise specified.

³ The intent of S 4.1.2 is that these materials should be handled with due care where they are transported. The Scheduled Wastes Management Group has recommended that ANZECC submit a proposal to the Advisory Committee on the Transport of Dangerous Goods seeking that scheduled HCB waste be handled under the ADG Code as environmentally hazardous substances, solids or liquids (as appropriate).

⁴ Includes Botany Bay City Council, Randwick City Council and other councils that are members of the Southern Sydney Regional Organisation of Councils.

⁵ Amendments to this Commonwealth Act were legislated in June 1996 and exports of hazardous waste for final disposal are now permitted only in exceptional circumstances. It is current Commonwealth Government policy not to issue permits for export of scheduled wastes except where there is a direct and immediate threat to human health and the environment from continued storage; none have been exported since 1992. Any export application in relation to the destruction of some part of the HCB waste held by ICI would be considered on its merits, but precedent suggests that it would be unlikely to be favourably considered unless all domestic disposal possibilities had been exhaustively examined and eliminated. The Hazardous Waste Act has its own consultation and advisory processes, involving an expert technical group and a representative policy reference group. Advice from the Scheduled Wastes Management Group and the National Advisory Body and similar bodies would also be sought.

⁶ German level -17 Bundesimmissionsschutz-Verordnung.

⁷ USEPA Fact Sheets for Hexachlorobenzene and Hexachlorobutadiene (HCB Waste Background and Issues Paper, Appendix 1).

⁸ UK Quality Objectives, UK Department of Environment, 30 March 1989, Water and the Environment: Implementation of European Directives on the Environment on Pollution caused by Dangerous Substances Discharged into the Aquatic Environment.

⁹ UK general discharge limits quoting Environmental Protection Act 1990, Process Guidance Note IPR 5/3, Waste Disposal and Recycling Municipal Incineration, London; HMSO.

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Acknowledgments

The objective of the Australian and New Zealand Environment and Conservation Council (ANZECC) is to provide a forum for consultation and co-ordination between the State, Territory and Commonwealth governments of Australia and the Government of New Zealand on environmental and conservation issues.

The hexachlorobenzene (HCB) waste management plan was prepared between August 1994 and November 1996 as part of the National Strategy for the Management of Scheduled Wastes. The assistance of a large number of organisations and individuals played a crucial role in its success and widespread acceptance. It was funded by ANZECC.

ANZECC would like to acknowledge the efforts of the Scheduled Wastes Management Group and the National Advisory Body (NAB). The SWMG was set up to oversee the development of scheduled waste management plans and the NAB was set up to provide interest group advice to ANZECC on scheduled waste issues. The NAB consists of representatives of a range of interested stakeholders: environment groups, farmers, local government, unions, waste holders (from the chemical industry, electricity supply and mining sectors), waste managers and scheduled waste treatment firms. The NAB conducted an extensive community consultation program for the HCB waste management plan on behalf of ANZECC and it played an important role in incorporating public comment through the process to prepare the endorsed plan.

Finally, ANZECC offers its thanks to Botany Bay City Council, to ICI Australia Operations Pty Ltd and to the many local residents who provided advice and specific comments on two previous drafts of the HCB waste management plan through the extensive public involvement program.

© Australian and New Zealand Environment and Conservation Council, 1996
Information presented in this document may be copied provided that any extracts are fully acknowledged.