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E1285, v. 2 
 
Demonstration Project of Alternatives to Chlordane 
And Mirex for Termite Control in China 
 
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Jiangsu Academy of Environmental Science 
December 6, 2005 
Page  2
Closure of Liyang Guanghua Chemical Co., Ltd. 
2 
 
This document is a safeguards document prepared for the GEF project 
China: 
Demonstration of Alternatives to Chlordane and Mirex in Termite Control
.
The project is 
a
$28
million demonstration of approaches to implement the Stockholm Convention on 
persistent organic pollutants (POPs) in termite control. There are three safeguards  
documents prepared for this project.  
 
1. Pest Management Plan (PMP) prepared for the entire project. The PMP was 
developed according to the requirements of th
e
World Bank’s Operational Policy OP 
4.09 on Pest Management which mandates the use of integrated pest management (IPM). 
The project itself is essentially a large-scale implementation of IPM in termite control, 
since it promotes replacement of the current chemical-based termite control methods with 
environmentally more sustainable IPM-based method. Majority of project funding – more 
than $20 million – is allocated directly to IPM activities. The PMP and the project 
document, therefore, are very closely related, and the principal recommendations and 
consideration of the PMP are an integral part of the project design. 
 
2. Environmental Impact Assessment (EIA) and Environmental Management Plan 
(EMP) specific to the component 4 of the project. The component – with the budget of 
about $2.64 million – demonstrates a closure of a chlordane and mirex manufacturer – 
Liyang Guanghua Chemical Company Ltd. – in Jiangsu Province. The EIA and EMP 
were prepared according to Chinese environmental impact assessment regulations and the 
World Bank’s Operational Policy OP 4.01 on Environmental Assessment. 
 
3. Social Assessment (SA) which complements the EIA. The SA was prepared to 
address the social and economic impacts of the closure of the Liyang Guanghua 
Chemical Company, Ltd. on the plant work force. The SA was prepared as a matter of 
best practice, and serves as a basis for the worker compensation and retrenchment 
program which will be implemented under the project. 
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Closure of Liyang Guanghua Chemical Co., Ltd. 
3 
 
Table of Contents 
CHAPTER 1
 
SUMMARY.......................................................................................................................7
 
CHAPTER 2
 
BACKGROUND OF THE DEMONSTRATION PROJECT.......................................9
 
2.1 Country 
Situation................................................................................................9 
2.2 
Chlordane and Mirex...........................................................................................9 
2.3 Project 
description.............................................................................................10 
2.4 EIA 
Implementation..........................................................................................12 
2.5 
Main technology and approaches adopted in assessment .................................13 
2.6 
Organization in Charge for Environmental Impact Assessment.......................13 
CHAPTER 3
 
POLICY, LEGAL AND ADMINISTRATION FRAMEWORK ................................15
 
3.1 
The Synergy of Four International Chemical Conventions ..............................15 
3.2 
Relevant Regulations on Phase-out of Chlordane and Mirex in China.............17 
3.3 
Key Provisions of Major Laws, Regulations and Standards.............................18 
3.4 
Relevant Environment Standards Outside of China..........................................22 
3.5 
Institutional Setup in China for the Management of POP.................................25 
3.6 
Project Administrative Arrangements...............................................................26 
CHAPTER 4
 
BASELINE INFORMATION AND SITE INVESTIGATION...................................28
 
4.1 
Basic Information about Liyang........................................................................28 
4.2 
Liyang Guanghua Chemical Company, Ltd......................................................32 
4.3 
Production Process and Pollution Discharge ....................................................44 
4.4 
Environment Monitoring of the Liyang Guanghua Site ...................................48 
4.5 
First Phase of Environmental Monitoring.........................................................49 
4.6 
Second Phase Sampling and Monitoring ..........................................................64 
4.7 
Pollutants Concentration Gradient Distribution................................................67 
CHAPTER 5
 
RISK ASSESSMENT.....................................................................................................69
 
5.1 
Introduction to Risk Assessment.......................................................................69 
5.2 Acceptable 
Risk.................................................................................................70 
5.3 
Risk Evaluation Using US EPA PRGs..............................................................71 
5.4 
Evaluation of the Current Risk from Chlordane and Mirex..............................72 
5.5 
Risk from Chlordane and Mirex in Groundwater.............................................83 
5.6 
Hazard from Hexachlorocyclopentadiene and Endosulfan in Groundwater.....85 
5.7 
Evaluation of Post-Cleanup Risk From Chlordane and Mirex .........................86 
CHAPTER 6
 
REMEDIATION ALTERNATIVES.............................................................................89
 
6.1 
General description of Available Technologies................................................89 
6.2 Natural 
Attenuation...........................................................................................91 
6.3 Bioremediation..................................................................................................93 
6.4 Incineration........................................................................................................95 
6.5 Thermal 
Desorption...........................................................................................97 
6.6 Vitrification.......................................................................................................98 
6.7 Pyrolysis............................................................................................................99 
6.8 Chemical 
Treatment........................................................................................100 
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Closure of Liyang Guanghua Chemical Co., Ltd. 
4 
6.9 
Excavation and Disposal in a Secure Landfill ................................................101 
6.10 
Pump and Treat ...............................................................................................102 
6.11 
Physical Barriers, Passive/Reactive Treatment Walls.....................................103 
6.12 Summary.........................................................................................................105 
CHAPTER 7
 
ENVIRONMENTAL IMPACTS.................................................................................106
 
7.1 
Environmental Impacts of Site Remediation Activities..................................106 
7.2 
Potential negative impacts associated with the site remediation actions........107 
7.3 
Environmental Impacts of Disposal of Contaminated Wastes........................109 
7.4 
Environmental Impacts of Storage and Sales of Raw Materials and Products109 
CHAPTER 8
 
ENVIRONMENT MANAGEMENT PLAN .............................................................. 110
 
8.1 
Mitigation for Impacts Originated from Past Production................................110 
8.2 
Mitigation Measures for Social Impacts Associated with Plant Closure........118 
8.3 
Mitigation Measures Associated with Remediation Activities.......................118 
8.4 Monitoring 
Plan...............................................................................................123 
8.5 Institutional 
Arrangements..............................................................................124 
8.6 Implementation 
Arrangement .........................................................................125 
8.7 
Institutional Controls of the Use of the Site....................................................126 
8.8 
Capability Building and Training Program.....................................................126 
8.9 Implementation 
Schedule................................................................................126 
8.10 Cost 
Analysis...................................................................................................127 
8.11 Reporting.........................................................................................................131 
CHAPTER 9
 
PUBLIC PARTICIPATION ........................................................................................132
 
9.1 
Legal Basis for Public Participation................................................................132 
9.2 
Public Participation/Consultation and Information Disclosure of the Project 132 
9.3 
Analysis of the First Round Public Participation............................................134 
9.4 
Analysis of the Second Round Public Consultation .......................................139 
9.5 Public 
disclosure .............................................................................................139 
ANNEX 1: CHLORDANE AND MIREX PRODUCERS IN CHINA..................................................140
 
ANNEX 2: ADDITIONAL INFORMATION ON CHEMICALS AT THE LIYANG GUANGHUA 
SITE...........................................................................................................................................................141
 
ANNEX 3: QA/QC FOR MONITORING AND ANALYSIS ................................................................146
 
ANNEX 4: REGISTERED HAZARDOUS WASTE DISPOSAL AND MANAGEMENT 
COMPANIES IN JIANGSU ....................................................................................................................152
 
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Closure of Liyang Guanghua Chemical Co., Ltd. 
5 
List of Tables 
 
Table 3-1: National, Zhejiang and Jiangsu Termite Control Standards  
Table 3-2: Summary of Relevant Environmental Standards on Chlordane, Mirex and 
Others in Foreign Countries 
Table 4-1 Production Facilities at the Liyang Site 
Table 4-2 Sensitive Environmental Objects Surrounding the Project site 
Table 4-3 Pysical and Chemical Properties of Products and Major Raw and Auxiliary 
Materials 
Table 4-4 Pysical and Chemical Properties of Products and Major Raw and Auxiliary 
Materials 
Table 4-5 Major Manufacturing Equipment, Utilities and Storage and Transportation 
Equipments of this Project 
Table 4-6 Waste Water Discharge Standard 
Table 4-7 Equipment, Chemicals and Wastes Left on the Liyang Guanghua Site 
Table 4-8 Sampling Plan for Soil and Groundwater 
Table 4-9 First Phase Monitoring Results of Hexachlorocyclopentadiene in Soil 
Table 4-10 First Phase Monitoring Results of Endosulfan in Soil 
Table 4-11 First Phase Monitoring Results of Chlordane in Soil 
Table 4-12 First Phase Monitoring Results of Mirex in Soil 
Table 4-13 First Phase Monitoring Result 
–
Groundwater 
Table 4-14 First Phase Monitoring Result of Surface Water 
Table 4-15 Result of Assessment on Status of Chlordane in Soil 
Table 4-16 Result of Assessment on Status of Mirex in Soil 
Table 4-17 Second Phase Sampling Points and Monitored Pollutants 
Table 4-18 Second Phase Monitoring Results of Chlordane and Mirex in Soil, Sediments, 
Groundwater and Surface Water 
Table 4-19 Evaluation of Second Phase Monitoring Results - Mirex 
Table 4-20 Evaluation of Second Phase Monitoring Results – Chlordane 
Table 5-1 PRGs for Chlordane and Mirex (October 2004) 
Table 5-2 Comparison of Chlordane and Mirex in Surface Water to PRG Reference 
Levels (Unit: ug/L) 
Table 5-3 Comparison of Chlordane and Mirex in Ground Water to PRG Reference 
Levels (Unit: ug/L) 
Table 5-4 Risk Caused by Chlordane and Mirex in Soil 
Table 5-5 Hazard Index of Hexachlorocyclopentadiene and Endosulfan in Soil 
Table 5-6 Health Risk Resulting from Groundwater Pollution 
Table 5-7 Hazard Index of Hexachlorocyclopentadiene and Endosulfan in Groundwater 
(concentration unit: ug/l) 
Table 7-1 Noise of Construction Machinery and Equipment 
Table 7-2 Environment Risk Caused by Cleanup Activities in this Project 
Table 8-1 Applicability of Three Disposal Technologies for the Liyang Site 
Table 8-2 Summary of Proposed Mitigation Measures and Cost Estimation 
Table 8-3 Cleanup, Environment Danger and Mitigation Measures 
Table 8-4 Schedule for Mitigation Measures 
Table 8-5 Budget for Mitigation Measures 
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Closure of Liyang Guanghua Chemical Co., Ltd. 
6 
Table 9-1 Public Participation Survey Methods in the First Stage 
Table 9-2 Basic Information of Target Groups in the First Survey 
Table 9-3 Basic Information of Target Groups in the Second Survey 
Table 9-4 Result of the First Survey 
Table 9-5 Result of the Second Survey 
 
List of Figures 
Figure 4-1: Jiangsu Province and Location of Liyang Guanghua Chemical Company, Ltd. 
Figure 4-2: Liyang City and Liyang Guanghua Chemical Company, Ltd. 
Figure 4-3: Satellite Image of the Greater Liyang City Area 
Figure 4-4: Liyang Guanghua Chemical Company, Ltd. and Surroundings  
Figure 4-5: Major Rivers Adjacent to the Liyang Guanghua Site 
Figure 4-6: Process Flowchart for Chlordane and Mirex Production 
Figure 4-7: Groundwater Depth and Flow at the Liyang Guanghua Site 
Figure 4-8: Sampling Points at the Liyang Guanghua Chemical Company, Ltd. 
Figure 4-9: Soil Monitoring Results at Six Sampling Points 
Figure 4-10: Chlordane and Mirex Concentration in Soil  
Figure 5-1: Carcinogenic risk of chlordane  
Figure 5-2: Carcinogenic risk of mirex 
Figure 8-1: Site Clean Up Plan of the Liyang Guanghua Chemical Company, Ltd. 
Figure 8-2: Organizations for Implementing Site Cleanup Plan 
 
List of Photos 
Photo 4-1: Boat Building Workshop Next to the Liyang Guanghua Site 
Photo 4-2: Branch of the Wangmuqiao River at the Liyang Guanghua Chemical Co., Ltd. 
Photo 4-3: Chlordane and Mirex Production Facilities at the Liyang Guanghua Site 
Photo 4-4: Abandoned Endosulfan Production Facilities at the Liyang Guanghua Site 
Photo 4-5: Wastewater Treatment Facility at the Liyang Guanghua Site 
Photo 4-6: Stockpiled Chlordane and Mirex Products 
Photo 4-7: Contaminated Packaging Materials 
 
Page  7
Chapter 1: Summary 
7   
Summary 
 
1. 
This Environmental Impact Assessment (EIA) addresses the closure Liyang 
Guanghua Chemical Company in Jiangsu Province, China.  It includes demolition of the 
facilities, disposal of hazardous waste and clean up of the site to a level acceptable for the 
site’s future industrial use.  
2. 
The closure of the Liyang Guanghua Chemical Company is one of the 
components of the GEF project 
China: Alternatives to Chlordane and Mirex in Termite 
Control.
 The project aims to provide China with an opportunity to build knowledge and 
experience necessary to formulate a national program for phaseout of chlordane and 
mirex – two of the twelve persistent organic pollutants (POPs) controlled by the 
Stockholm Convention.  
3. 
Chapter 2 of this EIA provides detailed information about the background of the 
project. It also give additional details about the component focusing on the closure of the 
Liyang Guanghua Chemical Company is presented in.  
4. 
Chapter 3 lays out the policy, legal and administrative framework which governs 
the preparation and implementation of the project and the Liyang Guanghua Closure 
Component. Four international chemical conventions affect the design of the project: 
Stockholm Convention, Basel Convention, Rotterdam Convention and the Montreal 
Protocol. In addition, a number of Chinese laws, regulations and standards, at both 
national and provincial levels, govern the various activities of the project, including the 
design and implementation of the closure and clean up of the Liyang Guanghua Chemical 
Company.  
5. 
Despite a number of applicable laws and regulations, China does not have a 
standard setting maximum allowable concentration of chlordane or mirex in the 
environmental media. In the absence of a national or provincial standard, the Stockholm 
Convention recommended level of 50 ppm was adopted as the clean up level for this 
project. 
6. 
Chapter 4 provides detailed information about the Liyang Guanghua Chemical 
Company, chlordane and mirex production as well as geographical, hydrological and 
climatological information about the plant site. Importantly, the chapter presents results 
of site investigation and contamination data collected through two phases of site 
monitoring program. Through site investigation and monitoring, the extend and severity 
of contamination by the key contaminants –chlordane and mirex – have been determined 
in the soil, surface water, ground water, and sediments. Concentration of other site 
contaminants in various environmental media has been measured as well. The site 
investigation also included the area surrounding the plant, including the nearest 
residential settlements, to ensure that there is sufficient information to develop a 
comprehensive clean up plan. 
7. 
Data from the site investigation and monitoring show that the site is moderately 
contaminated with chlordane and mirex. The contamination exceeding the acceptable 
Page  8
Chapter 1: Summary 
8   
level is contained within the plant compound, and the pattern of contamination is 
consistent with the normal operation of the plant. 
8. 
Chapter 5 evaluates the risk to human health that the site currently represents. It 
also confirms that after reducing the contamination to the Stockholm Convention 
recommended level of 50 ppm, the site will not represent excessive risk to human health. 
For the risk evaluation in this chapter, the methodology and reference concentrations set 
by the US EPA were used.  
9. 
Chapter 6 surveys the technological and other alternatives for remediation of the 
site and disposal of hazardous chlordane and mirex waste. The consideration of 
alternatives is based largely on international experience, since only limited experience 
with such disposal is available in China. The information from this chapter serves as a 
basis for selection of the clean up technology in chapter 8. 
10. 
Chapter 7 assesses potential environmental impacts associated with the plant 
demolition and site remediation. These impacts include noise, air pollution from heavy 
machinery, dust from excavation and demolition, borrow pits for backfilling the 
excavated area, transport and storage of contaminated waste, and pollution associated 
with final disposal of hazardous materials by incineration of landfilling.  
11. 
Chapter 8 presents the measure for mitigation of the potential environmental 
impacts identified in chapter 7, and details the site clean up plan and post clean up 
monitoring. The site clean up relies mainly on excavation of contaminated soil and its 
final disposal in a hazardous waste landfill. The non-hazardous solid waste will be 
disposed in a municipal landfill. Contaminated clean up water from washing, rinsing of 
pesticide containers, etc. will be treated in a licensed industrial wastewater treatment plan 
capable of handling chlordane and mirex residues.  
12. 
Chapter 9 documents the two round consultation and public participation process 
that was organized to ensure that the views of general public are adequately reflected in 
the EIA. 
 
Page  9
Chapter 2: Background 
9   
Background of the Demonstration Project  
 
1. 
Chlordane and mirex are two of the twelve persistent organic pollutants (POPs) 
controlled by the Stockholm Convention. China, as a signatory to the Stockholm 
Convention, is obliged to eliminate these chemicals according to the convention 
requirements. Both chemicals, due to their effectiveness and low cost, have been a 
backbone of the Chinese termite control industry for decades, despite their carcinogenic, 
neurological, and physiological impacts on human health, and a broad range of 
neurological, liver, skin and male reproductive system and immune system disorders that 
they cause. Similarly to other POPs, chlordane and mirex travel long distances through 
the global ecosystem, accumulate in the food chain and are highly persistent 
–
their 
residues have been detected in water, soil, food and beverages, breast milk and human 
tissues for as long as 12 years after exposure.  
 
Country Situation 
2. 
China is one of the countries with the greatest diversity of termites and most 
severe termite damage in the world. About 482 species of termites are found in all but six 
Northern provinces (Heilongjiang, Jilin, Inner Mongolia, Ningxia, Qinghai, and Xinjiang) 
in China, concentrated mostly south of the Yangtze River. Affecting more than 40% of 
the total land area in China, termite has caused damages to between 30 and 90% of 
buildings south of the Yangtze River. In addition, termites have caused damage to 
historic architecture, dams, bridges and other constructions in China. It is estimated that 
the direct economic loss caused by termites in China is about 2 to 2.5 billion RMB 
yuan 
annually. China’s explosive growth in new residential construction and general 
infrastructure development has substantially increased the demand for termite control. 
 
Chlordane and Mirex  
3. 
Since their introduction to China in 1964 and 1979, respectively, chlordane and 
mirex have become the principal instruments for termite prevention and control, although 
their use declined in recent years due to regulatory restrictions. Their effectiveness, 
persistence, low cost and ease of application have lead to their widespread use and 
contributed to the fact that termite management in China heavily relies on chemical 
methods. As of December 2004, there were nine chlordane and mirex manufacturers in 
China, all located in Jiangsu Province. Among the nine manufactures, five produced both 
chlordane and mirex and four produced only chlordane. From 2000 to 2003, these nine 
manufacturers produced 450 – 820 tons of chlordane and 9 -31 tons of mirex annually. In 
practice, chlordane and mirex are mainly used in termite control in residential and other 
buildings. The use of both termiticides poses significant local and global risks to human 
health and the environment. 
 
Page  10
Chapter 2: Background 
10  
Project description 
4. 
When China ratified the Stockholm Convention in October 2003, China requested 
the Bank to help in the development of a Demonstration Project of alternatives to 
chlordane and mirex in termite control.  As a consequence, a demonstration project has 
been developed.   
5. 
The project is a self-standing, full-size GEF operation which is not a part of an 
existing program. The project is, however, designed to lay a foundation for a nationwide, 
multi-phase national replication program on the elimination of chlordane and mirex in 
China. The project thus supports the broad effort of China to comply with the Stockholm 
Convention, and it is an essential part of a suite of internationally supported 
interventions.  The project further seeks to ensure replicability by including a specific 
component on promoting and disseminating projects results and lessons to the rest of 
China.  National, provincial and local governmental organizations, institutes and 
companies involved in this project will also help ensure the dissemination of relevant 
information.  Finally, the project’s internet website will make its results widely available, 
as well as giving access to new information on IPM approach to termite control. 
6. 
The Demonstration Project is design to (i) demonstrate elimination of chlordane 
and mirex use for termite control in the demonstration provinces through introduction of 
integrated termite management; and (ii) prepare a national replication program for 
complete phase-out of chlordane and mirex in China by 2014.  
7. 
Consistent with this design and objective, the key project outputs will include (i) 
elimination of chlordane and mirex consumption in the demonstration area’s building 
construction sector; (ii) comprehensive policy, regulatory and institutional reforms at the 
national and provincial level to replace termiticide-based termite management with 
integrated termite management; (iii) closure and clean-up of the Lyiang Guanghua 
Chemical Co, Ltd., and corresponding permanent reduction in the national chlordane and 
mirex production; and (iv) development of a national replication program and production 
quota system for phaseout of chlordane and mirex in the rest of China.   China 
recommends that the cleanup value of contaminated soil with chlordane and mirex to be 
50ppm which is consistent with recommendation from the Basel Convention.  
8. 
The key indicator of project’s success will be the use of chlordane and mirex by 
the termite control professionals in the demonstration area, which should reach zero level 
by the end of the project. 
9. 
This demonstration project is closely linked with several related and ongoing 
projects, upon which it either builds or to which it contributes.  These include (a) 
development of a National Implementation Plan (NIP) for the Stockholm Convention, 
being conducted by SEPA/CIO with the assistance of UNIDO and the GEF, (b) the 
completed Sino-Italian project titled “POP Pesticides and Draft Strategy on Phaseout in 
China”, (c) the termite study financed by a Canadian Trust Fund, and (d) a toxicity also 
financed by a Canadian Trust Fund.   
Page  11
Chapter 2: Background 
11  
10. 
The NIP includes national strategies and action plans to reduce and eliminate all 
POPs, building national inventory and capacity building so as to help China in fulfilling 
its commitment to the Stockholm Convention.  
11. 
The major outputs of the Canadian Termite Study are testing of a small sample of 
termite treatment chemicals, and development of an initial IPM toolbox for termite 
control.   The output of the Sino-Italian Pesticide project is a preliminary strategic 
framework for the elimination of all POP pesticides in China. These two projects provide 
direct inputs into the NIP as well as this demonstration project.  The NIP, to be completed 
in November 2006 will have an initial action plan on elimination of chlordane and mirex 
based on the Sino-Italian Pesticide Project.  One of the major outputs of the 
demonstration project, to be completed in December 2009, is the National Replication 
Program which will elaborate and update the initial action plan on chlordane and mirex 
prepared in the NIP.   
12. 
The toxicity study is to investigate the exposure of DDT and PCBs and their 
adverse effects with special emphasis on the health of women and children. The initial 
study result indicates that the tested area in Zhejiang has a high-concentration PCB 
exposure. PCB geometric concentration levels in women and children in this area are 
moderately elevated.  They are below those found in Arctic Canada (Nunavut) and above 
those found in southern Canada.  The major outputs of the Canadian Toxicity Study are: 
(a) an evaluation for DDT and PCBs exposure level in the environment, and (b) an 
evaluation for DDT and PCBs accumulation level in the biological sample.   
13. 
The Demonstration Project selected two provinces as demonstration provinces 
–
Jiangsu and Zhejiang.   These two provinces are severely affected by typical termites in 
China and consume most chlordane and mirex among the provinces which consumes 
chlordane and mirex.   As two of the most developed provinces in China, Jiangsu and 
Zhejiang have suffered significant economic and social impacts caused by termite 
damages, and are strongly motivated and experienced in termite control.  
Organizationally, both provinces have well-established institutions for the management 
and implementation of termite control activities, and these institutions are supported by 
qualified research organizations and technical service providers. Finally, both provinces 
have relatively well-developed termite control.   
14. 
Only the Jiangsu province produces chlordane and mirex in China and there are 
nine producers.  As a demonstration, China has selected the Liyang Guanghua Chemical 
Company, Ltd. as a demonstration in closing the plant and cleans up its site for future 
use. Annex 1 lists the remaining eight chlordane and mirex manufacturers in Jiangsu 
Province.    
15. 
Closure of the Liyang Guanghua Chemical Company, Ltd.  
The objective of 
this activity is to demonstrate (a) permanent physical closure and dismantling of the 
Liyang Guanghua Chemical Ltd. which manufactures chlordane and mirex; and (b) clean 
up the facility’s chlordane and mirex contaminated site and disposal of chlordane waste. 
This activity will provide practical experience with closing down a chlordane and mirex 
manufacturer and addressing the local environmental and social issues associated with 
the closure. At the same time, it will achieve permanent reduction of national mirex 
production by 2 tons, and national chlordane production of chlordane by 190 tons 
Page  12
Chapter 2: Background 
12  
annually. The reduction of chlordane production exceeds the chlordane consumption 
reduced through the introduction of the bait system in the demonstration provinces. This 
activity will have two components as follows. 
a. 
Closure and dismantling of Liyang Guanghua Chemical Company
.
This sub-
component will fund complete dismantling and removal of all equipment and 
facilities at Liyang Guanghua Chemical Company, as well as compensation for 
lost profits directly associated with the closure and workers compensation.  
b. 
Clean-up and disposal of chlordane and mirex wastes.
 
This sub-component will 
fund clean up of the contaminated site and dispose of contaminated waste 
appropriately. 
 
EIA Implementation   
16. 
This EIA report is prepared as required by the Environmental Protection Law of 
the People's Republic of China. This Law stipulates that
 “an EIA report must be prepared 
and submitted for approval for the construction of new projects and the renovation and 
expansion of existing projects.” The compilation of this EIA report also complies with 
the Environmental Protection Management Methods on Construction Projects [SEPA 
(1986) No. 003] and the Environment Impact Assessment Law of the People’s Republic 
of China, Notice on Strengthening EIA Management about Construction Projects Loaned 
by International Financial Organizations (issued by SEPA cooperated with NDRC, MOF 
and Bank of China, [1993: No.324]).  
17. 
According to the 1993 Notice on Strengthening EIA Management about 
Construction projects Loaded by International Financial Organizations, a comprehensive 
EIA is required because implementation of the project will have negative impacts on 
local ambient environment.  However, as far as this Demonstration Project is concerned, 
the closure of Liyang Chemical Co. aims at cleanup of a contaminated site and is 
inherently beneficial to the local and global environment. 
18. 
According to the Chinese Technical Guidelines for EIA preparation, the scope of 
this EIA includes the following issues: 
a. 
Soil quality in the area of the site and its surroundings; 
b.  Surface water courses in the vicinity of the site in the length of about 1,500 
meters; 
c. 
Groundwater in the area enclosed within 0.2 km radius of the project site; 
d.  Land use in the area – there is no development planned in the area, and in the 
future, this site will be used for industrial purpose; 
e. 
Fish ponds (for crab farming) within  0.1 km radius of the project site;  
f. 
Ambient air quality in the area of the site and its surroundings; 
g.  Noise in the area enclosed within  0.3 km radius of the project site; and 
h.  Vegetation in the area enclosed within 0.3 km radius of the project site; there are 
no important or sensitive ecosystems in the vicinity of the site. 
 
Page  13
Chapter 2: Background 
13  
Main technology and approaches adopted in assessment  
19. 
Four steps and approaches are adopted to conduct the assessment.  
 
a) 
Based on the analysis of environmental situation and activities of the enterprise, 
an environmental monitoring plan is developed and a certified monitoring 
institute is hired to monitor soil, surface, groundwater and sediment. Monitoring 
data are used to evaluate the pollution status of Chlordane and Mirex as well as 
some other contaminants in the study area. 
b) 
The risk-based decision making approach is adopted to conduct risk analysis to 
evaluate the risk that the site represents to human health. The risk analysis 
methodology of USEPA is applied. 
c) 
Conclusions from monitoring and risk analysis, as well as the cleanup criteria 
are used to set up the cleanup plan. 
d) 
According to laws, regulations, technical guidelines and standards, 
environmental management plan (EMP) is developed. 
 
Organization in Charge for Environmental Impact Assessment.    
20. 
Jiangsu Academy for Environmental Sciences (JAES) is responsible for the 
Environmental Impact Assessment for closure of the Liyang Guanghua Chemical Co. 
Ltd. under the Demonstration of Alternatives to Chlordane and Mirex in Termite Control 
Project in China.  JAES was founded in 1985 and took the name Jiangsu Institute for 
Environmental Sciences in 2001.    It engages in environmental research, environmental 
impact assessment and environmental program, environmental engineering, pollution 
control technology, R&D on environment protection products, promotion of BAT and 
BEP, and certification of environmental management system etc.  JAES has the 
certificates including Grade A Certificate for Environment Impact Assessment issued by 
SEPA, Grade B Design Certificate for Environmental Engineering, and the Certificate for 
ISO 14000 EMS. Jiangsu Key Lab of environmental engineering affiliated to the JAES 
has the first class testing lab facilities and analytical apparatus. 
21. 
Another Organization involved in the preparation of the Environmental Impact 
Assessment is the Environmental Monitoring Center of Jiangsu Province. The center has 
the capability of investigating and monitoring eight categories of pollutants including 
water, wastewater, ambient air, air emissions, soil, biology, automobile exhausts, indoor 
air, decorating materials, and also noise and vibration. Its on-line monitoring systems for 
air are widely distribute in the whole province, forecast daily report on the air qualities of 
the main cities. It has also set up 36 of on-line monitoring systems for monitoring water 
qualities in the sensitive area of the province. The center passed the measurement 
authentication by China Metrology Accreditation (CMA) in Oct.1992, and passed the re-
auditing by China National Accreditation of Lab (CNAL) and CMA in Oct. 2002. The 
certification number of CNAL is NO.L0089. 
22. 
Following the guideline of the CNAL/AC01 (GB/T15481-2000 and 
ISO/IEC17025: 1999), and Examination Code of Metrology / Checking Accreditation for 
the Product Quality Test, the 
Quality Manual
 is developed by the Jiangsu Environmental 
Page  14
Chapter 2: Background 
14  
Monitoring Center. This 
Quality Manual 
provides quality control and assurance system 
for all the monitoring activities of the center, including sampling and analysis.   
Page  15
Chapter 3: Policy, Legal and Administration Framework 
15 
 
 
Policy, Legal and Administration Framework  
 
The Synergy of Four International Chemical Conventions  
 
1.
Chemical contamination of the environment shows no respect for territorial 
borders. For that reason, multilateral environmental agreements (MEAs) provide 
effective international or regional frameworks to prevent and minimize the impacts of 
toxic chemicals and hazardous waste in the global commons.  
2.
Combined, the four MEAs (the Basel Convention, the Rotterdam  Convention, 
the Stockholm Convention, and the Montreal Protocol) address international trade in 
toxic chemicals, the transport of hazardous waste, the reduction and eventual 
elimination of releases, use and production of persistent organic pollutants, the 
environmentally sound remediation of waste stockpiles and the identification of 
contaminated sites. Most importantly, they help avoid problems in the future.   The 
four MEAs actively promote information exchange and technical capacity building, as 
well as providing some financial assistance for developing countries or countries with 
economies in transition. 
 
3.
The MEAs is a prime tool for regional environmental cooperation. They are 
international instruments binding all signatory countries and together, they take 
measures to remedy, mitigate or otherwise deal with global and or regional 
environmental concerns.  They emphasize on 
"efficient use of collective resources - 
information, financial and expertise; the reduction of duplication and overlaps; 
emphasis on program and policy coherence; and averting fragmented sectoral 
initiatives".
 
4.
The overarching objective of the different chemicals and hazardous wastes 
Conventions is the protection of human health and environment from pollution by 
certain chemicals and hazardous wastes. The scope of the Basel Convention covers a 
broad range of hazardous wastes, including chemical wastes, subject to transboundary 
movements. The Convention aims to reduce these movements to a minimum by 
minimizing the quantity and hazardous nature of the wastes generated and by 
promoting the treatment and disposal of hazardous wastes as close as possible to their 
source of generation. The Rotterdam Convention specifically addresses certain 
hazardous pesticide formulations, subject to international trade. The Stockholm 
Convention has as its priorities the reduction or elimination of releases of persistent 
organic pollutants (POPs) from international production, unintentional productions, 
stockpiles and wastes. The Rotterdam and Stockholm Conventions have provisions to 
add further chemicals to the treaties. The aim of the Montreal Protocol is to protect 
the ozone layer by phasing out the production and consumption of ozone-depleting 
substances. 
Page  16
Chapter 3: Policy, Legal and Administration Framework 
16 
 
 
5.
The Stockholm Convention on Persistent Organic Pollutants (POPs).
 
The 
objective of Stockholm Convention on Persistent Organic Pollutants (Stockholm 
Convention) is to reduce or eliminate release of POPs, and to protect human health 
and environment. The initial list of 12 POPs includes aldrin, chordane, DDT, dieldrin, 
dioxins, endrin, furans, heptachlor, hexachlorobenzen, mirex, polychlorinated 
biophenyls, and toxaphene.  
6.
The Stockholm Convention includes many agreements, such as:  
a. 
measures to reduce or eliminate production, use, import/export and releases of 
POPs.  
b.  register of specific exemption;  
c. 
screening criteria of chemicals specified in Annexes D;  
d.  financial resources and mechanisms;  
e. 
technical assistance;  
f. 
public information, awareness and education;  
g. 
research, development and monitoring; etc. Stockholm Convention request the 
Party should finally phase-out nine pesticides of POPs during a ten-year period 
from the date on which this Convention has entered into force, as well as 
manage POPs stockpiles and dispose POPs wastes with environmentally 
sound manners.   
7.
It is stipulated in Paragraph 2, Article 6 of the Stockholm Convention that the 
Conference of the Parties shall cooperate closely with the appropriate bodies of the 
Basel Convention on the Control of Transboundary Movements of Hazardous Wastes 
and their Disposal to, inter alia: 
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;  
b. 
determine what they consider to be the methods that constitute 
environmentally sound disposal referred to above; and  
c. 
work to establish, as appropriate, the concentration levels of the chemicals 
listed in Annexes A, B and C in order to define the low persistent organic 
pollutant content referred to in paragraph 1  
8.
Basel Convention on the Control of Trans-boundary Movements of 
Hazardous Wastes and Their Disposal.  
Basel Convention on the Control of Trans-
boundary Movement of Hazardous Wastes and Their Disposal (Basel Convention) 
was adopted on 22 March 1989 by the Conference of Plenipotentiaries which was 
convened at Basel, Switzerland from 20 to 22 March 1989. This convention enters 
into force in May of 1992. About one hundred countries signed this convention. China 
signed it on March 22
nd
,
1990.   
9.
Basel Convention is intended to prohibit trans-boundary movement of 
hazardous wastes, especially to developing countries through exportation and 
consignment. The Convention calls for signatories to minimize hazardous waste 
generation and encourages on site storage and disposal in environmentally sound 
Page  17
Chapter 3: Policy, Legal and Administration Framework 
17 
 
 
manner. This convention states clearly, in case of wastes have to be transferred across 
boundaries out of environment concern, the exporting country must inform in advance 
the recipient country and other related countries of quantity and quality of the wastes. 
The exporting country must obtain a written approval issued by the Government of 
the recipient country before conducting hazardous waste trans-boundary operations. 
10.
In Article 28 of the general technical guidelines for the environmentally sound 
management of wastes consisting of, containing or contaminated with persistent 
organic pollutants, it is described that, as stated in article 6, paragraph 2 (c), of the 
Stockholm Convention, the Stockholm Conference of the Parties shall cooperate 
closely with the appropriate bodies of the Basel Convention to “work to establish, as 
appropriate, the concentration levels of the chemicals listed in Annexes A, B and C in 
order to define the low persistent organic pollutant content referred to in paragraph 1 
(d) (ii).” Wastes consisting of, containing or contaminated with POPs above the low 
POP content should, in accordance with article 6, paragraph 1 (d) (ii), be disposed of 
in such a way that the POP content is destroyed or irreversibly transformed or 
otherwise disposed of in an environmentally sound manner when destruction or 
irreversible transformation does not represent the environmentally preferable option.  
11.
In Article 29, it is presented that the following provisional definitions for low 
POP content should be applied to aldrin, chlordane, DDT, dieldrin, endrin, heptachlor, 
HCB, mirex and toxaphene: 50 mg/kg. 
 
Relevant Regulations on Phase-out of Chlordane and Mirex in China 
 
12.
The following is the list of regulations on the Control over Safety of 
Dangerous Chemicals that will apply to the Demonstration Project: 
 
a. 
Environment Protection Law of People’s Republic of China (December 26, 
1989) 
b. 
Solid Waste Pollution Control Law of People’s Republic of China (April 1, 
1996) 
c. 
Infectious Disease Control Law of People’s Republic of China (September 1, 
1989; 
d.  Environmental Impact Assessment Law of People’s Republic of China, 
(October 28, 2002); 
e. 
Construction Project Environmental Protection Regulation, (No. 253 Decree 
of State Council of People’s Republic of China (November 29, 1998); 
f. 
Environmental Impact Assessment Technology Guideline, SEPA (HJ/T2.1-
2.3-93); 
g. 
Environmental Impact Assessment Technology Guideline- Acoustic 
Environment, SEPA (HJ/T2.4—1995); 
h. 
Hazardous Solid Waste Incineration Pollution Control Standard, (GB18484-
2001); 
i. 
Hazardous Solid Waste Landfill Pollution Control Standard, (GB18598-2001); 
j. 
Hazardous Solid Waste Storage Pollution Control Standard, (GB18597-2001); 
Page  18
Chapter 3: Policy, Legal and Administration Framework 
18 
 
 
k.  Inventory of Hazardous Wastes in China, SEPA (1998); 
l. Hazardous 
Waste 
Identification 
Standard, 
(GB5085-1996); 
m.  Technological Requirements for the Construction of Hazardous Waste 
Landfills, SEPA (No. [2004] 75); 
n. 
Hazardous Waste Transportation Manifest (October 1999); 
o. Waste 
Water Integrated Discharge 
Standards, (GB8978-1996); 
p. 
Ambient Air Quality Standards (GB3095-1996); 
q.  Surface Water Environment Quality Standards, (GB3838-2002); 
r. 
Ground Water Environment Quality Standards, (GB/T14848-93); 
s. 
Industrial Enterprise Plant Boundary Noise Standards, (GB12348-90); 
t. 
Hygiene Standard for the Design of Industrial Enterprises, (TJ36-79); 
 
13.
In addition, guidelines from the World Bank and international conventions 
apply: 
a. 
Operational Manual of World Bank (January 1999); 
b.  Operational Directive 4.01: Environment Assessment (and its attachments), 
the World Bank;  
c. 
Stockholm Convention on Persistent Organic Pollutants; and  
d.  Basel Convention on the Control of Trans-boundary Movements of Hazardous 
Wastes and Their Disposal, (1989.3). 
 
Key Provisions of Major Laws, Regulations and Standards 
 
14.
Solid Waste Pollution Control Law.  
This Law is the legal basis for 
hazardous waste treatment in China. Article 3 of the law stipulates that China adopts 
the principle of reducing the production of solid wastes, and utilizing and disposing of 
solid wastes to control solid waste pollution. Article 49 of the law stipulates that 
organizations that collect, store and dispose of hazardous wastes must apply for 
operational licenses from the environmental protection authority at county or higher 
levels governments. The State Council issues a specific management rule on such 
licensing process. It is prohibited to collect, store or dispose of hazardous wastes 
without obtaining the proper operational license. It is also prohibited to provide 
hazardous wastes to, or entrust any organizations without an operational license for 
collection, storage or disposal. Article 12 of the law stipulates that the impacts of solid 
wastes generated from construction projects on the environment must be assessed. 
Measures to prevent the environmental pollution must be carried out after being 
approved by environmental protection authorities according to related procedures. 
Only after the Environment Impact Assessment (EIA) Report is approved, the 
feasibility study report or design report of construction projects can be approved for 
implementation. Article 13 of the law stipulates that solid waste prevention facilities 
identified in EIA Reports of the construction projects must be designed, constructed 
and operated simultaneously with main facilities of the project. Solid waste 
prevention facilities have to be checked and accepted by authorities that approve the 
Page  19
Chapter 3: Policy, Legal and Administration Framework 
19 
 
 
EIA Report of the same construction project before these facilities are being operated. 
The check and acceptance of solid waste prevention facilities and that of main 
facilities of the construction project should be conducted simultaneously. These 
articles provide a legal basis for this environmental impact assessment. 
15.
Existing termite control policies.
 Since 1987, MOC has established and 
issued a series of policies and regulations for termite control. Of which, “Regulation 
on
Termite Prevention and Control in Urban Construction”, as the MOC No. 72 
regulation issued in 1999, is the most significant regulation in termite control in 
China. This regulation was revised and amended by the MOC No. 130 regulation in 
2004. The main rules in both regulations include:  
a.  In termite affected area, all new buildings and renovations, expansions and 
decorations of old buildings must have termite prevention treatment;  
b.  MOC takes charge of the management of termite control in China, and the 
Departments of Construction of local governments take charge of the 
management of termite control in the corresponding provinces; 
c. 
Termite control units must have the qualification to do termite control, and the 
chemicals for termite control must be registered in the Department of Pesticide 
Management of the Ministry of Agriculture (MOA);  
d.  The quality assurance term of termite control is 15 years, which starts from the 
date that house and buildings is transferred to users.  
e. 
Termite control in city area should follow the “prevention as the first priority” 
principle, use preventive and remedial measures jointly, and implement IPM 
strategies in termite control as soon as possible; and 
f. 
The government encourages to do research on the control of termites in city 
area, and promotes the use of new alternatives, techniques, crafts and 
equipments. 
16.
In order to strengthen the management of termite control, China has issued 
many technical standards for termite control in urban areas and dams and dykes, and 
for termite control studies. Table 3-1 lists standards issued by national agencies and 
by the Zhejiang and Jiangsu Provinces. 
17.
In order to reduce the environment pollution and to protect the human health, 
the Chinese government has issued many policies to eliminate or limit the production 
and use of chlordane and mirex. Regulations related to the production and use of 
chlordane and mirex are:  
 
a. 
Regulation for Environment Management on the First Import of Chemicals 
and Import/Export of Toxic Chemicals
 (issued by SEPA, Ministry of Foreign 
Trade and General Agency of Customs in 1994). This regulation aims to 
strengthen the monitoring and management of the first import of chemicals 
and the import and export of toxic chemicals included in the List of Toxic 
Chemicals Banned or Strictly Restricted in China. Chlordane was one of 27 
Page  20
Chapter 3: Policy, Legal and Administration Framework 
20 
 
 
chemicals included in this list. In other words, the import and export of 
chlordane are strictly controlled in China. 
 
Table 3-1: National, Zhejiang and Jiangsu Termite Control Standards  
Category Issuance 
Agency 
and 
Year 
Titles of Standards 
Urban 
Areas 
MOC, 1993 
Technical Standards for Preventive 
Engineering of Termite Control in Houses 
and Buildings 
China Property 
Management Institute, 
April 2002 
Technical Standards for the Preventive 
Engineering of Termite Control in Houses 
and Buildings (Draft) 
Department of 
Construction of Zhejiang 
Province, October 1986 
Technical Standards for Preventive 
Engineering of Termite Control in New 
Houses and Buildings 
Construction Committee 
of Jiangsu Province, 1993 
Operation Rules for Preventive 
Engineering of Termite Control in Houses 
and Buildings in Jiangsu Province (draft), 
and Rules for the Use of Chemicals for 
Termite Control in Houses and Buildings 
Department of 
Construction of Zhejinag 
Province, 1998 
Detailed Rules for the Quality 
Management of Termite Prevention 
Engineering on Houses and Buildings 
Department of 
Construction of Zhejinag 
province, 1999 
Measures for the management of chemical 
application during the termite control in 
house and buildings 
Dams and 
Dykes 
Ministry of Water 
Conservancy, August 
1996 
Notice on Further Strengthening Termite 
Control in Dams and Dykes and Ensuring 
the Security of Dams and Dykes 
Department of Water 
Conservancy of Jiangsu 
Province, 1990 
Temporary Measures for Termite Control 
in Dams and Dykes in Jiangsu Province  
Research GB/T18260-2000 
(issued 
in December 2000, 
effective in April 2001) 
Preventive Termiticides for Wood 
Treatment: Experimental Methods in 
Laboratory for the Toxic Effects of Wood 
Antiseptic Against Termites  
GB2951.38-86 (issued in 
December 1987, effective 
in December 1987) 
Preventive Termiticides for Cable and 
Electric Wire Treatment: Experimental 
Methods in Laboratory for the Cable and 
Electric Wire Against Termites 
Wuxi Institute of Termite 
Control, Standard 
Q/320201NBV101-2001 
(effective in 2001) 
Experimental Methods and Evaluative 
Criteria in Laboratory for the Effects of 
Termiticides against Termites  
b. 
Regulation for Pesticide Management
 (issued by MOA
 
in 1997 and revised in 
2001). This regulation aims to strengthen the monitoring and management of 
Page  21
Chapter 3: Policy, Legal and Administration Framework 
21 
 
 
the production, distribution and use of pesticides, to ensure pesticide quality, 
and to protect human and environmental health. The core measure of this 
regulation is a pesticide registration system. MOA is in charge of the 
registration of pesticides and provincial-level Departments of Agriculture 
provide assistance in pesticide registration. In China, the chlordane and mirex 
are not registered pesticides.   
c. 
State Council Order, No. 216 -  a
dministrative regulations of the People's 
Republic of China on Pesticides entered into force on May 8, 1997 and revised 
in 2001
.
This is to strengthen the supervision and management of the production, 
dissemination and use of pesticides, guarantee the quality of pesticides, protect 
agricultural production and eco-environment and the safety of human and 
animals.  The regulation sets out explicitly the provisions and requirements 
over the registration, production, dissemination and use of pesticides in PRC. 
The pesticides referred by the Regulation covers a chemical compound or a 
substance or a mixture of several substances, and prepared medicines 
originating from life-form or other natural substances used to prevent, 
eliminate or control the diseases, pests, weeds and other harmful life-form that 
endanger agriculture and forestry as well as modulate the growth of plants and 
insects. The state encourages and supports the research, production, 
manufacturing and use of safe, high effective and economical pesticides.  
d. 
No. 6 Regulation “List of Obsolete Production Capability, Techniques, and 
Products that Need to be Eliminated
 (issued by the State Economic and Trade 
Commission (SETC) in January 1999). This regulation stipulates that the 
obsolete production capability, techniques, and products included in the 
appendix of regulation should be shut down and eliminated within stated time 
limit. Effective on February 1, 1999, this regulation has listed chlordane and 
its production as one of obsolete products and technologies to be eliminated.  
e. 
No. 72 Regulation on Termite Prevention and Control in Urban Construction 
(issued by MOC in October 1999). As noted earlier, this regulation requires 
that chemicals used for termite control be registered with the Department of 
Pesticide Management as pesticides. Because chlordane and mirex are not 
registered with the Department of Pesticide Management, legally all termite 
control stations cannot use chlordane to control termite in cities. 
The Regulation applies to the management of termite prevention and control in 
urban houses in termite-stricken areas. The management of termite prevention 
and control in urban houses refers to the management of termite inspection 
and control for new buildings, renovated buildings, and old houses. The 
principle of “prevention first, combined with control and integrated 
management”should be adhered to and the pesticides approved by the relevant 
departments of the State could be used in the termite prevention and remedy of 
urban houses. The termite prevention and control unit should develop 
Page  22
Chapter 3: Policy, Legal and Administration Framework 
22 
 
 
registration system for claiming pesticides. The pesticides should be stored in 
a
special warehouse and controlled by special personnel. The state should 
encourage the scientific research of termite prevention and remedy of urban 
houses and popularize the use of new pesticides, new technologies, new 
methods and new equipments. 
f. 
Regulation for Safe Management of Hazardous Chemicals
 (issued by the State 
Council
 
in 1987 and revised in March, 2002). This regulation aims to 
strengthen the safe management of hazardous chemicals and to protect human 
and environmental health. The regulation has assigned responsibilities to 
various government agencies to supervise the production, storage, use, sales, 
transport, and registration of hazardous chemicals. 
 Article 25 specifies that appropriate measures should be taken to dispose the 
production facilities, stockpiles and the raw materials in order to root out any 
potential accident in the case of manufacture companies shutout or 
bankruptcy. The disposal scheme should be put on records to (1) the local 
department in charge of supervision and management of hazardous chemical 
safety under city-level government, (2) local Environmental Projection Bureau 
and Public Security Bureau. 
g. 
Environmental Quality Standard of Soil 
(GB15618-1995) is a national 
standard of China, which come into effect on March 1, 1996. There are three 
classes of standards: the first class standard is for protecting the regional 
natural environment, maintain the limit-value of environmental quality of soil 
in natural background; the second class standard is for protecting agriculture, 
the soil limit-value for human health protection; the third class is the soil 
critical value for protecting agriculture and forestry as well as natural 
vegetation growth. There are ten regulated contaminants including cadmium, 
arsenic, copper, lead, chrome, zinc, nickel, HCH and DDT. There is, however, 
no standard for Chlordane and Mirex.  
 
Relevant Environment Standards Outside of China 
18.
So far, only some countries such as USA and Russia had formulated the 
environmental quality and pollution control standards for chlordane, mirex, 
endosulfan and hexachlorocyclopentadiene.
1
After reviewing the data and consulting 
experts, a list of relevant standards applicable in foreign countries is presented as 
following Table 3-2. 
1
Endosulfan was another product produced at the Liyang Guanghua Chemical Company, Ltd. 
Hexachlorocyclopentadiene is a raw material for the production of chlordane. 
Page  23
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Page  25
Chapter 3: Policy, Legal and Administration Framework 
25 
 
 
19. 
Even some developed countries, which have the very stringent environment 
standards, such as Denmark and Japan, do not have no standards for soil and groundwater 
for chlordane, mirex, endosulfan and hexachlorocyclopentadiene.      
20. 
In China, there is no standard for chlordane and mirex available.  
 
Institutional Setup in China for the Management of POP   
21. 
SEPA.  
In charge of China
’s environmental protection efforts, SEPA is the 
leading agency for China’s negotiation delegation to the Stockholm Convention and 
serves the focal point for the implementation of the Stockholm Convention in China. The 
supervision and management of hazardous wastes is one of the major responsibilities of 
SEPA. Based on the Solid Waste Pollution Control Law, SEPA, working with other 
ministries, has issued a series of management methods, standards and policies on 
hazardous wastes. The main departments of SEPA involved in the implementation of 
Stockholm Convention are its Departments for International Cooperation, Pollution 
Control, Policy and Law, Science and Standards, Planning and Finance, and Monitoring 
and Supervision. In particular, the Department of International Cooperation of SEPA is in 
charge of negotiation and foreign cooperation issues, and the Department of Pollution 
Control is SEPA’s key department in charge of the implementation of the Stockholm 
Convention, the Basel Convention and the Rotterdam Convention. Specifically, the Solid 
Waste and Chemical Management Division under the Department of Pollution Control is 
in charge of the management and control of PCBs pollution in China. 
22. 
Supporting Institutions Affiliated with SEPA in Hazardous Waste 
Management.  
These institutions include the National Chemical Registration Center, the 
Solid Waste Import Registration and Management Center, and the China Technology 
Transfer and Training Center for Hazardous Waste Management and Disposal. The 
National Chemical Registration Center provides technical supports to SEPA in chemical 
management. The Center is managed by the Chinese Research Academy of 
Environmental Science, and supervised by the Solid Waste and Chemical Management 
Division of the Pollution Control Department of SEPA. In addition to managing the 
registration of chemicals imported to China for the first time and import and export of 
hazardous chemicals, the Center is also engaged in improving methods and technologies 
for chemical management.   
23. 
Since July 1, 2003, SPEA has entrusted the Chinese-Japanese Environmental 
Protection Publicity and Education Center to control the approval of the import of wastes 
to be used as raw materials. The Waste Import Registration Center affiliated with the 
Chinese-Japanese Center is in charge of such approval. 
24. 
Technology Transfer and Training Center for Hazardous Waste Management and 
Disposal is located in the Solid Waste Control and Resource Research Institute in the 
Department of Environmental Science and Engineering at Tsinghua University. The 
Center provides technical support to the negotiation of the Basel Convention and related 
training activities. 
Page  26
Chapter 3: Policy, Legal and Administration Framework 
26 
 
 
Project Administrative Arrangements 
25. 
National Leading Group (NLG) for implementation of the Stockholm 
Convention.  
China established the National NIP Development Leading Group in 
September 2003, with SEPA as the Lead Agency. The NLG provided overall guidance 
and coordination for the NIP development process at its Project Concept and Project 
Brief stages.  This Group will serve as the National Leading Group for Implementation of 
the POP Convention after China ratified the Convention on August 13, 2004.  It will 
provide (i) overall guidance to development of the NIP, (ii) review of significant policies 
related to POPs, and (iii) guidance to implementation of all POP activities.  It consists of 
11 agencies: State Environmental Protection Administration (SEPA), National 
Development and Reform Commission (SDRC), Ministry of Foreign Affairs (MOFA),  
Ministry of Finance (MOF).  MOF is the GEF Focal Point in China, Ministry of 
Commerce (MOCom), Ministry of Science and Technology (MOST), Ministry of 
Agriculture (MoA), Ministry of Public Health (MOH), Ministry of Construction (MoC), 
General Administration of Customs (GAC), and State Electricity Regulatory Commission 
(SERC).  
26. 
SEPA has been designated as the national lead agency for all POPs activities and 
for implementation of the POPs Convention.  All major national and local government, 
scientific institutions and professional termite control organizations will be involved in 
project implementation.  Roles and responsibilities of key agencies are briefly described 
as followed:  
a. 
Convention Implementation Office (CIO).  SEPA has organized a CIO for overall 
management of POPs related projects.   The CIO is part of SEPA and is 
responsible for day-to-day compliance with the Stockholm Convention. The CIO 
has set up a Termite Project team to be in charge of the day to day management 
and implementation of the proposed demonstration project under the guidance of 
the CIO, and oversee the provincial PIUs. The project will recruit a Chief 
Technical Advisor (CTA, an international consultant), a National Technical 
Advisor (NTA), and various technical experts to assist CIO in project activities.   
b.  The National Termite Control Center (NTCC)
 
under the Ministry of Construction 
will oversee policy issues and develops the Operational and Training Manual for 
use of IPM in termite control. 
c. 
Provincial Steering Group.  In each project province, key stakeholders will form a 
steering group to provide advice to provincial PIU on technical, policy, 
management and other aspects of project implementation. 
d.  Local Project Implementation Units in Zhejiang and Jiangsu (local PIUs
).
 
Zhejiang and Jiangsu provinces will establish project implementation units (PIUs) 
to conduct day-to-day project management and coordination of provincial level 
activities in their respective provinces. In Jiangsu, the Jiangsu Environmental 
Protection Bureau is leading the Jiangsu PIU. 
Page  27
Chapter 3: Policy, Legal and Administration Framework 
27 
 
 
e. 
The Zhejiang Provincial Institute for Termite Prevention and Control (ZPITPC). 
The institute is presently responsible for all training provided to termite stations 
and termite staff in Zhejiang province and for corporation between termite 
institutes/stations within the province.   
f. 
The Jiangsu Provincial Termite Association.
 
The Association will maintain its 
present role in the Province. Under the project, it will be
 
responsible for all IPM 
training to be provided to staff employed by the termite stations in the province. It 
will continue cooperation between termite institutes and stations within the 
province. 
g. 
Termite stations in Jiangsu and Zhejiang Provinces
.
The professional termite 
stations will receive IPM training and implement integrated termite management 
using bait systems instead of chlordane and mirex. As of 2004, Zhejiang has 90 
and Jiangsu has 82 provincial and municipal termite stations, all of which will be 
involved in this project. 
h.  Suppliers of bait systems. Contracts to supply bait systems will be awarded based 
on World Bank procurement rules about six month after the start of the project to 
allow domestic and international suppliers to register their products with MoA. 
Bait system will be procured periodically during the implementation period in 
order to ensure most cost effective supply of bait systems. 
 
i. 
Hazardous waste management companies
.
Hazardous waste management 
companies will be selected competitively for the closure of the Liyang Guanghua 
Chemical Company, cleaning up the production site and disposal of chlordane and 
mirex contaminated wastes. 
 
Page  28
Chapter 4: Baseline Information 
 
28 
 
Baseline information and site investigation 
 
Basic Information about Liyang  
Geographic location 
1. 
Located at south of Changzhou Municipality, Liyang City, Jiangsu Province, is at 
the intersection of Jiangsu, Zhejiang and Anhui provinces. The city is west to the Taihu 
Lake, south to the Yangtze River and north to the Tianmu Mountain. It has been known 
as the center of 
‘the land of fish and grain’ of Jiangsu and Zhejiang Provinces (see Figure 
4-1 for details). Geographically, the city is located between 31
°
1’N and 31
°
41’N, and 
between 119
°
08’E and 119
°
36’E. Its length from south to north is about 59.06 km, and 
its width from east to west is 45.14 km. The total area of Liyang City is 1,535 km
2
,
and 
the total population is 780,000 (as of 2004). 
2. 
Liyang City has a total of 18 towns and 2 provincial-level development zones (see 
Figure 4-2 for details). As one of the hundred well-known towns in Jiangsu Province, 
Licheng Town is the political, economic and cultural center of Liyang city and has a 
population of 187,000 (as of 2004) and a total area of 123.7 km
2
.
The famous Beijing-
Hangzhou Grand Canal runs through the town. 
3. 
Liyang Guanghua Chemical Company, Ltd. is located in the Liyang Economic 
and Technology Development Zone. The site is close to Niucheduo Village of Licheng 
Township, Liyang city, Jiangsu province. It is about 5 km away from the city center. See 
Figures 4.1 and Figure 4-2 for the geographic location of Liyang City and the Liyang 
Guanghua Chemical Company, Ltd., and the municipal boundary of Liyang City, 
respectively. 
4. 
Economic Information
.
In 2004, Liyang City achieved an industrial output of 
25.802 billion RMB yuan and a pre-tax profit of 2.257 billion RMB yuan. In 2004, 
Licheng Town achieved a GDP of 2.11 billion RMB yuan and an industrial output of 
4.87 billion RMB yuan. 
5. 
Geology and Physiognomy.
 Topographically, the south, west and north parts of 
the city are relatively high and hilly but the central and east parts of the city are low and 
flat. Low hills in the south part of the city are extensions of Tianmu Mountain, with 
major peaks such as Shimen Peak, Tongguan Peak and Daode Peak. The highest peak is 
Shimen Peak with an elevation of 506 meters. Low hills at the northwest part of the city 
are extensions of Maoshan Mountain, with major peaks such as Yiahuan Peak, Wawu 
Peak, and Zhishan Peak. The highest peak is Yiahuan Peak with an elevation of 410 
meters. The Liceng town is almost flat with an elevation of 5-6 meters. Overall, low hill 
areas account for 65.15% of the total area of the city, and the rest are plain areas. 
 
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Chapter 4: Baseline Information 
 
30 
 
Figure 4-2: Liyang City and the Liyang Guanghua Chemical Co., Ltd 
 
6. 
Geologically, Liyang areas are alluvial plain in ancient down warped basin
.
Most 
area of the Liyang city is covered by a 30 to 50 meters thick layer of lake alluvium 
sediments from the Quaternary epoch. The top part of this layer has low permeability and 
water is confined between sands and gravels. Consequently, ground water is not abundant 
in the area and is mainly supplied by precipitation and surface runoff at the edge of the 
basin. Soil mechanics of the area determines that bearing pressure of soil foundation is 
less than 8 ton/m
2
for locations along rivers but 12 to 20 ton/m
2
for other locations, which 
is suitable for engineering construction. Figure 4-3 shows a satellite image of the Liyang 
area. 
Page  31
Chapter 4: Baseline Information 
 
31 
 
Figure 4-3 Satellite Image of the Greater Liyang City Area 
 
7. 
Hydrology
.
Liyang is west to the Tai Lake and belongs to the Tai Lake 
watershed. Liyang City has 125 rivers with a length of 1 kilometer or more. The total 
length of rivers in Liyang is 614 km, and the annual flow of all rivers is about 0.576 
billion m
3
.
The river network density is about 0.40 km/km
2
.
Water levels of Liyang rivers 
vary between 2.50 and 6.0 meters. The highest water level occurs between July and 
September, and the lowest water level occurs between December and February.  
8. 
Climate
.
Liyang has a sub-tropic monsoon climate, with a clear division of four 
seasons. It has plentiful rainfall, a short frost season, and an annual average temperature 
of 15.5

.
The average temperatures are 3.2

in January and 31.1

in July. The average 
annual precipitation, evaporation and relative humidity are 1152.1 mm, 1558.6 mm and 
79%, respectively. The precipitation is 42.2 mm in January and 154.1 mm in July. 
Average sunlight hours are from 137.6 hours in January to 229 hours in July. The 
dominant wind is easterly wind, with an annual average wind velocity of 3.1 m/s. 
9. 
Soil
.
Parent soil material in Liyang is mainly sediments (of loess) from rivers and 
lakes. Some parts of the area do have clay (or subclay) sediments from river plains or 
sandy sediments from riverbed. 
Page  32
Chapter 4: Baseline Information 
 
32 
 
10. 
Atmospheric Environment
.
In 2004, the air quality within Liyang City is Class 
II defined by the Air Environmental Quality Standards (GB3095-1996). The annual 
average concentrations of SO
2
,
NO
2
and inhalable particles (with a diameter less than 
10
m, or PM10) in 2004 were 0.040 mg/m
3
,
0.037
mg/m
3
and 0.097 mg/m
3
,
respectively. Comparing to those of 2003, there is an increase of 0.017 mg/m
3
,
0.011 
mg/m
3
and 0.002 mg/m
3
,
respectively, in 2004. The integrated air pollution index of 2004 
was 0.82, or the air was lightly polluted. The principal air pollutant was inhalable 
particles. There was no acid rain event recorded in 2004. 
11. 
Ecological Environment
.
The local ecosystem is classified as mixed deciduous 
and evergreen forestry. However, the primary vegetation has been severely destroyed, 
and only some secondary vegetation can be found in Jilong Mountain, Xianren Mountain 
and some low hills. Such vegetation includes Rhoipteleaceae, camellia, elm, cypress, 
bamboo, etc. There are also some planted poplar, osier, metasequoia and paulownia.  
 
Liyang Guanghua Chemical Company, Ltd.   
12. 
Overview
.
Liyang Guanghua Chemical Company, Ltd. was established in June 
1989 as a collective enterprise. In 2004, the company has a production area of 15064 m
2
,
90 employees, and fixed assets of 3 million RMB yuan. Its gross revenue amounted to 80 
million RMB yuan with chlordane, mirex and endosulfan as its major products. The sales 
incomes from chlordane and mirex were 63 million RMB yuan. About 40 workers 
worked on the chlordane and mirex production facility.  
13. 
Liyang Guanghua Chemical Company, Ltd. is located in the industrial park of the 
Liyang Economy and Technology Development Zone (LETDZ). The LETDZ was set up 
in April 1992 and was approved as provincial-level economic zone in November 1993. 
The LETDZ has an area about 40 km
2
,
of
which around 10 km
2
has been developed. The 
major industries in the zone are machinery, iron steel, metallurgy and food processing. 
14. 
In 1992, the company built its chlordane and mirex production facilities at the 
current site. The site was used for agricultural purposes and had no prior industrial 
activities. From the period from 1992 to 1997, only endosulphane were produced at the 
site. The chlordane and mirex production line were added in 1997. Its site is at east of 
Zhen-Guang Highway, south of Zhong River, west of Zhaocun River and north of 
Wushen canal.  
15. 
In 2004, the company’s production facilities consisted of a combined production 
line for chlordane and mirex, heating boilers, raw material and product warehouses, a 
laboratory, a wastewater treatment facility and other auxiliary facilities. The production 
line of chlordane and mirex was built in 1997 with a capacity of 250 t/a, and was 
expanded with an investment of 0.5 million RMB yuan to a current production capacity 
of 500t/a. The production and storage facilities of chlordane and mirex cover an area of 
1000 m
2
.
The actual production of chlordane in 2004 was 180 t/a. Mirex was produced on 
orders. Due to the planned closure, the company stopped its chlordane and mirex 
production in July 2005.  
16. 
On the same site, the company also had an endosulfan production facility. The 
endosulfan production line was built in 1992 with a capacity of 300t/a. It was closed in 
Page  33
Chapter 4: Baseline Information 
 
33 
 
early 2004 as part of the Montreal Protocol program. Endosulfan production equipments 
were dismantled. The company has rebuilt its endosulfan production with a non-ODS 
technology at the Binhai Chemical Industry Park in Yancheng Municipality of Jiangsu 
Province.  
17. 
Layout of the Production Facility
.
The Liyang facilities cover a total area of 
15064 m
2
(176.6
h
85.3m
2
).  Table 4-1 provides a detailed overview of production lines, 
warehouses and other auxiliary facilities. The layout of the Liyang Guanghua Chemical 
Company, Ltd. is shown in Figure 4-4. 
Page  34
Chapter 4: Baseline Information 
 
34 
 
Table 4-1  Production Facilities at the Liyang Site 
Names of the Engineering Works 
Designed 
capacity 
Remarks 
Production device 
of endosulfan 
(dismantled) 
300 t/a 
2
workshops, covering an 
area of 163.3 m
2
,
the 
production line closed and 
dismantled in early 2004 
Major 
engineering  
works 
Production device 
of chlordane and 
mirex 
500 t/a 
Chlordane and mirex share a 
production device, covering 
an area of 500 m
2
Chlordane 
formulating 
workshop 
Warehouse 
/
175 m
2
(25m 
×
7m) 
Two separate workshop in 
one building 
Machine 
maintenance room 
Product warehouse 
/
175 m
2
(25m 
×
7m)  
Two separate workshop in 
one building 
Raw and auxiliary 
material warehouse 
/
503.4 m
2
(29.1m 
×
17.3m) 
Boiler house 
/ 
82.5 m
2
(7.3m
×
11.3m) 
Power distribution 
house 
/
Covering an area of 140 m
2
Analytical lab 
/ 
Covering an area of 80 m
2
Office 
/ 
Covering an area of 20 m
2
Warehouses 
and auxiliary 
works 
Toilet 
/ 
Covering an area of 20 m
2
Wastewater 
treatment facility 
 
4t/d 
 
Biochemical method 
covering an area of 47 m
2
Environmental 
protection 
Works 
Exhaust gas 
treatment facility 
a/
 
/
Cl and HCl disposed of with 
water and alkali absorption 
methods.
 
a/
 Exhaust gas treatment facility is part of the production facility. Therefore, it is not shown in the 
figure separately. 
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Chapter 4: Baseline Information 
 
36 
 
18. 
Surrounding Environmental Situation
.
According to the master plan of the 
Liyang City, the LETDZ (the Liyang Economy and Technology Development Zone), 
where the LGC site is located, has been planned for industrial use. As of 2005, the site of 
Liyang Guanghua Chemical Company, Ltd. is still surrounded by farmlands. The farm 
products produced are paddy rice, wheat, cotton and other melons and fruits. There are 
scattered farmers’ houses 300 meters away southwest, 150 meters away south and 600 
meters away southeast to the site (see Figure 4-4). Zhen-Guang Highway lies about 75 
meters northwest to the site. A small building next to the access road between the main 
road and the site is used as a workshop run by two people. These two people built the 
small building without the permission from the government (see Photo 4-1). They lived 
there to build cement ships. However, it is anticipated that the Liyang City government 
will request them to vacate the site before the site cleanup activities are carried out.  
19. 
The Liyang Organic Chemical Company Ltd. is located about 300 meters north to 
the site of the Liyang Guanghua Chemical Company, Ltd. The Liyang Organic Chemical 
Company is a legally independent company with 18 employees and a production area of 
3317 m
2
.
Its major products are dicyclopentene and water-soluble paint. It has a 
production capacity of 120 t/a of dicyclopentene.  
 
Photo 4-1: Boat Building Workshop Next to the Liyang Guanghua Site 
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Chapter 4: Baseline Information 
 
37 
 
20. 
Major surface water bodies surrounding the Liyang Guangha Chemical Co. Ltd. 
site are Danjin Licao River, Zhong River, Zhaocun River and Wushen Canal (see Figure 
4-5). These rivers are not used as drinking water. Water flow direction of the rivers is 
from west to east or from north to south. These rivers have been used for industrial and 
agricultural uses. According to the Year 2010 Master Plan
,
Danjin Licao River is 
classified as Class IV while Zhong River and Zhaocun River are classified as Class III. 
Based on 2004 monitoring data and the Surface Water Environmental Quality Standards 
(GB3838-2002), these rivers have a water quality of Class IV to Class V, while some 
parts of the rivers are worse than Class V. In recent years, the quality of the water bodies 
within Liyang has decreased due to the discharge of large amount of industrial and 
municipal wastewater.  
 
Figure 4-5: Major Rivers Adjacent to the Liyang Guanghua Site 
 
21. 
The river bodies directly related to the Liyang Guanghua site are Zhujiafu River 
and Wanmuqiao River, which have received pollutants from the Liyang Guanghua site 
(See Figures 4-4 and 4-5). Locations
 
and water flow directions of these two rivers are 
determined through site investigation, interviews, GPS positioning and on-site 
measurement. Due to serious eutrophication problems, it was reported that these rivers 
were only used for agricultural irrigation.  
Page  38
Chapter 4: Baseline Information 
 
38 
 
22. 
A branch of the Wanmuqiao River is located along the west boundary of the 
Liyang Guanghua Chemical Company, Ltd. This branch is the planned water body for the 
collection of wastewater from neighboring industrial areas (see Photo 4-2). 
 
Photo 4-2: Branch of the Wangmuqiao River at the Liyang Guanghua Site  
 
23. 
Five fishponds used for crab farming are located 20 meters away to the north 
boundary of the Liyang Guanghua site (see Figure 4-4). 
24. 
It is informed that Liyang Guanghua Chemical Company, Ltd. used tap water 
provided by the Liyang Tap Water Company (the water source is the Tianmu Lake) for 
equipment cleaning, product rinsing and employees
’
daily uses. However, the company 
used surface water from the branch of the Wanmuqiao River as cooling water and for 
cleaning the ground. 
25. Domestic
\03
water supply for areas around the Liyang Guanghua site is provided by 
the Liyang Tap Water Company with water taken from the Tianmu Lake. The Tianmu 
Lake is a designated water source reservoir and is protected for drinking water usage. The 
water from the lake is of generally good quality (Grade II) and consistent with the 
requirements for drinking water supply. 
26. 
There are still eight groundwater wells in the surrounding villages.  Most of them 
are not in use anymore because of the availability of tap water supply. The closest wells 
to the Liyang Guanghua site are located about 150-600 meters south, southwest and 
southeast to the site. It is noted that few residents do use ground water from some wells 
and from the rivers for bathing and laundry. According to the site investigation, the flow 
direction of the ground water is from west to east. 
27. Table 
4-2
 
lists all potential environmental risk associated with the Liyang 
Guanghua site.  
 
Page  39
Chapter 4: Baseline Information 
 
39 
 
Table 4-2  Sensitive Environmental Objects Surrounding the Project site 
Objects  
Location 
Distance to 
the Site (m) 
Scale/use 
southwest, south 
about 300 
~ 50 households, 150 people 
Residential area of 
Niucheduo Village 
South 
about 150 
~ 8 households, 24 people 
Residential area of 
Southern Village 
Southeast 
about 600 
~ 25 households, 75 people 
Workshop next to 
the access road of 
the site 
South 50 
2 
people 
Branch of the 
Wanmuqiao River 
North about 
20 
Water from the river used 
for irrigation of surrounding 
farmlands. The river 
received wastewater from 
the site. 
Fishponds North 
about 
25 
Four ponds. Used for crab 
farming 
Farmland 
East, south, west 
Surrounding 
the site 
Used for growing 
vegetables.  
Wells 
Southeast, south, 
southwest 
150-600 
Eight wells. Not used as 
drinking water for the 
residents, livestock, or 
irrigation. 
28. 
Health Impacts on Workers
.
According to the interviews and on-site survey 
with the manager and workers of the company, there was no regular medical checking for 
workers in the factory, and no evidence of any unusual health situation had been 
observed. 
29. 
Chemicals Produced or Used on Site
.
The Physical and Chemical Properties of 
the products and major raw and auxiliary material are shown in Tables 4-3 and 4-4.
\03
Data 
are from the Handbook on Safety and Technology of Hazardous Chemicals (Beijing: 
Chemical Industry Press). Additional information about chlordane, mirex and other 
chemicals used at the Liyang Guanghua site is provided in Annex 2. 
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Page  42
Chapter 4: Baseline Information 
 
42 
 
30. 
Production Equipment
.
Table 4-5 lists major manufacturing equipment used at 
the Liyang Guanghua Chemical Company, Ltd. Photo 4-3 shows chlordane, mirex, and 
production facilities, and Photo 4-4 shows abandoned endosulfan production facilities at 
the Liyang Guanghua Chemical Company, Ltd. 
 
Table 4-5  Major Manufacturing Equipment, Utilities and Storage & Transportation 
Equipments of this Project 
Type 
Name of equipment 
Specification of 
equipment 
Unit
Number 
1000L set 
1 
Reaction kettle 
500 L 
set 
3 
Decelerator / 
set 
1 
Condenser 500 
L 
set 
1 
Glass condenser 
/ 
set 
4 
Electrolytic furnace 
/ 
set 
2 
Reaction kettle  
100 L 
set 
2 
Chloride 
 And 
 Mirex 
Horizontal package boiler
1m
3
set 2 
Synthetic kettle 
500L 
set 
1 
Water decomposing kettle
500L set 
1 
Cleansing kettle 
500L 
set 
2 
Refined kettle 
500L 
set 
1 
Slicer 500L 
set 
1 
Condenser 2m
2
set 1 
Centrifugal machine  
/ 
set 
1 
Production
Endosulfan
*
Vacuum pump 
/ 
set 
3 
Environmental 
protection 
Biochemical Treatment 
equipments 
Disposal capacity4t/d
set 1 
Liquid chloride steel 
bottle 
 piece
10 
Storage and 
transportation 
Packaging material 
 
piece
1800 
*
The endosulfan equipment has been dismantled but piled up on site. 
Page  43
Chapter 4: Baseline Information 
 
43 
 
Photo 4-3: Chlordane and Mirex Production Facilities at the Liyang Guanghua Site 
 
Photo 4-4: Abandoned Endosulfan Production Facilities at the Liyang Guanghua Site 
Page  44
Chapter 4: Baseline Information 
 
44 
 
Production Process and Pollution Discharge 
31. 
Production of Chlordane
.
The raw materials for chlordane are 
dicyclopentadiene, hexachlorocyclopentadien, chlorine gas and carbontetrachloride. 
Chlordane is produced through the following two steps:  
Step 1:   C
10
H
12 
decomposed under 170
into cyclopentadiene; 
Step 2: 
C
5
Cl
6
condenses with cyclopentadiene under 75
 85
 and then 
chlorinated in CCl
4
under 70

.
32. The 
process
 
flowchart of chlordane production is shown in Figure 4-6. Wastes 
from the production are as the following: 
 
a. 
Exhaust gas. Exhaust gas is absorbed with NaOH to remove excessive Cl
2
before 
being discharged;  
b. Solid wastes:
 
dicyclopolymer waste residue;   
c. 
Wastewater: water for equipment and floor washing is collected and sen
W
to the 
wastewater treatment facility on site (see Figure 4-4 for the location) for treatment 
before being discharged into the branch of the Wangmuqiao River next to the site. 
 
(a) Production of Chlordane 
 
(a) Production of Mirex 
Figure 4-6: Process Flowchart of Chlordane and Mirex Production 
 
33. 
Production of Mirex
.
The raw materials for mirex are C
5
Cl
6
,
Al
3
Cl, CCl
4
and 
CH
3
-CH
2
-OH. Mirex is produced by C
5
Cl
6
and cyclopentadiene at the presence of Al
3
Cl. 
Raw mirex is washed with ethanol and water before being dried into the final product.  
The process flowchart for the production of mirex is shown in Figure 4-6. 
C10H12 
decomposed
C5CL6 
condenses 
chloridize
Chlordane
Cl
2
residue
Exhausted gas: 
CCl4 
C
5
Cl
6
ALO3 
reactor 
H2O
 etha
drying 
CCL4 
mirex 
Waste water 
waste gas: ethanol 
washing 
Page  45
Chapter 4: Baseline Information 
 
45 
 
34. 
Wastes from the production are as the following: 
a. 
Exhaust gas: Small quantity of ethanol gas emitted from the drying process is 
directly discharged into the air; 
b.  Wastewater: Generated from the washing process. Mirex is recovered from 
wastewater before being transferred to the on-site wastewater treatment facility. 
c.  Solid wastes: no solid wastes are produced.   
 
35. 
Production of Endosulfan
.
The raw materials for production of Endosulfan are: 
C
5
Cl
6
,
C
4
H
8
O
2
and SOCl
2
.
C
5
Cl
6
and C
4
H
8
O
2
react and form endosulfan alcohol after 
being heated at the presence of catalysts. Next, endosulfan alcohol and SOCl
2
will further 
produce endosulfan liquid under a certain temperature. Finally, endosulfan liquid is 
cooled, centrifuged and dried to endosulfan final products.   
36. 
Wastes from the production are as the following: 
a. 
Exhaust gas: HCl and Cl
2
are formed during the production process. HCl is 
absorbed with water to produce hydrochloric acid; Cl
2
is absorbed with NaOH   
b.  Wastewater: Wastewater is generated from equipment washing and is mainly acid 
water containing C
5
Cl
6
.
The insoluble C
5
Cl
6
is recycled. Alkaline liquid is used to 
adjust the pH value of wastewater before it is transferred to the on-site wastewater 
treatment facility for treatment.    
c. 
Solid waste:  A small quantity of waste residue is produced during rectification. It 
is transported for landfill.  
37. 
Disposal of Wastewater
.
During the operation of the Liyang Guanghua Chemical 
Company, Ltd., wastewater was collected and pre-treated by individual workshops and 
then sent to the on-site wastewater treatment facility. Effluent was discharged after 
meeting Class II standards of the Integrated Wastewater Discharge Standards (GB 8978-
1996) as shown in Table 4-6. Since there is no discharge standard for chlordane and 
mirex in China, chlordane and mirex in wastewater were not monitored. Photo 4-5 shows 
the wastewater treatment facility at the Liyang Guanghua Chemical Company, Ltd. 
Table 4-6  Waste Water Discharge Standard (unit:mg/L, except for pH) 
Items Limit 
Standard 
pH 6-9 
COD 150 
SS 150 
 Integrated Wastewater D
ischarge Standard
 (GB8978
-1996) 
Table 4 Class II 
38. 
Waste Disposal Records and Records of Accident
.
Liyang Guanghua Chemical 
Company provided neither waste disposal records nor accident records. EIA preparers 
were informed that there was no reported accident such as leaking, overflow in the 
history of the company. 
Page  46
Chapter 4: Baseline Information 
 
46 
 
Photo 4-5: Wastewater Treatment Facility at the Liyang Guanghua Site 
 
39. 
Remaining Equipment and Chemicals On Site
.
Table 4-7 for equipment and 
chemicals left on site after the stop of chlordane and mirex production in 2005. Photo 4-6 
shows stockpiled chlordane and mirex products on site. Photo 4-7 shows contaminated 
packaging materials. 
 
Photo 4-6: Stockpiled Chlordane (Left) and Mirex (Right) Products
Page  47
Chapter 4: Baseline Information 
 
47 
 
Table 4-7  Equipment, Chemicals and Wastes Left on the Liyang Guanghua Site 
 
Name 
      Quantity 
 Remarks 
Facilities and workshops 
Production and auxiliary 
facilities, workshops, public 
utilities for chlordane, mirex 
and endosulfan 
To be dismantled and 
disposed of 
Chlordane 16t 
Mirex 2t 
Stored in the product 
warehouse 
Hexachlorocyclopentadien 6t 
Dicyclopentadiene 5t 
Carbontetrachloride 10t 
Liquid chloride 
3t 
Sliced alkaline 
2t 
Ethanol 1t 
Stored in the raw material 
warehouse 
Plastic cask 
approximately 1500 pieces 
For hexachlorocyclo-
pentadien 200 L capacity 
Packing 
materials 
Iron drum 
approximately 300 pieces 
For CTC,200L capacity 
Dicyclopolymer residue 
150t 
/ 
Asbestos contaminated 
insulation material  
1t 
Left on steam pipes 
Acid organic wastewater 
200t 
Left in the wastewater 
treatment facility 
Contaminated soil 
/ 
To be determined 
Photo 4-7: Contaminated Packaging Materials (1 and 2, chlordane containers;  
3, raw material containers; 4, CTC drums) 
1
2
3
4
Page  48
Chapter 4: Baseline Information 
 
48 
 
Photo 4-7 (
continued.
)
(5, raw material containers filled with Chlordane; 6, raw 
material containers)
 
Environment Monitoring of the Liyang Guanghua Site  
40. 
Organizational Arrangement for the Monitoring
.
On April 1, 2005, the 
Jiangsu Academy of Environmental Science and Jiangsu Environmental Monitoring 
Center conducted a site investigation at the Liyang Guanghua facility. The site is 
relatively flat. After consulting with relevant experts and referring to relative information, 
JAES developed an Environmental Monitoring Plan. The aim of the Environmental 
Monitoring Plan was to collect sufficient environmental 
LQIRUPDWLRQ
through soil and 
water sam
S
les from the site and its surroundings to determine the extent of potential 
contamination caused by chemicals that were either used as raw-materials or produced on 
site. This baseline environmental information will determine the extent of site 
remediation action necessary to meet the requirements of the Stockholm Convention and 
national environmental standards. 
41. 
Two phases of environmental monitoring were conducted. The first phase 
monitoring was conducted in May 2005. Based on the analysis of the results of the first 
phase monitoring, the Environmental Monitoring Plan was revised and the second phase 
monitoring was conducted in September 2005.    
42. 
Environmental Monitoring Principles
.
National technical criteria adopted are 
as following:  
a. 
Soil Environment Monitoring Technical Standards (HJ/T166-2004); 
b.  Ground Water Environment Monitoring Technical Standards (HJ/T164-2004); 
and 
c. 
Surface Water Environment Monitoring Technical Standards (HJ/T91-2002). 
 
43. 
Laboratory Quality Assurance System and Control Measures (QA/QC) for 
Sampling and Analysis
.
Sampling and analyzing of samples have followed the 
Quality 
Manual
 developed by Monitoring Center of Jiangsu Province. For detailed discussion on 
QA/QC, see Annex 3. 
 
5
6
Page  49
Chapter 4: Baseline Information 
 
49 
 
First Phase of Environmental Monitoring 
44. 
Location and Layout of Sampling Points 
45. 
Ground water. 
The pollution monitoring wells were distributed according to the 
flow direction of groundwater and positions of pollution sources. The sampling points are 
numbered from GH1 to Gh14. Figure 4-7 shows groundwater depth and flows at the 
Liyang Site. Figure 4-8 and Table 4-6 for the detailed locations of sampling points.
 
46. 
Soil
.
Based on the lay-out of the Liyang Guanghua site, it was estimated that the 
production area of chlordane and mirex would be the most seriously polluted area. Based 
on technical guidelines for environmental monitoring
 and experts’ advice, Sampling 
Points 2 to 13 were selected from the potential polluted sources radiating toward the 
boundary of the site. Monitoring Point 14 was set outside of the site. At all sampling 
points, i.e. GH1 to GH14 as soil sampling points, cylinder samples were taken. Figure 4-
8
and Table 4-6 shows the distribution pattern of sampling points of the first round 
monitoring. 
47. 
Surface water
.
Two Surface water sampling points are located both in the branch 
of Wanmuqiao River next to the outlet of the wastewater treatment facility at the Liyang 
Guanghua site. The sampling points are numbered S1 and S2, respectively. See Figure 
ff
-
8
and Table 4-8 for the detailed point location. 
Page  50
Chapter 4: Baseline Information 
 
50 
 
Figure 4-7 Groundwater Depth and Flow at the Liyang Guanghua Site.
Page  51
Chapter 4: Baseline Information 
 
51 
 
Figure 4-8: Sampling Points at the Liyang Guanghua Chemical Company, Ltd.
Page  52
Chapter 4: Baseline Information 
 
52 
 
Table 4-8  Sampling Plan for Soil and Groundwater (
unit: 
g/kg
)
Sampling points 
Monitoring Factors for soil and ground water 
soil 
Ground 
water 
Depth 
(m) 
Soil 
Sample 
Number 
Hexachloro- 
cyclopentadien 
(C
5
Cl
6
)
chlorodane endosulfan mirex 
0
1-0 x 
x  x 
x 
0.1 1-1 
x 
x 
x 
x 
0.3 1-2 
x 
x 
x 
x 
0.6 1-3 
x
x
x
x
1.0 1-4 
x
x
x
x
GH1 
1.5 1-5 
x
x
x
x
0.1 2-1 
x
x
x
x
0.3 2-2 
x
x
x
x
0.6 2-3 
x
x
x
x
1.0 2-4 
x
x
x
x
1.5 2-5 
x
x
x
x
GH2 
2.0 2-6 
x 
x
x
x
0.1 3-1 
x 
x
x
x
0.3 3-2 
x 
x
x
x
0.6 3-3 
x
x
x
x
1.0 3-4 
x
x
x
x
1.5 3-5 
x
x
x
x
GH3 
2.0 3-6 
x
x
x
x
0.1 4-1 
x
x
x
x
0.3 4-2 
x
x
x
x
0.6 4-3 
x
x
x
x
1.0 4-4 
x
x
x
x
1.5 4-5 
x 
x
x
x
GH4 
2.0 4-6 
x 
x
x
x
0.1 5-1 
x 
x
x
x
0.3 5-2 
x
x
x
x
0.6 5-3 
x
x
x
x
GH5 
1.0 5-4 
x
x
x
x
0.1 6-1 
x
x
x
x
0.3 6-2 
x
x
x
x
0.6 6-3 
x
x
x
x
GH6 
1.0 6-4 
x
x
x
x
0.1 7-1 
x
x
x
x
0.3 7-2 
x 
x
x
x
0.6 7-3 
x 
x
x
x
GH7 
1.0 7-4 
x 
x
x
x
GH8 
0.1 8-1 
x
x
x
x
Page  53
Chapter 4: Baseline Information 
 
53 
 
Sampling points 
Monitoring Factors for soil and ground water 
soil 
Ground 
water 
Depth 
(m) 
Soil 
Sample 
Number 
Hexachloro- 
cyclopentadien 
(C
5
Cl
6
)
chlorodane endosulfan mirex 
0.3 8-2 
x
x
x
x
0.6 8-3 
x
x
x
x
1.0 8-4 
x
x
x
x
1.5 8-5 
x
x
x
x
2.0 8-6 
x
x
x
x
0.1 9-1 
x 
x
x
x
0.3 9-2 
x 
x
x
x
0.6 9-3 
x 
x
x
x
GH9 
1.0 9-4 
x
x
x
x
0.1 10-1 
x
x
x
x
0.3 10-2 
x
x
x
x
0.6 10-3 
x
x
x
x
GH10 
1.0 10-4 
x
x
x
x
0.1 11-1 
x
x
x
x
0.3 11-2 
x
x
x
x
0.6 11-3 
x
x
x
x
GH11 
1.0 11-4 
x
x
x
x
0.1 12-1 
x
x
x
x
0.3 12-2 
x
x
x
x
0.6 12-3 
x
x
x
x
GH12 
1.0 12-4 
x
x
x
x
0.1 13-1 
x
x
x
x
0.3 13-2 
x
x
x
x
0.6 13-3 
x
x
x
x
GH13 
1.0 13-4 
x
x
x
x
0.1 14-1 
x
x
x
x
0.3 14-2 
x
x
x
x
0.6 14-3 
x
x
x
x
GH14 
1.0 14-4 
x
x
x
x
48. 
Monitoring Parameters
.
As shown in Table 4-6, the monitoring focused on 
chlordane, mirex, endosulfan and hexachlorocyclopentadiene (a raw material used in the 
production of mirex, chlordane and endosulfan). 
49. 
Sampling Frequency
.
Soil and groundwater samples were sampled once a day. 
Surface water samples were sampled twice a day at each monitoring point. 
50. 
Sampling Method of Soil and Ground Water
.
Fourteen groundwater 
monitoring wells were drilled according to the sampling location at the site. All boring 
Page  54
Chapter 4: Baseline Information 
 
54 
 
equipment was cleaned before boring to prevent cross pollution. All boreholes were 
drilled with a helical auger, and soil was sampled in an interval of 0.5 m or so in the 
borehole.  The operator wore new gloves in each sampling. Each borehole was supported 
with packing to prevent the borehole from collapsing. During the sampling, signs of 
pollution, such as the stratum’s structure, color, odor, etc., were recorded during the 
sampling process. Soil samples were sent to the laboratory for analysis at the same day. 
51. 
The groundwater monitoring wells were built upon soil sampling holes. Each 
borehole was installed with a PVC pipe. The length of the pipe depends on the depth of 
the borehole. The PVC pipe consists of one filter tube (the slit width was 0.25mm) and a 
seamless pipe. The length of filter tube was determined by the depth of groundwater 
level. In each borehole, the lower end of the filter tube was set at the bottom of the well, 
and the upper end was 10 cm above the static water surface. Surrounding the filter tube, 
clean quartz sand with a diameter no less than 0.25mm was backfilled as the filtration 
bed to a level of 20 cm higher than the filter tube. The space between the quartz and the 
ground was left hollow. 
52. 
The monitoring wells were washed before sampling. The water pumped out from 
the wells was five times to the wells’ capacity when such water is clean and free of any 
fine particles.  
53. 
After the well was washed and kept in a static condition for a while, sampling was 
conducted. Collected samples were added with fixative and sent to the laboratory for 
analysis immediately. Before sampling, each well’s water level, PVC pipe elevation, 
ground elevation and the location of borehole were recorded. 
54. 
Selection of Analysis Method
.
Usually the analytical procedure for organic 
pollutants includes sample preparation, pre-concentration and instrument analysis such as 
GC,HPLC,GC-MS,HPLC-MS etc. GC-ECD method uses ECD as the detector and GC-
MS uses MS as the detector. The absolute sensitivity for analyzing organochlorine 
compounds using GC-ECD is higher than that of GC/MS sometimes; however the 
detection limit of GC-MS is far below than that of GC-ECD in actual application. The 
reason is that ECD identify the compounds by the compounds’ retention time, while MS 
method identify the compounds by both the compounds’ retention time and the 
compounds’ mass ion segment. Hence, it can differentiate the target compounds from the 
interference compounds having the same retention time, and improve the quantification 
accuracy. When highly concentrated (such as 10000 times of concentration), the 
concentration of many trace components is also enlarged and even higher than the 
detection limit. This means that when only GC is used, it is more difficult to get baseline 
separation, and results in two or several compounds appeared at the same retention time. 
Therefore MS detector is needed to identify target compounds by Selected Ion Mass 
Spectrum instead of Total Ion Mass Spectrum in order to obtain accurate results. For the 
reasons above, usually the concentration factor for GC-ECD is only 10-100 times, while 
the factor for GC-MS can be 10000 times. This makes GC-ECD method have higher 
detection limit. In actual monitoring, the detection limit of GC-MS is far below than that 
of GC-ECD. GC-MS is used to ppt level’s compound analysis, while GC-ECD is used to 
ppb level’s compound analysis. 
Page  55
Chapter 4: Baseline Information 
 
55 
 
55. 
In environmental monitoring, GC-ECD and GC-FID are widely used to monitor 
wastewater and exhaust gas. GC-MS is used in many background investigations for 
ambient air, groundwater and soil, except for those high concentration organic pollutants. 
56. 
For the analysis of mirex and chlordane, GC-ECD or GC-MS can either be 
selected according to the actual situation. Normally GC-MS can take in place of GC-
ECD, but not vice versa. In 2004, the Chinese National Monitoring Center adopted the 
GC/MS method for analyzing mirex, chlordane etc. in the groundwater. The US 
EPA8081 and US EPA 8270 developed the GC-ECD method earlier than that of GC-MS 
method. Although GC-MS method has high sensitivity and more accuracy, method of 
GC-ECD or GC-FID is often used in monitoring wastewater, waste solid and sediment 
thanks to the high cost of analysis of GC-MS method. 
57. 
Mirex and chlordane are persistent organic pollutants (POPs), their concentration in 
the environment are as trace as ppt level. They can be bioaccumulated in advanced 
organism
.
The amount of mirex and chlordane in soil is approximately ppt level, but can 
be biologically accumulated multimillion times in organisms at the top of the food chain. 
So usually the amount of these compounds for soil investigation is about ppt, ppm or ppb 
level. In this report, GC-MS method with more accuracy and relatively high resolution 
has been selected. 
58. 
Method of Analysis
 
•
Pretreatment method: EPA 3546 (Microwave Extraction) 
•
Analysis method of soil: EPA  8270C (Semi-volatile Organic Compounds by 
GC/MS )   
•
Analysis method of ground and surface water: EPA  525 (Organic Compounds-
LSE/ GC/MS)  
59. 
Monitoring Results
.
For the first phase monitoring, monitoring results of 
hexachlorocyclopentadiene, endosulfan, chlorodane and mirex in soil, ground water, 
surface water are shown in Tables 4-9, 4-10, 4-11, 4-12, 4-13 and 4-14 respectively.  
 
Page  56
Chapter 4: Baseline Information 
 
56 
 
Table 0-9  First Phase Monitoring Results of Hexachlorocyclopentadiene in Soil 
(Unit: mg/kg) 
Depth(meter) 
Sampling 
point 
0.0 0.1 0.3 0.6 1.0 1.5 2.0 
GH1 
0.00200 8.01000 0.01400 7.12000 0.03500 0.15300 
/ 
GH2 
/
0.00260
0.88400 1.33000 0.01640 0.01160 0.00250 
GH3 
/
0.00004
0.00510 0.06460 0.00680 0.00440 0.00320 
GH4 
/
0.01150
0.00340 0.00100 0.00160 0.01040 0.00010 
GH5 
/
0.00040
0.00032 0.00050 0.00092 
/ 
/ 
GH6 
/
0.00071
0.00004 0.00004 0.00004 
/ 
/ 
GH7 
/
0.00517
0.00585 0.00040 0.00005 
/ 
/ 
GH8 
/
0.00236
0.00272 0.00285 0.00227 0.00068 0.00009 
GH9 
/
0.00258
0.00049 0.00004 0.00181 
/ 
/ 
GH10 
/
0.00677
0.00303 0.01000  0.128 
/ 
/ 
GH11 
/
0.03450
0.04210 0.00438 0.00270 
/ 
/ 
GH12 
/
0.43000
1.72000 2.46000 3.75000 
/ 
/ 
GH13 
/
L
0.00076 0.00002 0.00004 
/ 
/ 
GH14 
/
0.00004
0.00070 0.03340 0.00343 
/ 
/ 
Note: The detection limit of Hexachlorocyclopentadiene is0.01
g/kg ( in 10g soil); 
 
L
is the detection limit; 
“/” is no sample taken 
 
Table 0-10  First Phase Monitoring Results of Endosulfan in Soil (Unit: mg/kg) 
Depth(meter) 
Sampling 
point 
0.0 0.1 0.3 0.6 1.0 1.5 2.0 
GH1 
2.510 95.200 3.050 1.160 8.610 16.000 
/ 
GH2 
/
1.780 85.400 110.000 3.770 1.950 14.200 
GH3 
/
2.130 5.260 4.410 28.600 1.880 0.271 
GH4 
/
3.920  1.320 30.700 7.980 2.890 0.853 
GH5 
/
0.979 0.531 1.360 0.328 
/ 
/ 
GH6 
/
1.040 9.220 1.160 1.300 
/ 
/ 
GH7 
/
18.600 2.430 5.930 7.180 
/ 
/ 
GH8 
/
19.200 1.960 32.500 32.900 9.480 8.940 
GH9 
/
0.007 0.180 0.634 0.060 
/ 
/ 
GH10 
/
0.091 1.270 0.200 0.090 
/ 
/ 
GH11 
/
0.709 0.610 0.307 0.225 
/ 
/ 
GH12 
/
160.000 200.000 285.000 232.000 
/ 
/ 
GH13 
/
0.084 0.804 0.317 10.700 
/ 
/ 
GH14 
/
1.280 6.580 0.116 0.495 
/ 
/ 
Note:   The detection limit of Endosulfan is0.02
g/kg ( in 10g soil); 
“/” is no sample taken 
 
Page  57
Chapter 4: Baseline Information 
 
57 
 
Table 0-11 First Phase Monitoring Results of Chlordane in Soil (Unit: mg/kg) 
Depth (meter) 
Sampling 
point 
0.0 0.1 0.3 0.6 1.0 1.5 2.0 
GH1 
2.2900 73.6000 12.9000 7.0200 36.5000 8.0300 
/ 
GH2 
/
0.4720
18.4000
21.4000
15.600
0.1640
0.6780 
GH3 
/
0.2650
8.9000
26.3000
1.0400
0.3110
0.7910 
GH4 
/
12.0000
0.2350
0.6100
0.8300
4.2400
0.8290 
GH5 
/
0.7560
0.3500
0.1730
0.4180
/
/
GH6 
/
0.5860
0.1680
0.2610
0.1870
/
/
GH7 
/
0.5200
0.8920
0.1280
0.0996
/
/
GH8 
/
0.8220
0.6590
0.8690
0.4500
0.1300
0.2610 
GH9 
/
0.1570
0.0686
0.1200
0.2860
/
/
GH10 
/
0.1030
0.2250
0.0582
3.4100
/
/
GH11 
/
0.124
0.0740
0.0801
0.8320
/
/
GH12 
/
0.5330
0.7440
3.0100
0.5070
/
/
GH13 
/
0.5820
0.0744
0.0544
0.1080
/
/
GH14 
/
0.0751
0.4070
0.0217
1.8700
/
/
Note:   The detection limit of Chlordane is0.01
g/kg ( in 10g soil); 
 
“/” is no sample taken 
 
Table 0-12 First Phase Monitoring Results of Mirex in Soil (Unit: mg/kg) 
Depth (meter) 
Sampling 
point 
0.0 0.1 0.3 0.6 1.0 1.5 2.0 
GH1 
0.2240 43.4000 0.1770  0.1860  0.5800 0.1470 
/ 
GH2 
/
0.1130 0.9830 10.0000 0.2710 0.0204  47.5 
GH3 
/
0.1230 0.4570 0.7260 0.1450 0.1070 0.0224 
GH4 
/
0.3230 0.0603 0.3930 0.5080 0.1450 0.0524 
GH5 
/
0.0823 0.0585 0.3870 0.0776 
/ 
/ 
GH6 
/
0.0175 0.0133 0.0306 0.0375 
/ 
/ 
GH7 
/
0.0017 0.0412 0.0185 0.0145 
/ 
/ 
GH8 
/
0.1230 0.1240 0.0981 0.1550 0.0820 0.1550 
GH9 
/
0.0138 0.0043 0.0035 0.0115 
/ 
/ 
GH10 
/
0.00921
0.0577
0.0202
0.0106
/
/
GH11 
/
0.0524 0.3620 0.6520 0.0764 
/ 
/ 
GH12 
/
0.2670 0.0678 0.0541 0.0243 
/ 
/ 
GH13 
/
0.0123 0.0080 0.0008 0.0286 
/ 
/ 
GH14 
/
0.1260 0.0709 0.0074 0.0598 
/ 
/ 
Note:   The detection limit of Mirex is 0.04
g/kg (in 10g soil); 
“/” is no sample taken 
Page  58
Chapter 4: Baseline Information 
 
58 
 
Table 0-13  First Phase Monitoring Result - Groundwater (Unit: 
g/L) 
 
Hexachlorocyclopentadiene Chlordane Endosulfan   
Mirex 
GH1 
0.38800 4.42000 
23.50000 
0.02370 
GH2 
0.69000 0.90800 
19.00000 
0.00256 
GH3 
1.23000 1.68000 
47.70000 
0.06500 
GH4 
0.63300 0.48000 
8.41000 
0.13800 
GH5 
0.84700 7.40000 
164.00000 
0.06300 
GH6 
0.89100 0.65200 
38.40000 
0.00686 
GH7 
1.63000 2.69000 
156.00000 
0.00783 
GH8 
0.30300 9.80000 
92.30000 
0.02710 
GH9 
1.23000 0.89600 
97.90000 
0.00463 
GH10 
0.46100 0.51800 
30.90000 
0.00479 
GH11 
0.93600 2.80000 
115.00000 
0.00266 
GH12 
1.24000 2.51000 
57.70000 
0.01150 
GH13 
0.40200 0.25500 
18.10000 
0.01180 
GH14 
0.56200 0.41300 
19.80000 
0.00363 
Detection 
limit 
0.1ng/L 0.1ng/L 
0.2ng/L 
0.4ng/L 
Table 0-14 First Phase Monitoring Result of Surface Water  (Unit:
­
g/L) 
 Sampling 
point 
Hexachloro-
cyclopentadiene 
 Chlordane 
   Endosulfan 
 Mirex 
S1 0.0786 
0.320 
4.24 
0.0006 
S1 parallel  
0.0811 
0.955 
6.49 
0.0078 
S2 0.0672 
0.621 
58.1 
0.0004 
S2 parallel  
0.0551 
0.826 
73.1 
0.0004 
Detection 
limit 0.1ng/L 
0.1ng/L 0.2ng/L 0.4ng/L 
60. 
Evaluation of First Phase of Monitoring Results
.
The monitoring results of the 
first phase were evaluated against the Preliminary Remediation Goal (PRG) reference 
levels developed by the US EPA. The reference levels serve as a concentration, which, if 
exceeded, merit further consideration and possibly additional site investigation. (For 
detailed discussion of the PRGs and their use, please see Chapter 5).  
61. 
Endosulfan and hexachlorocyclopentadiene concentrations were below the 
reference levels. The contamination with these chemicals was sufficiently low that the 
site did not merit further monitoring or investigation to obtain additional data.  
Page  59
Chapter 4: Baseline Information 
 
59 
 
62. 
Chlordane and mirex concentrations, however, exceeded the reference levels. The 
detailed comparison of the measured concentrations against PRG reference level and the 
extent of exceedance of the reference concentration are summarized in the following 
tables. Figure 4-9 shows concentrations of four different pollutants 
–
hexachlorocyclopentadiene (HEX), endosulfan, chlordane and mirex – at different depths 
at six sampling points – GH1, GH2, GH3, GH4, GH12 and GH13. These figures show 
that in general these contaminants have highest concentrations within 1 meter of depth, 
and their concentrations drop sharply after 1 meter.  
 
Figure 4-9 Soil Monitoring Results at Six Sampling Points
GH1 Monitoring Results
-2.5
-2
-1.5
-1
-0.5
0
0
20
40
60
80
100
mg/kg
m
HEX
Endosulfan
Chlordane
Mirex
GH 12 Monitoring Results
-2.5
-2
-1.5
-1
-0.5
0
0
50
100
150
200
250
300
mg/kg
m
HEX
Endosulfan
Chlordane
Mirex
GH 13 Monitoring Results
-2.5
-2
-1.5
-1
-0.5
0
02
468
10
12
mg/kg
m
HEX
Endosulfan
Chlordane
Mirex
GH2 Monitoring Results
-
2.5
-2
-1.5
-1
-0.5
0
0
20
40
60
80
100
120
mg/kg
m
HEX
Endosulfan
Chlordane
Mirex
GH3 Monitoring Results
-2.5
-2
-1.5
-1
-0.5
0
0
5
10
15
20
25
30
35
mg/kg
m
HEX
Endosulfan
Chlordane
Mirex
GH4 Monitoring Results
-2.5
-
2
-1.5
-
1
-0.5
0
0
5
10
15
20
25
30
35
mg/kg
m
HEX
Endosulfan
Chlordane
Mirex
Page  60
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Page  64
Chapter 4: Baseline Information 
 
64 
 
Second Phase Sampling and Monitoring  
63. 
Based on Phase One’s findings, a second monitoring phase was designed and 
carried in September 2005. The aim of Phase Two monitoring was to determine the 
chlordane and mirex concentrations further away from the source, and to determine the 
approximate extent of the contaminated area. Additional sampling points were placed at 
locations of suspected contamination, or in potential sensitive environmental media or 
landscape features (fishpond, residential wells, groundwater aquifer, sediments, surface 
waters). Two other chemicals, endosulfan and hexachlorocyclopentadiene, were not 
monitored in the second phase because their concentrations in the first monitoring phase 
were lower than the reference level. 
64. 
Location of Sampling Points.
 See Figure 4-8 for locations of sampling points for 
the second phase monitoring. Table 4-17 lists parameters monitored in the second phase. 
Mirex in soil (SB1) and surface water (SW1, SW2, SW3) was not sampled as its 
concentration in the first monitoring phase was generally lower than the reference level. 
 
Table 4-17 Second Phase Sampling Points and Monitored Pollutants 
Pollutants 
Sampling point
Target Depth 
(m) 
Chlordane Mirex 
Number of samples
1.5 x / 
2.0 x / 
SB1 Soil 
2.5 x / 
3
SW1  
x 
/ 
SW2  
x 
/ 
SW3 
Surface water 
 x 
/ 
3
FP1 Fish 
pond   
x 
x 
1
SED1 x 
x 
SED2 x 
x 
SED3 x 
x 
SED4 x 
x 
SED5 x 
x 
SED6 x 
x 
SED7 
Sediments  
x
x
7
MW3 x 
x 
MW7 
Surface soil 
 
x
x
2
MW1  
x 
x 
MW2  
x 
x 
MW3  
x 
x 
MW4  
x 
x 
MW5  
x 
x 
MW7 
Ground water 
 x 
x 
6
Residential well 1 
 
x 
x 
Residential well 2 
 
x 
x 
2
65. 
Monitoring Frequency.
 Surface soil, soil, sediments and ground water were 
sampled once a day. Surface water was sampled twice a day at each point.
 
Page  65
Chapter 4: Baseline Information 
 
65 
 
66. 
Analysis Method.
 
Pretreatment method: EPA 3546 (Microwave Extraction) 
Analysis method of surface soil, soil and sediments:EPA  8270C (Semi-volatile 
Organic Compounds by GC/MS )   
Analysis method of chlordane and mirex in ground and surface water:EPA  525 
(Organic Compounds-LSE/ /cap col GC 
 
67. 
Monitoring Results
.
The second phase monitoring results for chlordane and 
mirex in soil, sediments, groundwater and surface water are as follows.  
 
Table 4-18 Second Phase Monitoring Results of Chlordane and Mirex in Soil, 
Sediments, Groundwater and Surface Water
 
Samples Location 
Mirex 
Chlordane 
SED1 
0.065 mg/kg 
0.105 mg/kg 
SED2 0.057 
mg/kg 
2.09 
mg/kg 
SED3 
0.014 mg/kg 
0.110 mg/kg 
SED4 ND 
ND 
SED5 ND 
ND 
SED6 ND 
ND 
Sediment 
SED7 ND 
ND 
MW3 0.129mg/kg 
0.099 
mg/kg 
Surface soil 
MW7 ND 
ND 
SB1-1.5m / 
0.008 
mg/kg 
SB1-2.0m / 
1.66 
mg/kg 
soil 
SB1-2.5m / 
1.92 
mg/kg 
SW1 / 
ND 
SW2 / 
ND 
Surface water 
SW3 / 
ND 
MW1 ND 
ND 
MW2 ND 
ND 
MW3 ND 
ND 
MW4 ND 
ND 
MW5 ND 
ND 
Ground water 
MW7 ND 
ND 
Fish pond 
FP1 
ND 
ND 
1
ND ND 
Drinking well 
2
ND ND 
Note:  ND is None Detection 
“/”is no sample taken 
 
68. 
Monitoring Evaluation Results
.
The measured concentrations are compared to the US 
EPA PRG reference levels. Since there are no reference levels developed specifically for 
sediments, reference levels for soil are used also for evaluation of sediment. Overall, the samples 
collected during the second phase of monitoring did not exceed the reference levels. In a 
considerable number of samples, in fact, no presence of chlordane or mirex was detected. This 
Page  66
Chapter 4: Baseline Information 
 
66 
 
suggests that the contamination is well contained within the site, especially in the immediate 
vicinity of the production workshop, and the highest levels are concentrated at sampling points 
GH1, GH2, GH3 and GH 4.  Tables 4-19 and 4-20 show the evaluation results.  
 
Table 4-19  Evaluation of Second Phase Monitoring Results - Mirex 
Samples 
Sampling 
Points 
Results 
Evaluation reference 
standard
 
Met the reference 
standard 
SED1 0.065 
mg/kg 
SED2 0.057 
mg/kg 
SED3 0.014 
mg/kg 
SED4 ND 
SED5 ND 
SED6 ND 
Sediments 
SED7 ND 
0.96mg/kg 
yes 
 
MW3 0.129mg/kg 
yes 
Surface  
soil 
MW7 ND 
0.96mg/kg* 
yes 
SB1-1.5m / 
yes 
SB1-2.0m / 
yes 
Soil 
SB1-2.5m / 
0.96mg/kg 
yes 
SW1 / 
yes 
SW2 / 
yes 
Surface 
water 
SW3 / 
0.037
g/L
 
yes 
MW1 ND 
MW2 ND 
MW3 ND 
MW4 ND 
MW5 ND 
Ground 
water 
MW7 ND 
0.037
g/L
 yes 
Fish pond 
FP1 
ND 
0.037
g/L 
 yes 
1
ND 
Residential  
well 
2
ND 
0.037
g/L 
 yes 
Page  67
Chapter 4: Baseline Information 
 
67 
 
Table 4-20  Evaluation of Second Phase Monitoring Results 
–
Chlordane 
S
amples 
Sampling 
Points 
R
esults 
Evaluation reference 
standard
 
Met the reference 
standard 
SED1 
0.105 mg/kg 
SED2 2.09 
mg/kg 
SED3 0.110 
mg/kg 
SED4 ND 
SED5 ND 
SED6 ND 
Sediments 
SED7 ND 
6.5mg/kg yes 
MW3 
0.099 mg/kg 
Yes 
Surface  
soil 
MW7 ND 
6.5mg/kg 
yes 
SB1-1.5m 
0.008 mg/kg 
yes 
SB1-2.0m 1.66 
mg/kg 
yes 
Soil 
SB1-2.5m 1.92 
mg/kg 
6.5mg/kg  
yes 
SW1 
ND yes 
SW2 ND 
yes 
Surface 
water 
SW3 ND 
0.19
g/L
 
yes 
MW1 
ND 
MW2 ND 
MW3 ND 
MW4 ND 
MW5 ND 
Ground 
water 
MW7 ND 
0.19
g/L 
yes 
yes 
yes 
yes 
yes 
yes 
Fish pond 
FP1 
ND  
yes 
1
ND 
Residential  
well 
2
ND 
 
0.19
g/L
 
yes 
yes 
Pollutants Concentration Gradient Distribution 
69. 
The gradient distribution of pollutant concentration in environmental medium can 
be obtained by using the Surfer software and actual measured data (see Figure 4-10). 
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Page  69
Chapter 5: Risk Assessment 
 
69 
Risk Assessment 
 
Introduction to Risk Assessment  
 
1. 
Risk assessment is quantitative and qualitative analysis of the risk resulting from a 
specific occurrence of a contaminant, taking into account the potential harmful effects on 
human or ecological receptors. In the context of site clean up, it is the evaluation of the 
risk posed to human health or the environment by the contaminants at the site. 
 
2. 
Risk assessment serves as a basis for risk management. In the risk management 
process, the results of the risk assessment are integrated with other considerations, such 
as economic or legal concerns, to make decisions regarding the need for and 
practicability of implementing various risk reduction activities.
2
3. 
Risk assessment serves also as the basis for risk communications. In the risk 
communication process, the risk managers use risk assessment results as a basis for 
communicating risks to interested parties and to the general public.
3
4. 
Risk assessment can focus on ecological or human receptors. Ecological risk 
assessment evaluates the likelihood that adverse ecological effects may occur or are 
occurring as a result of exposure to one or more stressors. The process is used to 
systematically evaluate and organize data, information, assumptions, and uncertainties to 
help understand and predict the relationships between stressors and ecological effects in a 
way that is useful for environmental decision making. The elements of an ecological risk 
assessment include planning and scoping, problem formulation, evaluating toxicity, 
assessing exposures and characterizing risks.
4
5. 
Human health risk assessment is the characterization of the potential adverse 
health effects of human exposures to environmental hazards. It entails planning and 
scoping, identification of  hazards, evaluating toxicity, assessing exposures and 
characterizing risks.
5
The risk evaluation of the Liyang Guanghua Chemicals site is 
focusing on risk to human health risk perspective. 
 
6. 
Toxic contaminants may have two kinds of adverse health effects: cancer or non-
cancer (systemic) effects (e.g. birth defects). For carcinogenic chemicals, toxicity is 
measured as a slope factor of a curve representing the relationship between chemical 
concentration and cancer risk. For chemicals causing non-cancer effects, toxicity is 
measured using a hazard quotient (hazard index). It is a ratio of the dose of the chemical 
to the reference dose representing no adverse health effects.  
2
http://www.epa.gov/oswer/riskassessment/risk_management.htm 
3
Ibid. 
4
Ibid. 
5
http://www.epa.gov/oswer/riskassessment/basicinfo.htm 
Page  70
Chapter 5: Risk Assessment 
 
70 
7. 
For a site to constitute risk to human health, three elements must interplay: (i) 
contaminants, (ii) exposure pathways and (iii) human receptors. First, hazardous 
chemicals must contaminate the site in sufficient quantities and concentrations to cause 
health effects. Second, exposure pathways, e.g. inhalation or digestion, must exist 
through which the contaminants will reach the human receptors. Third, people must be 
exposed to those contaminants, and the exposure must be sufficient to cause health 
effects. Thus, risk evaluation considers these three elements to characterize, 
quantitatively or qualitatively, the risk from the site.
 
Acceptable Risk 
8. 
To make a decision about “how clean is clean” i.e. what level of clean up is 
necessary to achieve acceptable protection of human health and environment from the 
contaminated site, it is necessary to determine what level of risk is considered acceptable. 
The clean up is then designed to reduce contamination, or implement other measures 
(e.g., restrict access) to reduce the risk to the acceptable level. Cleaning up a site less than 
to this level would result in undue risk to some people or the environment. Cleaning up a 
site more than to the acceptable risk level would result in waste of resources for 
unnecessary remedial actions.  
9. 
Based on the US EPA practice, and adopted for the Liyang Guangua Chemicals 
clean up, the following are the generally acceptable risk levels. For carcinogenic health 
damage, the risk (probability) is considered acceptable if it is in the range between 10
-4 
and 10
-6
 (one in ten thousand and one in a million) or less.  
10. 
For non-carcinogenic (systemic) health damage, the threat is considered 
acceptable if the exposure to the site does not result in hazard index (HQ) greater than 
one, that is, if it lead to an uptake of a contaminant greater than the reference uptake 
associated with no adverse health effects.
6
11. 
For most contaminants, setting the clean up level based on the acceptable 
carcinogenic risk of 10
-4 
to 10
-6
 will also provide adequate protection from non-
carcinogenic health effects. For chlordane in industrial soil, this is true only for the risk 
range of 10
-5 
to 10
-6
.
7
At the carcinogenic risk level of 10
-4
,
the chlordane concentrations 
would exceed the level acceptable from the non-carcinogenetic perspective.
8
12. 
For interpreting and using results of risk assessment, it is essential to note that the 
risk-based concentrations of contaminants are “not very precise, and at best, are order-of 
magnitude estimates or risk.”
9
Even among scientists, different opinions exist of toxicity 
values of various chemicals. For example, for some chemicals, the safe risk-based 
6
The non-cancer health effects of chemical contaminants are evaluated using a ratio
of the dose of the 
chemical to the reference dose representing no adverse health effects. This ratio is referred to as hazard 
index or hazard quotient (HQ). Contamination levels corresponding to HQ of 1 or less are generally 
considered acceptable. 
7
Users’ Guide and Background Technical Document for US EPA Region 9’s Preliminary Remediation 
Goals (PRG) Table 
8
Ibid. 
9
Ibid. 
Page  71
Chapter 5: Risk Assessment 
 
71 
concentrations calculated by the California Environmental Protection Agency differ from 
the values calculated by the US EPA by a factor of four or more. 
 
Risk Evaluation Using US EPA PRGs 
13. 
This evaluation of risks of negative health effects from the main contaminants at 
the site is based on the US EPA Region 9 Preliminary Remediation Goals (PRGs)
10
.
PRGs are risk-based tools for evaluating and cleaning up contaminated sites. They are 
used to facilitate and standardize the risk decision-making process.  
14. 
PRGs are concentrations of different chemicals, derived from standardized 
equations combining exposure information assumptions with toxicity data that are 
considered sufficiently protective of humans, including sensitive groups, (children, 
pregnant women, elderly, etc.) over a lifetime. The PRGs are determined for different 
environmental media 
–
soil, water and air – for about 600 chemicals.  
15. 
If chemical concentrations at the site are below the PRGs levels no further 
evaluation of the site is necessary. If chemical concentrations exceed the PRG levels, it 
does not necessarily designate the site as "dirty" or trigger a response action. Rather, 
exceeding a PRG suggests that further evaluation of the potential risks that may be posed 
by site contaminants is appropriate. Such further evaluation may include additional 
sampling, consideration of ambient levels in the environment, or a reassessment of the 
assumptions contained in the PRGs (e.g. appropriateness of route-to-route extrapolations, 
appropriateness of using chronic toxicity values to evaluate childhood exposures, 
appropriateness of generic exposure factors for a specific site etc.).  
16. 
The PRGs may be used as screening goals (reference levels) or as cleanup goals. 
As screening goals, they are intended to provide health protection without knowledge of 
the specific exposure conditions at a site. As cleanup goals, they may be used when the 
exposure assumptions based on site-specific information match the default exposure 
assumptions on which the PRGs are based. When used PRGs as cleanup goals, it is 
preferred to assume maximum beneficial use of a property (that is, residential use) unless 
a
non-residential use (for example, industrial soil PRG) can be justified.  
17. 
PRGs concentrations are based on direct contact pathways for which generally 
accepted methods, models, and assumptions have been developed (i.e. ingestion, dermal 
contact, and inhalation) for specific land-use conditions. When using PRGs at a particular 
site, it is necessary to consider whether the exposure pathways and exposure scenarios at 
the site are fully accounted for in the PRGs. Based on the reconnaissance of the Liyang 
Guanghua Chemicals site, the key exposure pathways associated with its industrial use – 
ingestion, inhalation of particulates and inhalation of volatiles – are fully accounted for in 
the PRGs. The use of PRG values for industrial land, therefore, is appropriate at the 
Liyang Guanghua site. 
18. 
PRGs are chemical concentrations that correspond to a fixed level of risk. They 
correspond either to one-in-one million [10
-6
]
cancer risk or a non-carcinogenic hazard 
quotient of 1 in soil, air, and water. In most cases, where a chemical causes both cancer 
10
 This entire section is a based on the Users’ Guide and Background Technical Document for US EPA 
Region 9’s Preliminary Remediation Goals (PRG) Table. 
Page  72
Chapter 5: Risk Assessment 
 
72 
and non-cancer (systemic) effects, the PRG concentrations based on 10
-6
 cancer risk will 
result in more stringent level of protection. In some cases, the concentrations based on 10
-
5
or 10
-4 
cancer risk (which would be still within the range of acceptable cancer risk) 
would exceed the concentrations based on the non-cancer risk (i.e., they would result in 
hazard quotient greater than 1). In those cases, the clean up levels are set only within a 
limited risk range where non-cancer hazard quotient does not exceed the cancer risk-
based concentration. This is the case for one of the main contaminants at Liyang 
Guanghua Chemicals site 
–
chlordane. For chlordane at the carcinogenic risk level of 10
-
4
,
the concentrations would exceed the level acceptable from the non-carcinogenetic 
perspective. Therefore, for chlordane, the concentrations are acceptable only within the 
10
-5 
to 10
-6 
carcinogenic risk range. For example, the province of British Columbia in 
Canada set the remediation goals of 65ppm for chlordane and 9.6 ppm for mirex. These 
values are 100 and 10 times the PRG values, respectively, which is consistent with the 
PRG guidelines.   
19. 
PRGs are calculated for individual chemicals. For sites contaminated with 
multiple chemicals, the cumulative cancer risk is determined by adding up the risk for 
each chemical and compared to the acceptable risk. If the site is contaminated with 
chemicals that cause non-cancer health effects, the hazard index (HI) for each chemical is 
summed up and compared to the hazard index of 1.  
 
Table 5-1  PRGs for Chlordane and Mirex (October 2004) 
(PRGs) 
Pollutant 
Industrial soils  
Carcinogenesis based 
concentration 
(mg/kg) 
Industrial soils 
Non-Carcinogenesis based 
concentration  
(mg/kg) 
Chlordane 6.5E+00 
ca* 
4.0E+02 
Mirex 9.6E-01 
ca 
1.2e+02 
ca: PRG is based on cancer risk of 10
-6
;
it may be used within the cancer risk range of  10
-4 
to 10
-6 
to 
determine the final clean up level. 
ca*: PRG is based on cancer risk of 10
-6 
;
it may be used within the cancer risk range of  10
-5 
to 10
-6 
to 
determine the final clean up level but the concentrations in the cancer risk range of  10
-4
 would exceed the 
acceptable non-carcinogenic hazard. 
 
Evaluation of the Current Risk from Chlordane and Mirex 
20. 
Chlordane and mirex are the main contaminants of concern at the Liyang 
Guanghua Chemicals site. They were produced, packaged, transported and loaded, stored 
and otherwise handled at the site in significant quantities. Between 2000 and 2003, 150-
190 tons of chlordane and 2-4 tons of mirex were produced there annually. They have 
contaminated the site through operational spills associated with production and handling, 
especially in the immediate vicinity of the production and storage workshops. Although 
they bind strongly to soil, some portion migrated into the groundwater. The detailed 
quantitative risk evaluation, therefore, focuses on the risk from chlordane and mirex in 
soil and groundwater. The risk from chlordane and mirex in other media – air, surface 
Page  73
Chapter 5: Risk Assessment 
 
73 
water, and food 
–
is considered negligible either because of low exposure and low 
contamination, and is discussed only qualitatively. To illustrate low level of risk from 
other site contaminants – endosulfan and hexachlorocyclopentadiene – quantitative risk 
evaluation was carried out for soil and groundwater.  
 
5.4.1 QUALITATIVE EVALUATION 
 
Qualitative Evaluation of Risk from Air  
 
21. 
Chlordane is highly persistent in soil, where it sorbs strongly and very rapidly to 
organic particles
11
 and clay particles
12
.
Although it has low volatility, soil chlordane can 
vaporize under normal conditions and result in contaminated air and inhalation 
exposure.
13
 
22. 
Chlordane volatilization into the air is relevant particularly for indoor air 
contamination of homes that were treated with chlordane. Indoor air exposure to 
chlordane is listed in the US EPA Hazard Summary for chlordane among sources and 
potential exposure to chlordane.
14
 Outdoor air exposure is not listed among the sources 
and potential exposures (except for workers who applied chlordane or worked in 
chlordane treated environment).
15
 
23. 
Chlordane in the atmosphere is partially degraded by sun light, where it reacts 
with photochemically produced hydroxyl radicals
16
.
Its persistence in the air is 
significantly lower than in the soil. Its calculated half-life in the atmosphere is 2 – 7 days, 
compared to 4 – 20 years in the soil.
17
 
24. 
In the US, no measured mean chlordane concentrations in ambient air exceeded 
the allowable concentrations. The measured mean ambient concentrations of chlordane 
ranged from 1.05 nanograms per cubic meter (ng/m
3
)
or
0.06
parts per billion (ppb) from 
1979-80 in College Station, Texas, to 38.4 ng/m
3
or 2.29 ppb during 1987-88 in 
Jacksonville, Florida.
18
 All of these concentrations were lower than the US EPA 
calculated concentration of 1ug/m
3
which corresponds to a generally acceptable 10
-4
 risk 
of cancer.
19
 
11
 Usarat Pakdeesusuk, Mahmut Pulat and George M. Huddleston III, Environmental Fate Evaluation of 
DDT, Chlordane and Lindane, 1998; http://www.ces.clemson.edu/ees/lee/organochlorines.html
 
12
 
ATSDR, Public Health Assessment, Agana Power Plant, Mongmong, Guam 
13
 
ATSDR, Medical Management Guidelines 
14
 Hazard Summary, Chlordane, 2000  http://www.epa.gov/ttn/atw/hlthef/chlordan.html 
15
 Ibid. 
16
 Environmental Defense, Chlordane Scorecard  http://www.scorecard.org/chemical-
profiles/html/chlordane.html 
17
 Environmental Defense, Chlordane Scorecard  http://www.scorecard.org/chemical-profiles/text-
search.tcl?query_string=chlordane 
18
 Environmental Defense, Chlordane Scorecard  http://www.scorecard.org/chemical-
profiles/html/chlordane.html 
19
 Hazard Summary, Chlordane, 2000  http://www.epa.gov/ttn/atw/hlthef/chlordan.html 
Page  74
Chapter 5: Risk Assessment 
 
74 
25. 
Given the literature data suggesting that in the US the ambient air chlordane 
concentrations never exceeded allowable levels and short half-life of chlordane in the air, 
chlordane air emissions from the Liyang Guanghua site were not considered a significant 
source of exposure of nearby residents, and were not included in the site sampling and 
testing program. The potential short term exposure of workers involved in site 
remediation is considered significant, and will be addressed through the use of self-
contained personal respirators and other protective measures. The potential long term 
exposure of the future users of the site will be addressed through removal of the 
chlordane contaminated soils from the site.  
 
Qualitative Risk Evaluation from Chlordane Residues in Crops 
26. 
The chlordane and mirex production facility was formulating these products 
exclusively for structural pest management (termite control) as required under the 
national and local regulations.  These formulations are not suitable for agricultural use.  
In case of accidental drifts to the land surrounding the production facility, the risks of 
contaminating the food crops will be very limited. Chlordane and mirex figure among the 
organochlorine compounds with very high hydrophobicity (log K
ow
 exceeding 3), it is 
assumed that uptake into and movement through the aqueous transport system of plants 
will be minimal. The level of uptake depends on several factors including clay, organic 
matter and water content of the soil as well as the root system of the cultivated crops.    
 
27. 
The site in question is located in a wet area, with heavy clay soils and high 
organic matter content.  The most commonly grown crops are rice and leafy vegetables 
with shallow root systems. Furthermore the loss of chlordane from plants by normal 
weathering is extremely rapid. Studies by Klein and Link (1967) showed that of a starting 
load of 110 ppm, at the end of the seventh day only 7 ppm remained on kale, and only 0.1 
ppm remained after 28 days. Crops such as zucchini, pumpkins, and sugar beets have 
been reported to uptake minimal amounts of chlordane but concentrations levels were in 
the parts per billions. Therefore, it is possible that chlordane can be
 
cycled via certain 
crops but it is unlikely this will occur in the land surrounding the contaminated site 
because of the clay texture of the soil and the cultivated crops in the area.  
 
Qualitative Evaluation of Chlordane Residues in Shellfish
 
28. 
In the proximity of the chlordane and mirex production facility, there is a complex 
of man-made ponds for commercial crab production.  The pond is isolated from the 
natural water ways and the crabs are fed an artificial diet.  Crabs are typically harvested 
after 4-5 months and the pond is completely emptied and cleaned every 4 to 5 years for 
optimal production.  There is no reason to believe that the crab produced in the vicinity 
would accumulate any levels of chlordane or mirex.  Bioaccumulation of these two 
compounds is only possible through the food chain.  Consumption of crabs produced in 
the area does not present any risk of chlordane poisoning for consumers. 
 
Page  75
Chapter 5: Risk Assessment 
 
75 
Qualitative Evaluation of Risk from Surface Water 
29. 
As described in more detail in Section 4.2 on aquatic environment in the plant 
area, the small water courses are minimally utilized due to their serious eutrophication 
and high background pollution from municipal and industrial sources as well as 
aquaculture. Because of the high pollution levels, there is no use of the surface waters for 
swimming, drinking, washing, livestock watering, etc. Therefore, there is no direct 
exposure of people to the surface waters.  
30. 
PRG tables do not provide reference concentrations for surface water. For 
comparison purposes, drinking (tap) water reference levels are used (see Table 5-2). For 
chlordane, all measured concentrations in surface exceeded the PRG reference level for 
drinking water. The maximum exceedance was by a factor of 5. The risk from exposure 
to surface waters however is considered negligible, since there is no direct human 
exposure to these waters, and the drinking water in the area comes from a treated 
municipal source. Even in a hypothetical scenario of a person drinking only the untreated 
surface water, the carcinogenic risk from chlordane would not exceed the generally 
acceptable level.  
 
Table 5-2  Comparison of Chlordane and Mirex in Surface Water to PRG Reference 
Levels (Unit: 
ug/L
)
Chlordane Mirex 
Sampling 
point 
Concen
-tration
 
Reference 
level 
(PRG) 
for tap 
water
 
Amount 
Exceeding 
Standard
 
Value 
Equivalent  
to 
Standard 
Concen-
tration
 
Reference 
level 
(PRG) for 
tap water
 
Amount 
Exceeding 
Standard
 
Value 
Equivalent 
Standard 
S1 0.32 0.19 
0.13 
1.7 
0.0006 0.037 
-0.0364 
0.0 
Parallel 
with S1 
0.955 0.19 
0.765 
5.0 
0.0078 0.037 
-0.0292 0.0 
S2 0.621 
0.19 
0.431  3.3 
ND 
0.037 
-
 
-
Parallel 
with S2 
0.826 0.19 
0.636 
4.3 
ND 
0.037 
-
-
Note: The Amount Exceeding Standard is the measured value minus the standard value. The Value 
Equivalent to Standard is the result of the actual concentration divided by the standard value. ND means 
that the contaminant was not detected (its concentration was lower than the detection limit).   
 
31. 
The highest values for endosulfan and hexachlorocyclopentadiene concentration 
in surface water were 73.1ug/l and 0.0811ug/l GH7, respectively, and far below the PRG 
reference values of 220ug/l. The ratios of these values to the PRG reference value are 0.3 
and 0.0004 respectively. Similarly, the mirex concentration of surface water at all 
sampling points was below the reference level. The risk from these chemicals in the 
surface water is, therefore, considered negligible. For measured concentrations of 
endosulfan and hexachlorocyclopentadiene, please refer to Table 4-14. 
 
Qualitative Evaluation of Risk from Soil 
32. 
The soils concentrations of the principal contaminants 
–
chlordane and mirex – as 
well as two other contaminants of interest – endosulfan and hexachlorocyclopentadiene – 
Page  76
Chapter 5: Risk Assessment 
 
76 
were extensively measured at the site. The measured concentrations for chlordane and 
mirex at some sampling points exceeded the reference levels. For these chemicals, a 
quantitative risk assessment was carried out (see next section on quantitative risk 
assessment) to quantitatively determine the risk they represent. The comparison of the 
measured concentrations against the reference levels is discussed below. 
33. 
The concentrations obtained from the site sampling were compared to two 
reference levels. First, they were compared against the PRG reference level. Second, they 
were compared against the Stockholm Convention level of 50 ppm, which was adopted as 
a
clean up target for this project.  
Chlordane and Mirex
34. 
For chlordane, comparing with the PRG reference level of 6.5mg/kg (See Table 5-
1), the concentration at the following sampling points is noteworthy.  
(i) At the sampling point GH1, except in the surface layer, soil concentrations at 
all other depths are above the PRG level. The maximum concentration is 11.3 
times the PRG.  
(ii) At the sampling point GH2, the concentration in the depth between 0.3 and 
1.0 meters exceeds the PRG. The maximum concentration is 3.3 times the PRG 
value. At other depths at this sampling point, the measured concentration does not 
exceed the PRG value.  
(iii) At the sampling point GH3, only the concentration at depths of 0.3m and 
0.6m exceed the PRG reference value. At the sampling point GH4, the layer at 
0.1m away from the surface is over standard, others not exceeding the standard. 
(iv) At all other sampling points 
–
GH5, GH6, GH7, GH8, GH9, GH10, GH11, 
GH12, GH13 and GH14 – the measured concentrations are below the PRG 
reference value.  
35. 
Comparing chlordane concentrations with the adopted Stockholm Convention 
based clean up target of 50ppm, only the concentration at the depth of 0.1meters at the 
sampling point GH1 exceeds the target. For all chlordane sampling results, please see 
Table 4-11.  
36. 
For mirex, comparing against the PRG level of 0.96mg/kg, all measured 
concentrations are below the reference level, except at the depth of 0.1 meter at sampling 
point GH3 and 0.3 and 0.6 meter at sampling point GH2. The maximum exceedance of 
the measured concentration over the reference level is 45.2 times.  
37. 
Comparing mirex concentrations at the site with the Stockholm Convention based 
clean up target of 50ppm, no sampling point exceeds the standard. For detailed sampling 
results, please see Table 4-12.  
38. 
Given the exceedance of PRG reference values for chlordane and mirex, and the 
quantity of chemicals in soil, risk from soil is considered significant and is further 
evaluated quantitatively – please see section on quantitative risk evaluation.  
Endosulfan and Hexachlorocyclopentadiene
Page  77
Chapter 5: Risk Assessment 
 
77 
39. 
The highest values for endosulfan and hexachlorocyclopentadiene contents in soil 
are 285mg/kg at 0.6m of GH12 and 8.01mg/kg at 0.1m of GH1, respectively. The ratios 
of these values to the 3700mg/kg specified in PRGs of US Region 9 are 0.08 and 0.002 
respectively which are far below the reference value. Nonetheless, a quantitative risk 
assessment was carried out to illustrate the extremely low levels of risk from these non-
POPs chemicals.  
 
Qualitative Evaluation of Risk from Ground Water   
Chlordane and Mirex
40. 
Comparing the measured concentration of chlordane and mirex to the PRG 
reference level for tap water it is found that: 
(1) The chlordane concentration in ground water at all sampling points exceeds the 
reference level. The maximum exceedance was 51.6 times the reference level; 
(2) The mirex concentration was below the reference level at the sampling points 
except GH3, GH4 and GH5. The maximum exceedance of the reference value 
was 3.7 times. 
 
Table 5-3  Comparison of Chlordane and Mirex in Ground Water to PRG Reference 
Levels 
(Unit: ug/L)
 
Chlordane Mirex 
Sampling 
point
 
Concentra- 
tion 
 
Evaluation 
reference 
 
Amount 
exceeding 
standard
 
value 
equivalent 
standard 
Concentra- 
tion 
 
Evaluation 
reference 
 
Amount 
exceeding 
standard
 
value 
equivalent 
standard 
GH1 4.42  0.19 4.23 23.3 0.0237 0.037 
-0.0133 
0.6 
GH2 0.908  0.19 0.718 4.8 0.00256 0.037 
-0.03444 
0.1 
GH3 1.68  0.19 1.49 8.8  0.065 0.037 
0.028 1.8 
GH4 0.48  0.19 0.29 2.5  0.138 0.037 
0.101 3.7 
GH5 7.4  0.19 7.21 38.9 0.063 0.037 
0.026 1.7 
GH6 0.652  0.19 0.462 3.4 0.00686 0.037 
-0.03014 
0.2 
GH7 2.69  0.19 2.5 14.2 
0.00783 
0.037 
-0.02917 
0.2 
GH8 9.8  0.19 9.61 51.6 
0.0271 
0.037 
-0.0099 
0.7 
GH9 0.896  0.19 0.706 4.7 0.00463 0.037 
-0.03237 
0.1 
GH10 0.518 
0.19 0.328  2.7  0.00479 0.037 
-0.03221 0.1 
GH11 2.8 
0.19 2.61 14.7 
0.00266 
0.037 
-0.03434 
0.1 
GH12 2.51 
0.19 2.32 13.2 0.0115 0.037 
-0.0255 0.3 
GH13 0.255 
0.19 0.065  1.3  0.0118 0.037 -0.0252 0.3 
GH14 0.413 
0.19 0.223  2.2  0.00363 0.037 
-0.03337 0.1 
Note: The amount exceeding standard is the measured value minus the standard value. The value 
equivalent to standard is the result of the actual concentration divided by the standard value. 
 
41. 
Similarly to soil, because of the elevated groundwater concentrations of chlordane 
and mirex, a further quantitative risk evaluation was carried out.   
 
Endosulfan and Hexachlorocyclopentadiene
Page  78
Chapter 5: Risk Assessment 
 
78 
42. 
The highest values for endosulfan and hexachlorocyclopentadiene contents in the 
ground water respectively at GH9 and GH7 are far below the reference value of 220ug/l. 
The ratios of these values to the standard value are 0.007 and 0.45 respectively. Given the 
low concentrations, no further quantitative evaluation was carried out. 
 
Qualitative Evaluation of Risk from Sediment 
43. 
The sediment in the dead-ended branch of the Wanmuqiao River adjacent to the 
plant was suspected of high concentration of chlordane and mirex. This was because the 
river branch was a recipient of the effluent fr
om
the plant’s wastewater treatment facility, 
and was located in the proximity of the production area where the highest soils 
concentrations of chlordane and mirex were measured. Also, river courses adjacent to the 
production facilities are generally known to for occasional use as dumps for liquid and 
solid waste from the facilities. (It must be noted, however, the there is no evidence that 
there any such dumping occurred at Liyang Guanghua Chemical Company).  
44. 
The measured concentrations of chlordane and mirex in sediment, however, did 
not confirm this hypothesis. The highest chlordane concentration of 2.09 mg/kg was 
measured at sampling point SED 2, located at the discharge point of the wastewater 
treatment plant. Concentrations of about 0.1 mg/kg were measured at sampling points 
SED 1 and SED 3 within about 50 meters from the discharge point. No detectable 
concentrations were measured at other sampling points.  
45. 
The sampling results suggest that the contamination of the sediment is minimal 
when compared to the chlordane PRG soil reference of 6.5 mg/kg. The spatial pattern of 
chlordane concentrations in sediment suggest that the chlordane containing sediment is 
contained in the vicinity of the discharge point, and did not migrate out of the dead-ended 
Wanmuqiao River branch. This patter is consistent with the field observations that the 
branch has no measurable water flow, and is filled with stagnant water and overgrowing 
with weeds.   
46. 
The highest measured mirex concentration in sediment was o.965 mg/kg, well 
below the PRG soils reference level of 0.96 mg/kg. Mirex distribution in sediment 
followed similar spatial pattern as chlordane. Again, no mirex was detected in sediment 
outside the dead-ended Wanmuqiao River branch. 
47. 
Given the low concentrations of chlordane and mirex in sediment, and no 
possibility of human exposure to sediment which is permanently under several feet of 
water, the risk from chlordane and mirex in sediment is considered negligible. Since 
sediment with chlordane and mirex traces is contained in the dead-ended Wanmuqiao 
River branch, and the area does not have any sensitive aquatic life that would require 
protection from low levels of chlordane and mirex in the sediment, no further evaluation 
is considered necessary. 
 
5.4.2 QUANTITATIVE EVALUATION 
Quantitative Evaluation of Risk from Chlordane and Mirex Contamination in Soil 
 
Page  79
Chapter 5: Risk Assessment 
 
79 
48. 
Soil is the main environmental medium polluted with chlordane and mirex. The 
actual concentrations of chlordane and mirex in soil were determined by the sampling at 
fourteen sampling points at different depths during the first phase of site monitoring. 
Complementary sampling at three additional sampling points was carried out during the 
second phase of site monitoring. The measured concentrations are summarized in Tables 
4-18 and 4-19. The cancer risk associated with maximum and average value for each 
sampling point was calculated using the PRG guidelines and PRG values (see Table 5-1). 
According to the guidelines, the cancer risk was determined as a ratio of actual 
concentration to the PRG multiplied by 10
-6
.
49. 
For example, the chlordane concentration of 73.6 mg/kg 
–
the highest measured 
concentration of chlordane at the entire site (measured at depth of 10 cm at sampling 
point GH1 located between the production and storage workshops) – corresponds to 
cancer risk of 1.13E-05, calculated as 73.61mg/kg  ÷ 6.5 mg/kg x 10
-6 
.
50. 
The mirex concentration of 43.4 mg/kg – again the highest measured 
concentration at the site (measured at the same sampling point as the maximum chlordane 
concentration) – corresponds to cancer risk of 4.52E-05, calculated as 43.4 mg/kg ÷ 0.96 
mg/kg x 10
-6
.
Table 5-4 shows cancer risk for maximum and average concentration at 
each sampling point. 
 
51. 
The cumulative cancer risk from combined chlordane and mirex carcinogenesis is 
a
sum of the individual risks. For the sampling point with the highest measured 
concentration of both chlordane and mirex (sampling point GH1 at 10 cm depth), the 
cumulative cancer risk is 5.65E-05, calculated as 1.13E-05 + 4.52E-05. Table 5-4 shows 
cancer risk corresponding to the combined chlordane and mirex contamination for other 
sampling points.  
 
Page  80
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Page  81
Chapter 5: Risk Assessment 
 
81 
 
52. 
The calculation shows that the highest level or cancer risk from chlordane and 
mirex at the site is 5.65E-05. This risk is one order of magnitude smaller than the upper 
bound of acceptable cancer risk of 10E-04. Thus, remediation of the site would not be 
necessary. However, since according to PRG guidelines, chlordane concentrations 
exceeding 65 mg/kg may fall within the range that represents an unacceptable non-
carcinogenic health threat, and the highest chlordane concentration is 73.6 mg/kg, it is 
conservative to remediate the site to reduce the chlordane concentrations to levels below 
65 mg/kg.
20
 
Quantitative Hazard Evaluation from Hexachlorocyclopentadiene and Endosulfan 
in Soil 
 
53. 
Although hexachlorocyclopentadiene and endosulfan were measured in soil in 
concentrations below the reference levels, a quantitative evaluation is carried out to 
illustrate the extremely low hazard that the residues of these chemical represent at the 
site.  
 
54. 
The PRGs for both hexachlorocyclopentadiene and endosulfan are based on non-
carcinogenic health effects. According to the US EPA User Guide for the PRG table, for 
non-cancer hazard estimates, the measured concentration is divided by its respective non-
cancer PRG designated as "nc" in the PRG table. For cumulative hazard estimate from 
multiple contaminants, the ratios are then and summed up. The cumulative ratio 
represents a non-carcinogenic hazard index (HI). A hazard index of 1 or less is generally 
considered “safe”. A ratio greater than 1 suggests a need for further evaluation.  
 
55. 
For the hexachlorocyclopentadiene and endosulfan concentrations at the site the 
HI is calculated in Table 5-5.  The highest cumulative HI is 7.77E-02, which is far below 
the acceptable value of 1. This confirms that even cumulative hazard from combined 
impacts of hexachlorocyclopentadiene and endosulfan is well below the generally 
acceptable level. 
 
Table 0-5 Hazard Index of Hexachlorocyclopentadiene and Endosulfan in Soil 
(Unit: mg/kg) 
Sampling 
point 
Depth 
Hexachlorocy-
clopentadiene 
PRG (tape 
water) 
HQ Endosulfan 
PRG (tape 
water) 
HQ 
Accumulative 
HI 
0.0 
0.00203 
3700 5.49E-07 
2.510 
3700 6.78E-04 
6.79E-04 
0.1 
8.01000 
3700 2.16E-03 
95.200 
3700 2.57E-02 
2.79E-02 
0.3 
0.01380 
3700 3.73E-06 
3.050 
3700 8.24E-04 
8.28E-04 
0.6 
7.12000 
3700 1.92E-03 
1.160 
3700 3.14E-04 
2.24E-03 
1.0 
0.03510 
3700 9.49E-06 
8.610 
3700 2.33E-03 
2.34E-03 
GH1 
 
 
 
 
 
1.5 
0.15300 
3700 4.14E-05 
16.000 
3700 4.32E-03 
4.37E-03 
GH2 0.1 
0.00260 
3700 7.03E-07 
1.780 
3700 4.81E-04 
4.82E-04 
20
 According to an InterCalc table that supplements the PRG guidelines, the hazard index for chlordane at 
industrial sites for all combined soil exposure routes (inhalation, dermal contact and ingestion) equals to 
one only at 400 mg/kg. This level would be exceeded in the 6.5 mg/kg carcinogenic reference level was 
multiplied by 100, corresponding to 10E-04 carcinogenic risk. Conservatively, therefore, only level of 65 
mg/kg, corresponding to multiplication by 10 (and carcinogenic risk of 10E-05), is accepted for this 
evaluation.  
Page  82
Chapter 5: Risk Assessment 
 
82 
Sampling 
point Depth 
Hexachlorocy-
clopentadiene 
PRG (tape 
water) HQ 
Endosulfan 
PRG (tape 
water) HQ 
Accumulative 
HI 
0.3 
0.88400 
3700 2.39E-04 
85.400 
3700 2.31E-02 
2.33E-02 
0.6 
1.33000 
3700 3.59E-04 
110.000 
3700 2.97E-02 
3.01E-02 
1.0 
0.01640 
3700 4.43E-06 
3.770 
3700 1.02E-03 
1.02E-03 
1.5 
0.01160 
3700 3.14E-06 
1.950 
3700 5.27E-04 
5.30E-04 
 
 
 
 
 
2.0 
0.00245 
3700 6.62E-07 
14.200 
3700 3.84E-03 
3.84E-03 
0.1 
0.00004 
3700 1.08E-08 
2.130 
3700 5.76E-04 
5.76E-04 
0.3 
0.00514 
3700 1.39E-06 
5.260 
3700 1.42E-03 
1.42E-03 
0.6 
0.06460 
3700 1.75E-05 
4.410 
3700 1.19E-03 
1.21E-03 
1.0 
0.00679 
3700 1.84E-06 
28.600 
3700 7.73E-03 
7.73E-03 
1.5 
0.00443 
3700 1.20E-06 
1.880 
3700 5.08E-04 
5.09E-04 
GH3 
 
 
 
 
 
2.0 
0.00317 
3700 8.57E-07 
0.271 
3700 7.32E-05 
7.41E-05 
0.1 
0.01150 
3700 3.11E-06 
3.920 
3700 1.06E-03 
1.06E-03 
0.3 
0.00342 
3700 9.24E-07 
1.320 
3700 3.57E-04 
3.58E-04 
0.6 
0.00102 
3700 2.76E-07 
30.700 
3700 8.30E-03 
8.30E-03 
1.0 
0.00157 
3700 4.24E-07 
7.980 
3700 2.16E-03 
2.16E-03 
1.5 
0.01040 
3700 2.81E-06 
2.890 
3700 7.81E-04 
7.84E-04 
GH4 
 
 
 
 
 
2.0 
0.00010 
3700 2.70E-08 
0.853 
3700 2.31E-04 
2.31E-04 
0.1 
0.00004 
3700 1.08E-08 
0.979 
3700 2.65E-04 
2.65E-04 
0.3 
0.00032 
3700 8.65E-08 
0.531 
3700 1.44E-04 
1.44E-04 
0.6 
0.00005 
3700 1.35E-08 
1.360 
3700 3.68E-04 
3.68E-04 
GH5 
 
 
 
1.0 
0.00092 
3700 2.49E-07 
0.328 
3700 8.86E-05 
8.89E-05 
0.1 
0.00071 
3700 1.92E-07 
1.040 
3700 2.81E-04 
2.81E-04 
0.3 
0.00004 
3700 1.08E-08 
9.220 
3700 2.49E-03 
2.49E-03 
0.6 
0.00004 
3700 1.08E-08 
1.160 
3700 3.14E-04 
3.14E-04 
GH6 
 
 
 
1.0 
0.00004 
3700 1.08E-08 
1.300 
3700 3.51E-04 
3.51E-04 
0.1 
0.00517 
3700 1.40E-06 
18.600 
3700 5.03E-03 
5.03E-03 
0.3 
0.00585 
3700 1.58E-06 
2.430 
3700 6.57E-04 
6.58E-04 
0.6 
0.00040 
3700 1.08E-07 
5.930 
3700 1.60E-03 
1.60E-03 
GH7 
 
 
 
1.0 
0.00005 
3700 1.35E-08 
7.180 
3700 1.94E-03 
1.94E-03 
0.1 
0.00236 
3700 6.38E-07 
19.200 
3700 5.19E-03 
5.19E-03 
0.3 
0.00272 
3700 7.35E-07 
1.960 
3700 5.30E-04 
5.30E-04 
0.6 
0.00285 
3700 7.70E-07 
32.500 
3700 8.78E-03 
8.78E-03 
1.0 
0.00227 
3700 6.14E-07 
32.900 
3700 8.89E-03 
8.89E-03 
1.5 
0.00068 
3700 1.84E-07 
9.480 
3700 2.56E-03 
2.56E-03 
GH8 
 
 
 
 
 
2.0 
0.00009 
3700 2.43E-08 
8.940 
3700 2.42E-03 
2.42E-03 
0.1 
0.00258 
3700 6.97E-07 
0.070 
3700 1.89E-05 
1.96E-05 
0.3 
0.00049 
3700 1.32E-07 
0.180 
3700 4.86E-05 
4.88E-05 
0.6 
0.00004 
3700 1.08E-08 
0.634 
3700 1.71E-04 
1.71E-04 
GH9 
 
 
 
1.0 
0.00181 
3700 4.89E-07 
0.060 
3700 1.61E-05 
1.66E-05 
0.1 
0.00677 
3700 1.83E-06 
0.091 
3700 2.46E-05 
2.65E-05 
0.3 
0.00303 
3700 8.19E-07 
1.270 
3700 3.43E-04 
3.44E-04 
0.6 
0.01000 
3700 2.70E-06 
0.200 
3700 5.41E-05 
5.68E-05 
GH10 
 
 
 
1.0 
0.12800 
3700 3.46E-05 
0.090 
3700 2.43E-05 
5.89E-05 
0.1 
0.03450 
3700 9.32E-06 
0.709 
3700 1.92E-04 
2.01E-04 
0.3 
0.04210 
3700 1.14E-05 
0.610 
3700 1.65E-04 
1.76E-04 
0.6 
0.00438 
3700 1.18E-06 
0.307 
3700 8.30E-05 
8.42E-05 
GH11 
 
 
 
1.0 
0.00270 
3700 7.30E-07 
0.652 
3700 1.76E-04 
1.77E-04 
0.1 
0.43000 
3700 1.16E-04 
160.000 
3700 4.32E-02 
4.34E-02 
0.3 
1.72000 
3700 4.65E-04 
200.000 
3700 5.41E-02 
5.45E-02 
0.6 
2.46000 
3700 6.65E-04 
285.000 
3700 7.70E-02 
7.77E-02 
GH12 
 
 
 
1.0 
3.75000 
3700 1.01E-03 
232.000 
3700 6.27E-02 
6.37E-02 
0.1 
0.00001 
3700 2.70E-09 
0.084 
3700 2.27E-05 
2.27E-05 
0.3 
0.00076 
3700 2.05E-07 
0.804 
3700 2.17E-04 
2.18E-04 
0.6 
0.00002 
3700 5.41E-09 
0.317 
3700 8.57E-05 
8.57E-05 
GH13 
 
 
 
1.0 
0.00004 
3700 1.08E-08 
10.700 
3700 2.89E-03 
2.89E-03 
0.1 
0.00004 
3700 1.08E-08 
1.280 
3700 3.46E-04 
3.46E-04 
0.3 
0.00070 
3700 1.89E-07 
6.580 
3700 1.78E-03 
1.78E-03 
0.6 
0.03340 
3700 9.03E-06 
0.116 
3700 3.14E-05 
4.04E-05 
GH14 
 
 
 
1.0 
0.00343 
3700 9.27E-07 
0.495 
3700 1.34E-04 
1.35E-04 
Page  83
Chapter 5: Risk Assessment 
 
83 
Risk from Chlordane and Mirex in Groundwater  
56. 
The results from the second phase of site sampling confirm that there is no 
detectable concentration of chlordane or mirex in the residential wells nearest to the 
contaminated site. The residential well sampling data are consistent with the overall 
spatial pattern of the chlordane and mirex in soils, surface water and groundwater. The 
pattern suggests that the contamination is localized around the production and storage 
workshop, and has not migrated significantly outside of that area.  
 
57. 
Since no chlordane and mirex contamination was detected in the residential well, 
and since the wells are not use as sources of water for drinking or domestic use, there is 
no risk. However, the data from the first phase of sampling show that the groundwater at 
the contains some chlordane and mirex, even though both chemicals have only minimum 
solubility in water, and literature typically considers them simply insoluble (see table 2-3 
for solubility properties). The measured concentrations of chlordane and mirex at the site 
are summarized in table 3-7. The highest concentration of chlordane was measured at 
sampling point GH8. It was 9.8 ug/L. The highest concentration of mirex was measured 
at sampling point GH4. It was 0.138ug/L. 
 
58. 
Since it may be possible that, overtime, some contaminated groundwater would 
migrate into the residential wells, the risk evaluation, evaluates a hypothetical worst-case 
scenario that (i) contaminated ground water with unreduced chlordane and mirex 
concentrations would reach the wells and (ii) there would be some limited use of well 
water for domestic purposes due to breakdown of the central municipal water supply.  
 
59. 
The risk from the worst-case scenario is calculated using an ASTM E1739-95 
formula. 
 
The exposure (dose) of the pollutants is calculated as follows. 
E
=
(C
×CR×EF×ED) / (BW ×AT) 
 
E: exposure (available, potential dose) (mg/kg-day) 
C: mean concentration of chemical (mg/kg, mg/L) 
CR: rate of contacts contaminated medium (assuming 2L/day) 
EF: Exposure frequency, assuming 350 days per year  
ED: Exposure duration, assuming 30 years 
BW: mean body weight, assuming 60kg, adjusted to typical adult weight in China from the 
70 kg adult weight  
AT: period, when C is constant (day) assuming 70years x 365days = 25550 days 
 
The exposure (dose) for chlordane in the groundwater than is: 
E
chlordane
 =  (C(9.80 ug/L)×CR (2L/day)×EF (350 days/year)×ED (30 years)) / (BW (60 
kg)×AT (25500 days)) = 1.34× 10
-4 
mg/kg-day 
 
The exposure (dose) for mirex in the groundwater then is: 
Page  84
Chapter 5: Risk Assessment 
 
84 
E
mirex
 =  (C(0.138 ug/L)
×CR (2L/day)×EF (350 days/year)×ED (30 years)) / (BW (60 
kg)×AT (25500 days)) = 1.89× 10
-6 
mg/kg-day 
 
The actual health risk associated with such exposure is determined by the following 
formula: 
Risk = E ×SF 
 
Risk: a unit less probability (
e.g., 
1E-05) of an individual developing cancer; 
SF: Slope factor, expressed in (mg/kg-d)
-1
or toxicity expressed as a carcinogenic slope factor. 
The Integrated Risk Information (IRIS) database give the toxicity of chlordane and mirex 
expressed as a carcinogenic slope factor SF. The values are 0.35 (mg/kg.day)
-1
 for chlordane and 
1.8 (mg/kg.day)
-1
 for mirex.  
 
Therefore, risk for chlordane from groundwater is: 
 
Risk 
chlordane
 = E
 chlordane
 (1.34× 10
-4
 mg/kg.day) × SF(0.35(mg/kg.day)
-1
)
=
4.7× 10
-5
 
Risk for mirex from groundwater is: 
 
Risk 
mirex
 = E
 mirex
 (1.89× 10
-6
 mg/kg.day) ×SF(1.8 (mg/kg.day)
-1
)
=
3.4×
10
-6
 
Potential health affected persons for chlordane = Risk (4.7× 10
-5
)× Number of people 
(239)  
=
0.0117
Potential health affected persons for mirex = Risk (3.4× 10
-6
)× Number of people (239)  
=
0.000847 
 
Based on the formula and calculation shown above, the actual health risk R would be as 
shown in Table 5-6. 
 
Table 5-6   Health Risk Resulting from Groundwater Pollution 
Actual exposure 
concentration 
(
g/L)
 
Exposure 
(dose) 
mg/kg.day 
SF 
(mg/kg.day)
-1
Actual 
Health Risk 
Potential Health 
Affected Persons 
Chlordane
9.80 1.34× 
10
-4
 
0.35  
4.7× 10
-5
 0.0117 
Mirex 0.138 1.89× 
10
-6
 
1.8  
3.4× 10
-6
 0.000847 
60. 
Table 3-16 also shows the calculated values for the overall public health impact 
expressed as Potential Health Affected Persons = Actual Health Risk × Exposed Persons. 
Page  85
Chapter 5: Risk Assessment 
 
85 
61. 
Based on the site reconnaissance, the factory is about 150m from the nearest 
residential settlement of Nichuedo village with 8 households. Altogether, there are 83 
households with 249 residents in the nearby residential settlements of Nichuedo and 
Nanafang (see Table 2-2 for more detailed description).  
62. 
According to the risk assessment result, if the groundwater polluted by chlordane 
and mirex is used as drinking water, the resultant potential health risk calculated based on 
the worst situations is 4.7×10
-5
 and 3.4×10
-6 
respectively, which are within the range of 
risk levels of 10
-4
 and 10
-6
.
Therefore, there is no significant risk for individuals of the 
study area. Taking all 249 people into account, the overall risk loss will be 0.0117 
person-death and 0.000847 person-death for chlordane and mirex, respectively. This is 
much less than 1 person-death threshold considered significant by both risk scholars and 
decision-makers. 
 
63. 
It is important to reiterate that the above calculation of risk from groundwater is 
based on the worst case scenario, assuming exposure that, based on the available 
information, does not exist, and is unlikely exist in the future. As long as the exposure to 
the groundwater as drinking water remains as it is now, there is no health risk from 
chlordane and mirex in groundwater to the nearby residents and site users. Given the fact 
that chlordane and mirex bind very rapidly and strongly to clay and organic matter in soil, 
and that they are practically insoluble in water, it is unlikely that their movement through 
groundwater represents a significant route of their migration in the environment. 
Generally, these chemicals have low potential for causing significant ground or surface 
water contamination.
21
 
Hazard from Hexachlorocyclopentadiene and Endosulfan in Groundwater 
64. 
Hexachlorocyclopentadiene and endosulfan were also detected in the groundwater 
samples, albeit at low concentrations. (See Table 4-13 for sampling results). To illustrate 
the negligible health impact they would have if the groundwater was used for drinking, 
the hazard they represent is quantified in Table 5-7. Since hexachlorocyclopentadiene and 
endosulfan are non-carcinogens, the PRG calculation for non-carcinogenic substance is 
used to estimate the hazard index (see the section on hexachlorocyclopentadiene and 
endosulfan in soil for more details). For groundwater, the highest cumulative HI is 0.749, 
which is below the value of 1, indicating that no unacceptable risk from 
Hexachlorocyclopentadiene and Endosulfan in groundwater exists.  
 
Table 5-7 Hazard Index of Hexachlorocyclopentadiene and Endosulfan in 
Groundwater 
(concentration unit: ug/l) 
Sampling 
point 
Hexachloro-
cyclopentadiene 
PRG (tape 
water) 
HQ Endosulfan 
PRG (tape 
water) 
HG 
Accumulative 
HI 
GH1 0.388 
220 0.002 
23.5 
220 0.107 
0.109 
GH2 0.690 
220 0.003 
19.0 
220 0.086 
0.090 
GH3 1.230 
220 0.006 
47.7 
220 0.217 
0.222 
21
 Usarat Pakdeesusuk, Mahmut Pulat and George M. Huddleston III, Environmental Fate Evaluation of 
DDT, Chlordane and Lindane, 1998; http://www.ces.clemson.edu/ees/lee/organochlorines.html
 
Page  86
Chapter 5: Risk Assessment 
 
86 
GH4 0.633 
220 0.003 
8.4 
220 0.038 
0.041 
GH5 0.847 
220 0.004 
164.0 
220 0.745 
0.749 
GH6 0.891 
220 0.004 
38.4 
220 0.175 
0.179 
GH7 1.630 
220 0.007 
156.0 
220 0.709 
0.717 
GH8 0.303 
220 0.001 
92.3 
220 0.420 
0.421 
GH9 1.230 
220 0.006 
97.9 
220 0.445 
0.451 
GH10 0.461 
220 0.002 
30.9 
220 0.140 
0.143 
GH11 0.936 
220 0.004 
115.0 
220 0.523 
0.527 
GH12 1.240 
220 0.006 
57.7 
220 0.262 
0.268 
GH13 0.402 
220 0.002 
18.1 
220 0.082 
0.084 
GH14 0.562 
220 0.003 
19.8 
220 0.090 
0.093 
Evaluation of Post-Cleanup Risk From Chlordane and Mirex 
65. 
Based on the guidance from Stockholm and Basel Conventions, China adopted 50 
ppm as a target clean up level for chlordane and mirex at Liyang Guanghua Chemicals 
site. The analysis below shows that cleaning up the site to the 50 ppm level will render 
the site sufficiently clean to pose no unacceptable risk of damage to human health 
(concentration of other contaminants at the site are already below the reference levels, 
hence the clean up decision is based on chlordane and mirex). The analysis is based on 
the PRG methodology introduced earlier.  
66. 
According to PRG guidelines for cancer risk estimates (both chlordane and mirex 
are carcinogens), the site-specific concentration is divided by the PRG reference levels 
for cancer evaluation and multiplied by 10
-6
 to estimate chemical-specific risk for a 
reasonable maximum exposure. For multiple pollutants, add the risk for each chemical.  
Therefore: 
RISK = actual concentration / PRG 
×
10
-6
 
So: 
Log (risk) = log (actual concentration/PRG) - 6 
Negative logarithm of risk ( - Log (risk) ) = 6 - log (actual 
concentration/PRG) 
If actual concentration equals to PRG, then negative logarithm of risk will be 6.  
67. 
For chlordane, if the concentration is 50 ppm and PRG is 6.5ppm, therefore, 
actual concentration divided by PRG (50/6.5) will be 7.69. Log (7.69) equals to 0.89. 
Then the negative logarithm of risk will be 5.11. That means that the 50ppm 
concentration of chlordane will cause the risk of 10
-5.11
 or 7.69× 10
-6
.
This is well within 
the range of generally acceptable cancer risk of 10
-4
 and 10
-6
.
68. 
For mirex, if the concentration is 50 ppm and PRG is 0.96ppm, therefore, actual 
concentration divided by PRG (50/0.96) will be 52.08. Log (52.08) equals to 1.72. Then 
the negative logarithm of risk will be 4.28. That means that 50ppm concentration of 
mirex will represent the risk of 10
-4.28
 or 5.21× 10
-5
.
This again is well within the range of 
generally acceptable cancer risk of 10
-4
 and 10
-6
.
Page  87
Chapter 5: Risk Assessment 
 
87 
69. 
The relationship between the chemical concentration and risk for chlordane and 
mirex is shown in Figures 5.1 and 5.2. 
70. 
In Figure 5.1 and Figure 5.2, the points with 50ppm chlordane and mirex are 
marked. 
Cancer Risk of Chlordane
ff
ff\11breve
breve
breve\11breve
caron
caron\11breve
fl
fiflfl
fflflfl
ffiflfl
ffflfl
breveflfl
caronflfl
\1aflfl
concentration(ppm)
n
e
g
a
t
i
v
e
l
o
g
a
r
i
t
h
m
o
f
c
a
n
c
e
r
r
i
s
k
\0bbrevefl\0fbreve\11fifi\0c
 
Figure 5-1   Carcinogenic risk of chlordane 
 
Cancer Risk of Mirex
ff
ff\11breve
breve
breve\11breve
caron
caron\11breve
fl
fflfl
fffl
caronfl
dotaccentfl
fiflfl
fifflfl
concentration
ppm
n
e
g
a
t
i
v
e
l
o
g
a
r
i
t
h
m
o
f
c
a
n
c
e
r
r
i
s
k
\0bbrevefl\0fff\11ffldotaccent\0c
 
Figure 5-2 Carcinogenic risk of mirex 
 
71. 
The combined carcinogenic risk from both chlordane and mirex at 50 ppm level is 
a
sum of the individual risks of the two chemicals. It is 10
-4.22
 (6.02×10
-5
). Again, this is 
well within the range of generally acceptable cancer risk. The non-carcinogenic hazard 
Page  88
Chapter 5: Risk Assessment 
 
88 
index (HI) corresponding to the combined chlordane and mirex exposure from the site is 
a
cumulative value from individual HI for chlordane and mirex. The cumulative HI for 
chlordane and mirex at 50 ppm concentration is 0.541, which again is well below the 
threshold value of 1
.
As shown in the calculations above, the 50 ppm clean up level sets 
adequate protection against combined health impact of chlordane and mirex in soil, either 
from the carcinogenic or non-carcinogenic perspective. As in other risk calculations in 
this document, the standard exposure assumptions used to develop PRG values are 
considered valid also for Liyang Guanghua Chemicals site.   
 
72. 
For detailed technical guidance on calculating risk, please refer to 
Users’ Guide 
and Background Technical Document for US EPA Region 9’s Preliminary Remediation 
Goals (PRG) Table.
 
The carcinogenic and non-carcinogenic concentrations for 
chlordane and mirex in soil used for the calculation can be found in the 
Region 9 2004 
PRG Table. 
The documents are available online at www.epa.gov/region09/waste/sfund/. 
 
Page  89
Chapter 6: Remediation Alternatives 
 
89 
 
Remediation Alternatives   
 
1. 
Challenges exist in conducting remediation at the site, and China in general, due 
to the current lack of (1) any jurisdictional environmental quality standards or 
preliminary remediation goals (PRGs) and (2) experience in POP site remediation. As 
part of the demonstration project, there is a particular need to establish a process for 
assessing the most appropriate technology and remedial options at this site, which will 
serve as a model for future activities of this nature.    
2. 
Given the baseline information presented in the previous sections, the principal 
contaminant of concern is chlordane, and the main medium is contaminated soils. In 
addition, the project requires dismantling and disposal of the production line, disposal of 
raw materials and obsolete stocks, contaminated packaging materials, asbestos 
contaminated insulation materials, 200 tons of wastewater and sludge stored in the water 
treatment facility. The following discussions on available cleanup technologies are 
extracted from a report prepared for the project with actual case studies.
22
 
General description of Available Technologies  
3. 
Traditional methods of treating soils contaminated with halogenated semi-volatile 
organic pesticides include thermal processes (e.g., incineration, thermal desorption), 
chemical processes (e.g., dechlorination), and excavation and off-site disposal in a 
landfill. The USEPA Treatment Technologies for Site Cleanup: Annual Status Report 
(Eleventh Edition) lists 100 Superfund Remedial Action projects that involved organic 
pesticides and herbicides from fiscal year 1982 to 2002 (USEPA, 2004a). Soil remedial 
technologies employed at these sites (number of sites involved) were as follows: 
ƒ
incineration (36),  
ƒ
bioremediation (25),  
ƒ
solidification/stabilization (14),  
ƒ
thermal desorption (9),  
ƒ
soil vapor extraction (3),  
ƒ
physical separation (3),  
ƒ
in-situ thermal treatment (3),  
ƒ
chemical treatment (2),  
ƒ
soil washing (2),  
ƒ
flushing (1),  
ƒ
phytoremediation (1), and 
ƒ
solvent extraction (1).  
3. 
Pesticides at Superfund sites were treated most often by incineration followed by 
bioremediation and thermal desorption; the relatively high number of bioremediation 
projects may be attributed to its use for non-chlorinated pesticides. The use of 
22
 Royal Roads University, 2005. Case Study on POPs Alternatives for Termite Control: Remedial Options for 
Chlorinated Pesticides Contaminants at the Liyang Guanghua Chemical Plant. 
Page  90
Chapter 6: Remediation Alternatives 
 
90 
 
bioremediation to treat contamination by more persistent chlorinated pesticides is 
emerging and is discussed later in this report.   
4. 
Groundwater may be treated in situ or ex situ. In situ technologies that have been 
employed for groundwater contaminated with chlorinated pesticides and herbicides 
include air sparging, treatment walls, chemical treatment and bioremediation. In situ 
remedial technologies used for chlorinated pesticides and herbicides in groundwater from 
fiscal year 1982 
–
2001
at USEPA Superfund sites included the following: 
ƒ
air sparging (5),  
ƒ
bioremediation (7),  
ƒ
chemical treatment (1),  
ƒ
multiphase extraction (1),  
ƒ
permeable reactive barrier (2) and 
ƒ
phytoremediation (1).   
5. 
Ex situ groundwater remediation involved pump and treat, using technologies 
such as activated carbon adsorption, UV oxidation, high energy destruction and 
bioremediation.   
6. 
The remediation of chlordane, mirex and other possible contaminants at the 
Liyang Guaghua Chemical Plant using the main technologies for soil and groundwater 
listed in the previous paragraphs is presented in this report. The application of each 
remedial option to the site is evaluated using the following criteria: 
 
ƒ
Ability to Meet Remedial Objectives
 –
the suitability for the remedial option to 
reduce contaminants to acceptable levels that is protective of human and 
environmental health is considered.  
ƒ
Proven Technology
 –
the track record of the technology with respect to its use at 
other sites in China is considered. Factors considered include whether the 
technology has been used at a real site, or whether pilot studies have been 
conducted in the field or laboratory with the demonstrated ability to be scaled-up 
to field use.  
ƒ
Potential for Toxic Residual Compounds
 –
some remedial options may potentially 
produce intermediate and/or residual compounds with toxicity equal to or even 
greater than the targeted contaminant.  
ƒ
Logistics
 –
the suitability and availability of the technology including the number 
of commercial suppliers that can design, construct, deliver and maintain the 
technology in China; availability of a suitable work area, e.g., if excavation and 
stockpiling is required, would there be a suitable location on-site for setting up the 
stockpile area?  
ƒ
Potential Impact to Tenants, Visitors, Other Site Users and Other Receptors 
During Implementation
 –
site works during the implementation of some remedial 
alternative may pose the risk of adverse environmental impacts, in addition to the 
existing contaminants on-site. For example, contaminated water generated during 
remedial activities may impact surface water adjacent to the site.   
Page  91
Chapter 6: Remediation Alternatives 
 
91 
 
ƒ
Public and Land Owner Acceptability
 
–
will the approach be acceptable to the 
public? In particular, the “not in my backyard (NIMBY) syndrome” for the 
disposal of contaminated materials is considered here.  
ƒ
Implementation Timeline
 – the time required to conduct the cleanup using the 
technology is considered.  
ƒ
Environmental Risks and Uncertainties
 –
potential risks include accidental spills, 
excavation slope failure, and encountering larger volumes or higher 
concentrations of waste than anticipated during the prior characterization, and/or 
generating large quantities of groundwater. 
ƒ
Relative Cost
 –
if more than one remedial technology is feasible, capital costs for 
construction and implementation of the different technologies may be a major 
factor in the decision of a remedial option.  Costs include planning construction, 
implementation, operation, maintenance and/or monitoring. 
 
7. 
Each of these factors are discussed under “advantages” and “limitations” for each 
technology and a brief overview of the applicability of the technology to the site and 
specific requirements are provided. Searches were conducted using “EPA REACH IT” 
(http://www.epareachit.org/), the US EPA Innovative Technologies databases 
(http://cfpub.epa.gov/asr/search.cfm), Science Direct (http://www.sciencedirect.com/) 
and other sources for case examples of each technology. 
 
8. 
The most effective technology and cleanup strategy (or combination of strategies) 
will be that which provides the best balance amongst the criteria listed above, as well as 
others. In some cases, greater weighting may be placed on one criterion (e.g., costs, 
regulatory acceptance) over others.  
 
Natural Attenuation 
9. 
Description of the Technology
.
Soil and water has physical, chemical and 
biological characteristics that can enable volatilization, adsorption, chemical and 
photochemical reactions and biodegradation processes, to reduce contaminants to 
acceptable levels. Natural attenuation or intrinsic remediation is a risk-based management 
process that relies on these existing natural conditions to provide remediation. In order to 
consider this option, the site should be well characterized. Using site specific properties; 
such as contaminant concentrations and volumes, groundwater plume depths and flow 
rates, and soil properties such as organic matter, pH and moisture content; modeling is 
conducted to predict degradation rates, pathways and potential contaminant 
concentrations in receptors. The modeling is conducted to demonstrate that natural 
process occurring at the site will eventually reduce the contaminants to acceptable levels 
and that there will be minimal risk to receptors if the contaminants are left in place. A 
long term monitoring program is instituted to confirm that degradation is occurring at 
rates consistent with meeting the cleanup objectives. 
10. 
Natural attenuation is usually applied to fuel hydrocarbons, volatile organic 
compounds (VOCs, e.g., carbon tetrachloride), Semi-Volatile Organic Compounds 
(SVOC, e.g., cyclopentadienes) and some pesticides (AFCEE, 2005; FTTR, 2005a). 
Page  92
Chapter 6: Remediation Alternatives 
 
92 
 
11. 
Volatilization from soil is a major loss mechanism for chlordane; the rate depends 
on parameters such as the soil organic content, water content, temperature, and relative 
humidity as well as adsorption to soil. In general, sandy soils and soils with small 
amounts of organic matter retain chlordane less than soils with high clay and/or organic 
content, or moisture. Soil moisture is the most important factor. Chlordane does not 
degrade rapidly in water and no information is available on whether chlordane undergoes 
photochemical reactions in the aquatic environment (ATSDR, 1994).  
12. 
Mirex can undergo photodecomposition in water to yield photomirex with the rate 
increasing with increasing dissolved organic matter (ATSDR, 1995). Photolysis, aerobic 
and anaerobic biodegradation of mirex in soils is very slow (ASTDR, 1995).  Endosulfan 
released to soil will most likely be subjected to photolysis (on soil surfaces), hydrolysis 
(under alkaline conditions), or biodegradation (ATSDR, 2000). 
13. 
Advantages of Monitored Natural Attenuation 
ƒ
The overall relative cost is generally lower than active remediation; 
ƒ
There will be less generation and handling of contaminated materials; 
ƒ
Technical requirements for the implementation will be available in China; 
ƒ
Potential impact of remedial activities on-site users, visitors, and other ecological 
features will be minimal; and 
ƒ
It can be used with other remedial technologies or as a follow up to other intrusive 
remedial measures 
14. 
Limitations of Monitored Natural Attenuation 
ƒ
The application of monitored natural attenuation for this project will require that 
there is a framework in place for the robust assessment of its performance. This 
will require additional site data to model site-specific, natural attenuation 
potential;  
ƒ
The long term effectiveness of natural attenuation for chlordane and mirex is 
unknown and a risk assessment will be required; 
ƒ
Site physical and chemical conditions may change with time resulting in 
remobilization of stabilized contaminants (the stability of current in-place 
contaminants at the site is also not known); 
ƒ
The contaminants may migrate into the adjacent river before they are degraded;  
ƒ
Intermediate degradation products may be more mobile and more toxic than the 
parent materials. For example photo-isomerization of chlordane can occur in the 
environment leading to photoisomers that are more toxic than chlordane; and 
mirex has been shown to produce intermediate compounds, e.g., kepone, which 
are persistent;  
ƒ
Longer time frames (years) will be required to achieve remediation objectives, 
compared to active remediation. The site will not be available for reuse until 
contaminant levels are reduced.  
ƒ
Long term monitoring is required, with associated costs; and 
ƒ
It may not be acceptable to the public on the basis of perceived exposure and 
extensive consultations may be needed in order to gain public acceptance. 
Page  93
Chapter 6: Remediation Alternatives 
 
93 
 
15. 
Applicability in China. 
The natural attenuation of chlorinated pesticides such as 
chlordane and mirex is very slow, especially in cooler climates, and the applicability of 
this to the Liyang Guaghua Chemical Plant may not be practical at this point due to data 
limitations. It may be suitable after removal of the highly contaminated substrate. The 
application of monitored natural attenuation to the residual contaminants will require the 
establishment of a framework for the robust assessment of its performance. This 
framework will need to include suitable strategies for monitoring the degradation of 
chlordane, mirex, and other contaminants in situ and predicting the potential for natural 
attenuation. Contingency plans will also be needed in case the contaminants do not 
behave as predicted by the model. Data requirements include: 
ƒ
Soil and groundwater quality data including volume and distribution of chlordane, 
mirex and other contaminants; 
ƒ
Physical characteristics of soil and geochemical data to assess the potential for the 
degradation of the contaminants including soil pH, total organic carbon (TOC), 
redox potential (E
h
).  For example, very high or very low pH levels will limit 
microbial diversity and biodegradation, while sorption of the pesticides will be 
greater in soils with a higher TOC. Since evaporation is the major route of 
removal from soils and sediments, sorption can significantly reduce pesticide 
degradability;  
ƒ
Location of potential receptors including groundwater wells and potential surface 
water discharge points;  
ƒ
A
risk assessment to indicate the measures are protective of human and 
environmental health; and 
ƒ
Determination of the monitoring requirements to validate that degradation of the 
contaminants is occurring including suitable monitoring locations, frequency, and 
surrogate data as part of a risk management plan. 
 
Bioremediation  
16. 
Description of the Technology.
 Bioremediation uses microorganisms to degrade 
organic contaminants and convert them to biomass, intermediate products, and 
byproducts such as carbon dioxide, methane, and inorganic salts. It is suitable for soil, 
sediment, sludge, wastewater and groundwater. The key environmental conditions that 
affect biodegradation include pH, soil moisture content, temperature, and nutrient 
concentration.  In 
Enhanced
 
Bioremediation
,
the degradation process is accelerated by 
providing nutrients, microorganisms, and oxygen. Treatabilty studies, which determine 
the biodegradability of the contaminants, identify intermediates and byproducts, and 
disclose ways to enhance the process, are usually required to determine the feasibility of 
application.  
17. 
Enhanced bioremediation can be conducted in situ or ex situ using either aerobic 
or anaerobic processes. In enhanced aerobic bioremediation, nutrients, electron acceptors 
(usually oxygen) and microorganisms are introduced to accelerate the natural 
biodegradation process. Oxygen is introduced by either air sparging, circulating hydrogen 
Page  94
Chapter 6: Remediation Alternatives 
 
94 
 
peroxide or by using solid phase peroxide.  For anaerobic bioremediation, nitrate (the 
electron acceptor) is circulated throughout the contaminated media to enhance 
degradation. In ex-situ bioremediation, contaminated soils are excavated while 
groundwater is pumped out of the aquifer, mixed with amendments and placed in a 
treatment cell. Water is treated in bioreactors while soils are placed in cells that have 
leachate collection systems and some form of aeration. Moisture, heat, nutrients, oxygen, 
and pH are monitored and controlled to enhance biodegradation. Ex-situ bioremediation 
technologies include bioreactors, biofilters, land farming and some composting methods; 
while in-situ bioremediation technologies include bioventing, biosparging, biostimulation 
and liquid delivery systems. A basic summary and current status of the use of 
bioremediation to treat pesticide contaminated media has been provided by Frazar
23
 
(2000). Additional details on bioremediation and its application may also be obtained 
from the Federal Remediation Technologies Roundtable (FRTR)
24
.
18. 
Bioremediation techniques have been successfully used to remediate soils, 
sludges, and ground water contaminated with petroleum hydrocarbons, solvents, 
pesticides, wood preservatives, and other organic chemicals. They are especially effective 
for remediating low level residual contamination after source removal (FRTR, 2005b). 
The application of bioremediation to organochlorine remediation is, however, limited to a 
few laboratory studies or bench scale experiments.   
19. 
Various studies have shown the biodegradability of endosulfan by a wide variety 
of soil microorganisms including fungi (28 species) and soil bacteria (15 species).  
Endosulfan sulfate was the major product of fungal metabolism, whereas bacterial 
transformation produced endosulfan diol (ATSDR, 2000). Its half-life is dependent on the 
type of isomer and has been reported to be up to 60 and 800 da
ys, for the 
-
and
-
isomers respectively.  Only a few microorganisms capable of degrading chlordane have 
been isolated and the literature indicates that chlordane can persist in soils for more than 
20 years (ATSDR, 1994).  Degradation of mirex in soil may occur by anaerobic 
biodegradation with an estimated half-life of 10 years (ASTDR, 1995). The lignin 
degrading white rot fungi, 
Phanerochaete chrysosporium
,
was found to extensively 
degrade chlordane by Kennedy et al. (1990) suggesting it may also be useful for 
degrading chemical constituents such as chlordane, lindane, and DDT.  
20. 
Advantages of Bioremediation
 
ƒ
The overall cost is generally lower than active remediation, especially if 
conducted in situ; 
ƒ
There is less generation and handling of contaminated materials if the remediation 
is conducted in-situ; 
ƒ
Low technological requirements; 
ƒ
It can be used with other remedial technologies or as a follow up to other intrusive 
remedial measures after the removal of highly contaminated materials. 
21. 
Limitations of Bioremediation
 
23
 http://clu-in.org/download/studentpapers/frazar.pdf 
24
 http://www.frtr.gov/matrix2/section4/4_2.html 
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Chapter 6: Remediation Alternatives 
 
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ƒ
Bioremediation of pesticide-contaminated soils/groundwater is still in the 
developmental phase.  
ƒ
Before any full-scale bioremediation project can begin, treatability studies must 
be conducted;  
ƒ
Byproducts of contaminant transformation are sometimes hard to predict; 
ƒ
Compared to active remediation, a longer time frame may be needed to achieve 
remediation objectives due to the persistence of chlordane and mirex; 
ƒ
Cleanup objectives may not be attained if the soil matrix prohibits contaminant-
microorganism contact; 
ƒ
High concentrations of chlorinated organics may be toxic to the microorganisms; 
ƒ
Additional site data on the soil environment including soil characteristics, pH, and 
TOC is needed;  
ƒ
The circulation of water-based solutions through the soil during enhanced in-situ 
bioremediation may increase contaminant mobility;  
ƒ
In-situ enhanced bioremediation may not be suitable for clay, highly layered, or 
heterogeneous subsurface environments because of oxygen (or other electron 
acceptor) transfer limitations. 
ƒ
Preferential flow paths may be generated for the injected fluids which will 
severely decrease contact between the fluids, organisms and contaminants 
throughout the contaminated zones.  
22. 
Applicability of Bioremediation. 
There is considerable experience around the 
world on using bioremediation for treating volatile and semi-volatile organic 
contaminants in general; however, the application of bioremediation to chlorinated 
pesticides is limited.  Therefore, this EIA will not suggest the use of this technology at 
the Liyang site.  
 
Incineration 
23. 
Description of the Technology.
 This technology uses high temperatures (870 to 
1200
O
C) and oxidizing atmospheres to destroy waste by converting organic or biological 
materials to H
2
O
and CO
2
and other inorganic gases. It is used to treat soils, sediments, 
sludge, and other solid and liquid wastes. It is not applicable to groundwater. Normally 
the heat required is generated from the combustion of the organic material contained in 
the waste or by adding supplemental fuel. Organic substances commonly destroyed by 
incineration include alcohols, ketones, xylene, methyl ethyl ketone (MEK) and ethyl 
acetate. It is a proven technology for the destruction of organochlorine wastes - including 
PCBs and pesticides such as DDT and chlordane - in soil, sediment and sludge. Off gases 
require treatment to remove particulates and neutralize and remove acid gases (HCl, 
NOx, and SOx). The US EPA regulations for incineration require the destruction and 
removal efficiency to exceed 99.99% for principal organic hazardous wastes and 
99.9999% for PCBs and dioxins (FRTR, 2005d). Combustion residuals (ash) can be 
disposed of in a landfill if they meet safety regulations, otherwise they must be treated. 
Incineration may be conducted on-site using a transportable unit or waste may be 
transported off-site to a central facility.  
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Chapter 6: Remediation Alternatives 
 
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24. 
Hazardous waste incinerators may be classified into the following, based on the 
type of combustion chamber: 
·
Rotary kiln 
–
primary chamber is a slightly-inclined, rotary cylinder lined with 
refractory materials that serves as the combustion chamber and operates at 
temperatures up to 980
O
C. Waste leaving the kiln is passed through an after-
burner to complete the process followed by a quench, and an air pollution control 
system; 
·
Fixed-hearth incinerators – may contain single multiple hearths in which the 
combustion occurs; 
·
Fluidized bed incinerators – a bed of granular solid is suspended in air above the 
waste to remove hazardous gas and ash products; 
·
Plasma incinerators – extremely hot plasma is generated by injecting ionized air 
through an electric arc; and 
·
Infrared systems – intense IR radiation is generated by passing electric current 
through silicon carbide heating elements. 
25. 
Advantages of Incineration
 
·
Incineration is a proven technology that has frequently been used to remediate 
organochlorine compounds; 
·
It provides a nearly complete destruction of contaminants; 
·
Treatment duration is short- to long-term depending on the volume of 
contaminated materials;  
·
Applicable to a wide variety of media; and 
·
Incineration may be conducted on-site, yielding transport cost savings. 
26. 
Limitations of Incineration
 
·
High costs – Internationally, treatment costs for soils contaminated with PCBs or 
dioxins cost $1,650 to $6,600 USD per metric ton ($1,500 to $6,000 per ton) to 
incinerate” (FRTR, 2005d). 
·
Metals if present, can react with other elements in the feed stream, such as 
chlorine or sulfur, forming more volatile and toxic compounds than the original 
material;  
·
Emission controls are needed to prevent the release of pollutants such as dioxins, 
furans, NOx, SOx and particulates; 
·
Complex supporting infrastructure are needed, including analytical laboratories 
for emission monitoring; and, 
·
Potential public concerns with emissions. Some community groups have opposed 
the operation of hazardous waste incinerators in their communities.  . 
27. 
Applicability. 
Incineration is the recommended technology for the destruction of 
chlordane by dissolving it in a flammable solvent and incinerating it under controlled 
conditions (ATSDR, 1994).  Incineration is also the recommended method for the 
disposal of mirex (ATSDR, 1995) and endosulfan (ATSDR, 2000). The disposal of 
obsolete stockpile of pesticides at the site including chlordane and mirex could be 
achieved through incineration. Therefore, highly contaminated soils at the Liyang site 
may be treated by this technology.   
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28. 
As noted, the cost per unit for destruction is extremely high for incineration and it 
may not be the preferred choice on the basis of economics. In addition to identifying soil 
contaminants and their concentrations, other information on soil properties, including soil 
moisture content and classification, and particle size distribution will be required. Soil 
particle size data allows an accurate estimation of the dust loading in the system for 
proper design of the air pollution control equipment. A test burn will need to be 
conducted to determine performance and cost, followed by a detailed cost analysis. The 
incinerators need to be operated efficiently in order to ensure destruction and removal 
efficiency of over 99.9999%. Failure to ensure proper design can potentially result in the 
production of dioxins and furans that can lead to severe health and environmental 
concerns.  
 
Thermal Desorption  
29. 
Description of the Technology. 
Thermal desorption involves volatilization of the 
contaminants and water by heating them to temperatures between 90 to 560 °C. A carrier 
gas or vacuum system is then used to transport the volatilized water and organics to a gas 
treatment system to remove particulates and contaminants. Particulates are removed by 
conventional particulate removal equipment, such as wet scrubbers or fabric filters. 
Contaminants are removed through condensation followed by carbon adsorption, or they 
are destroyed in a secondary combustion chamber or a catalytic oxidizer. Based on the 
operating temperature of the desorber, thermal desorption processes can be categorized 
into two groups: high temperature thermal desorption (HTTD) and low temperature 
thermal desorption (LTTD). In HTTD, the waste is heated to temperatures between 320 
and 560 
O
C, whereas the wastes are heated to between 90 and 320 
O
C
for LTTD. LTTD 
has the advantage of retaining most of the soil’s physical properties and, as such, can be 
re-used on-site after remediation. The targets of this technology include a range of semi-
volatile organic, PAH, PCBs, and organochlorine pesticide contaminated soils, sediments 
and sludges. It is not considered suitable for liquids (FRTR, 2005f).  
30. 
Advantages
 
·
It provides a nearly complete destruction of contaminants; 
·
Duration is short- to long-term depending on the volume of contaminated 
materials; 
·
May be conducted on-site yielding transport cost savings; and 
·
Soil can be reused on site for low temperature thermal desorption. 
31. 
Limitations
 
ƒ
Soils and sediments with high moisture content may require dewatering (drying) 
to achieve suitable feedstock moisture content levels; 
ƒ
Heavy metals in the feedstock may produce solid residual that requires further 
treatment; 
ƒ
High organic matter content soils increase reaction time as a result of binding of 
contaminants;  
ƒ
Clays and silty soils may cause poor performance of the thermal desorption 
technology, as a result of caking and strong binding of contaminants; 
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98 
 
ƒ
If operating conditions are not optimal, excessive particulate and volatile air 
emissions can occur; and 
ƒ
High capital and high operation and maintenance costs. 
32. 
Applicability. 
As of 2005, there is no information about the availability and 
applicability of this technology in China. The GEF supported China PCB Management 
and Disposal Demonstration Project will purchase one thermal desorption unit and use it 
for the clean-up of contaminated soil with low PCB concentration (50-500ppm) after 
2007. This unit may be available for the clean-up of the contaminated soil at the Liyang 
site. 
33. 
The costs of thermal desorption may be less than that of incineration since it has 
lower energy requirements. This technology will be a suitable candidate for the 
remediation of chlordane contaminated soils. Apart from contaminant concentrations, 
information on other soil properties including soil moisture content, classification, and 
particle size distribution will also be required. Soil particle size data is again needed to 
determine dust loading in the system, which is essential for air pollution control 
equipment parameters. A test burn will also be needed to determine performance and 
costs, followed by a detailed cost analysis. The furnace will need to be operated 
efficiently in order to ensure destruction and removal efficiency of over 99.9999%. 
Failure to ensure proper design can potentially result in the production of dioxins and 
furans that can lead to severe health and environmental concerns. 
 
Vitrification  
34. 
Description of the Technology. 
Vitrification, also known as glassification is a 
high temperature process of immobilizing waste that produces a glass-like solid. It can be 
used to treat media contaminated with organic, inorganic or radioactive materials. The 
waste is combined with glass constituents such as silicon dioxide (SiO
2
), sodium 
carbonate (Na
2
CO
3
), calcium oxide (CaO) or borax (B
2
O
3
). An electric current is then 
used to heat (melt) and vitrify the contaminated material. The organic contaminants in the 
soil being treated are pyrolized (decomposed) and are generally reduced to simple gases. 
Inorganic contaminants are incorporated into the molten soil which solidifies into a glass-
like solid. Gases are collected through a stainless steel hood placed over the treatment 
area and subsequently treated. It can be conducted in-situ or ex-situ.  
35. 
Advantages of Vitrification
 
ƒ
It can be conducted in situ thereby minimizing waste handling; 
ƒ
It can deal with multiple contaminants at the same time; 
ƒ
It provides complete destruction of organic contaminants; 
ƒ
It is a proven technology. 
36. 
Limitations of Vitrification
 
ƒ
It is very energy intensive (temperatures of up to 1300
o
C
are required) and 
consequently expensive; 
ƒ
Accessibility to sufficient power supply is needed; 
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ƒ
Environmental conditions may affect the long-term immobilization of some 
contaminants;
 
ƒ
Treatability studies are generally required;
 
ƒ
Larger particles, such as coarse gravel or cobbles are undesirable for vitrification, 
while smaller particles may limit the effectiveness by slowing vapor release; 
ƒ
Long-term effectiveness has not been demonstrated for some contaminants; and 
ƒ
Off-gases for organic contaminants require treatment;  
ƒ
Use or disposal of the resultant slag is required; and 
ƒ
Regulatory and public acceptance is low. 
37. 
Applicability. 
This technology is not recommended for remediation at the Liyang 
Guaghua Chemical Plant for the following reasons: 
ƒ
There is little experience worldwide on the use of vitrication to the destruction of 
organochlorine contaminants (including chlordane, mirex and endosulfan); 
ƒ
Specialized equipment required may not be currently available in China; 
ƒ
High energy requirements;  
ƒ
Possibility exists of releasing toxic off gases such as dioxins and furans; and 
ƒ
Long term stability has not been demonstrated for some contaminants. 
 
Pyrolysis 
38. 
Description of the Technology. 
In pyrolysis the organic contaminant is heated in 
an oxygen deficient atmosphere leading to decomposition. The organic materials are 
transformed into gaseous components, small quantities of liquid and a solid residue 
containing fixed carbon and ash. The gases require treatment and this can be 
accomplished in a secondary combustion chamber, flared, or partially condensed. 
Particles are also generated and may be treated using conventional particulate removal 
equipment such as fabric filters or wet scrubbers. The equipment used is similar to that of 
incineration (i.e., rotary kiln, rotary hearth, fluidized bed), with the exception that lower 
temperatures and less oxygen are required for combustion. The target contaminant groups 
for pyrolysis are semi-volatile organics and pesticides (FRTR, 2005g).  
39. 
Advantages of Pyrolysis
 
ƒ
Equipment similar to that of incineration and so may be available in China; 
ƒ
Complete destruction of waste 
ƒ
Medium time frame 
40. 
Limitations
 
ƒ
Pyrolysis is an emerging technology with limited data for its application to 
chlordane, mirex and endosulfan; 
ƒ
There are specific feed size and materials handling requirements that impact 
applicability or cost at specific sites;  
ƒ
The technology requires drying of the soil to achieve a low soil moisture content 
(< 1%), otherwise high moisture content increases treatment costs; and 
ƒ
Treated media containing heavy metals may require stabilization prior to final 
disposal (FRTR, 2005).  
Page  100
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41. 
Applicability. 
No case examples on the use of pyrolysis for chlordane and mirex 
remediation are noted in the remedial literature. Therefore, this EIA will not recommend 
this technology for the remediation of the Liyang site. 
 
Chemical Treatment  
42. 
Description of the Technology. 
In chemical treatment methods, a chemical 
reaction is used to convert the contaminants into innocuous substances. Methods 
available for chlorinated organic compounds include Base Catalyzed Decomposition 
(BCD), Glycolate/Alkaline Polyethylene Glycol (APEG), Gas Phase Chemical Reduction 
(GPCR) and Chemical Oxidation. 
43. 
Base Catalyzed Decomposition (BCD).
 
The BCD process involves treatment of 
the contaminated liquid, soil or sediment in a reactor with fuel oil, alkali metal hydroxide 
(e.g., sodium hydroxide) and a proprietary catalyst. The mixture is heated to above 300 
°C in a reactor. The reagents produce atomic hydrogen which decomposes the 
contaminants yielding carbon and inorganic salts. The carbon and salts are separated 
from the oil by gravity or centrifugation. The oil and catalyst is recovered and reused in 
other treatments (UNEP, 2005). 
44. 
Glycolate/Alkaline Polyethylene Glycol (APEG).
 
In the APEG process an alkaline 
polyethylene glycol (APEG) reagent (e.g., potassium polyethylene glycol) is mixed with 
the contaminated soils and heated in a treatment vessel. The reaction between the APEG 
reagent and halogenated compounds renders the halogenated compounds non-toxic 
through the replacement of halogen molecules (e.g. chlorine) by polyethylene glycol 
molecules. Treatment of the wastewater generated by the process may include chemical 
oxidation, biodegradation, carbon adsorption, or precipitation (Environment Canada, 
2005). 
45. 
Gas Phase Chemical Reduction (GPCR).
 
This involves the gas phase chemical 
reduction of organic compounds by hydrogen at temperatures of over 850
O
C. Chlorinated 
hydrocarbons, such as PCBs, HCB, dioxins, furans and other POPs, are chemically 
reduced to methane and hydrogen chloride. GPCR is capable of treating waste with high 
POP concentrations including aqueous and oily liquids, soils, sediments, transformers 
and capacitors (UNEP, 2005). Gases leaving the reactor are scrubbed to remove water, 
heat, acid and carbon dioxide. Scruuber residue and particulate is disposed off-site. 
46. 
Advantages of Chemical Treatment
 
ƒ
The BCD process has the advantages of not requiring very high temperatures, 
high pressure, or energetic reagents; 
ƒ
BCD can be used as a final treatment step other processes such as thermal 
desorption; 
ƒ
Air emissions are relatively minor for BCD; and 
ƒ
The technologies are amenable to small-scale applications. 
47. 
Limitations of Chemical Treatment
 
ƒ
High capital and high operation and maintenance costs; 
Page  101
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ƒ
High clay and moisture content will increase treatment costs;  
ƒ
The APEG technology is generally not cost-effective for large waste volumes;  
ƒ
Concentrations of chlorinated organics greater than 5% require large volumes of 
reagent;  
ƒ
With the BCD process, capture and treatment of residuals (volatilized 
contaminants captured, dust, and other condensates) may be difficult, especially 
when the soil contains high levels of fines and moisture; and 
ƒ
Use of hydrogen in GPCR requires suitable controls and safeguards. 
48. 
Applicability of Chemical Treatment. 
While the costs of these technologies 
may be slightly lower than that of incineration, they require proprietary technology and 
equipment that are currently not available in China in addition to the limitations listed 
above. They are not recommended for adoption for this project. 
 
Excavation and Disposal in a Secure Landfill  
49. 
Description of the Technology. 
This is not a treatment system per se; the 
contaminants are relocated to a safer site where contaminant migration into the 
surrounding ecosystem is curtailed. The contaminated material is excavated and 
transported to a permitted hazardous waste landfill for disposal. The landfill is equipped 
with a cover and specialized liners to prevent infiltration and contaminant migration, and 
monitoring systems are installed to ensure system integrity. Excavation and off-site 
disposal is applicable to a full range of contaminants, including organochlorine 
pesticides.  There area a number of different categories of secure landfills in operation in 
Canada and the US designed to accept specified waste by regulations.  The construction, 
operation, maintenance and monitoring of these landfills are heavily regulated. Before 
waste is accepted into the landfill, it generally undergoes a leaching test such as the Toxic 
Characteristics Leaching Protocol (TCLP 
–
US EPA SW 846 Method 1311; 
http://www.epa.gov/epaoswer/hazwaste/test/pdfs/1311.pdf).  The TCLP is designed to 
test the mobility of the contaminants present in the waste. The waste is leached with an 
extraction fluid designed to mimic leachate generated in a landfill followed by chemical 
analysis of the leachate. Analyte concentrations in the leachate are compared to the 
regulatory levels. If the values exceed the regulatory limits, the waste is designated as 
toxic. Treatment of leachable waste (e.g., by stabilization) is required before its 
placement into designated landfill.  
50. 
Advantages of Excavation and Disposal in a Landfill
 
ƒ
The main advantages is the contaminant is removed in a short time frame; 
ƒ
Low technology requirements; and 
ƒ
Public acceptance is generally high. 
51. 
Limitations of Excavation and Disposal in a Landfill
 
ƒ
Fugitive emissions may be generated during excavation; 
ƒ
Overall costs can be high due to transportation costs and landfill tipping fees; 
ƒ
Transport of the soil through populated areas may affect community acceptability; 
ƒ
Contaminants are not treated but simply moved from one location to the other; 
Page  102
Chapter 6: Remediation Alternatives 
 
102 
 
ƒ
Potential exists for the migration of contaminants from the secure landfill 
(without careful monitoring and controls); and 
ƒ
Long term monitoring of the landfill is required; 
ƒ
Regulatory acceptance is low because treatment of contaminant is preferred. 
52. 
Applicability of Excavation and Disposal in a Secure Landfill. 
This 
technology is very cost effective and ready available in China. Therefore, this EIA 
recommends this technology for the Liyang site. Additional data requirements for this 
option will be the TCLP (toxic characteristics leaching procedure) or an equivalent test 
for leaching properties depending on the concentration of contaminants.  
 
Pump and Treat  
53. 
Description of the Technology. 
The main objective of groundwater pumping is 
to remove contaminated water from an aquifer and prevent contaminant migration 
through groundwater. Following a detailed site characterization and risk analysis a 
decision will be made as to whether pumping is necessary. If pumping is chosen the 
criteria for well design, pumping system and treatment method is then determined. 
Factors that need to be considered in designing the pumping system include hydraulic 
conductivity, the extent of the groundwater contaminant plume in three dimensions, and 
aquifer soil properties. However, the first question in designing a pumping recovery well 
system is whether pumping is even feasible. If the hydraulic conductivity is too low 
(below 10
-5
 cm/sec) or the hydrogeology is very complex and variable pumping is not 
feasible (FRTR 2005h). Once the groundwater is retrieved to the surface it must be 
treated to destroy the contaminants prior to discharge.  Treatment technologies available 
for organochlorine pesticides include granulated activated carbon (GAC)/liquid phase 
carbon adsorption, advanced oxidation and chemical treatment. These are briefly 
described below. 
54. 
Granulated Activated Carbon (GAC)/Liquid Phase Carbon Adsorption.
 The 
groundwater is pumped through a series of canisters or columns containing activated 
carbon to which the dissolved organic contaminants adsorb. The effluent is monitored 
and when contaminants in the effluent exceed the cleanup level, the activated carbon is 
replaced. The spent carbon is regenerated or removed and disposed off at a licensed 
facility. 
55. 
Advanced Oxidation.
 
Advanced oxidation processes use UV light, ozone or 
hydrogen peroxide to destroy the organic contaminant as the groundwater flows into the 
treatment tank. Oxidation of the contaminants results in the formation of carbon dioxide, 
water and salts. If ozone is used, the off gas is treated to destroy residual ozone before 
discharge.   
56. 
Advantages of Pump and Treat
 
ƒ
Pumping is a commercially available technology that can be easily implemented 
using conventional pumps in wells or trenches; 
ƒ
Cost is low to moderate; 
Page  103
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103 
 
ƒ
Treatment by granulated activated charcoal (GAC) is a well established technique 
and has been used to treat municipal, industrial, and hazardous waste streams;  
ƒ
GAC is relatively non-specific and is effective for removing many organic, 
explosive, and some inorganic contaminants; 
ƒ
Practically any organic contaminant that is reactive with the hydroxyl radical can 
potentially be treated by advanced UV oxidation, for example chlorinated 
hydrocarbons that are generally resistant to oxidation but they may be treated by 
UV/oxidation; 
ƒ
The contaminant is destroyed in UV/oxidation and chemical treatment compared 
to other techniques such as GAC and air stripping. 
57. 
Limitations of Pump and Treat
 
ƒ
Time frame require to reach remedial goal may be long; 
ƒ
Pumping is not applicable to aquifers with hydraulic conductivity of less than 10
-5
 
cm/sec; 
ƒ
Chemicals with high sorption capabilities may not be removed from the aquifer; 
ƒ
Off site migration of contaminants is possible before complete remediation; 
ƒ
Cost for installing and operating the system may be high; 
ƒ
Potential for biofouling of the extraction wells and associated treatment stream 
which may impact system performance; 
ƒ
Additional cost for disposal or regeneration of spent cartridges is treatment is by 
GAC; 
ƒ
Multiple contaminants may affect the performance of GAC and treatability test 
will be needed to assess the performance of the cartridges; 
ƒ
High suspended solids (>50 mg/L) and oil and grease (>10 mg/L) may cause 
fouling of the cartridges leading to frequent changes and higher costs; and, 
ƒ
Advanced oxidation requires the handling of large volumes of hazardous reagents. 
58. 
Applicability of Pump and Treat.
 Pumping is a commercially available 
technology that can be easily implemented using conventional pumps in wells or 
trenches. The retrieved water can be treated by granulated activated charcoal with of-site 
disposal of spent cartridges. Apart from the contaminant concentrations, volumes and 
extent, hydrogeologic information would be required. This includes the size of the 
contaminated aquifer, depth to water table, hydraulic conductivity of the surrounding 
aquifer material, ground water flow direction and velocity, recharge and discharge areas, 
seasonal variations of ground water conditions. Methods such as slug test or pump test 
can be used to assess aquifer properties. 
 
Physical Barriers, Passive/Reactive Treatment Walls  
59. 
Description of the Technology. 
Physical barriers (or slurry walls) are used to 
contain the contaminated ground water and prevent migration into the surrounding 
environment. A trench is excavated and slurry, usually consisting of bentonite and water, 
is placed into it to provide the barrier. Other wall compositions, such as cement/bentonite, 
pozzolan/bentonite, attapulgite, organically modified bentonite, or slurry/geomembrane 
composite, may be used if greater structural strength is required or if chemical 
Page  104
Chapter 6: Remediation Alternatives 
 
104 
 
incompatibilities between bentonite and site contaminants exist (FRTR, 2005i). Since this 
is not a contaminant treatment process it is applicable to a wide range of contaminants.  
60. 
For passive treatment walls, the barrier is used is permeable to water but not the 
contaminant. The barrier allows the passage of water while causing the degradation or 
removal of contaminants. The degradation or retention of contaminants is achieved using 
such agents as zero-valent metals, chelators (ligands selected for their specificity for a 
given metal), sorbents, microbes, and others. Target contaminant groups for passive 
treatment walls are VOCs, SVOCs, and inorganics (FRTR, 2005i).  For chlorinated 
hydrocarbons, the reaction barrier consists of an iron treatment wall. This is made of iron 
granules or other iron bearing minerals. As the iron is oxidized, a chlorine atom is 
removed from the compound by one or more reductive dechlorination mechanisms, using 
electrons supplied by the oxidation of iron. The iron granules are dissolved by the 
process, but the metal disappears so slowly that the remediation barriers can be expected 
to remain effective for many years, possibly even decades (FRTR, 2005j). 
61. 
The permeable wall can also be made of a bioactive filter. This is an innovative 
technology that consists of native sand mixed with a carbon material that will selectively 
adsorb dissolved organic contaminants. A natural organic material such as peat may be 
used for the barrier. If peat is used, the organic compounds collected by the filter may 
biodegrade more rapidly when adsorbed to this more biologically active material.  
62. 
Advantages of Treatment Walls
 
ƒ
Slurry walls contain the contaminant and prevent migration; 
ƒ
Slurry walls are applicable to a wide range of contaminants and it is a relatively 
easy to install technology; 
ƒ
Treatment walls have the added advantage of treating the contaminants in situ. 
63. 
Limitations of Treatment Walls
 
ƒ
Slurry walls only contain the contaminants with no treatment;  
ƒ
Strong acids, bases, and some organic chemicals can degrade the soil-bentonite 
slurry; 
ƒ
Limited to depths that can be reached with excavation equipment; 
ƒ
Treatment walls may loose their capacity before all the contaminants are 
remediated necessitating reinstallation; 
ƒ
Precipitation of metal salts may limit the permeability of a treatment wall; 
ƒ
Biological activity may limit the effectiveness of a treatment wall; 
ƒ
High cost of treatment media. 
64. 
Applicability of Physical Barrier or Treatment Wall.
 Slurry walls are well 
established technology however the excavation backfilling of the trench is critical and 
requires experienced contractors. In addition the contaminant is not treated and an 
interceptor trench may be needed to allow for recovery and treatment of the contaminated 
water. The installation of reactive walls requires specialized reagents which may not be 
available in China. There will the need for additional site characterization data and 
monitoring. These technologies are not recommended for the treatment of groundwater at 
the site. 
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Chapter 6: Remediation Alternatives 
 
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Summary 
65. 
The discussion presented above,  mostly from the US, indicate that the most 
common technologies employed for the treatment of chlorinated pesticide contaminated 
soils include incineration, thermal desorption and excavation and disposal in a secure 
landfill. All three technologies are available in China and one or a combination could be 
employed. Technologies such as bioremediation, vitrification, pyrolysis and chemical 
treatment have also been used. Of these, ex situ bioremediation will be the most 
applicable in China. Treatability studies and additional data will be required as presented 
in relevant sections above. Natural attenuation has also been employed for groundwater 
following removal of contaminated soil and could be used at the Liyang Guaghua 
Chemical Plant. 
 
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Chapter 7: Environmental Impacts 
 
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Environmental Impacts 
 
1. 
The closure of the Liyang Guanghua Chemical Company, Ltd. and the 
remediation of the contaminated production site of the company will largely eliminate 
pollution sources of chlordane and mirex and other toxic chemicals previously produced 
or used at the site but contained in soil, equipment, packaging materials, construction 
materials and other wastes. The proper disposal of these contaminated wastes will 
minimize environmental and health risks associated with these wastes. By doing so, the 
closure and site remediation activities will generate positive impacts on the environment, 
positive health impacts on people working or living close to the contaminated sites. 
Ultimately, the remediation of this site will generate a global benefit as it reduce the risks 
of having chlordane and mirex enter and accumulate in the human food chain. 
2. 
The closure of the Liyang Guanghua Chemical Company, Ltd. will also generate 
two types of social impacts: the loss of jobs for employees used to work at the Liyang 
Guanghua Chemical Company; potential public concerns over the remediation of the 
Liyang site. The first type of social impacts will be addressed through a careful designed 
compensation and retrenchment plan (see the Social Assessment Report of this EIA). The 
second type of social impacts was addressed through a well designed and implemented 
two-round public participation and consultation practices during the preparation of this 
EIA. It will also be addressed during the site clean-up through public information 
campaign. 
 
Environmental Impacts of Site Remediation Activities 
Positive impacts associated with the site remediation actions 
3. 
The proposed closure of the Liyang Guanghua Chemical Company, Ltd. and the 
remediation of the contaminated production site of the company will greatly improve 
environmental status of the contaminated site. The proposed soil remediation activities 
will remove about 1,900 metric tons of contaminated soil, about 900 metric tons of 
contaminated and 400 metric tons of general construction materials, 10 metric tons of 
production equipment, about 1500 plastic HCP casks and 300 iron CTC drums, 200 
metric tons of wastewater and sludge stored in the wastewater treatment plant, about 150 
metric tons of dicyclo-polymer waste residue, and 1 metric ton of asbestos contaminated 
insulation materials.  
4. 
Proper removal and disposal of all toxic chemicals and chemical wastes stored on 
site will totally eliminate the risks that any of these chemicals or chemical wastes will be 
released on site due to negligence or natural disaster. Proper demolition and disposal of 
chlordane and mirex contaminated construction materials and production equipment will 
eliminate the chances for these contaminants to be gradually released into the air, soil or 
water environment, and thus minimize the risks of human exposure to chlordane and 
mirex.   
 
Page  107
Chapter 7: Environmental Impacts 
 
107 
 
5. 
According to the proposed remediation activities, proper soil excavation will 
reduce chlordane and mirex concentration in contaminated soil to much less than 50ppm. 
This action will greatly reduce estimated health risks associated with exposure to 
chlordane and mirex contaminated soil. Furthermore, this action will ensure that the bulk 
of soil contaminated with high concentration of chlordane and mirex will be removed so 
that chlordane and mirex cannot migrate into the groundwater and surface water system. 
This will further reduce the risks of human exposure to chlordane and mirex 
contaminated water.  
6. 
The reduction of risks for human exposure to chlordane and mirex will benefit 
local people who work or live close to the contaminated site. The implementation of this 
remediation effort will educate local public, business owner and officials about 
environmental and health risks. As chlordane and mirex are persistent organic pollutants, 
the proper disposal of chlordane and mirex wastes will have a global benefit as it 
eliminates the risks of accumulating chlordane and mirex in the human food chain. 
7. 
The experience and knowledge gained from the remediation of the Liyang site 
will benefit the remediation of the remaining eight chlordane/mirex production facilities 
in China. As China has very limited experience and knowledge in remediation of 
contaminated sites, this site remediation effort will help both Chinese government and 
business develop their capacity in managing risks associated with the production and 
disposal of chemical products, especially those persistent organic pollutants.  
8. 
The remediation of the Liyang facility and the remaining eight chlordane and 
mirex production facilities will help China fulfill its commitments under the Stockholm 
Convention successfully.  
 
Potential negative impacts associated with the site remediation actions 
9. 
The remediation activities include soil excavation, building demolition, removal 
of production equipment, loading and unloading of contaminated wastes, and 
transportation of contaminated wastes for properly disposal. Potential negative 
environmental impacts resulting from these activities are: (1) noise and exhaust gases of 
excavating machinery and trucks; (2) dusts from soil excavation, building demolition, 
and removal of the production line; and (3) environmental impact related to borrow pits.  
 
10. 
Two potential environmental risks associated with the site remediation are: (1) 
careless excavation may cause disturbance to ground water by allowing contaminated soil 
entering ground water; and (2) careless transport or traffic accident may cause the release 
of contaminated wastes to the environment. Site investigation of the EIA has revealed 
that the ground water level at the site is about 2 meters. As the site remediation will 
excavate contaminated soil up to 1.5 meters, any over excavation may disturb 
groundwater, causing contaminated soil to fall into groundwater, and lead to the further 
contamination of groundwater and its sediments. As the contaminated soil and wastes 
will have to be transported to appropriate landfill for disposal, proper measures have to 
be taken to prevent any of the waste from releasing to the environment during the 
transportation and to prevent any traffic accidents. 
 
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108 
 
fifi\11\03
Noise
.
Noise is one of the major pollutants in the remediation process. 
Excavators, bulldozers and trucks will be main noise sources. According to related data, 
the noise condition of the major construction machineries is shown in Table 7-1.
\03
Table 0-1  Noise of Construction Machinery and Equipment 
Name of construction 
equipment 
Average sound level A 10m from the 
equipment dB(A) 
Excavator 82 
bulldozer 76 
Truck 85 
fiffl\11\03
It can be seen from Table 7-1 that noise produced by site construction machinery 
and equipment is very high and in actual construction process, many types of machineries 
often work at the same time and mutual superposition of various noise sources makes the 
noise level even higher and radiation range even wider. 
\03
fiffi\11\03
Impact of construction noise on the acoustic environment in the surrounding 
regions is evaluated according to the 
“Noise Limit for Construction Site” (GB12523-90), 
in which the noise limit value for bulldozer, excavator and loader etc in daytime and at 
night is 75 dB(A) and 5 dB(A) respectively. 
\03
14. 
The noise produced by the construction machinery during clean-up process is 
mainly medium and low frequency noise, thus only diffusive attenuation is considered in 
the prediction of its impact, i.e. prediction model can use:  
L
2
=L
1
—20lgr
2
/r
1
(r
2
>r
1
)
Where: L
1
and L
2
are equivalent sound level A (dB(A)) from sound sources r
1
and 
r
2
;
r
1
and r
2
are distance from receiving point to sound source (m). 
15. 
It is predicted that the range of noise generated by the construction machinery 
exceeding the standard is within 100m in daytime and 300m at night. The protection 
target of this project is at 150m-300m and the noise produced from the cleanup activities 
has a minor impact on nearby residents in daytime and has certain impact on the 
protection target at 150m. Thus this EIA suggests that all excavation activities should be 
conducted during day time only.  
 
ficaron\11\03
Exhaust gases of excavators and trucks
.
The waste gases in the cleanup process 
are generated from excavators and trucks. As the remediation will be a short-term 
operation, impacts of these exhaust gases will be short-term.
\03
17. 
Borrow pits. 
After the soil excavation, the site will be filled with soil from 
borrow pits. The removal of soil from borrow pits may have negative environmental 
impacts to the environment surrounding the pit. In addition, the excavation and 
transportation of borrowed soil may lead to the release of dusts to the environment. 
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109 
 
18. 
Dusts. 
Soil excavation, building demolition, and removal of the production line 
may increase the risks of the release of contaminated soil dusts. Moreover, the removal of 
insulation materials containing asbestos may lead to the release of asbestos particles to 
the environment. As chlordane, mirex, asbestos and other chemicals used or produced on 
site are toxic chemicals; the direct inhalation of any of these chemicals may pose 
immediate health threats to workers participating in the site remediation.  
 
Environmental Impacts of Disposal of Contaminated Wastes 
19. 
Environmental impacts related to the disposal of contaminated wastes mainly 
include: (1) vibration, noise from disposal process at a landfill; (2) leachate and odor of 
the landfill; (3) wastewater and sludge from the treatment of acid wastewater and sludge; 
and (4) wastewater from triple washing of containers. If not treated or improperly treated, 
they will generate certain impact on the local atmosphere, water, soil and acoustic 
environment.  
20. 
Detail risks to the environment from remediation activities are shown in Table 7-
2. 
Table 0-2  Environment Risk Caused by Cleanup Activities in this Project 
Activities Environmental 
impacts 
Triple washing of used containers with water 
Waste water 
Landfill of contaminated wastes 
Vibration and noise; 
Leachate and odor 
Wastewater and sludge treated at industrial 
wastewater treatment plant 
Wastewater and sludge 
Environmental Impacts of Storage and Sales of Raw Materials and Products 
21. 
As noted, the facility still has in stock about six metric tons of 
hexachlorocyclopentadiene, five metric tons of dicyclopentadiene, ten metric tons of 
carbon tetrachloride, three tons of liquid chlorine, two tons of caustic soda and one ton of 
ethanol. Stored products include sixteen tons of chlordane and two tons of mirex. These 
raw materials and products will be liquidated before the site remediation of the facility.  
22. 
The sale of these stored chemicals will not generate adverse impacts on the 
environment. However, the storage and transportation of these chemicals on site and from 
the site to buyers may pose risks to the environment and workers involved in the transfer 
of these chemicals. Improper packaging, loading and unloading of these chemicals may 
lead to emission, overflow, dripping, leaking or spill of chemicals. As most of these 
chemicals are toxic, these events will lead to contamination to the environment, tools or 
trucks used to transport these chemicals, and workers operating these tools or trucks. 
Measures have to be taken to ensure the proper handling of these chemicals. 
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Environment Management Plan 
1. 
The environmental management plan includes measures for mitigating the 
potential impacts created by the previous production of chlordane and mirex at the 
site and generated during the clean up work, dismantling of production equipment, 
transportation and disposal waste from the site. For all site clean-up activities, the 
following requirements have to be followed: 
·
Contractors should be licensed hazardous waste management companies to 
carry out any site clean-up task related to chlordane, mirex and other 
hazardous chemicals and their wastes, and follow strictly national and local 
laws, regulations and technical guidance on hazardous waste management 
and disposal.  
·
Qualified (and certified if applicable) technical and management personnel 
should be hired for the clean-up of the Liyang Site. They are required to take 
training courses organized by the Termite Control Demonstration Project. 
Safety measures should be taken for and by the personnel work on site.  
2. 
Detailed requirements of the qualifications for the contractor will be provided 
in terms of reference before the start of the site remediation. 
 
Mitigation for Impacts Originated from Past Production  
3. 
Mitigation Measures for Disposal of Raw Materials.
 The stockpile raw 
materials and products will be liquidated before the site clean-up starts. These 
chemicals will be stored and handled strictly following the Regulation for Safe 
Management of Hazardous Chemicals
 
(issued by the State Council
 
in 1987 and 
revised in March, 2002) to avoid any spill and leakage of any of these chemical and to 
ensure that these chemicals will be safely transported from Liyang to interested 
buyers.  
4. 
As China will implement a production quota system to control the production 
of chlordane and mirex, the production quotas for 2006 (assumed the first year of the 
implementation of the Termite Control Demonstration Project) for chlordane and 
mirex will be reduced accordingly. 
 
Clean-up of Contaminated Soil 
5. 
Licensed hazardous waste management companies will be hired through a 
competitive bidding process to perform remediation activities to be performed at the 
Liyang site. 
 
6. 
Amount of Contaminated Soil.
 Based on the clean-up standard for wastes 
contaminated with all identified chemicals at the Liyang Guanghua Chemical 
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Company Ltd., this EIA determines that only soil around the monitoring well GH1 
has been contaminated with chlordane 73.6ppm (over 50ppm standard) at a depth of 
0.1 meter. The next highest concentrations of chlordane in the soil are found at the 
monitoring well GH1 at a depth of 1.0 meters (about 36.5ppm), at the monitoring well 
GH2 at a depth of 0.6 meters (about 21.4ppm) and at the monitoring well GH3 at a 
depth of 0.6 meters (about 26.3ppm). In practice, these three monitoring wells are 
positioning immediately outside to places where chlordane and mirex are produced, 
stored, and production facilities are maintained. In particular, the monitoring wells 
GH1 and GH3 are positioned on the aisle between the chlordane/mirex production 
workshop and the chlordane formulating workshop and warehouse (i.e., the 
Workshop (Building 7) and Warehouse (Building 8) below the Chlordane and Mirex 
Workshop (Building 5) shown on Figures 4-4 and 4-8), and the monitoring well GH2 
is positioned on the aisle between the chlordane formulating workshop and warehouse 
and the machine maintenance room and the warehouse for chlordane products (i.e. 
Warehouse and Machine Maintenance Room shown on Figures 4-4 and 4-8). The 
high concentrations of chlordane in the soil are consistent with the manners of 
production, formulating, packaging, and storage activities at the facility. 
7. 
As the monitoring data does not provide a sufficient concentration gradient 
map to reliably reflect the actual concentration changes between the monitoring wells, 
this EIA suggests a conservative approach that all soil around these wells be 
remedied. To minimize the risk of relatively high concentration of chlordane in the 
soil around the monitoring well GH1 from migrating in the soil or even to the ground 
water, this EIA suggests that a radius of 14m (the longest distance between any two of 
the three monitoring wells) around the monitoring well GH1 be classified as 
contaminated soil to be remedied. This equals to a round area of about 616 square 
meters. Considering that previous excavation has indicated that groundwater levels at 
GH1, GH2 and GH3 are all about 1.5 meters below the surface soil, it is 
recommended that the soil up to 1.5 meters be remedied to avoid disturbing 
groundwater. Therefore, this EIA suggests that a cylindrical soil remediation area 
with a total volume of 924 cubic meters (i.e., 616 square meters times 1.5 meters) be 
included for remediation. 
8. 
Selection of Soil Remediation Technologies.
 Based on discussion earlier in 
this chapter, this EIA has identified the following technologies available in China for 
treating soils contaminated with halogenated semi-volatile organic pesticides: 
incineration, thermal desorption, and excavation and off-site disposal in a landfill. 
Based on the following considerations, this EIA suggests that the third approach, 
excavation and off-site disposal in a regulated hazardous waste landfill, be selected 
for the remediation of contaminated soil at the facility. 
(1) Concentration of pollutants in the soil. As discussed in this report, soil to be 
considered for remediation at the facility has chlordane concentration slightly 
above the standard and concentration of all other contaminants below the 
standards. Internationally, it is the common practice to dispose soils with low 
concentrated wastes to a hazardous waste landfill. Another suitable option for 
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soil decontamination, as noted in Chapter 6, is thermal desorption, which can 
treat chlordane and mirex contaminated soil (although this technology was not 
recommended for this particular clean up for cost and risk reasons discussed 
below).  
(2) Technology availability. China has developed its hazardous waste incineration 
facilities since 2001. However, few of these facilities are built with best 
available technologies (BAT). Here, a hazardous waste incinerator with BAT 
refers to the incinerator has adopted internationally best available incineration 
technologies, inter alia, designed for high temperature and equipped with 
prevention of reformation of dioxins and furans and dedicated dioxin and 
furans removal. In contrast to incineration, hazardous waste landfill is 
technologically simple and has been widely operated in many places in China 
for a couple of decades. As China will have a thermal desorption unit under 
the GEF funded PCB Management and Disposal Demonstration Project, 
thermo desorption will also be available for the treatment of contaminated soil 
at the Liyang Site. 
(3) Treatment costs. It is estimated that the unit cost for incinerating wastes at a 
BAT hazardous waste incinerator in China is about US$2,500 per ton of 
waste, and the cost for thermal desorption will be around US$2,000.25 In 
contrast to the high cost of incineration and thermal desorption, the unit cost 
for hazardous waste landfill is only about US$300. 
(4) Potential risks associated with technologies. As China has yet to 
systematically monitor dioxin and furan emission from hazardous waste 
incinerators, there are risks that these facilities have failed to take necessary 
measures to minimize the release of dioxins and furans. In addition to air and 
wastewater releases during the thermal desorption process that need to be 
treated, contaminants concentrated by the thermal desorption process will have 
to be treated by the second disposal technologies, which is often incineration. 
As soil at the Liyang Guanghua site is mainly clay or sub-clay, the 
decontamination of such soil may compromise the removal efficiency and 
generate excessive dusts, which places a greater dust loading on the 
downstream air pollution control equipment.
26
 In contrast to incineration and 
thermal desorption, well regulated and operated hazardous landfill is a safe 
disposal technology for low concentration contaminants and poses a low risk 
of producing secondary pollution.
 
9. 
The following table summarizes the above discussion for the applicability of 
these technologies at the Liyang Guanghua site.  
25
 This estimation is quoted from the EIA Reports of the China PCB Management and Disposal 
Demonstration Project.  
26
 Clay content in soil reduces the effectiveness of thermal desorption technology and increases the dust 
loading. 
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Table 8-1 Applicability of Three Disposal Technologies for the Liyang Site 
 Incineration 
Thermal 
desorption 
Hazardous 
waste landfill 
Concentration of 
contaminants 
High Low Low 
Technology availability 
BAT yet to be 
adopted. 
Available around 
2007 under the PCB 
Project 
Yes 
Treatment costs 
High 
Medium 
Low 
Risks for secondary pollution 
High 
High 
Low 
10. 
A certified hazardous waste management company will be hired to perform all 
soil remediation tasks. Landfill will be carried out according to a national standard - 
Standard for Pollution Control at Hazardous Waste Landfill (GB18598-2001). In 
addition, the operation and design of the landfill will be reviewed as a part of the 
landfill selection process to ensure that the landfill is safe for disposal of chlordane 
and mirex hazardous waste. Particular attention will be paid to safe operation of the 
landfill, e.g., regular monitoring of groundwater in the vicinity of the landfill in 
established  monitoring wells, not mixing of waste to avoid chemical reactions, 
tracking of waste location within the landfill, and keeping of records of what disposed 
wastes (their source, time of disposal, etc.) Also reviewed will be design issues, such 
as the existence of a proper liner system with permeability below 10 E-07 cm/s, 
adequate leachate collection and treatment system, and possibly gas collection and 
ventilation system.  
11. 
Estimated Costs for Soil Remediation.
 The costs for soil remediation will 
include four types of costs: the cost for protective clothing and respiratory equipment 
for workers, the cost for excavating contaminated soil, the cost for packaging and 
transporting the excavated soil from the Liyang facility to a licensed hazardous waste 
landfill, and the cost to disposal the excavated soil at the landfill. In sum, the 
estimated total costs for soil remediation is about US$622,428. 
(1) Cost for protective clothing and respiratory equipment.  
It is estimated that a total of 10 workers will involve in the task. The 
cost will be around $1,500. 
(2) Soil excavation cost:  
It is estimated that unit price for soil excavation is US$6 per metric 
tons. It is also estimated that each cubic meter of soil weigh about two 
metric tons. So the cost for excavation of a total of 924 cubic meters 
will be US$11,088.  
(3) Packaging and transportation cost:  
It is assumed that the unit packaging and transportation cost is about 
US$30 per metric tons. So the cost for transportation of a total of 924 
cubic meters (or 1,848 metric tons) will be US$55,440.  
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(4) Landfill cost:  
It is estimated that the unit cost for hazardous landfill of a metric ton is 
about US$300. So the cost for the landfill of a total of 924 cubic 
meters (or 1,848 metric tons) will be US$554,400.  
12. 
Disposal of Insulation Materials Containing Asbestos.
 This EIA has 
identified that at the Liyang facility, insulation materials containing asbestos has been 
used on some pipes transmitting heating vapor (or cooling water) to the chlordane 
production line. As asbestos is well recognized as a health hazard and is highly 
regulated in China, a certified waste management company will be hired to carefully 
remove all pipes together with their insulation materials, which containing asbestos, 
from the production line. This action will be conducted before all other site 
remediation activities. 
13. 
The removed pipes and asbestos will be sealed in thick plastic bags with 
plastic tapes. The sealed bag should be clearly marked with warning signs and the 
content of the bag such as chemical asbestos waste (in Chinese). This clearly marked 
and tightly sealed bag will be sealed in a transparent plastic bag. All contaminated 
protective clothing of workers will be treated as asbestos wastes and disposed in the 
same manner.  
14. 
As it is well acknowledged that the best technology to disposal of asbestos is 
hazardous waste landfill, this EIA suggests that all asbestos insulation materials 
should be disposed of at a licensed hazardous waste landfill. It is estimated that the 
total quantity of asbestos wastes, including the pipes on which insulation materials 
are, will be around one metric ton. In sum, the estimated total costs for disposal of 
asbestos contaminated insulation materials are about US$8,500. 
(1) Cost for protective clothing and respiratory equipment.  
It is assumed that a total of 10 workers will involve in the task. The 
cost will be around $1,500. 
(2) Removal, packaging and transportation cost:  
It is estimated that the cost will be around US$2,000.  
(3) Landfill cost:  
It is estimated that the cost will be around US$5,000.  
15. 
Disposal of Contaminated Building Materials.
 Two types of building 
materials have been identified in this EIA: contaminated construction materials and 
general construction materials. Contaminated construction materials refer to floors, 
walls and ceiling of both chlordane/mirex and endosulfan production workshops, 
storage rooms for raw materials and products, chlordane formulating room, and the 
workshop for equipment maintenance. All other construction materials will be 
deemed as general construction materials. Note that some of the floor areas of 
production related building will be removed during the excavation of contaminated 
soil. 
16. 
For contaminated construction materials, the appropriate remediation 
technology will be hazardous waste landfill due to low concentration of contaminants 
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on/in these materials and large quantity of these materials. For general construction 
materials, this EIA suggests that these materials to be disposed of at municipal 
landfill. The option of on site cleaning was considered, which will allow all wastes 
could be sent to ordinary landfill. However, it is rejected due to its negative 
environmental impact of on-site cleaning. 
17. 
It is estimated that the 2000 square meters of production related building will 
produce about 900 metric tons of contaminated construction materials, and about 900 
square meters of other buildings will generate about 400 metric tons of general 
construction materials. As noted earlier in this report, insulation materials containing 
asbestos will be removed before the demolition of any existing building. In sum, the 
estimated total costs for soil remediation is about US$356,500. 
(1) Cost for protective clothing and respiratory equipment.  
It is estimated that a total of 10 workers will involve in the task. The 
cost will be around $1,500. 
(2) Building demolition cost:  
It is estimated the total cost for demolition of all buildings will cost 
about $30,000.  
(3) Packaging and transportation cost:  
For contaminated construction materials, it is assumed that the unit 
packaging and transportation cost is about US$30 per metric ton, the 
cost for transportation of a total of 900 metric tons will be US$27,000. 
For general construction materials, it is assumed that the unit 
packaging and transportation cost is about US$20 per metric ton, the 
cost for transportation of a total of 400 metric tons will be US$8,000.  
(4) Landfill cost:  
It is estimated that the unit cost for hazardous waste landfill of a cubic 
meter is about US$300; the cost for the landfill of a total of 900 metric 
tons will be US$270,000. It is estimated that the unit cost for municipal 
waste landfill of a metric ton is about US$50; the cost for the landfill 
of a total of 400 metric tons will be US$20,000.  
18. 
Disposal of Contaminated Production Equipments.
 All production 
equipment will be properly dismantled and disposed of as contaminated wastes. Three 
technical options are considered: landfill, solvent cleaning and incineration. It has 
been documented that solvent cleaning will increase the emission of chlordane and 
mirex during the cleaning process. Not to mention, this option requires the disposal of 
used solvent. As China has no previous experience in solvent cleaning of POP related 
wastes, this EIA suggests that solvent cleaning not be considered. For the incineration 
option, it is documented that metals will react with chlorine or sulfur in wastes and 
form more volatile and toxic compounds than the original species. As noted earlier, 
the cost of incineration is also much higher than the cost of landfill. Therefore, 
hazardous waste landfill is the best option for the disposal of the remaining 
production equipment at the Liyang facility. 
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19. 
A special note on the disposal of the wastewater treatment plant at the Liyang 
facility is that the disposal of the wastewater treatment plant can be performed only 
after all wastewater and sludge contained in the plant have been removed. See the 
sub-section on the disposal of wastewater and sludge in this section for details on how 
to dispose of this wastewater.  
20. 
It is estimated that there are about 10 metric tons of equipment left at the 
Liyang facility. In sum, the estimated total costs for soil remediation is about 
US$14,500. 
(1) Cost for protective clothing and respiratory equipment.  
It is estimated that a total of 10 workers will involve in the task. The 
cost will be around $1,500. 
(2) Equipment removal, packaging and transportation cost:  
It is estimated the total cost for removal, packaging and transportation 
of a total of 10 metric tons equipment will be US$10,000.  
(3) Landfill cost:  
It is estimated that the unit cost for hazardous waste landfill of a metric 
ton is about US$300, the cost for the landfill of a total of 10 metric 
tons will be US$3,000.  
21. 
Disposal of Contaminated Packaging Materials.
 As noted earlier in this 
report, there are about 1500 plastic HCP casks and 300 iron CTC drums. Based on 
current industrial practices, the most cost efficient approach for the disposal of these 
containers will be washing, i.e. triple rinse and pressure rinse. This EIA suggests that 
a
licensed waste management company be hired to pressure rinse all containers with 
water. Rinse water shall be properly collected and treated at a licensed industrial 
wastewater treatment plant. Based on the condition of these containers, cleaned casks 
or drums can be re-used (or recycled), or crushed and disposed of at municipal 
landfill. Incineration is not suggested due to its high costs and negative environmental 
impacts. 
22. 
It is estimated that the unit cost for transporting and cleaning up all these 
containers at the waste management company’s facility will cost about US$3 per 
container. Therefore the total cost will be US$5,400. Costs for landfill unusable casks 
or barrels will be minimal and thus not estimated in this EIA. 
23. 
Disposal of Wastewater and Sludge in the Wastewater Treatment Plant. 
The 200 metric tons of wastewater and sludge stored in the wastewater treatment 
plant are acid in nature and contain hexachloro-cyclopentadiene. This EIA suggests 
that these wastewater and sludge be treated at a licensed industrial wastewater 
treatment facility that is capable of treating such wastewater and sludge, including 
chlordane and mirex residues through appropriate technology (e.g., carbon absorption 
or another suitable kind of tertiary treatment). It is estimated that the unit cost for 
transferring these wastewater and sludge to the licensed industrial wastewater 
treatment facility will be US$100 per metric ton. Therefore, the costs for 200 metric 
tons will be US$20,000.  
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24. 
Disposal of Dicyclo-polymer Waste Residue.
 Similar to other contaminated 
solid wastes, the best option for the disposal of about 150 metric tons of dicyclo-
polymer waste residue will be disposal at a licensed hazardous waste landfill. Cost for 
the disposal is estimated as below. In sum, the estimated total costs for soil 
remediation is about US$51,000. 
(1) Cost for protective clothing and respiratory equipment.  
It is estimated that a total of 10 workers will involve in the task. The 
cost will be around $1,500. 
(2) Equipment removal, packaging and transportation cost:  
It is assumed that the unit packaging and transportation cost is about 
US$30 per metric ton. For a total of 150 metric tons, the total costs will 
be US$4,500.  
(3) Landfill cost:  
It is estimated that the unit cost for hazardous waste landfill of a cubic 
meter is about US$300; the cost for the landfill of a total of 150 metric 
tons of wastes will be US$45,000.  
25. 
Summary.
 Table 8-2 summarizes the mitigation measures proposed by the 
EIA for impacts originated from past production of chlordane and mirex at the Liyang 
site. Annex 4 lists identified hazardous waste management companies registered in 
Jiangsu Province. Qualified landfills, wastewater treatment plants and hazardous 
waste management companies will be selected through a national competitive bidding 
process to participate in the clean-up of the Liyang Guanghua site. 
 
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Table 8-2  Summary of Proposed Mitigation Measures and Cost Estimation 
Wastes 
Quantity (MT) 
Mitigation measures 
Costs (US$) 
Contaminated soil 
1,848
Disposal of at a licensed 
hazardous waste landfill 
~622,500
Asbestos 
contaminated 
insulation materials 
1
Disposal of at a licensed 
hazardous waste landfill 
8,500
Building materials 
356,500
Contaminated 900
Disposal of at a licensed 
hazardous waste landfill 
General 400
Disposal of at a licensed 
municipal landfill 
Contaminated 
production 
equipment 
10
Disposal of at a licensed 
hazardous waste landfill 
14,500
Contaminated 
packaging materials 
5,400
Plastic HCP casks 
1500 pcs
Iron CTC drum 
300 pcs
Triple rinse with water and based 
on the condition, reuse (including 
recycle), or crush and landfill 
Wastewater and 
sludge 
200 
Treated at a licensed industrial 
wastewater treatment plant 
20,000
Dicyclo-polymer 
waste residue 
150 
Disposal of at a licensed 
hazardous waste landfill 
51,000
Total  -- 
 
 
~1,080,000
Mitigation Measures for Social Impacts Associated with Plant Closure 
26. 
As noted in Chapter 7, the closure of the Liyang Guanghua Chemical 
Company, Ltd. will also generate two types of social impacts: displacement of 
workers of the Liyang Guanghua Chemical Company; potential public concerns over 
the remediation of the Liyang site. Social impacts on displaced workers are addressed 
by compensation plan and re-training discussed in more details in the Social 
Assessment Report of the EIA.  
27. 
To alleviate possible public concerns over the site remediation operation may 
stem from unusual activities at the site (workers in protective gear and respirators 
demolishing otherwise perfectly sound buildings), a public information campaign will 
be implemented prior and during the clean up operations. The campaign will target 
the nearby residents to explain what activities are going on at the site and why.  
 
Mitigation Measures Associated with Remediation Activities 
28. 
All the mitigation measures will strictly follow the national regulation on the 
hazardous waste and hazardous cargo including the Standards for Hazardous Cargo 
Page  119
Chapter 
8: 
Environmental 
Management 
Plan 
     119 
 
Categorization and Numbering (GB 6499-86); the Standards for Hazardous Cargo 
Labeling (GB 190-85); the Standards for Markers for Packaging, Storage and 
Transportation (GB 191-85); the Standards for Receipt/Departure Labeling for 
Transportation (GB 6833-86); the Regulation on Hazardous Material Transportation 
by Vehicle (JT 3130-88); the Standards for Labeling of Hazardous Material 
Transportation Vehicles (GB13392); the Management Regulation on Road 
Transportation of Hazardous Material; the Permit Management Method for Hazardous 
Waste Business; etc. 
29. 
Site cleanup supervision will be carried out during the whole cleanup process.  
30. 
To avoid secondary pollution to the surface water, air, soil, ground water and 
other surroundings on-site, effective measures should be taken during the clean up 
work including dismantling of production equipment and buildings and excavation 
and removal of contaminated soil on the site. Measures such as set up of windproof 
and rainproof shed, leakage-proof ground and water collection ditches, need to be 
taken to prevent leaching, dust diffusion, raining, and rain water run off from 
jeopardize the site remediation.  
31. 
The containers for wastes should meet the standards for hazardous waste 
containers to prevent leakage and diffusion of waste from containers. Each container 
with wastes from the site will be labeled with detailed information on the name of the 
site, waste contained in the container (such as characteristics of wastes, emergent and 
remedial measures for accidental leakage and diffusion, and weight). 
32. 
Transport of hazardous wastes from the site to a disposal center or landfill will 
be closely supervised. Hazardous wastes manifests will be filled and submitted for 
approval to environmental protection authorities in Changzhou and the municipality 
where the hazardous wastes will be disposed. The drivers, loading personnel and 
supervisors will be trained in regard to the hazardous features of the wastes, the 
properties of containers, and emergent and remedial measures for accidental leakage 
and diffusion. Necessary personal protection equipment (including clothing) and 
emergency treatment equipments will be prepared. The transportation of hazardous 
wastes will conform to the requirement of the Regulation on Hazardous Waste 
Transportation Manifest and other relevant regulations. 
33. 
Information and warning signs will be installed at the Liyang Guanghua site, 
disposal sites, and treatment sites of hazardous waste based on the requirements of 
environmental protection authorities. 
34. 
Equipment, containers, packages and other materials used for the collection, 
storage, transportation and disposal of waste should be treated and decontaminated 
before other use.  
35. 
The following table summarizes identified impacts related to the closure of the 
Liyang Guanghua Chemical Company Ltd. and the remediation activities to be carried 
out at the Liyang Guanghua site. Figure 8-1 shows the site cleanup plan.
Page  120
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Page  122
Chapter 
8: 
Environmental 
Management 
Plan 
     122 
 
Figure 8-1 Site Clean Up Plan of the Liyang Guanghua Chemical Company, Ltd.
Page  123
Chapter 
8: 
Environmental 
Management 
Plan 
     123 
 
Monitoring Plan 
36. 
Monitoring Implementation Unit.
 According to the result of bidding, the 
project implementation unit will select qualified organizations to monitor the 
mitigation activities. Detailed requirements for contractors
’
qualifications will be 
provided in the bidding documents for the cleanup activity.
 
37. 
Environmental Monitoring Plan 
38. Environmental 
Monitoring 
Parameters
.
The target pollutants to be controlled 
under the proposed project are chlordane and mirex according to the requirements of 
the Stockholm Convention. Chlordane and mirex are selected as environmental 
monitoring factors and periodical monitoring should be carried out in the process of 
and after the closure of the plant and clean up of pollutants to
 
monitor the effects of 
mitigation measures and propose corresponding measures for possible problems 
appeared. 
 
39. Monitoring 
Method.
The monitoring method adopted by this EIA will be used. 
In other words, the analysis method of chlordane and mirex is according to the 
requirement of “Organic Compounds-LSE/cap col GC/MS of EPA525”.
 
40. Monitoring 
Position.
(1) Soil: About thirty composite soil samples at 10 cm below the excavation level at 
the excavation site. About five additional soil sampling poijnts around the site will 
be monitored. These will include a sampling point placed just north of the 
switching house (between the switching and the MW7), sampling point placed 
between MW5 and MW7, sampling point placed about twenty meters west to S1, 
sampling point placed 40 meters south to the third, and sampling point placed 40 
meters east to GH12. At selected sampling points, samples will be taken from 
depth below 2 meters, to confirm that the concentration in greater depths is 
acceptable (particularly in respect to mirex, which measured relatively high 
concentration registered at 2 m depth at GH2) 
(2) Potentially affected people: Two randomly selected workers for the contractor and 
two randomly selected residents from neighboring communities will be 
monitored. 
(3) Biological sample: 2 fish samples in the fishpond out of the northern boundary of 
the plant will be monitored untill the fishpond is filled. 
(4) Fishpond Water: Water in the fishpond out of the northern boundary of the Liyang 
facility will be monitored till the fishpond is filled. The sampling scheme is the 
same as that adopted by EIA. 
(5) Surface Water: The sampling scheme is the same as that adopted by EIA (referring 
to Fig. 3-1 of environmental status monitoring location for surface water). 
Page  124
Chapter 
8: 
Environmental 
Management 
Plan 
     124 
 
(6) Ground Water: The sampling scheme is the same as that adopted by EIA (referring 
to Fig. 3-1 of environmental status monitoring location for groundwater). In 
addition, two additional samples will be taken between the switching house and 
the MW7 and between MW5 and MW7. 
 
41. Monitoring 
Frequency
(1) Soil: After the remediation, take samples to confirm contaminated soil has been 
removed to the levels lower than the cleanup levels. 
(2) Potentially affected people: Before and after the remediation, monitor the selected 
contractor’s workers and residents (testing their fat) from neighboring 
communities to investigate the impact of chlordane and mirex. 
(3) Biological sample: Monitoring crabs (tissue sample) once every three months until 
the fishpond is closed down. 
(4) Fishpond Water: Monitoring the water of fish pond once every three months until 
the fishpond is closed down. 
(5) Surface Water: After the remediation, continue monitoring of ground water once 
every three months within two years. 
(6) Ground Water: After the remediation, continue monitoring of ground water once 
every three months within two years. 
42. 
Annual monitoring report will be submitted within project period. Monitoring 
results will be carefully reviewed and evaluated. Any abnormality in the monitoring 
results will lead to further monitoring requirements, and if necessary, additional 
institutional control actions will be proposed based on the evaluation of monitoring 
data. 
 
Institutional Arrangements 
43. 
National Management Institutions. 
At the national level, the management 
institutions are NIP Leading Group and Convention Implementation Office (CIO) of 
State Environmental Protection Administration (SEPA), which are responsible for the 
daily leading and management work on the proposed demonstration project 
respectively. 
44. 
Local Management Institutions.
 At the local level, the management 
institutions are Jiangsu Provincial Steering Group and Jiangsu Provincial Project 
Implementation Unit (PIU), which are responsible for the leading and management of 
this demonstration project respectively. 
45. 
Supervision Institutions.
 The supervision institutions are provincial 
authorities related to environmental protection, fire prevention and public security, 
etc. The expert team is in charge of technical supervision. 
Page  125
Chapter 
8: 
Environmental 
Management 
Plan 
     125 
 
46. 
Implementation Institutions.
 The contractors will be selected based on the 
bid evaluation and consistent with WB’s procurement guideline. 
47. 
Expert Team
.
An expert team will be established and take responsibility to 
prepare tendering documents, review documents and remediation Option, train staff 
and supervise the implementation of the monitoring Option and remediation Option, 
etc. 
 
Figure 0-2 Organizations for Implementing Site Cleanup Plan 
 
Implementation Arrangement 
48. 
PIU will prepare a detailed implementation plan for the clean-up of the Liyang 
Guanghua site. The plan will cover details of site clean up, as well as transport of 
hazardous waste for disposal, and final disposal. This implementation plan will be 
submitted to the World Bank for review. After agreed by the World Bank, PIU will 
carry out of this implementation plan under the guidance of the CIO and the expert 
team. PIU will hire an independent supervision engineer to supervise site cleanup 
activities. The responsibility of the independent supervision engineer will be clearly 
defined by a terms of references approved by the Bank. 
 
NIP National leading group
CIO, SEPA
Project Team, CIO 
EIA 
contractor
Expert team 
Jiangsu/Zhejiang 
Steering
groups
Jiangsu/Zhejiang PIUs
Waste 
disposal 
contractor
Soil 
remediation 
contractor
Monitoring
contractor
Page  126
Chapter 
8: 
Environmental 
Management 
Plan 
     126 
 
Institutional Controls of the Use of the Site 
49. 
After the cleanup activities are completed at the Liyang site, the following 
institutional controls of the use of the site shall be instituted: 
(1) The future use of the site as an industrial zone will be strictly enforced by the 
Liyang City land use planning and zoning authorities to ensure that the site 
will continue to be used for industrial purposes only; 
(2) The fencing, gate and guard station at the site will be maintained and repaired 
if necessary. Warning signs prohibiting access to the site will be posted on the 
perimeter and at the entrance. 
(3) The branch of Wanmuqiao River which received effluent from the waste water 
treatment plant will be sign-posted to warn that the water should not be used 
for swimming, fishing, irrigation or other similar uses.; 
(4) 
A
“non-portable” warning sign shall be installed at the ground water well on 
the site. 
(5) All signs will refer to local regulations and fines, and will contain a phone 
number for the Environmental Protection Bureau and the Public Security 
Bureau for reporting of violations. 
 
Capability Building and Training Program 
50. 
Capability Building.
 Since the proposed demonstration project is exploratory 
in nature and China lacks experiences and capacities in site cleanup management 
presently, in-class and on-the-job training and study tour will be conducted.  
51. 
Training Program.
 In-class and on-job training will be organized, 
international and domestic experts will be invited as instructors. Trainees should 
include but not limited to project managers, consultants, and construction managers, 
technicians, monitoring staff, supervisors and environmental administrators. Four 
trainings will be organized on (1) laws and regulations, (2) technical guidance and 
standards, (3) safety knowledge, and (4) vocational sanitation protection and 
emergency aid. About 15 trainees will participate in each training, and 60 trainees will 
participate in four trainings.  
52. 
A study tour for short-term training will be organized. The delegation for the 
study tour will have 8 members.  
 
Implementation Schedule  
53. 
The implementation period of the mitigation measures is 3 years, from the 
initiation of the closure of Optiont to the end of the implementation of the monitoring 
Option, including the post environmental management and monitoring. Detailed 
schedule see Table 8-4. 
Page  127
Chapter 
8: 
Environmental 
Management 
Plan 
     127 
 
Cost Analysis 
54. 
The budget for mitigation measures is detailed in Table 8-5. 
 
Page  128
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Page  130
Chapter 
8: 
Environmental 
Management 
Plan 
     130 
 
Table 0-5  Budget for Mitigation Measures 
Activities Description 
Unit 
Cost
Cost
(US$)
Site cleanup 
All activities 
–
see Table 8-2 
n/a 
1,080,000 
Expert Team 
 
Prepare tendering documents, 
review documents and remediation 
plan, train staff and supervise the 
implementation of the monitoring 
plan and remediation plan, etc.
\03
It 
is estimated that 3 experts and 100 
days each expert are needed. 
US$ 125 per 
day per person 
37,500 
Site 
maintenance 
Carry out security and 
maintenance work during and post 
the cleanup within 3 years, 3 
workers will be recruited. 
US$ 6,000 per 
person per year 
18,000 
Environ-
mental 
Monitoring 
Totally 10 times monitoring of 
soil, surface water, groundwater, 
fish and water in fishpond, as well 
as workers for contractor and local 
villagers. 
US$ 5,000 per 
time 
50,000 
Trainings and 
study tour 
4
trainings, totally about 60 
participants, 3 days for per 
training, 
1
overseas study tour, 8 
participants; 
3
foreign experts to China 
Trainees: 
US$60/person 
Overseas study 
tour: US$ 6,000 
per person; 
International 
experts: 
US$12,500 per 
experts 
89,100 
Site Cleanup 
Supervision 
Engineer 
Supervision and detailed recording 
and filing for dismantling, 
cleanup, waste treatment and 
disposal, and storage site 
maintenance, within 3 years, 1 
supervision engineer will be 
recruited. 
Staff: US$ 
6,000 per 
person per year; 
Equipment: 
US$ 5,000  
23,000 
Post-
appraisal 
Compilation of project interim 
report and post-appraisal report on 
Environmental Impact Assessment 
US$ 25,000 per 
report 
50,000 
Contingency 
Environmental administrative 
costs within 3 years 
5% of above 
costs 
67,380 
Total Costs 
(
in USD) 
1,414,980
Page  131
Chapter 
8: 
Environmental 
Management 
Plan 
     131 
 
Reporting 
55. 
The reporting on the progress of site clean up, waste disposal and post-cleanup 
monitoring will be an integral part of the regular Demonstration Project reporting (see 
Project Appraisal Document for detailed description of the Component 6 which deals 
with monitoring and evaluation). The Jiangsu Project Implementation Unit will be the 
key project body responsible for the reporting. The site cleanup reporting will include 
the following: 
a) 
report on preparation of the TOR for the hazardous waste disposal 
company to carry out the cleanup 
b) 
report on pre-qualification and selection of the hazardous waste disposal 
company (contractor) 
c) 
report on pre-cleanup briefing, training and any other preparatory capacity 
building that the contractor will receive 
d) 
report on pre-cleanup training and capacity building that the project 
personnel (staff of PIU and others involved in supervision of the cleanup) 
will receive to carry out informed supervision of the clean-up 
e) 
report of the clean-up operation while ongoing; these short operational 
reports will be generated on a weekly basis between the start and the end 
of the cleanup and provided to the PIU 
f) 
daily log, maintained by the contractor, and a separate daily supervision 
log maintained by the project personnel; these logs will be on file with the 
PIU 
g) 
record of receipt from the centralized waste disposal facilities, e.g., 
sanitary landfill or industrial wastewater treatment plant, which will 
accept the waste from the site 
h) 
clean up completion report, complete with disposal certificate from EPB, 
at the completion of the clean up and decommissioning of the site 
i) 
post-clean up monitoring report at the time when post-clean up samples 
are analyzed and interpreted by an independent lab. 
 
Page  132
Chapter 
9: 
Public 
Participation 
     132 
 
Public Participation 
Legal Basis for Public Participation 
1. 
The main legal basis for public participation is as following:  
a. 
“The Law of the People’s Republic of China on Environmental Impact 
Assessment”.
 
Article 21 of the “The Law of the People’s Republic of China 
on Environmental Impact Assessment (EIA Law)” (September 1, 2003) 
specifies that for the construction projects that may possibly cause major 
impact on environment and for which environmental impact statement should 
be compiled, except the situations of confidentiality specified by our country, 
the client shall hold demonstration meeting and hearing or use other forms to 
seek opinions from related organizations, experts and the public before 
submitting the construction project environmental impact statement for 
approval. The environmental impact statement submitted by the client shall be 
attached with description for adoption or refuse of the opinions from related 
organizations, experts and the public.  
b. 
“Rules of Environmental Protection Management of the Construction 
Project”.    
Article 15 of the “Rules of Environmental Protection Management 
of the Construction Project” (Decree No.253 of the State Council of the 
People’s Republic of China, November 29, 1998) specifies that in compiling 
environmental impact statement, the client shall seek opinions from related 
organizations and residents in the place of construction project according to 
related laws.    
 
Public Participation/Consultation and Information Disclosure of the Project 
2. 
Purpose of Public Participation/consultation
.
Public participation is a two 
way exchange between the project implementation unit or environmental impact 
assessment working group and the public, it is essential to the decision making and 
successful implementation of the project scheme. Through public participation, it is 
possible to report the specific situation of the project to the public completely at any 
time to:  
a. 
enable the public in the project affected area and particularly the people in the 
surrounding region of the project to promptly know information on the basic 
project situation and environmental problems including project survey, 
potential major environmental project influence and its solution, alternative 
scheme and mitigation measures;  
b.  enable the public to have opportunities to express their opinions through 
normal channel and know the protection objectives or the issues cared mostly 
Page  133
Chapter 
9: 
Public 
Participation 
     133 
 
by the public;  
c.  let the public to help identify the major and particularly many potential 
environmental problems possibly caused by the project so that appropriate 
measures can be taken to effectively protect sensitive protection objectives;  
d. a
ctively seek the public’s opinions and suggestions on the project and pool the 
wisdom of the collective to find basis for safeguarding the public’s vital 
interests;  
e. enhance the social acceptability of the project environmental impact 
assessment and ensure the feasibility and rationality of environmental 
protection measures to make the project design, construction and operation 
management more complete and rational;  
f.  enable the public to supervise the implementation of the environmental 
protection measures for the project construction and make the public’s various 
opinions and suggestions on the project as the supplementary basis for the 
environmental supervision and management; and  
g.  enable the project to be sufficiently recognized by the public and not to 
constitute hazard or threat to the public interests so as to realize the unification 
of economic benefit, social benefit and environmental benefit.  
 
3. 
Public Consultation prior to the final EIA.   There are two stages: 
a. 1
st
 stage -- public consultation.  Prior to completion of the draft environmental impact 
assessment report, internet is used to provide some information to the public possibly 
affected by the project, including basic project situation, possible environmental 
impact and arrangement of project environmental assessment work. Such information 
was published on the official website of Jiangsu Department of Environmental 
Protection. At the same time, to know the public’s attitude towards the project and 
their requirements for and suggestions on the project and environmental protection 
through field visit or questionnaire issuance to try to collect as many rational 
suggestions useable to this project as possible.  
b. 2
nd
 stage -- town hall meeting.   After completion of draft environmental impact 
assessment report, (and following the World Bank review of the draft EIA at a 
safeguards meeting) publish draft report and the environmental protection counter-
measures and means taken to reduce major pollution problems and hold meetings to 
seek the public opinions.  
 
4. 
Target groups.
 
Target groups include management personnel and workers of 
Liyang Guanghua Chemical Co. Ltd,  residents near the company,  owners of 
surrounding fish ponds and related personnel of government sectors etc. 
Page  134
Chapter 
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     134 
 
5. 
Information Disclosure.
 
Information release is also divided into two stages:  
a. 
Prior to drafting of the EIA.   To release  basic information of this project on 
the Jiangsu Environmental Protection Department Website, with brief 
description of the project as the main content, to tell the public that the 
environmental impact assessment of this project is under way, to seek the 
public opinions, welcome suggestions on this project, propose the issued 
concerned and publish the personnel and telephone number of the 
environmental impact assessment group.  
b. At the draft EIA stage.   The draft  EIA is released on the Jiangsu 
Environmental Protection Department Website and seeks extensive opinions 
from all walks of life. 
 
Analysis of the First Round Public Participation  
6. 
Survey Methodology.
 
Public participation in the first stage was carried out 
in the combined form of questionnaire and field visit in April to May 2005. Random 
sampling was used to inquire the public with different occupations and different 
educational attainments, at different ages and in different areas and introduce to them 
the major project contents including international conventions, demonstration 
projects, general situation of this project and possible environmental impact. The 
“Demonstration Project of Alternative to Chlordane and Mirex in Termite Control in 
China – Public Participation Questionnaire of the Closure and Cleanup of Liyang 
Guanghua Chemical Products Co. Ltd – was filled in and the specific survey situation 
is shown in Table 9-1. The important contents not involved in the first stage (e.g. 
whether the inquired residents suffered the harm of its products or production process 
etc) will be supplemented in the second stage of the public participation.  
Page  135
Chapter 
9: 
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     135 
 
Table 0-1  Public Participation Survey Methods in the First Stage 
Stage
Time Place 
Number 
of persons 
consulted 
Survey 
method 
Information 
Disclosure 
April 
2005 
The Development 
Zone,  
Niucheduo Nanfang 
Village,  
Yangzhuang Village,  
Shugang Village 
32 
Field visit and 
questionnaire 
survey 
First 
stage 
May 
2005 
Niucheduo,  
Nanfang Village,  
Yangzhuang Shugang 
Village 
31 
Field visit and 
questionnaire 
survey 
Released on 
Jiangsu 
Environmental 
Protection 
Bureau Website 
(http://www.jsh
b.gov.cn) 
7. 
Target groups.  
Among about 240 people in the study, 63 of them were 
consulted via two round questionnaires. The target groups are people in the study area 
including workers, peasants, technicians and management personnel (civil servants, 
teachers etc).The project team went to study area and informed them about the closure 
of the factory. These people were asked to fill up the questionnaires at the same time. 
The overall return rate is 100%. The first round consulted 32 people, while the second 
round consulted 31 people. 
 
Table 0-2  Basic Information of Target Groups in the First Survey 
Situation 
Public participation Subjects 
M
(17 persons) 53% 
Gender
F
(15 persons) 47% 
20~40 40~60 
Above 
60 
Age 
(13 persons) 
41% 
(17 persons) 
53% 
(2 persons) 6% 
Primary school 
and below  
Junior high 
school 
 
Technical 
secondary 
school and 
senior high 
school 
Junior 
college 
Educational 
background 
(7 persons) 22% 
(17 persons) 
53% 
(6 persons) 19% 
(2 persons) 
6% 
Technician 
Management 
personnel 
Worker Peasant 
Occupation 
(3 persons) 9% 
(5 persons) 16% 
(5 persons) 16% 
(19 persons) 
59% 
Page  136
Chapter 
9: 
Public 
Participation 
     136 
 
Table 0-3  Basic Information of Target Groups in the Second Survey 
 
Situation 
Public participation Subjects
 
M
(20 persons) 65% 
Gender
F
(11 persons) 35
20~40 40~60 
Above 
60 
Age 
(9 persons) 29%
(16 persons 
52%) 
(6 persons) 19% 
Primary school 
and below  
Junior high 
school 
 
Technical 
secondary 
school and 
senior high 
school 
Junior college 
Educational 
background 
(7 persons) 22%
(18 persons) 
58% 
(3 persons) 
10% 
(3 persons) 
10% 
Technician 
Management 
personnel 
Worker Peasant 
Occupation 
(2 persons) 6% 
(3 persons) 10% 
(6 persons) 
19% 
(20 persons) 
65% 
Remarks 
Including managers, employees of Guanghua Chemical Industry Co. 
Ltd and two fish pond contractors  
8. 
Survey Results and Analysis
.
Results of the two surveys are shown in 
Tables 9-4 and 9-5.
 
Page  137
Chapter 
9: 
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     137 
 
Table 0-4  Result of the First Survey 
 
Content of 
questionnaire 
Result analysis 
Very  
satisfied 
Moderately  
satisfied 
Unsatisfied 
Very 
unsatisfied
0
24 7 1 
Are you satisfied with the 
environmental quality?  
0
75

22

3

No A 
little  Yes 
- 
4
20 8 - 
Do you know or know of 
this project?  
12.5

62.5

25

-
Newspape
r
TV, 
broadcast  
Billboard 
Folk 
informatio
n
1
5
11
15
Through which channel 
do you know the 
information on this 
project?  
3

16

34

47

Yes No 
- 
- 
19 13 
- 
- 
Do you think the 
implementation of this 
project will improve the 
environment? 
59% 41% 
- 
- 
Yes No 
Not 
clear 
- 
11 8 
13 - 
Do you think the 
environment in the project 
location is polluted?  
34% 25% 
41% 
- 
No 
Minor 
influence 
Major 
influence 
-
4
24 4 - 
Do you think the 
implementation of the 
project will have 
influence on your life or 
work?  
12.5% 75% 
12.5% 
- 
Factory 
close 
down  
Site clean-up 
Others 
No answer
5
21 0 6 
What factors of the 
project implementation do 
you think will influence 
your normal life or work? 
16

66

0
18

Absolute 
support 
Conditional 
approval 
Indifference Objection 
18 4 
10 0 
What altitude do you hold 
towards this project?  
56.25

12.5

31.25

0
Page  138
Chapter 
9: 
Public 
Participation 
     138 
 
Table 0-5   Result of the Second Survey 
Content of 
questionnaire 
Result analysis 
Very 
satisfied 
Moderately 
satisfied 
Unsatisfied 
Very 
unsatisfied 
 
0
11
8
12
Are you satisfied 
with the 
environmental 
quality?  
0
35

26

39

No A 
little 
Yes 
 
 
13 13 
5 
 
 
Do you know 
or know of this 
project?  
42

42

16

Yes No Not 
clear  
 
29 1 
1 
 
 
Do you think 
the 
environment in 
the project 
location is 
polluted?  
94% 3% 
3% 
 
 
Water Air 
Soil 
Crops 
 
21 21 
19 
23 
 
What factors of 
the environment 
in the project 
location do you 
think are 
polluted? 
68% 68% 
61% 
74% 
 
Yes No 
No 
improvement 
in the near 
future 
 
30 0 
1 
 
 
Do you think the 
implementation 
of this project 
will improve the 
environment? 
94% 0 
6% 
 
 
No 
Minor 
influence 
Major 
influence 
 
22 3 
6 
 
 
Do you think 
the 
implementation 
of the project 
will have 
influence on 
your life or 
work?  
71% 10% 
19% 
 
 
Factory 
close 
down  
Site clean-
up 
Construction 
Farmland 
cultivation 
Others 
(thought 
to have 
no 
influence)
5
0
0
0
26
What factors of 
the project 
implementation 
do you think 
will influence 
your normal 
life or work?  
16% 0 
0 
0 84% 
Absolute 
support 
Conditional 
approval 
Indifference Objection 
 
27 2 
2 
0   
What altitude 
do you hold 
towards this 
project?  
87

6

6

0
Page  139
Chapter 
9: 
Public 
Participation 
     139 
 
9. 
Analysis of survey data from two round questionnaires indicates that: 
 
a.  The satisfaction degree of the public with the existing environment in the project 
location.  Of the respondents, 35 were moderately satisfied with the local 
environmental quality, 15 were unsatisfied and 13 were very unsatisfied. The main 
reason is that the surrounding environment was thought to be polluted.   
b. T
he
public’s knowledge degree of this project.   13 (21%) of the respondents knew this 
project, 33 knew a little (52%), and 17 (27%) knew nothing. Obviously, this project 
has received extensive attention from the public, but it is necessary to further increase 
the publicity of this project.   
c.  The public’s support degree for this project.   45 (71%) people supported the 
project,10% expressed conditional approval, 19% showed indifference and nobody 
objected it. 
d.  The suggestions and requirements of the public for this project.  26 people thought that 
the implementation of this project would have no influence on their own normal work 
and life, 27 thought the influence would be insignificant and 10 thought the influence 
would be significant. The major influences are noise arising from site clean-up and 
unemployment resulting from factory close-down. The employees of Guanghua 
Chemical Products Co. Ltd hope that workers will be properly arranged after factory 
close-down. The public hopes that during the project implementation, the rules and 
regulations related to environmental protection are strictly executed, necessary 
environmental protection measures are taken and discharge of noise and pollutants 
reach various environmental standards to minimize the possible impact on 
environmental and human health. 
 
Analysis of the Second Round Public Consultation 
10. 
Survey Methodology
.
The second round of public consultation will be 
conducted in the form of town or village meetings in November 2005 to release the 
conclusion of project environmental impact assessment and environmental protection 
countermeasures and means to be taken to reduce major pollution problems and to 
seek the public opinions.  
11. 
Analysis of Survey Objects. 
(To be added after the second round of public 
consultations.) 
12. 
Survey Results and Analysis. 
(To be added after the second round of public 
consultations.) 
 
Public disclosure  
13. 
The EIA will be to be disclosed in the Jiangsu Environmental Protection 
Department Website and local public libraries. It may also be requested from the 
World Bank Infoshop in Washington, DC.  
Page  140
Annex 1: Chlordane and Mirex Producers in China   
 
 
 
140 
 
ANNEX 1: Chlordane and Mirex Producers in China 
 
No.
Producers Location 
Chlordane 
Production 
Mirex 
Production 
1
Suzhou Jiangfeng Termite 
Control Company, Ltd. 
Suzhou, Jiangsu 
Yes No 
2
Liyang Guanghua Chemical 
Company, Ltd. 
Liyang, Jiangsu 
Yes Yes 
3
Taicang Xintang 2
nd
 
Chemical 
Factory 
Suzhou, Jiangsu 
Yes Yes 
4
Changzhou Yekang Chemical 
Products Company, Ltd. 
Changzhou, 
Jiangsu 
Yes Yes 
5
Shanghai Fengjiang Termite 
Control Materials Company, Ltd. 
Shanghai 
Yes Yes 
6
Liyang Xinhai Chemical Factory 
Liyang, Jiangsu 
Yes 
Yes 
7
Jintan Shuibei Termite Control 
Materials Factory 
Changzhou, 
Jiangsu 
Yes No 
8
Taicang Hushi Subsidary 
Company, Ltd.  
Suzhou, Jiangsu 
Yes No 
9
Dongtai 3
r
d
Chemical Factory 
Yancheng, 
Jiangsu 
Yes No 
Page  141
Annex 
2: 
Additional 
Chemical 
Information 
     141 
 
ANNEX 2: Additional Information on Chemicals at the 
Liyang Guanghua Site 
 
Chlordane 
1. 
Chlordane is a persistent organochlorine insecticide. It kills insects when 
ingested and on contact. Formulations include dusts, emulsifiable concentrates, 
granules, oil solutions, and wettable powders. 
 
2. 
The oral LD50 for chlordane in rats is 200 to 700 mg/kg, in mice is 145 to 430 
mg/kg, in rabbits is 20 to 300 mg/kg, and in hamsters is 1720 mg/kg. The dermal 
LD50 in rabbits is 780 mg/kg, and in rats is 530 to 690 mg/kg. The 4-hour inhalation 
LD50 in cats is 100 mg/L. 
 
3. 
Chlordane is moderately to highly toxic through all routes of exposure. 
Symptoms usually start within 45 minutes to several hours after exposure to a toxic 
dose. Convulsions may be the first sign of poisoning, or they may be preceded by 
nausea, vomiting, and gut pain. Initially, poisoning victims may appear agitated or 
excited, but later they may become depressed, uncoordinated, tired, or confused. 
Other symptoms reported in cases of chlordane poisoning include headaches, 
dizziness, vision problems, irritability, and weakness or muscle twitching. In severe 
cases, respiratory failure and death may occur. Complete recovery from a toxic 
exposure to chlordane is possible if proper medical treatment is administered. 
Chlordane is very irritating to the skin and eyes. Chlordane affects liver function, so 
many interactions between medicines and this pesticide may occur. Among these are 
decreased effectiveness of anticoagulants, phenylbutazone, chlorpromazine, steroids, 
birth control pills, and diphenhydramine. Increased activity of thyroid hormone may 
also occur. 
 
4. 
Chlordane is highly persistent in soils with a half-life of about 4 years. Several 
studies have found chlordane residues in excess of 10% of the initially applied 
amount 10 years or more after application. Sunlight may break down a small amount 
of the chlordane exposed to light. Evaporation is the major route of removal from 
soils. Chlordane does not chemically degrade and is not subject to biodegradation in 
soils. Despite its persistence, chlordane has a low potential for groundwater 
contamination because it is both insoluble in water and rapidly binds to soil particles 
making it highly immobile within the soil. Chlordane molecules usually remain 
adsorbed to clay particles or to soil organic matter in the top soil layers and slowly 
volatilize into the atmosphere. However, very low levels of chlordane (0.01 to 0.001 
ug/L) have been detected in both ground and surface waters in areas where chlordane 
was heavily used. Sandy soils allow the passage of chlordane to groundwater. 
 
Page  142
Annex 
2: 
Additional 
Chemical 
Information 
     142 
 
5. 
Chlordane does not degrade rapidly in water. It can exit aquatic systems by 
adsorbing to sediments or by volatilization. The volatilization half-life for chlordane 
in lakes and ponds is estimated to be less than 10 days. Chlordane has been detected 
in surface water, groundwater, suspended solids, sediments, bottom detritus, drinking 
water, sewage sludge, and urban run-off, but not in rain water. Concentrations 
detected in surface water have been very low, while those found in suspended solids 
and sediments are always higher (<0.03 to 580 ug/L). The presence of chlordane in 
drinking water has almost always been associated with an accident rather than with 
normal use. 
 
Mirex
27
 
6. 
Mirex is a bait insecticide used against a number of insect pests. It had been 
used heavily in South America and South Africa. Secondary use of mirex as a fire 
retardant in plastics, paints, and electrical goods is currently heavily restricted or 
banned in most countries. Mirex is highly resistant to biodegradation and has a half-
life of up to ten years in sediment. In the presence of sunlight, mirex breaks down to a 
fare more potent toxin, photomirex. Mirex is known to be one of the most stable and 
persistent pesticides. Mirex has been detected in Arctic freshwater, terrestrial 
organisms and in core sediment samples in Lake Ontario. It had also been found in 
lake trout captured in Lake Ontario, in fathead minnows and beluga whale oil from 
the St. Lawrence River. 
 
7. 
Mirex levels in human milk are above average for communities consuming 
high amounts of fish and sea bird eggs. Levels in the milk of Inuit from Nunavik, 
northern Quebec, are 10 times higher than those in southern Canadian residents. Even 
higher concentrations of Mirex are seen in fat tissue from Greenland Inuit.(WFPHA, 
World Federation of Public Health Associations, 2000). 
 
8. 
There have been few studies on human exposures, and little data exists for 
human health effects of mirex. Animal studies have shown several adverse reactions 
to mirex doses administered through diet. In rats, mirex exhibits toxic effects on 
fetuses, including cataract formation and it caused liver hypertrophy following long-
term, low-dose exposure in rats. Mirex is also associated with suppression of the 
immune system. (WFPHA, 2000).  
 
9. 
Mirex is a highly stable insecticide formerly used for fire ant control in the 
southeastern US. Mirex was also employed as a flame-retardant. Release into the 
environment has occurred via effluents from manufacturing plants and sites where 
mirex was utilized as a fire resistant additive to polymers, and at points of application 
where it was used as a insecticide. Mirex is expected to persist in the environment 
despite the 1978 ban on its use in the US. For the most part mirex is resistant to 
biological and chemical degradation. Photolysis of mirex may occur. However, 
27
 
http://www.speclab.com/compound/c2385855.htm
 
Page  143
Annex 
2: 
Additional 
Chemical 
Information 
     143 
 
sorption is likely to be a more important fate process. Persistent compounds such as 
kepone, and monohydro- and dihydro- derivatives of mirex have been identified as 
products of extremely slow transformation of mirex. Mirex has been shown to 
bioconcentrate in aquatic organisms. A Koc value of 2.4X10 7 indicates mirex will 
strongly adsorb to organic materials in soils and sediments. Therefore mirex is 
expected to be immobile in soil and partition from the water column to sediments and 
suspended material. A Henry's Law Constant for mirex of 5.16X10-4 atm-cu m/mole 
at 22 deg C suggests rapid volatilization may occur from environmental waters and 
moist soils where absorption does not dominate. Based on this Henry's Law Constant, 
the volatilization half-life from a model river (22 deg C; 1 meter deep flowing 1 m/sec 
with a wind speed of 3 m/sec) has been estimated to be 10.7 hr; however, this 
estimation neglects the potentially important effect of adsorption. The volatilization 
half-life from an environmental pond, which considers the effect of adsorption, can be 
estimated to be about 1143 years. 
 
Hexachlorocyclopentadiene
28
 
10. 
Hexachlorocyclopentadiene is an intermediate in the manufacture of some 
pesticides.  Hexachlorocyclopentadiene is very toxic following acute (short-term) oral 
and inhalation exposures.  The chemical is a severe eye, skin, and pulmonary irritant 
in humans, with effects including tearing of the eyes, sneezing, salivation, blistering, 
burns, and cough from acute exposures.  Limited information is available on chronic 
(long-term), reproductive, developmental, and cancer effects of 
hexachlorocyclopentadiene in humans.  Animal studies have seen effects on the lung, 
liver, kidney, and blood.  EPA has classified hexachlorocyclopentadiene as a Group 
D, not classifiable as to human carcinogenicity.  
 
11. 
Hexachlorocyclopentadiene is the key intermediate in the manufacture of 
some pesticides, including heptachlor, chlordane, aldrin, dieldrin, and endrin. (5, 6) 
 
12. 
Hexachlorocyclopentadiene is also used in the manufacture of flame retardants 
and some resins and dyes. (1, 8)  
Sources and Potential Exposure 
13. 
Workers involved in the manufacture of hexachlorocyclopentadiene and 
during the manufacture of products containing the chemical would have the highest 
exposure to hexachlorocyclopentadiene. (1, 9)  
 
14. 
Hexachlorocyclopentadiene has been detected at low levels in ambient air.  
The sources of the chemical in air appear to be releases from manufacturing processes 
or incineration and landfilling of waste containing hexachlorocyclopentadiene. (1)  
28
 http://www.epa.gov/ttn/atw/hlthef/hexa-die.html
 
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Annex 
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Additional 
Chemical 
Information 
     144 
 
Assessing Personal Exposure 
15. 
Laboratory tests can detect hexachlorocyclopentadiene in blood or urine. (1, 9)  
 
Health Hazard Information 
16. Acute 
Effects: 
 
·
Hexachlorocyclopentadiene is very toxic to humans. (2)  
·
Hexachlorocyclopentadiene is a severe eye, skin, and pulmonary irritant in 
humans.  Inhalation of the chemical causes tearing, sneezing, and salivation, 
and skin contact can cause blisters and burns. (1, 3)  
·
The major target organ for acute hexachlorocyclopentadiene toxicity is the 
lung, with cough, chest pains, and difficulty in breathing reported in humans.  
Nervousness, headaches, and abdominal cramps are other symptoms reported 
from hexachlorocyclopentadiene toxicity. (1, 3)  
·
Tests involving acute exposure of rats have shown hexachlorocyclopentadiene 
to have extreme toxicity by inhalation exposure, moderate toxicity by oral 
exposure, and high to extreme toxicity by dermal exposure. (3, 4)  
17. 
Chronic Effects (Noncancer):  
·
Epidemiologic studies on workers have not shown any significant differences 
in mortality between workers exposed to hexachlorocyclopentadiene and those 
in the general population.  However, these studies are limited by short follow-
up periods, lack of data on cigarette smoking, and other factors. (1, 2)  
·
Chronic exposure to hexachlorocyclopentadiene, via inhalation, has been 
studied in animals, with effects noted in the lung, liver, kidney, and blood. (1, 
3, 9)  
·
EPA has established a Reference Concentration (RfC) of 0.0002 milligrams 
per cubic meter (mg/m
3
)
for hexachlorocyclopentadiene, based on respiratory 
effects in rats. (2)  
·
The Reference Dose (RfD) for hexachlorocyclopentadiene is 0.006 milligrams 
per kilogram body weight per day (mg/kg/d) based on stomach lesions in rats.  
·
The RfC and RfD are not direct estimators of risk but rather reference points 
to gauge the potential effects.  At exposures increasingly above these levels, 
the potential for adverse health effects increases.  Lifetime exposure above the 
RfC or RfD does not imply that an adverse health effect would necessarily 
occur. (2)  
Carbon Tetrachloride
29
 
29
 
http://www.chemicalland21.com/industrialchem/organic/CARBON%20TETRACHLORIDE.htm
 
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Annex 
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Additional 
Chemical 
Information 
     145 
 
18. 
Carbon Tetrachloride, also called tetrachloromethane, is a colorless, dense, 
highly poisonous, highly volatile and nonflammable liquid with a characteristic 
aromatic odor, belonging to the family of organic halogen compounds. Carbon 
tetrachloride freezes at -23 C and boils at 77 C. It is sparingly soluble in water. When 
heated to decomposition, it forms highly toxic fumes of phosgene and hydrogen 
chloride. It is prepared by the reaction of chlorine with carbon disulfide or with 
methane in the presence of a catalyst. It is used principally in the manufacture of freon 
refrigerants e.g., dichlorodifluoromethane (Freon-12) and propellants for aerosol cans. 
Carbon tetrachloride is known to deplete the ozone layer. Its half-life is more than 30 
years. It was used as a dry cleaning solvent and for degreasing metals as it is not 
flammable and is a good solvent for fats, oils, and greases. Due to the property of 
much denser than air, it is used in fire extinguishers in mixtures with potent fumigants 
to reduce the fire hazard, to render benzene nonflammable and separate xylene 
isomers as components to reduce flammability. In veterinary medicine, it is used as an 
anthelmintic and to treat liver fluke infections in sheep. In polymer industry, it is used 
as a reaction medium, catalyst and chain transfer agent, as a solvent for resins. In 
organic synthesis, it is useful as a feedstock for chlorination of organic compounds 
used in soap perfumery and insecticidal industries. In automobiles, it is used as an 
azeotropic drying agent for wet spark plugs. It is also used in petroleum refining, 
pharmaceutical manufacturing, and general solvent use.  
Page  146
Annex 
3: 
QA/QC 
for 
Monitoring 
     146 
 
Annex 3: QA/QC for Monitoring and Analysis 
 
First Phase Monitoring: 
Laboratory Quality Assurance System and Control Measures (QA/QC) 
1. 
The quality assurance of this monitoring follows the 
Quality Manual
 developed 
by the Monitoring Center of Jiangsu Province. 20% of duplicate sample and 10% of 
matrix spike sample or standard sample is needed for wastewater sample. All 
monitoring staff have passed related examinations and hold certificates. All 
equipment is certificated by a metrology institution. All field equipment is calibrated. 
Monitoring data is audited. 
2. Analysis 
procedures 
are: 
1) Water: 
¾\03
Pass 1L of water sample through C
18
 SPE cartridge , elute the cartridge with 
methylene chloride 
¾\03
Concentrate the elute to 1ml 
¾\03
Analyze using GC/MS 
2) Soil: 
¾\03
Extract the 10g of soil sample with solvent of ethane/acetone (1:1) for 30 
minutes using microwave equipment  
¾\03
Wash the extracted solution with 10ml sulfuric acid, dry with sodium sulfate 
¾\03
Concentrate the extracted solution to 1ml 
¾\03
Pass the concentrated solution to the 6ml(1g) of Floristic cartridge to remove 
interferences, elute with ethane/acetone solvent 
¾\03
Concentrate to 1ml, add internal standard 
¾\03
Analyze using GC/MS 
—
Quality control method 
1)  Sequence calibration 
One concentration level of the standard solution is analyzed every 12 hours; 
the derivation should below 20%. 
2) Contrast sample determination 
Analyze the redistilled water or blank quartz sand with the same analysis 
procedure as the actual sample; no target compound is detected. The results 
are as follow: 
Page  147
Annex 
3: 
QA/QC 
for 
Monitoring 
     147 
 
Results  
Monitoring Factors 
redistilled water 
 (ng/L) 
blank quartz sand 
(mg/kg) 
Chlordane 0.1L 0.01L 
Mirex 0.1L 
0.01L 
Endosulfan 0.2L 0.02L 
Hexachlorocyclopentadiene 0.4L 
0.04L 
3) Accuracy 
Add 10,100,200 ng of standard to the redistilled water or blank quartz sand, 
the analysis results are as follow: 
 
Recovery(%) 
Compounds 
Amount added 
Standard (ng) 
water soil 
10 80.9 
56.9 
100 95.8 76.9 
Chlordane 
200 96.8 80.5 
10 85.9 
60.9 
100 92.8 77.4 
Mirex 
200 99.2 95.8 
10 85.4 
63.8 
100 92.9 69.5 
Endosulfan 
200 95.8 89.2 
10 85.9 
50.8 
100 95.5 62.1 
Hexachlorocyclopentadiene 
200 96.9 90.6 
The recovery of sample is as follow. The results meet the requirement of the 
accuracy and are acceptable.  
 
Matrix Monitoring 
Factors 
Recovery/(%) 
Chlordane 82.3~89.6 
Mirex 89.6~90.3 
Endosulfan 90.6~94.9 
water 
Hexachlorocyclopentadiene 86.1~95.9 
Chlordane 60.5~75.9 
Mirex 62.3~72.9 
Endosulfan 70.5~80.9 
soil 
Hexachlorocyclopentadiene 58.9~75.9 
4) Precision 
Add 10, 100, 200ng of standard to the redistilled water or blank quartz sand, 
repeat analysis 6 times, the results is like below:  
 
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Coefficient of 
variation (CV%) 
Permitted 
derivation (%) 
Monitoring Factors 
 
Amount added 
Standard (ng)  
water soil 
water soil 
10 1.5 
3.6 
15.2 
20.2 
100 0.9 
1.5 
10.6 
15.2 
Chlordane 
200 0.2 
0.5 
20.4 
20.5 
10 2.5 
2.9 
18.9 
22.5 
100 0.5 
1.0 
20.8 
25.9 
Mirex  
 
200 0.2 
0.7 
25.9 
30.0 
10 1.5 
2.5 
20.5 
16.3 
100 0.6 
0.9 
15.5 
17.8 
Endosulfan 
 
200 0.2 
0.5 
17.9 
18.8 
10 2.1 
2.8 
21.3 
22.8 
100 0.5 
1.6 
20.5 
25.8 
Hexachlorocyclo- 
pentadiene 
 
200 0.2 
0.5 
22.3 
19.8 
The coefficient of variation (CV) of sample is as follow. The results meet the 
requirement of the accuracy and are acceptable.  
The repetition meets the requirement of the precision, the results are 
acceptable.  
matrix Monitoring 
Factors 
CV 
(%) 
Chlordane 0.9~1.0 
Mirex 0.8~1.5 
Endosulfan 0.9~1.0 
water 
Hexachlorocyclopentadiene 0.5~0.7 
Chlordane 2.0~2.2 
Mirex 1.9~2.0 
Endosulfan 0.9~1.2 
Soil 
Hexachlorocyclopentadiene 0.7~1.0 
5) Detection limit 
The minimum quantification limit is 1ng/L for water and 0.1ug/kg for soil. 
The standard derivation is calculated by seven analyzable results, which is 
0.01~0.15 for water and 0.02~0.18 for soil. The detection limit is 3 times of 
the standard derivation (soil sample is calculated based on 10g). 
 
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Detection limit 
Monitoring Factors 
Water (ng/L) 
Soil (
g/kg)
 
Chlorodane 0.1 
0.01 
Mirex 0.1 
0.01 
Endosulfan 0.2 
0.02 
Hexachlorocyclopentadiene 0.4 
0.04 
6) Apparatus Check-up 
The transfer rate from DDT into DDD should not be higher than 20%. 
 
Second Phase Monitoring: 
Laboratory Quality Assurance System and Quality Control Measures (QA/QC) 
3. 
The quality assurance of this monitoring also follows the 
Quality Manual
 
developed by Monitoring Center of Jiangsu Province. 20% of duplicate sample and 
10% of matrix spike sample or standard sample is needed for wastewater sample 
according to the quality control requirement. All the monitoring staff passed 
examinations and hold certificates. All the metrology of equipments is certificated by 
the metrology institution. All the equipments used in the field are calibrated, and 
monitoring data is audited  
1)  Sequence calibration 
One concentration level of the standard solution is analyzed every 12 hours, 
the deviation should 
20%.
 
2) Contrast sample determination 
Analyze the redistilled water or blank quartz sand with the same analysis 
procedure as the actual sample; no target compound is detected. 
 
Results
 
Monitoring factors
 
Redistilled water 
(
g/L
)
Blank quartz sand 
(
g/kg
)
Chlordane  
0.01L 
0.1L 
Mirex 0.01L 
0.1L 
3) Accuracy 
Add 10,100,200 ng of standard to the redistilled water or blank quartz sand, 
the analysis results are as follow: 
 
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Accuracy (Recovery)/(%) 
Monitoring factor
 
Amount added 
Standard (ng) 
Water Soil 
10 
82.5  
75.5 
100 
97.7  
80.7  
Chlordane 
200 
98.7  
84.5  
10 
87.6  
63.9  
100 
94.7  
81.3  
Mirex 
200 
101  
101  
Add 10,100,200 ng of standard to the samples. The results are as follow. The 
results meet the requirement of the accuracy and are acceptable.  
 
Samples 
Monitoring 
factor
 
number of 
samples 
Number of added 
standards 
Accuracy 
(Recovery)/(%) 
Chlordane 9 
3 
83.6~95.6 
water 
Mirex 9 
3 
88.5~99.0 
Chlordane 10 
3 
80.2~81.5 
soil 
Mirex 10 
3 
70.1~99.5 
4) Precision 
Add 10,100,200ng of standard to the redistilled water or blank quartz sand, 
repeat analyses 6 times, the results are like below: 
 
Coefficient of variation (CV%) 
Monitoring factor
 
Amount of added 
standards(ng) 
Water Soil 
10 1.5 
3.6 
100 0.9 
1.5 
Chlordane 
200 0.2 
0.5 
10 2.5 
2.9 
100 0.5 
1.0 
Mirex 
200 0.2 
0.7 
Add 10,100,200 ng of standard to the samples. The repetition meets the 
requirement of the precision, the results are acceptable.  
 
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samples 
Monitoring 
factor 
Number of 
samples 
Parallel 
samples 
CV(%) 
Chlordane 12 3 
1.2~1.5 
water 
Mirex 9 
3 
1.5~2.1 
Chlordane 12 
3 
1.5~1.9 
soil 
Mirex 9 
3 
1.2~2.5 
5)Minimum quantification limit 
The minimum quantification limit is 1ng/L for water and 0.1ug/kg for soil. 
 
6)Check-up of Apparatus 
The transfer rate from DDT into DDD should not be higher than 20%. 
 
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Waste 
Companies 
in 
Jiangsu 
    152 
 
Annex 4: Registered Hazardous Waste Disposal and 
Management Companies in Jiangsu 
 
Hazardous Wastes Landfill Sites in Jiangsu
30
 
1. 
As of 2005, Jiangsu Province has built a landfill site for disposal of general 
industrial solid wastes. It is located in Zhangjiagang, Jiangsu. It can dispose of non-
hazadous industrial solid wastes.  
2. 
Wuxi Municipality has built a hazardous waste landfill site in September 
2005. Two other hazardous waste landfills 
–
Nanjing, Suzhou – are under 
construction and are expected to be in operation around 2007. Location of the Nanjing 
Hazardous Waste Landfill has been identified, and the design of this landfill is in 
progress. The Nanjing Landfill is expected to be in operation after 2007. The 
construction of the Suzhou Hazardous Waste Landfill is at its site selection stage, and 
thus its completion time is yet to be confirmed. 
Container Cleaning Companies 
3. 
In Wuxi and Suzhou, approximately 10 companies have permits issued by the 
Jiangsu Provincial Environmental Protection Bureau to handling contaminated metal 
and plastic containers. The following table provides a list of such enterprises. Note 
this is not a complete list for all such companies registered in Jiangsu. 
 
Name of enterprises 
Location 
Capacity 
Wuxi Zhongtian Environmental Protection 
Company, Ltd. 
Wuxi 
20000 
pieces/a 
Kunshan City Huisheng Metal Container 
Regeneration Company, Ltd. 
Kunshan City, 
Suzhou 
80000 
pieces/a 
Changzhou Kanglong Chemical Company, Ltd. 
Changzhou  
15000 
pieces/a 
Kunshan City Shuanglin Packing Container 
Regeneration Company, Ltd. 
Kunshan City, 
Suzhou 
60000 
pieces/a 
Changshu City Fuxin Drum Company 
Changshu City, 
Suzhou 
70000 
pieces/a 
Jiangyin City Jiangnan Metal Drum Factory Co. 
Ltd  
Jiangyin City, 
Wuxi 
40000 
pieces/a 
Soil Remediation Enterprises 
4. 
As of 2005, there are no soil remediation companies registered in Jiangsu 
Province.  
30
 Outside Jiangsu, Shanghai and Hangzhou (in Zhejiang) have hazardous waste landfills in operation. 
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    153 
 
Hazardous Waste Incinerators 
5. 
Jiangsu province has built 32 centralized centers for incineration of industry 
hazardous wastes in recent years. These thirty two incineration centers have thirty 
seven incinerators with annual disposal capacity of 10,000 tons of hazardous wastes. 
The following table provides a list of these centers. 
 
No. Name 
Location 
Capacity 
(tones/a) 
Main facilities 
1.
Nanjing Jianbei Waste 
Disposal Center 
Nanjing 5500 
2
incinerators 
(A) 
2.
Nanjing Huifeng Waste 
Disposal Cener 
Nanjing 1500 
1 
incinerator 
(A)
3.
Nanjing Jingzhijie Solid 
Wastes Treatment Co.,Ltd 
Nanjing 9000 
2
incinerators 
(B, C)  
4.
Wuxi Industrial Wastes 
Security Disposal Co., Ltd 
Wuxi 9000 
2
incinerators 
(B) 
5.
Fuding Env. Engeering 
Co.·Fuding Industrial Waste 
Security Disposal Center 
Yixing, Wuxi 
720 
1 incinerator (A)
6.
Jiangyin Industrial Solid 
Waste Disposal Center 
Jiangyin, 
Wuxi 
1800 1 
incinerator 
(A)
7.
Changzhou Industrial wastes 
Treatment Center 
Changzhou 5400 
1 
incinerator 
(B)
8.
Jiangsu Fuchang Chemical 
Residue Treatment Co. 
Wujin,  
Changzhou 
3000 1 
incinerator 
(A)
9.
Jintan Huazhen Waste 
Treatment Co. 
Jintan, 
Changzhou 
3000 1 
incinerator 
(A)
10.
Wuzhong District Solid 
Wastes Treatment Center 
Suzhou 4000 
1 
incinerator 
(A)
11.
Suzhou Rongwang Env. 
Protection Co. 
xiangcheng 
District, 
Suzhou 
8000 1 
incinerator 
(B)
12.
Wujiang Taihu Industrial 
Waste Treatment Center 
Wujiang, 
Suzhou 
2500 2 
incinerator 
(A)
13.
Wujiang Luyi Solid Wastes 
Recycling and Disposal 
Co.,Ltd 
Wujiang, 
Suzhou 
6000 1 
incinerator
 
(B) 
14.
Suzhou Industrial Park 
Heshun Solid Wastes 
Treatment Co.,Ltd 
Suzhou 4000 
1 
incinerator 
(B)
15.
Suzhou Industrial Park 
Zhongxing Solid Wastes 
Disposal Co.,Ltd 
Suzhou 3000 
1 
incinerator 
(A)
16.
Suzhou New District Env. 
Protection Service Center 
Suzhou 5000 
3
incinerators 
(B, 2A) 
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    154 
 
No. Name 
Location 
Capacity 
(tones/a) 
Main facilities 
17.
Kunshan Jinxin Material 
Recycling Co. 
Kunshan, 
Suzhou 
1500 1 
incinerator 
(A)
18.
Kunshan Liqun Solid Wastes 
Treatment Co.,Ltd 
Kunshan, 
Suzhou 
7200 1 
incinerator 
(C)
19.
Suzhou Env. Engeering 
Co.·Solid Waste Disposal 
Center 
 
Kunshan, 
Suzhou 
900 1 
incinerator 
(A)
20.
Taicang Kelin Solid Waste 
Treatment Co. 
Taicang, 
Suzhou 
2000 1 
incinerator 
(B)
21.
Nantong Qingyuan Industrial 
Solid Waste Treatment 
Factory 
Nantong 6000 
1 
incinerator
 
(A)
22.
Qidong Shisong Solid Waste 
Disposal Co. 
Qidong, 
Nantong 
1500 1 
incinerator 
(A)
23.
Rudong Daheng Hazardous 
Waste Treatment Co. 
Rudong, 
Nantong 
2000 1 
incinerator 
(A)
24.
Lianyungang Linmuzu 
Waste Treatment Co. 
Lianyungang 3000 
2
incinerator (A, 
C) 
25.
Huai’an Solid Waste 
Security Disposal Center 
Huai’an 2000 
1 
incinerator 
(A)
26.
Yizheng Fuchang Chemical 
Residue Treatment Co. 
Yizheng, 
Yangzhou 
3000 1 
incinerator 
(A)
27.
Zhenjiang Xinyu Soild 
Wastes Treatment Co.,Ltd 
Zhenjiang 3000 
1 
incinerator 
(B)
28.
Yancheng Yuxin Solid 
Waste Disposal Co. 
Yancheng 3000 
1 
incinerator 
(B)
29.
Taixing Fuchang Solid 
Waste Disposal Co. 
Taixing, 
Taizhou 
2250 1 
incinerator 
(A)
30.
Taizhou Yuxin Solid Waste 
Disposal Co. 
Taixing, 
Taizhou 
3000 1 
incinerator 
(B)
31.
Suqian Kelin Solid Waste 
Disposal Co. 
Suqian 3000 
1 
incinerator 
(B)
32.
Total -- 
107260 
37 
incinerators 
Note

A: direct combustion incineration kiln; 
B: destructive distillation gasification pyrolysis; 
C: rotary kiln
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Annex 4: Hazardous Waste Companies in Jiangsu 
 
 
 
 
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