50877 PCB Management and Disposal Demonstration Project Analysis of PCB Treatment & Disposal Options for the Socialist Republic of Vietnam Final Report to The World Bank July 2008 333051 SNCLAVALIN Inc. SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 2 of 119 TABLE OF CONTENTS Page EXECUTIVE SUMMARY ........................................................................................................................................6 1.0 INTRODUCTION.......................................................................................................................................11 1.1 PCBs...............................................................................................................................................11 1.2 Basel Convention ...........................................................................................................................12 1.3 Criteria for Determination of PCB Waste ......................................................................................12 1.4 Developing Countries.....................................................................................................................12 1.5 Vietnam ..........................................................................................................................................13 1.6 PCB Inventory in Vietnam .............................................................................................................14 1.7 Timeframe for Implementation of the Stockholm Convention ......................................................14 1.8 Responsibilities ..............................................................................................................................15 1.9 Existing PCB Disposal Technology ...............................................................................................15 1.10 Scope of Work................................................................................................................................16 2.0 PCB DESTRUCTION TECHNOLOGY REVIEW ....................................................................................18 2.1 Resources for Technology Selection ..............................................................................................20 2.2 Pre-treatments.................................................................................................................................27 2.2.1 Dewatering .....................................................................................................................27 2.2.2 Electrical Equipment Disassembly ................................................................................28 2.2.3 Shredding .......................................................................................................................28 2.2.4 Screening........................................................................................................................28 2.2.5 Oil / Water Separation....................................................................................................28 2.2.6 pH Adjustment ...............................................................................................................29 2.2.7 Soil Washing ..................................................................................................................29 2.2.8 Thermal Desorption .......................................................................................................29 2.2.9 Thermally Enhanced Soil Vapour Extraction ................................................................30 2.2.10 Solvent Washing ............................................................................................................30 2.2.11 Soil Flushing ..................................................................................................................31 2.2.12 Adsorption / Absorption.................................................................................................31 2.3 Post-Treatment Methods ................................................................................................................32 2.3.1 Cooling...........................................................................................................................32 2.3.2 Polishing ........................................................................................................................32 2.3.3 Liquid/Solid Separation .................................................................................................32 2.4 Oxidation Treatment Methods........................................................................................................32 2.4.1 Molten Salt Oxidation (MSO)........................................................................................32 2.4.2 Mediated Electro-Chemical Oxidation (MEO) ..............................................................33 2.4.3 Super-Critical Water Oxidation (SCWO) ......................................................................34 2.4.4 Advanced Oxidation Process (AOP)..............................................................................34 2.4.5 TiO2 Enhanced Photocatalysis (an AOP technology) ....................................................35 2.4.6 Fe (III) Photocatalyst Degradation (an AOP technology)..............................................36 2.4.7 Wet Air Oxidation (WAO).............................................................................................36 I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 3 of 119 2.5 Reduction Destruction Processes ...................................................................................................37 2.5.1 Gas Phase Chemical Reduction (GPCR) .......................................................................37 2.5.2 Solvated Electron Technology (SET) ............................................................................39 2.5.3 Sodium Reduction..........................................................................................................40 2.5.4 Other Alkali Reduction Techniques...............................................................................40 2.5.5 Based Catalyzed Decomposition Process (BCD or BCDP)...........................................40 2.5.6 Vacuum Heating and Decomposition ............................................................................41 2.5.7 Catalytic Hydrodechlorination .......................................................................................42 2.5.8 Catalytic Dechlorination and Photochemical Dechlorination ........................................42 2.5.9 Catalytic Hydrogenation ................................................................................................42 2.5.10 SonoProcess Technology ...............................................................................................43 2.6 Thermal Methods (Combustion) ....................................................................................................43 2.6.1 Large Scale Fixed Incinerators.......................................................................................44 2.6.2 Small Scale Fixed Incinerators.......................................................................................45 2.6.3 Mobile Incinerators ........................................................................................................45 2.6.4 Cement Kiln Incineration...............................................................................................46 2.7 Thermal Methods (Non-combustion) .............................................................................................47 2.7.1 Pact Process....................................................................................................................48 2.7.2 Plasma Converter System ..............................................................................................48 2.7.3 Plascon ...........................................................................................................................49 2.7.4 Molten Metal Media Processes ......................................................................................49 2.7.5 In-Situ Vitrification........................................................................................................49 2.7.6 Self-propagating High-Temperature Dehalogenation....................................................50 2.8 Bioremediation ...............................................................................................................................51 2.8.1 Anaerobic / Aerobic Composting...................................................................................52 2.8.2 Enhanced Bioremediation: In-Situ.................................................................................52 2.8.3 Biological Reactors ........................................................................................................53 2.8.4 Phytoremediation ...........................................................................................................54 2.9 Other Methods................................................................................................................................54 2.9.1 Long Term or Permanent Storage ..................................................................................54 2.9.2 Mechanochemical Dehalogenation (Ball Milling).........................................................55 2.10 Summary Task 1 Technology Evaluation ......................................................................................56 3.0 TASK 2: IN-COUNTRY POTENTIAL DESTRUCTION TECHNOLOGIES.........................................58 3.1 Center for Environmental Treatment Technologies .......................................................................58 3.2 Center for Environmental Protection and Consultation .................................................................60 3.3 Vietnamese Academy of Science and Technology ........................................................................61 3.4 Holcim............................................................................................................................................62 3.5 URENCO .......................................................................................................................................69 3.6 Task 2 Summary.............................................................................................................................70 4.0 TASK 3 ­ EVALUATION OF REGIONAL PCB DISPOSAL OPTIONS................................................71 4.1 Methodology ..................................................................................................................................71 4.2 Findings by Country.......................................................................................................................71 4.2.1 Australia .........................................................................................................................71 4.2.2 Cambodia .......................................................................................................................74 4.2.3 China ..............................................................................................................................74 I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 4 of 119 4.2.4 Japan ..............................................................................................................................74 4.2.5 Malaysia .........................................................................................................................75 4.2.6 New Zealand ..................................................................................................................75 4.2.7 The Philippines ..............................................................................................................76 4.2.8 Singapore .......................................................................................................................77 4.2.9 Taiwan............................................................................................................................77 4.3 Summary ........................................................................................................................................78 5.0 TASK 4 ­ EVALUATION OF PCB DISPOSAL OPTIONS OUTSIDE THE REGION ..........................79 5.1 Methodology ..................................................................................................................................79 5.2 Findings by Country.......................................................................................................................79 5.2.1 North America................................................................................................................79 5.2.1.1 Canada ........................................................................................................79 5.2.1.2 United States of America............................................................................84 5.2.2 Europe ............................................................................................................................85 5.2.2.1 Belgium ......................................................................................................85 5.2.2.2 Denmark .....................................................................................................86 5.2.2.3 Finland........................................................................................................86 5.2.2.4 France .........................................................................................................87 5.2.2.5 Germany .....................................................................................................88 5.2.2.6 Italy.............................................................................................................92 5.2.2.7 Netherlands.................................................................................................92 5.2.2.8 Norway .......................................................................................................94 5.2.2.9 Sweden .......................................................................................................94 5.2.2.10 Switzerland .................................................................................................95 5.2.2.11 United Kingdom .........................................................................................95 5.3 Summary ........................................................................................................................................96 6.0 INTERIM SUMMARY...............................................................................................................................99 6.1 Technologies for PCB Destruction by Waste Matrix.....................................................................99 6.1.1 Soil and Soil-like Materials............................................................................................99 6.1.2 Water and Aqueous Solutions........................................................................................99 6.1.3 Sediment, Sludge and Slurries .....................................................................................100 6.1.4 Oily Phase and Organic Liquids ..................................................................................100 6.1.5 Solid Waste and Electrical Equipment.........................................................................100 6.1.6 Technology Summary ..................................................................................................100 6.2 Operating PCB Waste Disposal Facilities ....................................................................................101 6.2.1 Rationale for Selection.................................................................................................101 6.2.2 Treatment within Vietnam ...........................................................................................101 6.2.3 Treatment outside of Vietnam......................................................................................102 6.3 Summary of Promising Technologies ..........................................................................................103 I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 5 of 119 7.0 TREATMENT cAPACITY Comparison ..................................................................................................105 7.1 Discussion of Results: Oil Treatment..........................................................................................106 7.2 Discussion of Results: Equipment Treatment .............................................................................106 7.3 Discussion of Results: Soil Treatment ........................................................................................107 7.4 Summary of Treatment Capacity Durations.................................................................................108 8.0 COST ASSESSMENT AND COMPARISON .........................................................................................109 8.1 Comparison of Cost Estimate Scenarios ......................................................................................111 8.1.1 Scenario 1.....................................................................................................................111 8.1.2 Scenario 2.....................................................................................................................112 8.1.3 Scenario 3.....................................................................................................................113 8.1.4 Scenario 4.....................................................................................................................113 8.1.5 Scenario 5.....................................................................................................................114 8.1.6 Summary ......................................................................................................................115 8.2 Comparison of Cost Estimates Scenarios: Soil ............................................................................116 8.2.1 Scenario 1.....................................................................................................................116 8.2.2 Scenario 2.....................................................................................................................116 8.2.3 Scenario 3.....................................................................................................................116 8.2.4 Scenario 4.....................................................................................................................117 8.2.5 Scenario 5.....................................................................................................................117 8.2.6 Summary ......................................................................................................................118 8.3 Next Steps ....................................................................................................................................118 I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 6 of 119 LIST OF TALES Page/Follows Page Table 2.1 Potential Remedial Technologies Assessed By Others ..................................................................21 Table 2.2 Treatment Technologies According to Matrices and Contaminants ..............................................26 Table 4.1 Summary of Task 3: Regional Disposal Options ..........................................................................78 Table 4.2 Details of Task 3: Regional Disposal Options ..............................................................................78 Table 5.1 Summary of Task 4: European and North American Disposal Options........................................98 Table 5.2 Details of Task 4: European and North American Disposal Options............................................98 Table 6.1 Summary of Recommendations ...................................................................................................104 Table 7.1 Cost Comparison ­ Scenario 1 .....................................................................................................105 Table 7.2 Cost Comparison ­ Scenario 2 .....................................................................................................105 Table 7.3 Cost Comparison ­ Scenario 3 .....................................................................................................105 Table 7.4 Cost Comparison ­ Scenario 4 .....................................................................................................105 Table 7.5 Cost Comparison ­ Scenario 5 .....................................................................................................105 Table 7.6 Summary of Oil Treatment Durations..........................................................................................106 Table 7.7 Summary of Equipment Treatment Durations .............................................................................107 Table 7.8 Summary of Equipment Treatment Durations .............................................................................107 Table 8.1 Cost Comparison ­ Scenario 1 .....................................................................................................112 Table 8.2 Cost Comparison ­ Scenario 2 .....................................................................................................112 Table 8.3 Cost Comparison ­ Scenario 3 .....................................................................................................113 Table 8.4 Cost Comparison ­ Scenario 4 .....................................................................................................114 Table 8.5 Cost Comparison ­ Scenario 5 .....................................................................................................114 Table 8.6 Cost Comparison Summary..........................................................................................................115 Table 8.7 Soil Cost Comparison ­ Scenario 1..............................................................................................116 Table 8.8 Soil Cost Comparison ­ Scenario 4..............................................................................................117 Table 8.9 Soil Cost Comparison ­ Scenario 5..............................................................................................117 Table 8.10 Soil Cost Comparison Summary ..................................................................................................118 APPENDICES Appendix A Acronyms Appendix B References Appendix C Task 1 Forms Appendix D Task 2 Supporting Information Appendix E Task 3 Forms and Supporting Information Appendix F Task 4 Forms and Supporting Information Appendix G PCB Destruction Technologies in Vietnam : Oil and Equipment Directions for Use Appendix H PCB Destruction Technologies in Vietnam : Soil Contamination Directions for Use I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 7 of 119 EXECUTIVE SUMMARY SNC-Lavalin International Inc. has been engaged by the World Bank to conduct a survey of destruction technologies for polychlorinated biphenyl (PCB) wastes in the Socialist Republic of Vietnam. The scope of work for this assignment is in keeping with the priority actions earmarked for completion between 2006 and 2010, in preparation for the final treatment and disposal of Vietnam's PCB waste. Project activities have been divided into the following six tasks: · Task 1: Desk Review of PCB Disposal Technologies · Task 2: Evaluation of Domestic PCB Disposal Options · Task 3: Evaluation of Regional PCB Disposal Options · Task 4: Desk Review of PCB Disposal Options Outside the Region · Task 5: Overall Evaluation of PCB Disposal Options for the PCB Project A subsequent task will be conducted upon acceptance of the draft report by the World Bank. Results of Task 1: PCB Destruction Technologies A large number of documents were reviewed including assessments of technologies, recommendations from other organizations and data provided by vendors. An evaluation was conducted for each technology with respect to its potential application in Vietnam for each of the waste matrices where PCB contamination has been identified. The following technologies were recommended for further examination: Soil and Soil-like Materials Anaerobic / aerobic composting; Based catalyzed decomposition process (BCD); Cement kiln co-processing; Enhanced bioremediation (in situ); Gas Phase Chemical Reduction (GPCR); Incineration (mobile plant); In-situ vitrification; and Plasma arc decomposition (Plascon, Pact process). Water and Aqueous Solutions Advanced Oxidation Process (AOP); Base catalyzed decomposition process (BCD); Gas Phase Chemical Reduction (GPCR); TiO2 enhanced photocatalysis (Photo-Cat, Purifics); and Wet Air Oxidation (WAO) technology, low concentrations only and requires successful waste tests. Sediment, Sludge and Slurries Base catalyzed decomposition process (BCD); Cement kiln co-processing; Gas Phase Chemical Reduction (GPCR); Plasma arc decomposition (Plascon); and Wet Air Oxidation (WAO) technology, low concentrations only and requires successful waste tests. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 8 of 119 Oily Phase and Organic Liquids Alkali Reduction including sodium; Base catalyzed decomposition process (BCD); Gas Phase Chemical Reduction (GPCR); Incineration (mobile plant); Plasma arc decomposition (Pact process); and Wet Air Oxidation (WAO) technology, low concentrations only and requires successful waste tests. Solid Waste and Electrical Equipment Base catalyzed decomposition process (BCD); Gas Phase Chemical Reduction (GPCR); and Incineration (mobile plant). Once the quantity and location of wastes are better defined and stakeholders consulted, a more detailed technology selection process can begin that includes social, economic and political considerations, as well as technical issues discussed in this report. Results of Task 2: Vietnamese Disposal Options The Holcim cement plant, using cement kiln co-processing, is the only PCB treatment technology in Vietnam that is close to the commercialization for the destruction of PCB waste. The other operations are either not focused on PCBs (Chemical Military Headquarters), not interested in treating PCBs (URENCO-Hanoi) or are at the research stage of technology development (Academy of Science and Technology). With the encouragement of the regulators and the extensive support of their international network, Holcim will likely be a significant waste disposal option in Vietnam. Results of Task 3: Regional Disposal Options With the exception of Australia, no country was identified that was willing to accept waste from Vietnam, but facilities were identified in Japan, New Zealand and the Philippines that were willing to export their technology to Vietnam to treat waste there. In Australia, three out of four facilities that are interested in the project indicated their willingness to import waste for treatment within Australia but they also expressed a preference for treating the waste in Vietnam. One Australian facility, Dolomatrix International, indicated that the permitting procedure for importation would be challenging, and would not consider importation further. In terms of technologies in use, there were a variety of options, including BCD, plasma arc, sodium reduction, catalytic hydrogenation, mechanochemical destruction and thermal desorption and destruction. Results of Task 4: Other International Disposal Options Many of the facilities identified within the European Union as capable of treating PCB waste are willing to assist with the disposal of PCBs from Vietnam. The majority of the facilities indicated a preference for importing waste for treatment (20 facilities) while some (6 facilities) indicated they were interested in treating waste in Vietnam. It should be noted that some facilities, such as Sita Decontamination (solvent flushing and sub-contracted incineration), Tredi Seche Global Solutions (various technologies), Celtic Recycling (catalytic dehalogenation) and Sakab (high temperature incineration and biological remediation) are capable of both importation and treatment in Vietnam, depending on the waste volumes and characteristics. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 9 of 119 In terms of technology, incineration was the predominant method of disposal, which accounts for the marked preference for importation, as these plants are not mobile. Other technologies include sodium reduction, catalytic dehalogenation and long term disposal in a salt mine. One facility in France (Tredi Seche Global Solutions) offered a variety of technologies, the selection of which will depend on the waste characteristics. In North America, PCBs cannot be imported into the United States except under special exemption in accordance with federal regulations. This eliminated many fixed treatment facilities in the United States who are not able to export their technologies to Vietnam. However, two facilities were identified that are able to treat waste in Vietnam. One uses solvated electron technology while the other uses sodium reduction. In Canada, importation of PCBs is legally permissible. However, of the seven Canadian facilities that expressed an interest in this project, three (Swan Hills Treatment Centre, Hazco Environmental Services (which works closely with the Swan Hills Treatment Centre), and Bennett Environmental Inc.) indicated that waste will be imported for treatment within Canada while four (Sonic Environmental Solutions Inc., Kinectrics Inc., Hallett Environmental and Technology Group Inc. and Sanexen Environmental Services Inc.) indicated a preference for treatment within Vietnam. The Swan Hills Treatment Centre and Bennett Environmental Inc. both employ high temperature thermal destruction facilities. With the exception of Hallet Environmental and Technology Group, which uses GPCR, the other facilities use alkali reduction (sodium or potassium). Task 5: Overall Assessment A summary of the comparative cost evaluation of preferred approaches for the disposal of PCB-contaminated oil and electrical equipment is shown in the table below. Cost Comparison Summary: PCB-contaminated Oil and Electrical Equipment Scenario Lowest Viable Vendor Offering Methods of Description No. Price (USD) Best Alternative Disposal All waste shipped to an overseas facility 1 $96,059,086 SAVA (Germany) Incineration for disposal. All oil shipped to an overseas disposal facility. Drained transformer and ESI Group (Australia) 2 $52,866,342 Sodium dechlorination capacitor hulks disposed of in a salt mine in Germany. All oil and cellulosic material destroyed Holcim (Vietnam) Cement kiln co- at Holcim in Vietnam. All drained 3 $60,518,666 processing transformer and capacitor hulks K+S (Germany) Salt mine storage disposed of in a salt mine in Germany. All waste materials treated in Vietnam, by relocatable treatment systems 4 $42,330,119 ESI Group (Australia) Sodium dechlorination provided and operated by overseas vendors. Oils and cellulosic material treated by Holcim (Vietnam), carcasses cleaned Holcim (Vietnam) Cement kiln co- 5 using relocatable treatment systems $48,812,411 processing operated by overseas vendors but ESI Group (Australia) Sodium dechlorination located in Vietnam. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 10 of 119 The most attractive scenario financially is Scenario 4, which treats all waste material in Vietnam by relocatable facilities provided and operated by overseas vendors. Costs will also be recovered by recycling scrap materials within Vietnam. A summary of the costs of the five scenarios developed for PCB-contaminated soil treatment is included in the table below. Cost Comparison Summary: PCB-contaminated Soil Scenario Lowest Viable Vendor Offering Methods of Description No. Price (USD) Best Alternative Disposal Soil shipped to an overseas facility for 1 $6,528,571 HIM (Germany) Incineration disposal. Soil shipped to German salt mine for 2 $5,988,571 K+S (Germany) Storage disposal. Cement kiln co- 3 Soil treated by Holcim (Vietnam). $5,583,333 Holcim (Vietnam) processing Soil treated in Vietnam, by relocatable ESI Group Sodium 4 treatment systems provided and operated $7,114,286 (Australia) dechlorination by overseas vendors. Soil treated in situ (in place) by AMEC Geomelt 5a $11,500,000 In situ Vitrification purchasing a Geomelt system. (USA, Australia) Soil treated ex situ (post excavation) Many vendors Anaerobic/Aerobic 5b $320,000 anaerobic and aerobic composting. possible. bioremediation If the PCB levels are low and there are no constraints for time then the best option would be Scenario 5b (soil treated ex-situ by a combination of anaerobic and aerobic composting). Otherwise, the most financially viable option would be Scenario 3 (treatment of soil by co-processing at a cement kiln in Vietnam). I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 11 of 119 1.0 INTRODUCTION Decades of human industrial activity have left a legacy of contaminated land throughout the world. Virtually every industrial sector has contributed to the problem. Historical practices, many of them environmentally unacceptable today, have created conditions that could potentially harm human health and the environment. These activities include improper use, handling, storage and disposal of materials containing toxic substances and chemicals. In many cases, release of these chemicals and substances into the environmental has led to contamination of human drinking water supplies and the natural wildlife habitat. While more mature in developed nations, industry is beginning to make significant progress in developing nations as their economies become robust and the need for such services is more visible. Polychlorinated biphenyls (PCBs) are one family of man-made chemicals that have been the object of specific regulation due to their persistence in the environment. Along with a number of other chemical compounds referred to as Persistent Organic Pollutants (POPs), these chemical are resistant to natural degradation processes and have negative impacts on the environment that are complex and far-reaching. 1.1 PCBs PCBs are synthetic chemicals comprising aromatic compounds (benzene rings) made of carbon and hydrogen atoms with up to 10 chlorine atoms. Depending on the number and location of the chlorine atoms, there are theoretically 209 congeners, although only about 130 congeners have been found in commercial chemical formulations (Holoubek, 2000). First synthesized in 1881, PCBs were found to be relatively fire-resistant, very stable, did not conduct electricity and had low volatility under normal conditions. These characteristics made them ideal for many industrial applications and consumer products, beginning in 1929, but predominantly used between 1950 and 1983. Most well known is the use of PCBs for dielectric fluid in electrical equipment, from large transformers to small capacitors in lighting fixtures. Industry used PCBs extensively as heat transfer fluids and as coolants for high temperature processes. PCBs were also used in hydraulic fluids, surface coatings, carbonless copy paper, as plasticizers in sealants, caulking, synthetic resins, rubbers, paints, waxes and asphalts and as flame retardants in lubricating oils. By recycling oils containing PCBs, they became widespread in any application of oil. Many transformers originally using non-PCB dielectric fluids, became contaminated with PCBs from servicing or being retrofilled, or partially retrofilled, with PCB contaminated dielectric fluids. As with many other contaminants, PCBs are released to the environment from improper handling, storage and disposal. Leaks from operating equipment have often contaminated surrounding soil, concrete and other building materials. Although PCBs are not very soluble in water, they will dissolve enough to migrate from the source of pollution and be a source of contamination to drinking and surface water. PCBs are a dense non-aqueous phase liquid (DNAPL) and will sink below the water table into the saturated zone until an impermeable layer is reached (clay or bedrock) where the PCBs slowly dissolve, acting as a continuous source of pollution to groundwater for years to decades. As PCBs are very stable, biodegradation processes are very slow, even in surface soils. PCBs have also been released directly to the atmosphere by improper disposal by burning. First detected in environmental samples in 1966, subsequent research found PCBs to be ubiquitously present in human beings and the environment. Their chemical properties (slow volatility, low solubility in water, high solubility in fat, resistance to degradation) have facilitated the widespread dispersion of PCBs throughout the environment, far from the areas where they were used or released. As PCBs are soluble in fat, they are readily absorbed in the fat of animals and tend to accumulate in aquatic and terrestrial species (bioaccumulate), reaching I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 12 of 119 increasing concentrations in species higher up the food chain (biomagnification). Top predators of aquatic species tend to have the highest concentrations of PCBs present in their body-fat (Holubek, May 2000). According to the US EPA, currently available evidence in human studies is inadequate to define PCBs as carcinogenic, however, animal studies indicate that several congeners have dioxin-like activity and may promote tumours by different modes of action. Serious health affects for PCBs are chronic, with only nuisance rashes comprising acute affects. Bioaccumulation and biomagnification can result in high doses in aquatic predators, particularly aquatic mammals, as well as sea birds and humans who consume large amounts of aquatic species. 1.2 Basel Convention The Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal is an international treaty that was designed to reduce the movements of hazardous waste between nations, and specifically to prevent transfer of hazardous waste from developed to less developed countries (LDCs). The Convention is also intended to minimize the amount and toxicity of wastes generated, to ensure their environmentally sound management as closely as possible to the source of generation, and to assist LDCs in environmentally sound management of the hazardous and other wastes they generate. 1.3 Criteria for Determination of PCB Waste The criteria for classifying waste as PCB-waste varies throughout the world, as shown below. Country Standard Stockholm Convention 50 mg-PCB/kg Guideline EU 50 mg-PCB/kg France 50 mg-PCB/kg Australia 50 mg-PCB/kg Germany 10 mg-PCB/kg UK 10 mg-PCB/kg Canada 2 mg-PCB/kg USA 2 mg-PCB/kg Holland 1 mg-PCB/kg Japan 0.5 mg-PCB/kg At the present time, there are no standards within Vietnam to classify waste as PCB-contaminated (Breeze and Associates Inc., 2007). 1.4 Developing Countries According to a 2004 Global Environment Facility (GEF) study, "the most widely used approach for disposing of stockpiles of obsolete POPs in developing countries is to pack and ship them overseas for high temperature incineration in developed countries" (GEF, October 2003). This is particularly true of Europe, where an overcapacity of such facilities exists. Although the GEF working group stated that this offered a safe, relatively inexpensive, proven and practical approach, pressure in developed countries to minimize imports of POPs and concerns over the safety of incinerating POPs has put pressure on developing countries to develop their own capacity for POP treatment. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 13 of 119 According the United Nations Environment Programme (UNEP), "developing countries present a unique challenge to modern technology [for contaminated waste destruction]. Instead of following the general trend of increasing complexity, the situations in developing countries demand simplicity. Any technology used in this situation must be appropriate. It must be able to operate successfully in the face of limited infrastructure, technical knowledge and expertise" (UNEP, January 2004). Furthermore, the reference report states that "present disposal technologies involve complex equipment, sophisticated controls and dangerous processes. Extensive infrastructure, such as reliable power supply, is needed for safe operation. These factors conspire to prevent many established technologies form operating in developing countries". 1.5 Vietnam "Vietnam is a densely populated, developing country that in the last 30 years has had to recover from the ravages of war, the loss of financial support from the old Soviet Bloc, and the rigidities of a centrally-planned economy. Substantial progress was achieved from 1986 to 1997 in moving forward from an extremely low level of development" (Central Intelligence Agency (CIA) Factbook, March 2007). Furthermore, "since 2001, Vietnamese authorities have reaffirmed their commitment to economic liberalization and international integration. They have moved to implement the structural reforms needed to modernize the economy and to produce more competitive, export-driven industries". "Vietnam has experienced rapid industrialization after adopting an open door economic policy. Industrial output expanded at an annual rate of 8.6% in the period between 1989 and 1993. This trend has continued at a greater pace in recent years. As a result, the generating of industrial waste including hazardous and toxic waste is increasing at an alarming rate, and Vietnam does not have the ability to deal with this hazardous waste. Such rapid development without planning creates potentially serious environmental consequences. Although national hazardous waste management regulations were enacted in July 1999, untreated hazardous waste is still being discharged with other waste. Poor compliance with the law is attributable to the regulation's weak enforcement. Budgetary constraints, lack of human resources, lack of pollution monitoring equipment and overlapping uncoordinated and poorly defined government responsibilities are among the major barriers to effective enforcement. In addition to these factors, the absence of facilities for proper hazardous waste treatment prevents full compliance with the law. Vietnam now recognizes the need to balance industrial growth with proper disposal of hazardous waste. Major cities have made industrial waste control and management the top priorities for their urban development strategies" (US and Foreign Commercial Service, 2003). Vietnam ratified the Stockholm Convention on July 22, 2002, committing to reducing and eventually eliminating 12 POPs, including PCBs. Under the convention, Vietnam must phase out the use of equipment containing PCBs by 2025, and treat the contained PCBs by 2028. Vietnam, through the Ministry of Natural Resources and the Environment (MONRE), has developed the "Draft Vietnam National Implementation Plan for Stockholm Convention on Persistent Organic Pollutants Toward 2020" (NIP, May 2006) outlining how POPs will be managed, reduced and eventually eliminated. This process was supported by a project implemented by the United Nations Development Programme (UNDP), with funding from GEF. The plan was developed in collaboration with relevant ministries, industry sectors and other stakeholders such as non-government organizations (NGOs), research institutes and local enterprises. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 14 of 119 1.6 PCB Inventory in Vietnam Although Vietnam has never produced PCBs it has imported PCBs in dielectric fluids (Breeze and Associates Inc., 2007). In the NIP, it has been estimated that before 1985, the total amount of imported PCBs into Vietnam in electrical equipment from China, the USSR and Romania may have reached 27,000 to 30,000 tonnes per year. Much of the equipment imported from the USA to southern Vietnam before 1975 also likely contain PCB oils (MONRE, 2006). The NIP further states that many transformers still use PCB oils because the scheduled date for oil replacement has not yet been reached. There are also suspected PCB-containing oil stockpiles in Vietnam. However, because PCBs were not previously regarded as chemicals that required full control, there are significant data gaps in the information available on PCB quantities. Initial inventories have been conducted in Vietnam which indicated that approximately 1,800 capacitors and 10,000 transformers contain PCBs. These figures are based on the electrical sector only with an assumed capture rate of 70%. The actual total number of PCB-containing equipment in Vietnam, including all other sectors representing 30% of the total, will be higher. For the 11,800 transformers and capacitors thus for identified, the quantity of PCB-contaminated oil is estimated to be 7,000 tonnes. Given the capture rates and sector estimates provided by the NIP, this can be extrapolated to approximately 18,600 transformers, 3,350 capacitors and 13,000 tonnes of PCB-contaminated oil. The NIP cautions that the quantities provided will most likely be higher. These inventories do not include estimates of PCB-contaminated soil or small electrical equipment such as fluorescent lighting ballasts. An Aide Memoire issued by the World Bank following a Bank Mission to Vietnam from September 25 to October 2, 2006, stated that the PCB National Survey and Assessment carried out under the UNDP/GEF financed National Implementation Plan for Persistent Organic Pollutants focused only on transformers and capacitors. No other information on PCB equipment such as switches, voltage regulators and liquid-filled electrical cables has been collected. No information is available on the use of PCBs in households. It is unclear whether PCBs have been used for non-electrical uses such as use as hydraulic fluids or as lubricants. In 2003, Electricity of Vietnam (EVN) implemented a ban to prevent the purchase of PCB-containing equipment and materials by all subsidiaries of EVN and set the allowable limit for PCBs at less than 5 ppm, as there are no national standards at this time. On a national level, a circular (01/2006TT-BCN) by the Ministry of Industry and Ministry of Trade placed a conditional ban on the import of PCBs and their products, which allows for the importation of PCBs under a licence (Breeze and Associates Inc., 2007). 1.7 Timeframe for Implementation of the Stockholm Convention In the NIP, the schedule for the reduction and eventual elimination of POPs is as follows: 2010: Reduce and eliminate stockpiles and exert full control of POP pesticides. 2020: Eliminate the use of PCBs in equipment. 2028: Safely dispose of PCBs. An "Implementation Roadmap" has been developed for implementation of the NIP, with activities phased over the following time periods: 2006 to 2010; 2006 to 2015; and 2015 to 2020. During the period between 2006 and 2010, work will be geared towards strengthening Vietnam's capacity to implement the phase-out and eventual treatment/disposal processes. Priority actions will include the following: I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 15 of 119 · research on technologies for the control and treatment of POPs; · develop and finalize the legal framework, policies, laws and standards for POPs; · increase in stakeholder awareness of POP issues; · implement capacity building for POP monitoring and analysis; and · create information systems and inventories of POPs and POP-contaminated sites. During this period, work on managing PCBs in use, collection of stockpiles of PCBs, commencement of the phase-out of PCB-containing equipment and oils, and commencement of cleanup of contaminated sites will begin. Over the longer term (2006 to 2015) capacity building will be ongoing, and work will continue on the phase-out of equipment and oils, and treatment of contaminated sites. Over the period 2015 and 2020, deconstruction, treatment and disposal of out-dated PCB-containing equipment and other PCB waste will be undertaken. Fifteen national priority programs have been developed in order to achieve these goals. 1.8 Responsibilities In addition to MONRE, other governmental agencies involved in the management of POPs in Vietnam include the Vietnam Environmental Protection Agency (which falls under the auspices of MONRE), Ministry of Science and Technology (MOST) ­ responsible for technology development and development of standards for POPs, the Ministry of Health (MOH), which plays a role in importation, distribution/marketing, usage and disposal, the Ministry of Trade, which plays a role in importation, production and distribution/marketing, the Ministry of Industry (MOI), responsible for import, distribution/marketing, usage and disposal, the Ministry of Agriculture and Regional Development, responsible for import, production, usage, distribution/marketing, usage and disposal and the Ministry of Finance and General Department of Customs, responsible for importation and production (MONRE, 2006). Key corporations that have a role to play in POP management include Electricity EVN which is responsible for the management of most of the electrical generators and transmission equipment in Vietnam, Vietnam Corporation on Chemicals, PetroVietnam Corporation and Petrolimex. One of the approaches and general principles upon which the NIP is based is the "polluter pays" principle, where polluters will be responsible for treatment of waste. 1.9 Existing PCB Disposal Technology In the Assessment of Policies and Legal Framework section of the NIP, it is stated that Vietnam has issued regulations on disposal methods for some hazardous chemicals, especially pesticides, but there are no other specific regulations for other types of POPs. Further, the NIP also states that due to limited experience, facilities and regulations on processing and technologies to dispose of POPs, Vietnam has not issued licences for POP treatment to any agency, or for any technology, although as will be clear in this report, this is changing. In accordance with the NIP, the Government of Vietnam has placed a high priority on the safe treatment of PCB- containing oils and equipment, but appropriate treatment and destruction technologies are not yet available in Vietnam. A reference had been made to a sodium-based PCB disposal facility at the Vietnam Science Institute ­ Chemical Institute and Vietnam Environmental Technology and Consulting Company in the UNEP Inventory of World-Wide PCB Destruction Capacity (2004 edition), but the Vietnam Environmental Protection Agency (VEPA) has indicated that the technology is experimental and has faced many technical difficulties, and as such I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 16 of 119 should not be considered for the PCB project. VEPA also reported that the country is considering the use of a cement kiln at Holcim to dispose of PCBs (World Bank, 2006). 1.10 Scope of Work The scope of work for this assignment is in keeping with the priority actions earmarked for completion between 2006 and 2010, in preparation for the final treatment and disposal of Vietnam's PCB waste. Project activities have been divided into six tasks, as described below: Task 1: Desk Review of PCB Disposal Technologies Under this task, PCB disposal technologies have been identified and assessed in accordance with criteria specified in the RFP, including: · theoretical soundness (proven technology); · applicability to various matrices and contaminant concentrations; · observed treatment results in real disposal exercises; · commercial availability; · capital and operating costs (including cost per unit of treatment); · human resource requirements for operations; · environmental performance and monitoring requirements; · health and safety performance ad monitoring requirements; · case studies of operating facilities; and · advantages and disadvantages. Task 2: Evaluation of Domestic PCB Disposal Options Under this task, the two technologies that are currently being considered for use in Vietnam (sodium reduction and cement kiln co-processing) have been assessed from the perspective of technological applicability, economic soundness and environmental impacts. Emphasis has been placed on the following elements: · capital and operating costs (including cost per unit of treatment); · human resource requirements for operations; · environmental performance and monitoring requirements; and · health and safety performance ad monitoring requirements. Other options investigated are also discussed in the report. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 17 of 119 Task 3: Evaluation of Regional PCB Disposal Options Under this task regional disposal options were identified and where facilities existed, information was collected on: · disposal performance, capacity and achieved through-put; · availability to receive waste (from Vietnam) or set up a treatment facility in Vietnam; · environmental performance including monitoring requirements and results; · health and safety records; · legal and administrative requirements to transport the waste from Vietnam (i.e. Basel Convention requirements); · waste acceptance criteria (waste types, forms and concentrations); · services provided by the facility including transportation, packaging, etc; · cost breakdowns for disposal; and · acceptance of the local population with regard to the disposal facility (for fixed facilities). Countries that were evaluated included Australia, Cambodia, China, Japan, Malaysia, New Zealand, the Philippines, Singapore and Taiwan. Task 4: Desk Review of PCB Disposal Options Outside the Region The scope of this task was identical to Task 3, except the countries considered were outside of the Asia Pacific region. Evaluation was limited to Western Europe and North America. Countries considered included Belgium, Canada, Denmark, Finland, France, Germany, Italy, the Netherlands, Sweden, Switzerland, the United Kingdom and the United States. Task 5: Overall Evaluation of PCB Disposal Options for the PCB Project The data gathered in Tasks 1 to 4 were used to make recommendations on each of the waste classes considered, i.e. transformer oil, hydraulic oil, contaminated soil, waste and equipment. Factors considered in making recommendations included environmental performance, economic efficiency, health and safety implications and public acceptance. Task 6, which will entail the development of a workplan for the implementation of the PCB waste disposal strategy, will be completed once the recommended approaches for PCB disposal have been accepted. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 18 of 119 2.0 PCB DESTRUCTION TECHNOLOGY REVIEW There is a wide variety of remedial techniques for hazardous waste and selecting applicable technologies for a project or a number of technologies for a national implementation process is a complex task. In Europe and North America, hazardous waste treatment technologies began earlier than most other regions and developed by the demands of the market, general encouraged by regulators, but without their orchestration. In other countries, such as Japan and Australia, governments took a more active role and coordinated efforts, particularly with respect to POPs and PCBs. Due to the Stockholm Convention, international funding is available and many developing countries are proceeding in a manner that is similar to the Japanese and Australian approach. For these efforts and numerous international projects and studies, there are a tremendous number of documents providing guidance and support for technology selection. Before discussing these resources, and then each technology that has potential for application, some basic remedial concepts need to be defined. Many remedial processes are general technologies with widespread application and others target specific contaminants or families of contaminants. Also important, some technologies can treat a wide range of contaminated media while other can only treat water or oils. The degree of contamination can also limit the application of some technologies. While some technologies provide "all-in-one" approaches, others are a series of individual steps, which when put together, can meet remedial objectives. This series of mechanical, thermal, chemical of other actions is often referred to as a "treatment train". An example would be the incineration of PCB-contaminated soil where first the sediments are mechanically dewatered, perhaps by a plate-and-frame filter press after being mixed with chemicals to enhance solid removal. The rinsate stream, water formerly entrained in the sediment, might then be treated by activated carbon filters before it can be discharged to the environment. The solid filter cake is transferred to a thermal desorption unit where PCBs are volatilized, transferring them from the solid matrix to the vapour phase. The vapour stream, containing all the PCBs, is then incinerated at high temperature, causing the PCBs to decompose to water vapour and carbon dioxide. The soil is cooled and re-used as fill. The entire process might be called "incineration" but there are multiple steps involved and the overall process can be quite complex. In this section, technlogies have been divided into pretreatment (Section 2.1), post-treatment (Section 2.2), destruction (Section 2.3 to 2.8) and "other" which includes no treatment methods such as long-term or permanent storage (Section 2.9). Technology Delivery Technologies are categorized by many attributes. Those that are implemented without removing the source material are defined as in situ technologies and those that require the source material be removed (by excavation in the case of soil, pumping in the case of groundwater or draining in the case of oil in transformers) are called "in situ". For ex situ technologies, the material may be remediated by mobile facilities taken to the source site, or may be containerized and transported to a centralized fixed destruction facility. Some mobile facilities are small and quick to set up for operation, while others are large and require extensive preparation and set-up. The latter are often called "transportable" instead of mobile and on the extreme end of the spectrum, just before fixed facilities, are those that are "re-locatable". Only in large countries with sufficient capacity and finance, should new large fixed facilities using innovative technologies be considered (GEF, 2004). Some other important issues to consider when assessing technologies are as follows. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 19 of 119 Non-combustion Technologies Combustion technologies, such as incineration and cement co-processing, while proven, suffer from poor public perception. Despite extensive evidence, there is a strong belief amongst the public that such technologies generate harmful dioxins and furans and release them to the atmosphere, harming human health and the environment. Responding to public pressure, many governments and government organizations have encouraged the development of non-combustion remedial technologies to treat hazardous wastes including PCBs and other POP wastes. Some, such as Japan, have gone so far as to ban combustion technologies for the treatment of many waste categories. "Non-combustion technologies cannot compete against combustion technologies on a commercial basis" (GEF, 2004). Furthermore, the GEF study points out that there is very little experience with new non-combustion technologies and there is often a lack of support systems in developing nations essential to applying these technologies successfully. The only commercialized non-combustion technologies for which considerable experience has been developed through repeated application are Gas-Phase Chemical Reduction (GPCR), Base Catalyzed Decomposition (BCD), Sodium Reduction, Supercritical Water Oxidation (SCWO) and Plasma Arc. These technologies are employed at operating plants which are licensed to destroy high strength POPs. An important lesson can be learned from the Australian approach, where non-combustion technologies were chosen for POP destruction. Of the four companies offering services for POP destruction, only one company remains in operations now that the POP stockpiles have been largely destroyed. This company still operates because they diversified to treat non-POP wastes. As POPs are phased out they represent a one-time market which is not sustainable for future operations. Diversification is critical to make good on investments. Testing of POP destruction facilities have shown that incinerators achieve destruction efficiencies that are considerable lower than those achieved by certain non-combustion technologies (GEF, 2004). State of Development Technologies are generally categorized by their state of development. This is not necessarily a spectrum of consecutive stages, as such development can follow a complex path with respect to contaminant destruction technologies. Some general categories are as follows: · Commercialized: The technology has been implemented by a vendor and is considered largely developed. Mature technologies have multiple vendors and widespread application. · Proven: The technology has been successfully applied to the contaminants of concern. · Emerging: A technology that is expected to be commercialized in the near future (i.e. 1 to 3 years). · Innovative: The technology is new and may have only been applied on a limit number of sites, perhaps only at pilot-scale and perhaps only in laboratories (bench-scale). "It can cost up to $1,000 million (USD) to produce a full-scale plant for a new innovative technology and take 5 to 7 years to bring a near commercial technology to market" (GEF, 2004). The timeline from taking a new technology from research to pilot scale is an additional 3 to 4 years and for upscaling a technology to function, 6 to 10 years. For this reason, the GEF study recommends that only commercially proven technologies be considered for developing countries. For this reason, innovative technologies will not be considered at any great depth in this report. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 20 of 119 2.1 Resources for Technology Selection Decision support tools for selecting remediation technologies have been developed including "Decision Aid for Remediation Technology Selection" (DARTS) developed by the United Nations Industrial Development Organization (UNIDO) and the International Centre for Science and High Technology (ICS). The criteria included in the DARTS prototype are applicability, overall cost, minimum achievable concentration, clean-up time required, reliability/maintenance, data needs, safety, public acceptability, development status, strand alone character and residuals produced (Zinovyev, et al). These are well considered criteria which will be addressed in this evaluation. "In terms of disposal methods, existing criteria, guidelines and protocols have been developed inter alia by UN Food and Agriculture Organization (FAO), the Basel Convention, US EPA and UN World Health Organization (WHO), and should be used in their existing form or be adapted to new requirements for POPs disposal" (GEF, 2004). One of the difficulties encountered by GEF when classifying and promoting technologies for application was the difficulty of obtaining performance data (GEF 2004). Technology providers are reluctant to provide data. As shown in this report, while the amount of information available for POP and PCB destruction technologies is significant, it is most often general in nature, often without detailed technical evaluation. Furthermore, the selection of destruction technologies requires consideration of political, legal, financial and technical factors. Political factors include the will of the host government to facilitate and support the undertaking as well as the willingness of the country's citizens and particularly the host communities and other stakeholders to accept either fixed or mobile destruction facilities. A country's legal system must be robust enough to ensure public and environmental safety and may restrict the choices of technologies to be selected (i.e. some countries may have a ban on combustion technologies in place). Even if there is a willingness to undertake PCB destruction initiatives, financial considerations may constrain the options available. How the project is implemented financially include such possibilities as whether efforts will be government funded, private-public partnerships or entirely left to the private sector are important considerations. For developing nations, international funding can be critical to a project's success. Technical issues may be the most numerous but the most easily addressed. They include such elements as destruction efficiency, robustness (not sensitive to minor changes), safety (no dangerous reactants), closed processes (limiting emissions), the ability to treat a full range of hazardous wastes, the ability to treat a full range of physical forms. Another important technical category is the state of local infrastructure including the dependability of electrical, water and fuel supplies. The state of transportation networks may also be an important factor for determining whether mobile or fixed facilities are desirable and where fixed facilities can be established. There are a large number of publications providing guidance on remedial technologies in general or for POPs and PCBs specifically. Most of these documents are produced by government organizations both national and international. This section describes some of the sources available. Table 2.1 summarizes each technology by reference source. Some technologies are named inconsistently through the references. In such cases the most common name has been applied. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 21 of 119 Table 2.1 : Potential Remedial Technologies Assessed By Others NATO/ US EPA Env. Basel UNEP ICS-UNIDO US EPA US EPA Japan Technology CCMS Screening Canada (2005) (2004) (2000) (1990) (1993) (2007) (2002) Matrix* (2004) 1 Oxidation X Molten Salt Oxidation (MSO) X X X X X Mediated Electro-chemical Oxidation (MEO) X X Supercritical Water Oxidation (SCWO) X X X X X X Advanced Oxidation Process (AOP) X X X TiO2 Enhanced Photocatalysis (an AOP X X technology) Catalytic Oxidation X 2 Reduction X Gas Phase Chemical Reduction (GPCR) X X X X X X Solvated Electron Technology (SET) X X X X X X Sodium/Alkali Reduction X X X X X X Based Catalyzed Decomposition Process (BCD) X X X X X Potassium tert-Butoxide Method X Vacuum Heating and Decomposition X Catalytic Dechlorination & Photochemical X X X Dechlorination Catalytic Hydrogenation X X Catalytic Hydrochlorination X X 3 Thermal, Combustion and Incineration X Incineration X X X X X X X Cement Kiln Incineration X X X X X Molten Metal Pyrolysis X X X Thermal Desorption Integrated Technologies X X X X Plasma Arc X X X X X 4 Bioremediation Anaerobic / Aerobic Composting X X Bioventing X X Land Spreading/Farming Bioslurries & Enhanced Bioremediation X X Phytoremediation X 5 Other In-situ Vitrification X X X Landfill/Burial X X Ball Milling (mechanochemical dehalogenation) X Adsorption/Absorption (carbon) X Soil Washing X X I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 22 of 119 Under the Basel Convention, UNEP has produced a number of technical guidelines including the "Technical Guidelines for the Environmentally Sound Management of Wastes Consisting of, Containing or Contaminated with Polychlorinated Biphenyls (PCBs), Polychlorinated Terphenyls (PCTs) or Polybrominated Biphenyls (PBBs)" (UNEP 2005) and "Updated General Technical Guidelines for the Environmentally Sound Management of Wastes Consisting of, Containing or Contaminated with Persistent Organic Pollutants (POPs)" (UNEP, undated). While the first document specifically addresses PCBs, when discussing remediation technologies, it refers to the second document. In the second document, brief descriptions and references are provided for the following destruction and irreversible transformation methods: · Alkali Metal Reduction; · Base-catalyzed Decomposition (BCD); · Catalytic Hydrodechlorination (CHD); · Cement Kiln Co-incineration; · Gas-phase Chemical Reduction (GPCR); · Hazardous Waste Incineration; · Photochemical Dechlorination (PCD) and Catalytic Declorination (CD) Reaction; · Plasma Arc; · Potassium tert-Butoxide (t-BuOK) Method; · Supercritical Water Oxidation (SCWO) and subcritical Water Oxidation; and · Thermal and Metallurgical Production of Metals. Information provided includes cost estimates, efficiencies, waste types treatable, pre-treatment requirements, emissions, residues, release control, energy requirements, material requirements, portability and safety issues. In addition, other disposal methods where wastes are neither destroyed nor irreversibly transformed were presented including permanent storage in specially engineered landfills, underground mines and formations. With respect to pre-treatment techniques, only definitions are provided. The techniques defined include adsorption/absorption, dewatering, mechanical separation, mixing, oil/water separation, pH adjustment, size reduction, solvent washing and thermal desorption. Training manuals have also been produced by UNEP in their Basel Convention series, although these do not provide much more information on remediation technologies (http://www.basel.int/meetings/sbc/workdoc/ techdocs.html). Given that combustion technologies are controversial, with concerns being raised about emissions of dioxins and furans as well as other pollutants, some organizations and nations desire an emphasis on non-combustion technologies. To facilitate a technical examination of such technologies, UNEP, UNIDO and GEF have formed a Scientific and Technical Advisory Group to examine the issue. The project, entitled "Demonstration of Viability and Removal of Barriers that Impede Adoption and Effective Implementation of Available, Non-combustion Technologies for Destroying Persistent Organic Pollutants", has prepared a preliminary discussion paper identifying such technologies. The paper introduces a screening matrix for all technologies for POP destruction, including combustion technologies, which includes the following: · Incineration; · GPCR-Ecologic; I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 23 of 119 · Base Catalyzed Dechlorination; · Sodium Reduction Processes; · Solvated Electron Processes; · Supercritical Water Oxidation; · Electrochemical Oxidation; · Vitrification; · Ball Milling; · Molten Salt; · Molten Metal; · Catalytic Hydrogenation; · Soil Washing; · Landfill/Burial; · Solidification/Stabilization; · Land Spreading; and · Deep-well Injection. A follow-up report to this evaluation, entitled "Review of Emerging, Innovative Technologies for the Destruction and Decontamination of POPs and the Identification of Promising Technologies for Use in Developing Countries", (UNEP, January 2004) is an excellent source of information on the technologies identified above. This document has categorized the technologies evaluated as follows: · Commercialized technologies with considerable experience; · Technologies near or at the start of commercialization; · Promising technologies; · Technologies which require significant research; and · Technologies which are unlikely to be applicable for destruction of POP stockpiles. The report entitled "Destruction Technologies for Polychlorinated Biphenyls (PCBs)" (ICS-UNIDO, November, 2000) evaluated the following technologies: · Landfill Cap System (historic treatment technology); · Deep Well Injection (historic treatment technology); · High Temperature Incineration (historic treatment technology); · Cement Kilns (historic treatment technology); · Super-critical Oxidation (emerging or innovative technology); · Electrochemical Oxidation (emerging or innovative technology); · Solvated Electron Technology (emerging or innovative technology) ; · Chemical Reduction Reaction (emerging or innovative technology); · Dehalogenation Process (emerging or innovative technology); · Molten Metal Pyrolysis (emerging or innovative technology); · Molten Salt Oxidation (emerging or innovative technology); · Plasma Arc (emerging or innovative technology); · Catalytic Hydrogenation (emerging or innovative technology); · Ultrasonic Technology (emerging or innovative technology); · Advanced Oxidative Process (emerging or innovative technology); I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 24 of 119 · Solvent extraction-chemical Dehalogenation-Radiolytic Degradation; (emerging or innovative technology); · Solar Detoxification-Photochemical Degradation (emerging or innovative technology); · Thermal Desorption Integrated Technologies (catalyzed dehalogenation, pyrolysis, retort system and vitrification); and · Bioslurries and enhanced bioremediation. A NATO/CCMS Pilot Study "Evaluation of Demonstrated and Emerging Remedial Action Technologies for the Treatment of Contaminated Land and Groundwater (Phase III)" prepared by John Vijgen of the International HCH and Pesticides Association (December, 2002), provides an excellent source of detailed technology data sheets and breaks technologies into the following categories: · Directly applicable: BDC, GPCR, Geomelt (vitrification) and in situ thermal destruction; · Applicable (breaking-through or at the start of commercialization): solvated electron processes, SCWO; · Full-scale within an estimated 0 to 5 years: CerOx system, Silver II system, TDT-34 system, mechanochemical dehalogenation process; and · Full-scale within a period that is not possible to estimate: self-propagating high temperature dehalogenation. The United States Environmental Protection Agency (US EPA) makes a large number of environmental guidance tools and publications available. Those specifically related to PCBs were produced in the early 1990's and are not current, but still useful. The "Guidance on Remedial Actions for Superfund Sites with PCB Contamination" (US EPA, August 1990) proposes a fairly short list of treatment technologies including incineration, chemical dechlorination (i.e. alkali reduction), biological treatment, solvent washing/extraction, solidification/stabilization and vitrification. The US EPA document "Technology Alternatives for the Remediation of PCB-Contaminated Soil and Sediment" (October 1993) assessed the same technologies for the treatment the soil and sediment waste matrices. One of their most recent documents provides guidance for non-combustion technologies for POP- contaminated stockpiles and soil (USEPA, December 2005). In this document, technologies are broken down as follows (only technologies with the potential to treat PCBs are shown): Full Scale: Proven Pilot Scale · Anaerobic Bioremedation; · Base-catalyzed Decomposition; · In Situ Thermal Desorption. · Electrochemical (CerOx); Full-Scale: Potential · Phytoremediation; · Plasma Arc; · Solvated Electron Technology; · Supercritical Water Oxidation. · Sonic Technology. The US EPA also maintains an extensive remediation selection matrix on their website (http://www.frtr.gov/matrix2/top_page.html). Although PCBs are not specifically identified in the treatment matrix, they are part of the family of chemicals identified as halogenated semi-volatile compounds. The matrix defines technologies as having above average potential for application, as well as average, below average and "other" (not applicable, insufficient data, or highly dependent on specific contaminant). The technologies that have been assigned "above average" and "average" for halogenated semi-volatile compounds are as follows: I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 25 of 119 Above Average Potential for Application Average Potential for Application · In Situ Thermal Treatment; · Chemical Oxidation; · In Situ Chemical Extraction; · Electrokinetic Separtion; · In Situ Dehalogenation; · Fracturing; · Incineration; · Soil Flushing; · Pyrolysis; · Solidification/stabilization' · Thermal Desorption; · Landfarming; · Bio Slurping; · Chemical Reduction/Oxidation; · Dual Phase Extraction; · Soil Washing; · Passive Treatment Walls; · Landfill; · Advanced Oxidation; · Containment Cell (Isolation); · Activated Carbon; · Monitored Natural Attenuation; · Separation; · Phytoremediation; · Physical Barriers; · Air Sparging; · Off-gas High Energy Treatment; · Hydrofracturing Enhancements; · Vapour Phase Oxidation; · Adsorption/Absorption; · Vapour Phase Carbon Adsorption. · Membrane Separation (vapour phase). Environment Canada prepared the document "Options for the Treatment/Destruction of Polychlorinated Biphenyls (PCBs) and PCB­contaminated Equipment" (November 1991) which examined the following: · Mineral Oil Transformer Decontamination Methods: o Dehalogenation by energized transfer mode; o De-energized retrofill; o Engergized retrofill; o Batch dehalogenation of bulk oil; · Mobile/Transportable/Fixed Incinerators (various configurations); · Decontamination Technologies for Waste Transformers: o Disassembly and Smelting; o Disassembly and solvent washing. More recently, Environment Canada engaged SNC-Lavalin to conduct a literature review whose report, "Analysis of Technologies for the Pretreatment, Destruction and Disposal of Persistent Organic Pollutant (POP) Waste" (Environment Canada, 2004) evaluated the technologies shown in Table 2.2. Australia conducted a series of extensive studies of hazardous waste treatment technologies for special waste with special attention paid to PCBs and pesticides. The last Review Report, entitled "Appropriate Technologies for the Treatment of Scheduled Wastes", (No. 4, CMPSandF-Environment Australia, November 1997) included extensive detailed, technical reviews of many technologies. While the report did not make definitive recommendations, Australia advanced with its waste management program and began operating a number of facilities using advanced technologies such as plasma arc, BCD, GPCR and alkali reduction. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 26 of 119 Table 2.2 : Treatment Technologies According to Matrices and Contaminants MATRICES TREATMENT TECHNOLOGIES WATER and SOLIDS - essentially SEDIMENT / OIL and SOIL aqueous 1 all the pesticides except SLUDGE organic liquids solutions chlordane 1 Oxidation Molten Salt Oxidation (MSO) PA PA Mediated Electro-chemical Oxidation PA PA PA Some organic solids2 (MEO) Supercritical Water Oxidation (SCWO) PA PA PA PA (PCB) Advanced Oxidation Process (AOP) PA TiO2 Enhanced Photocatalysis (an AOP PA PA PA technology) 2 Reduction Gas Phase Chemical Reduction (GPCR) PA PA PA PA PA Solvated Electron Technology (SET) PA PA PA PA Sodium Reduction PCBs PCBs Based Catalyzed Decomposition Process PA PA PA PA PA (BCD or BCDP) 3 Incineration Large-scale Fixed Incinerators PA PA PA PA PA Small Scale Fixed Incinerators Mobile Incinerators PA PA PA PA PA Cement Kiln Incineration PA PA 4 Plasma Arc Decomposition Pact Process PCBs Plascon PA PA PA 5 Bioremediation Anaerobic / Aerobic Composting PA PA Bioventing PA 6 In-situ Vitrification PA NOTES: PA-Potentially Applicable 1: Concentrated liquids (chlordane and PCBs (askarels)). 2: Organic solids that can be made into a slurry. "Japan now recognizes the following technologies as proven for the destruction of POP's: incineration (~1,000 ºC), mechano-chemical, geomelt, vacuum thermal, hydrothermal, super-critical water oxidation, DCD and sodium reduction" (Nato-CCMS, 2005). The JFE Techno-Research Corporation performed a desk-top review of POP destruction capacities in South East Asian countries and their draft report was available for review (JFE, June 2007). The review assessed the following technologies: I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 27 of 119 · high temperature incineration; · sodium reduction; · catalytic dechlorination; · plasma arc destruction; · gas phase chemical reduction; · super-critical water oxidation; · catalytic oxidation; and · solvated electron oxidation. Each of the technologies sited above that can be applied to PCB waste treatment, are described in the following sections in detail, beginning with pretreatment technologies. Technology Data Sheets are provided for each destruction approach where sufficient information was available to complete them (Appendix C). 2.2 Pre-treatments This section presents the most common pre-treatments that may be required for the proper and safe operation of the destruction technologies. They fall into two categories, material preparation and contaminant media transfer. Material preparation technologies are generally, relatively inexpensive compared to destruction technologies and include dewatering, shredding, screening, oil/water separation, pH adjustment and soil washing (which is a volume reduction technique). Media transfer technologies are more expensive, and can comprise a considerable portion of the cost for contaminant destruction. These include thermal processes such as low temperature thermal desorption (LTTD), or its in-situ variety, thermally enhanced soil vapour extraction, solvent extraction processes (often called soil flushing), and adsorption/adsorption techniques such as ion exchange or activated carbon adsorption. None of these technologies destroy contaminants. There may be other technologies used for pre- treatment besides these listed herein, as waste matrices can be complex and there are many treatment technologies with diverse material requirements, however, the most common are discussed below. Technology Forms have been completed only for the most complex technologies (LTTD and enhanced soil vapour extraction). 2.2.1 Dewatering Dewatering is a pre-treatment approach that partially removes water from the wastes to be treated. Dewatering can be employed for destruction technologies which are not suitable for aqueous wastes. For example, over a certain temperature and pressure environment, water can react explosively with molten salts or sodium. Both resulting waste streams, the soil/solids and the water/liquids, will likely require treatment after separation. There is wide-variety of dewatering techniques that depend on the matrices being treated. Soil de-watering techniques include plate-and-frame filter presses, drum filters, vacuum filters, centrifuges and many other systems. Selecting the systems for remediation is dependent on the characteristics of the waste to be treated (water content, particle size and distribution, through-put, end-point conditions, etc.). Thermal systems commonly called driers can also be used for dewatering. These technologies are well-developed and commercialized. The capital and operation costs for these systems are dependent on the characteristics of the wastes to be treated. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 28 of 119 2.2.2 Electrical Equipment Disassembly Large and medium-sized liquid-filled transformers comprise steel vessels, containing the dielectric fluid, windings and supports (lumber and paper). Once the oil has been drained, the transformers can be broken down. Lumber and paper can be separated and contained for destruction. The cores have proven resistant to solvent wasting and also require a multi-stage pretreatment approach which includes shredding, as well as the application of a direct destruction technology (i.e. incineration). The steel vessels, often referred to as hulks or carcasses, can be solvent washed or subject to a destruction technology. In Germany, the drained carcasses are stored in a salt mine depository for disposal. Small capacitors in fluorescent lighting ballasts can be broken down with the objective of size reduction. Mobile trailers specifically designed for the disassembly of fluorescent lighting ballasts were developed in North America and operate world-wide. 2.2.3 Shredding Some technologies are only able to process wastes within a certain size limit. For example, some will handle POP contaminated solid wastes only if less than 200 microns in diameter. Shredding can be used in these situations to reduce the waste components to a defined diameter. By reducing particle size, shredding creates more surface area, increases exposure to treatment chemicals or systems (heat, light, etc.). Small solid parts, such as capacitor pans from fluorescent lighting ballasts, are more amenable to treatment after they have been shredded as the oil is no longer encased in metal. Shredding technologies are widely used in the waste management and recycling industry with many systems being commercially proven, developed and widely available. Relative to remedial technologies, shredding is inexpensive, only requiring a small portion of the overall budget. Costs can increase dramatically if the items to be shredded are large, solid and complex (i.e. metal transformer carcasses). 2.2.4 Screening Screening as a pre-treatment step can be used to remove debris from the waste stream or for technologies that may not be suitable for both soils and solid wastes. There are several screening technologies commercially proven and developed including grizzly screens, trommel screens and vibratory screens amongst others. Such screening systems are widely available and commonly used in waste management and remediation operations. 2.2.5 Oil / Water Separation Some process technologies are not suitable for aqueous wastes (water may be reactive), others are not suitable for oily wastes (oil can foul treatment systems). Oil/water separation can be employed in these situations to separate the oily phase from the water. Both the water and the oily phase may be contaminated after the separation and both may require treatment. Oil/water separation is an old technology with many commercially proven and developed options. The selection of specific systems depends on material and sizing characteristics. Common oil/water separation systems include baffled gravity separators, skimmers and far more complicated systems such as centrifuges. Chemical treatment may be required to remove soluble oils or disperse colloids. Given that PCBs are lipophylic/hydrophobic (tend to partition to oils and fats and away from water), and often associated transformer dielectric fluids, which are oil, oil/water separation technology can be important for PCB remediation efforts as PCBs tend to concentrate in the oil phase. Costs are relatively low for simple systems and would not comprise a significant fraction of a treatment train. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 29 of 119 2.2.6 pH Adjustment Some treatment technologies are most effective in a defined pH range and in these situations, caustic, acid or CO2 are often used to control pH levels. Some technologies may also require pH adjustment as a post-treatment step. As PCBs are neither basic nor acidic, their presence does not influence pH itself, but other component in a wastewater stream may do so, particularly for such technologies as sodium reduction. Several pH adjustment technologies have been commercially proven. 2.2.7 Soil Washing Soil washing is a volume reduction technology for contaminated soil. Soil comprises varying sized particles, from fines to boulders. As contaminants are only adsorbed onto the smaller particles, separating the particles by size allows for more economical and efficient treatment. Soil washing comprises a multi-stage sizing procedure, beginning with the removal of large particles (stones, cobbles, boulders, etc.) by mechanical screening and then mixing the soil with water to form a slurry which is then separated by a variety of methods, most developed for mining ore extraction techniques. The fines generated contain the majority of contaminants. The stones, cobbles and boulders, once washed clean of fines, are generally-contaminant-free and can be used as fill. The concentrated fines are less expensive to transport, store, treat or destroy, whichever management strategy is selected. 2.2.8 Thermal Desorption Low-Temperature Thermal Desorption (LTTD), also known as low-temperature thermal volatilization, thermal stripping, and soil roasting, is an ex-situ remedial technology that uses heat to physically separate volatile and semi-volatile compounds and elements (most commonly petroleum hydrocarbons) from contaminated media (most commonly excavated soils). Such processes have been used for the decontamination of the non-porous surfaces of electrical equipment such as transformer carcasses that formerly housed PCB-containing dielectric fluids. For soil, two common thermal desorption designs operating as continuous process are rotary dryers and thermal screws. Rotary dryers are horizontal cylinders that can be indirectly or directly-fired and are usually fuelled by natural gas or fuel oil. The dryer is normally inclined and rotated to ensure good mixing of the material being treated. In thermal screw units, hollow augers known as screw conveyors, transport soil through an enclosed trough. Hot oil or steam is circulated through the auger to indirectly heat the soil. For electrical equipment, batch desorbers are used. The difference between thermal desorption units and incinerators is the end point objective which determines the temperature to which the material is raised. LTTD only volatilizes contaminants, hence, has lower temperatures than incinerators. Although the solid phase, whether soil or electrical equipment would no longer be considered "contaminated", the vapour stream requires further treatment as all contaminants have been transferred to this phase. The method of treatment is dependent on the nature of the contaminant, concentration and other physical factors. For PCBs, vapours are commonly incinerated at high temperatures, although absorption by activated carbon is possible for low concentration vapours. If the gas phase is subject to condensation or scrubbing, further treatment of the concentrated liquid state by a non-combustion technology is possible. There are many such technologies commercially proven and developed, both as fixed facilities and mobile/transportable systems. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 30 of 119 2.2.9 Thermally Enhanced Soil Vapour Extraction Under this approach for in situ treatment, steam/hot air injection or electrical resistance/ electromagnetic/fiber- optic/radio frequency heating is used to increase the volatilization rate of semi-volatiles and facilitate extraction. The system is designed to treat semi-volatile organic compounds (SVOCs) and will also treat volatile organic compounds (VOCs) and some PCB congeners. After application of this process, subsurface conditions are excellent for biodegradation of residual contaminants. The following factors may limit the applicability and effectiveness of the process: Debris or other large objects buried in the media can cause operating difficulties; Performance in extracting certain contaminants varies depending upon the maximum temperature achieved in the process selected; Soil that is tight or has a high moisture content has a reduced permeability to air, hindering the operation of thermally enhanced SVE and requiring more energy input to increase vacuum and temperature; Soil with highly variable permeabilities may result in uneven delivery of gas flow to the contaminated regions; Soil that has a high organic content has a high sorption capacity of VOCs, which results in reduced removal rates; Air emissions may need to be regulated to eliminate possible harm to the public and the environment. Air treatment and permitting will increase project costs; Residual liquids and spent activated carbon may require further treatment; Thermally enhanced SVE is not effective in the saturated zone, however, lowering the aquifer can expose more media to SVE (this may address concerns regarding light non-aqueous phase liquids (LNAPLs); and Hot air injection has limitations due to the low heat capacity of air. Remediation projects using thermally enhanced SVE systems are highly dependent upon the specific soil and chemical properties of the contaminated media. This technology may be suitable for some specific sites and should be evaluated on a case by case basis. 2.2.10 Solvent Washing Electrical equipment such as capacitors and transformers are difficult to treat, but if PCBs are removed by solvent, the contaminated solvent has many disposal options. This technology has also been used successfully for the treatment of contaminated soil. There are several technologies commercially proven and developed. For example, the Terra-Kleen solvent extraction technology was developed to remove PCBs, dioxins, furans and pesticides from soil. There are also commercial technologies available for PCB removal from containers (i.e. drums) and electrical equipment (i.e. transformer carcases, capacitors, etc.). In the early 1980's, it was found that the conventional approach to cleaning PCB transformers, where they were rinsed three to six times and soaked with oil or solvent, could not effectively bring concentrations to objectives (50 mg/kg PCB) unless the initial concentrations were very low. Although occasionally adequate for casings, the internal components of the transformers (core and windings) failed to meet objectives even after 18 hours of soaking and rinsing (Vijgen, 2002). Autoclaving is a batch process using solvent to extract PCBs from electrical equipment. The system works in cycles. After loading the waste to be cleaned, a vacuum is applied and solvent charged. The chamber is heated to I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 31 of 119 drive off water. The solvent, containing PCBs, is drained and distilled to produce clean solvent for re-use and PCB wastes for further treatment (generally high temperature incineration or alkali reduction). These facilities cannot economically complete with solid waste incinerators. Ontario Hydro constructed such a system to treat its transformers and capacitors. The system had been commissioned and begun treating the materials when the Swan Hill's facility in Alberta began to allow out-of-province wastes to be accepted and this more cost-effective option involving incineration became available. Ontario Hydro closed their facility and shipped all the collected electrical equipment waste to the incinerator in Alberta for PCB-destruction. 2.2.11 Soil Flushing For soil flushing methods, water, or water containing an additive to enhance contaminant solubility, is applied to the soil or injected into the groundwater to raise the water table into the contaminated soil zone. Contaminants are leached into the groundwater, which is then extracted and treated. The target contaminant group for soil flushing is inorganic wastes including radioactive contaminants. The technology can be used to treat VOCs, SVOCs, fuels, and pesticides, but it may be less cost-effective than alternative technologies for these contaminant groups. The addition of environmentally compatible surfactants may be used to increase the effective solubility of some organic compounds, however, the flushing solution may alter the physical/ chemical properties of the soil system. The technology offers the potential for the recovery of metals and can mobilize a wide range of organic and inorganic contaminants from coarse-grained soils. Factors that may limit the applicability and effectiveness of this process include: Low permeability or heterogeneous soils are difficult to treat; Surfactants can adhere to soil and reduce effective soil porosity; Reactions of flushing fluids with soil can reduce contaminant mobility; The potential of washing the contaminant beyond the capture zone and the introduction of surfactants to the subsurface concerns regulators. The technology should only be used where flushed contaminants and soil flushing fluid can be contained and recaptured; and Above ground separation and treatment costs for recovered fluids can drive the economics of the process. There has been very little commercial success with this technology. We do not recommend its use, except for special cases. 2.2.12 Adsorption / Absorption Sorption is the general expression for both absorption and adsorption processes. Sorption is a pre-treatment method that uses solids for removing substances from gaseous or liquid solutions. Adsorption involves the separation of a substance (liquid, oil) from one phase and its accumulation at the surface of another (activated carbon, zeolite, silica, etc.) Absorption is where a material transferred from one phase to another interpenetrates the second phase to form a solution (e.g., organic compounds such as PCBs transferred from liquid or vapour phase into activated carbon is well established). The adsorbent then requires treatment to destroy the contaminant. For activated carbon contaminated with PCBs, incineration is commonly used. These pre-treatment technologies may be used to concentrate contaminants and separate them from aqueous wastes. The concentrate and the adsorbent or absorbent will require destruction treatment. Sorption pre- treatments should produce wastewater which meets discharge criteria if initial concentrations are low. There are several sorption technologies commercially proven and developed. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 32 of 119 2.3 Post-Treatment Methods After contaminant destruction has taken place, some post-treatment may be required before the end-products are released to the environment, recovery operations (i.e. scrap metal recycling) or ultimate disposal (non-hazardous landfill or alternative fill site). This section addresses the non-destruction, post treatment approaches. 2.3.1 Cooling Most destruction methods that use combustion, thermal or other high temperature processes generate solid waste streams that must be cooled before they can be handled. Such processes may generate wastewater that also requires cooling before that can be discharged. Solid wastes are usually cooled by blowers passing ambient air over heated surfaces. The heated air is generally discharged through stacks. Wastewater is generally cooled using cooling towers. Such equipment may be ancillary to a destruction technology but would not constitute a significant cost in the technology delivery. 2.3.2 Polishing Used for both wastewater effluents and air emissions, the chance of low level contaminant releases is mitigated on some technologies by adding additional treatment such as adsorption/absorption technologies (Section 2.2.12). The use of activated carbon for both waste streams is a wide-spread practice. Similarly, fugitive emission capture from negative air pressure units can also be run through such polishing technologies. 2.3.3 Liquid/Solid Separation Any technology that treats sediments or slurries, as well as those that generate slurries for treatment (bioreactors), usually involves require the separation of the aqueous phase from solids. There a large number of such, many of which were described in Section 2.2.1 (Dewatering) but given the solids contents may be quite low in slurries, such methods as clarification, filtration and settling should be added. 2.4 Oxidation Treatment Methods Destruction by oxidation is the process by which organic compounds are converted to mineral matter. An organic compound is oxidized when it loses electrons to an oxidizer, typically oxygen, thereby being transformed to CO2, H2O and inorganic halogens. 2.4.1 Molten Salt Oxidation (MSO) Molten salt oxidation (MSO) is a flameless reaction that oxidizes (destroys) organic compounds at a temperature between 700 and 1,000°C. The oxidizer (air/oxygen) is added to the waste stream beneath the surface of an alkaline molten salt bath. Hot gases rise through the molten salt bath and the salt scrubs acids from the gases. Organic materials are converted into carbon dioxide, nitrogen and water vapour. Metals and other inorganic materials are captured and held in the salt. Molten salt oxidation is a proven destruction technology, although its commercialization is extremely limited (essentially not commercialized for PCB destruction). Very high destruction efficiencies (>99.9999%) are reported for liquid PCBs, PCB-containing solids, HCB, and chlordane. Considering the similarities between the chemical characteristics of PCBs, HCB, chlordane and the other POPs, we expect that the MSO technology will have similar destruction efficiencies for most POPs. This technology should only be used for oily phase, organic I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 33 of 119 liquids and solids destruction. It is suitable for high concentration wastes. Because water can react explosively with molten salts, MSO is not suitable for water and aqueous solutions. Oily or liquid phase wastes should be water free prior to destruction. Volatile organic compounds (VOCs) can also react explosively. VOC concentrations in waste must be controlled. Solid wastes must be dewatered and shredded as a pre-treatment before being injected with air under the surface of the molten salt bath. The pre-treatment system may produce contaminated water and require further treatment. MSO is not suitable for inorganic waste, especially for soil. Inorganic constituents will form metal oxides and slag that may be hazardous and require special disposal. Salt residues may contain heavy metals and inorganic contaminants and may need disposal. The process requires a high level of energy, water, salt and oxygen. To our best knowledge, there is a low risk for by-product emissions. The usability for remote areas could be limited due to electricity requirements and chemical product transportation. To our understanding, there is moderate potential of exposure for operators and other staff. Highly qualified technical personnel are necessary to operate the system. Application for Vietnam: This technology is not commercialized and therefore should not be considered. 2.4.2 Mediated Electro-Chemical Oxidation (MEO) Mediated Electro-Chemical Oxidation (MEO) is a non-combustion destruction technology. At low temperature and under atmospheric conditions, an electric current flows through a cell, causing chemical reactions in an electrolyte solution (usually nitric acid). A mediator dissolves in the electrolyte. It is then oxidized at the anode and, in turn, oxidizes the wastes introduced into the fluid. For example, natural Ag+ ions are transformed into highly reactive Ag++ ions. These Ag++ ions attack the organic feed. In the reaction, organochlorines are destroyed to form carbon dioxide, water and inorganic ions. The system consists of three subsystems: the MEO system; the acid recovery system; and, the oxidant recovery system. A gas-phase reactor will be necessary to destroy any emissions from the liquid reactor and an acid gas scrubber will also be necessary for removal of acid gases prior to venting to the atmosphere. This technology is commercially available (CerOx, AEA Silver II). High destruction efficiencies of POPs have been demonstrated in trials but at relatively small scales. One process reports a destruction efficiency for chlordane of 99.995%. Considering the similarities between chemical characteristics of chlordane and the other POPs, we expect that MEO technology will have similar destruction efficiencies for most POPs. The technology is applicable to water and aqueous solutions, sludge, oil and organic liquids and some organic solids. Organic solids must be introduced into the cell as slurries. The system will tolerate small quantities of heavy metals, alloys, halogens, sulfur and phosphorous. The system is limited to low concentration POP wastes. It is not recommended with streams containing arsenic, cyanide, selenium, tellurium, lead and fluorocarbons. The electrolyte and mediator can be recycled but there will be a resulting slurry consisting of nitrates and residual inorganics. These wastes could be sent for immobilization. This technology requires electricity, water, cooling water and compressed air. A medium energy level is required. Chemical products needed are caustic, nitric acid and the oxidizer. With the proper post-treatments, there should not be any by-product released into the environment. To our best knowledge, the risk to the environment and humans is low. Highly-qualified technical personnel are necessary to operate the system. Considering the process technology, there is medium potential for worker exposure. Self-contained skids are available. Although the technology is commercially available and high destruction efficiencies have been demonstrated, utilities, chemical products and qualified personnel might not be easily obtained in areas remote from industrial regions. This technology is suitable for low concentration POP waste destruction, in the described matrices, except for industrially remote areas. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 34 of 119 Application for Vietnam: This technology may be applicable but needs a better record of performance and more data to assess before consideration. 2.4.3 Super-Critical Water Oxidation (SCWO) SCWO destroys organic wastes in a compact totally enclosed system using an oxidizer in water at temperatures and pressures above the critical point of water (374°C and 22 MPa). Under these conditions, organic materials become highly soluble in water and react rapidly to produce carbon dioxide, water and inorganic salts and acids. In a traditional SCWO waste treatment system, dilute aqueous organic waste is combined with an oxidizer at supercritical conditions in a reactor for residence times in the order of 10 to 15 seconds. At the outlet of the SCWO reactor, the effluent is cooled, depressurized and separated into gaseous and liquid streams. "SCWO technology has been around for many years, but the earlier systems were plagued by reliability, corrosion and plugging problems. Recent developments by Foster Wheeler and General Atomics have effectively addressed these problems through the use of special reactor designs and corrosion resistant materials. The process has now been effectively demonstrated at pilot and developmental scales and was recently approved for full-scale development and use in the US Chemical Weapons programme" (UNEP). A SCWO commercial scale plant has recently begun operating in Japan. Available information about pilot plant testing demonstrated destruction efficiencies for most POPs in excess of 99.99%. SCWO is a thermal oxidation process that will destroy liquid waste and solid waste less than 200 microns in diameter. Solids can be shredded in the pre-treatment stage if they are too large. This technology is suited for water and aqueous solutions, sludge, oily phase and organic liquids, soil and solid phase wastes (<200 microns). The system is suitable for low and high concentration POP waste with less than 20% organic content. Hydrochloric acid can be formed by the oxidation of halogenated compounds. Post-treatment may be required. The acid can cause corrosion of the reactor and processing system. Furthermore, neutralization of these acids produces salts, which can form precipitates. Titanium alloys, which are highly expensive and not easily available, are recommended for protection against chlorine corrosion. Electricity, water and oxygen are required. Highly qualified technical personnel are necessary to operate the system. A number of commercial operations using this technology and its sub-critical water oxidation variant are working in Japan and the USA. Although the technology is commercially available and high destruction efficiencies have been demonstrated, the process is complex, expensive and requires materials of limited availability. Such systems were considered "highly transportable" (Vijgen, 2002). SCWO is best used for low and high concentration POP waste destruction (with less than 20% organic content), in the described matrices, except for industrially remote areas. Application for Vietnam: While such treatment systems are proven, their applications are limited. The reliance on stable electrical supplies limits its application in Vietnam. However, considerable practical experience is available in Japan. Regardless, this technology is not recommended for use in Vietnam. 2.4.4 Advanced Oxidation Process (AOP) Advanced oxidation technologies increase the rate of oxidation through the use of highly reactive species. The technology will destroy hazardous organic chemicals in water. Different process combinations like UV/ozone, UV/hydrogen peroxide or UV with ozone and peroxide exist. UV/oxidation processes combine the use of ultraviolet light (UV) and chemical oxidizers such as ozone (O3) and hydrogen peroxide (H2O2) to destroy organic I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 35 of 119 compounds. The UV light reacts with the H2O2 to form hydroxyl radicals (OH). These hydroxyl radicals will react with the contaminants to form CO2, H2O and residual ions such as Cl-. AOP is a proven technology and is commercially available (Rayox, Ultrox, etc.). AOP can reduce PCBs and pesticides in water, aqueous solutions and groundwater to acceptable discharge standards. The Perox Pure process has been successfully applied in over 80 sites throughout the United States, Canada and Europe. The results show a destruction efficiency of 95% for pesticides and PCBs in contaminated groundwater. Considering the similarity between chemical characteristics of PCBs, pesticides, and other POPs, we expect that the technology will have a similar destruction efficiency for most POPs. The technology is only applicable to water and aqueous solutions. It is not suitable for organic solids, oily phase and organic liquids. Free product and highly turbid waste streams tend to lower the UV reactor's efficiencies. Waste streams should be relatively free of heavy metal ions, insoluble oil or grease to minimize the potential for fouling of the UV quartz sleeves. To our best knowledge, no by-products to the environment should be produced with this technology, although possible air emission problems with ozone (as the oxidizer) have been encountered in some UV/oxidation systems. The technology requires high energy levels. AOP technologies are complex. Ozone is highly unstable and tends to decompose to oxygen. Ozone must be produced on-site. Peroxide is the main chemical product required. To our best knowledge, there is medium risk to the environment and humans. The process requires high performance construction materials and highly qualified technical personnel. Preventive maintenance is very important. Considering the process technology, there is high potential risk for worker exposure. Considering the complexity of the technology, the need for highly qualified personnel and high potential risk for worker exposure, AOP is not suitable in areas remote from industrial regions. AOP is useful for low and high concentration POP destruction, in the described matrices, for industrial regions. This technology could potentially be made portable, but to our knowledge, this has not been demonstrated. Application for Vietnam: This technology may be applicable in limited situations on a case-by-case basis. It may be used as part of a treatment train for polishing an aqueous wastewater or treating contaminated groundwater. 2.4.5 TiO2 Enhanced Photocatalysis (an AOP technology) Organic compounds, such as organochlorine pesticides, can be completely degraded in an aqueous environment by UV irradiation in the presence of oxygen and TiO2 based photocatalysts. The solution is placed into the reactor with TiO2 as a photocatalyst. The photocatalyst is made out of titanium dioxide (0.1 to 0.5% by weight) on glass micro-spheres, which are immobilized on a fixed support or on the reactor wall for easy separation once the reaction is completed. If not, the reactor has to be supplemented by liquid-solid separation as a post-treatment step. Skimming could be a separation method used since the TiO2 micro-spheres float on the water surface due to their low bulk density. Once the solution to be treated is into the reactor with the catalyst, the irradiation process starts (UV source between 300 to 360 nm) and contaminants are degraded. This process is usually rapid. This technology is commercially available (Purifics, Photo-Cat). It can reduce PCBs, dioxins, furans and herbicides / pesticides in soil, water and aqueous solutions and sludge to acceptable discharge standards. Purifics' installations, permitted by the USEPA, have been successfully applied throughout the world. Destruction efficiency varies from 92.95% for herbicides to 99.99% for PCBs. The Photo-Cat technology is expected to have a destruction efficiency between 92% and 99% for most POPs. That technology has been demonstrated for aqueous liquids and soil with low and high concentration POP wastes. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 36 of 119 To our best knowledge, no by-products to the environment should be produced with this technology. The technology requires electricity. This technology is available on skids and the installations are compact. To our best knowledge, there is low risk to the environment and humans. Considering the process technology, there is low potential for worker exposure. Considering the proven destruction efficiency and the low potential risk for worker exposure, it is recommended for low and high concentration POP destruction in aqueous liquid, soil and sludge matrices, but only for small scale treatment (groundwater), as this technology is not ideal for scale-up to larger operations. It should be noted that laboratory studies examining alternate catalysts and combination of catalysts have shown promising results but are far from commercial applications. Some catalyst combinations include MNOx/TiO2- Al2O3 and TiO2-based V2O5/WO3. Application for Vietnam: This technology may be applicable in limited situations on a case-by-case basis. It may be used as part of a treatment train for polishing an aqueous wastewater or treating contaminated groundwater. 2.4.6 Fe (III) Photocatalyst Degradation (an AOP technology) This technology is also called the Photo-Fenton reaction. It is an oxidation process that takes place in the liquid phase. The efficiency of this reaction is due to the generation of the hydroxyl radical, which has a high oxidation potential and can mineralize the organic compounds completely. The combination of the Fenton reaction in UV light, the so-called photo-Fenton reaction, has been shown in laboratory tests to enhance the efficiency of the Fenton process. This process can be used for the degradation of pesticides in water but some concerns have been raised regarding the generation of toxic products. In practice, the reaction was carried out in a double walled reaction vessel with water circulated through the walls to maintain a constant temperature. The photochemical reactor chamber contained fluorescent black lamps, which emit in the range of 300-400 nm. The pesticide, iron (III) percholate and sodium percholate were added, as needed, to the reaction vessel and temperature was equilibrated to 20°C. The pH was then adjusted to 2.8 with HClO4. The reaction was initiated by the addition of the H2O2 (30%). At this time, no information was found regarding pre-treatment or post-treatment requirements. This technology has only been tried at the laboratory scale. No information was found regarding a pilot plant. In lab, the reaction was tested on the pesticide's active ingredients like: alachor, aldicarb, atrazine, azinphos-methyl, captan, carbofuran, dicamba, disulfoton, glyphosate, malathion, ethoxylchlor, metolachlor, picloram and simazine. The complete degradation of those ingredients occurred in most cases in less than 30 minutes. The efficiencies found were 79% for methoxychlor, 94% for melathion and some 98 to 100% for other pesticides. The reaction is applicable to water and aqueous solutions only. Another limitation is the generation in some cases of by-products like formate, acetate and oxalate that have appeared in early stages of the degradation. Some Cl- has also been noted. Since this technology is at the laboratory scale only, it is difficult to make any assumptions regarding management requirements, safety, etc. Therefore, at this stage, this technology is not recommended. 2.4.7 Wet Air Oxidation (WAO) WAO is the oxidation of soluble or suspended oxidizable components in an aqueous environment using air as the oxidant. The process oxidizes and hydrolyzes organic contaminants in water at temperature of 150 to 320°C and pressures of 10 to 210 bars, which is below the critical temperature and pressure of water. At these elevated I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 37 of 119 temperatures and pressures, the solubility of oxygen in water is dramatically increased, providing a strong driving force for oxidation. With residence times between 60 to 120 minutes, the technology converts organics into CO2, H2O, and short chain biodegradable compounds such as acetic and formaldehyde. Depending upon waste characteristics, bioremediation as a post-treatment may be required. When present, toxic heavy metals should be precipitated and filtered out prior to biotreatment. Wastewater with low pH may cause corrosion damage to the metals used in the WAO. pH adjustment as pre-treatment may be required. Post-treatment evaluation for the potential products of incomplete oxidation must be considered prior to implementing this technology. WAO is a mature technology for the removal of COD with more than 300 units installed worldwide (Zimpro). The technology can treat liquid waste and sludges with high organic contents. Capacities of Zimpro WAO installations are between 0.5 and 66 m3/hr. According to literature, WAO may destroy pesticides, but no information was available on specific POP destruction efficiencies. WAO may not be effective in treating PCBs, dioxins and HCB. The WAO process does not always achieve complete oxidation of the organic compounds. By-products to the environment will be produced with this technology, but can be eliminated with further treatment like activated carbon for vapours and biotreatment for liquid. High levels of electricity are required, although heat energy can be recovered. Some concentrated wastes might require pure or enriched oxygen. Titanium, expensive and not easily available, is recommended to prevent corrosion. To our best knowledge, there is low risk to the environment and humans. The technology is intrinsically safe with regards to the risk of run- away reactions. In the presence of chloride and high temperature, the process requires high performance construction materials and preventive maintenance is very important. Qualified technical personnel are necessary to operate the system. Considering the process technology, there is high potential risk for worker exposure. This technology is available on skids (installations are compact). To our best knowledge, the destruction efficiency for POPs has not been demonstrated. Tests on the actual contaminated waste should be conducted to evaluate its suitability. It could possibly be used for the destruction of low concentration of POPs in all areas depending on test results. Advanced oxidation processes (ozone, UV) should be considered before WAO. Application for Vietnam: While this technology may be of use at some PCB contaminated sites in Vietnam, its potential for application is limited and it does not represent a significant multi-media solution. 2.5 Reduction Destruction Processes 2.5.1 Gas Phase Chemical Reduction (GPCR) The GPCR process is used to treat HCB, PCBs, dioxins, furans and pesticides. It is a two-stage process, beginning with heating the waste in the absence of oxygen to temperatures around 600ºC, causing organic compounds to desorb to the gas phase. The solid or liquid phase of the waste is treated and cooled for non-hazardous disposal. In the second stage, a gas-phase thermo-chemical reaction of hydrogen with organic compounds occurs at a high temperature (approx. 850°C) in a reaction vessel. The organic compounds are reduced by the hydrogen to methane, hydrogen chloride (if the waste is chlorinated) and minor amounts of low molecular weight hydrocarbons in the GPCR reactor. The reduced gases are then scrubbed to remove the particulates and acid before being stored for reuse as a fuel. The process can also operate without any external hydrogen supply if the methane produced is converted back to hydrogen. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 38 of 119 As this reduction reaction occurs in the gas phase, pre-treatment is required for liquid and solid wastes (first stage). These pre-treatments (vaporizer, thermal desorption batch processor (TRBP), TORBED Reactor Systems and liquid waste preheater systems (LWPS)) are part of the GPCR technology. The water and aqueous solutions could be evaporated using a steam heated vaporizer and then fed into the process. The bulk solid wastes are processed via a Thermal Reduction Batch Processor (TRBP), which is an oven-type chamber where the contaminants are volatilised. The organic vapours are then sent to the GPCR reactor. Contaminated soils/sediments can be pre-treated with the TORBED reactor, which allows higher throughput. Dewatering of waste material is not required. The GPCR process has been developed, patented and commercialized by Eco-Logic in Canada. A full-scale plant was operating in Kwinana, Australia but has since been shutdown. The technology is under full scale and pilot scale applications in Canada, USA and the Slovak Republic. For this process, the measured destruction efficiencies are 99.9999% for PCBs (with claims of 8-9s in 90% of PCB destruction with the newest system modifications (UNEP)), chlorobenzene, dioxins and furans. The expected destruction efficiency is 99% for all POPs. This process is flexible and can be applicable to bulk solids, contaminated soils/sediments, and liquids including oils. Some limitations are identified. For example, the pre-treatment can be limiting in the case of large equipment to be decontaminated. The treatment of waste containing arsenic and mercury produces highly toxic arsenic and mercury compounds. Even though mobile units are available; this technology remains mainly as large fixed plants as in Kwinana. That facility had an availability that ranged between 84% and 90%. Some modular, transportable units are available, but their capacities are limited by ancillary equipment (with TRBP, capacity is 75 tonnes/month; with TORBED Reactor, capacity is 300 to 600 tonnes per month; with LWPS, capacity is 3 L/min for homogeneous liquids). The size and complexity of this ancillary equipment is significant. The benefits of this technology are the high efficiency of the process (low emissions) and the range of matrices and contaminants that can be treated. All PCB wastes, including transformers, capacitors and oils, can be treated using this system. On the other hand, its limited capacity can be a disadvantage depending on the amount of waste to be treated and some by-products are generated which need to be disposed of (used liquor and solid residues). This technology could be considered as `high tech' meaning that some skilled operators would be required to operate such a plant. The principal raw materials and ancillaries required for this process are electricity, hydrogen (at least during start-up), water and caustic. The use of hydrogen at high temperatures is a significant risk and comprehensive fire safety and security measures are required for its management. A detailed cost analysis from a 1992 trial of the technology is available (USEPA SITE, Sept 1994), however the technology has been subsequently commercialized and significantly developed, therefore, these cost details would have questionable value for near-future applications. Capital costs for the 4 to 25 ton/day system were estimated at $585,000 with unit treatment costs being estimated at $500 to $2,000/ton (US-1993). For further details, refer to the USEPA SITE report previously identified. GCPR technology is recommended for low and high concentration POP destruction, in the described matrices, for industrial regions. GCPR is also recommended for use in remote locations. Access to fuel, spare parts and properly trained maintenance personnel would be required, but hydrogen and electricity could be generated locally. Application for Vietnam: This technology could be implemented in Vietnam, but it application may be constrained by its high costs and complex nature. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 39 of 119 2.5.2 Solvated Electron Technology (SET) The SET process is a method of reducing halogenated hydrocarbons in a mixture of sodium or other alkali metal in liquid ammonia. As sodium dissolves in ammonia, it decomposes into sodium ions (Na+) and electrons (e-.). The solvated electrons in the solution act as powerful reducing agents removing the halogens (primarily chlorine) from organic molecules and reducing other contaminants. The solvated electron reaction is highly exothermic. In application, contaminated materials are placed into a sealed treatment vessel and mixed, at room temperature, with the solvated electron solution where the contaminants are rapidly dehalogenated. Ammonia is recovered for further use in a separation vessel and by a condenser. Depending on the matrices treated, pre-treatment and/or post-treatment may be required. Possible pre-treatments are water removal, crushing, screening and washing, among others. Possible post-treatments include pH adjustment and ammonia recovery. Commodore Applied Technology Inc has commercialized the SET technology (although the company has apparently been de-listed from the American Stock Exchange in February 2003 for financial reasons). The reported efficiencies of this technology are rated as high depending on the treated contaminants and matrices. The SET technology can be used to destroy the following contaminants: halogenated organic compounds, PCBs, pesticides, CFCs, dioxins, furans and chlorinated solvents. The technology should have a destruction efficiency between 95% and 99% for most POPs. This process is flexible as it can handle various matrices: soils, sediments, sludges, oils, metals, non-aqueous liquids and concrete, among others. SET is not suitable for waste containing significant quantities of water. The reported capacity for this process is 10 tons/day for the commercial unit. The SET process has a number of limitations that need to be considered before using this technology: · Insufficient amounts of reagents could lead to only partial decomposition of the target contaminants; · Excess amounts of reagents would leave traces of sodium in the matrix. Sodium is very reactive and can burn or even explode in the presence of oxygen or water potentially posing a serious safety issue; · Handling and storing large quantities of anhydrous ammonia and sodium pose serious health and safety issues, which need to be addressed when using this technology; · The SET reaction is highly exothermic which can present a problem for a large-scale plant; · The process can create toxic by-products; · Pressure relief valves and permits for accidental venting of ammonia could be required when processing large amount of materials; and · The SET solution is highly corrosive. Most metals will be corroded in the SET reactor, therefore, the internals of the reactor must be constructed from inert materials like glass or ceramics. The benefits of this technology are the high efficiency of the process, the range of contaminants that can be treated as well as the type of matrices that can be processed. This process is also available in mobile units which can present an advantage. The number of pre-treatment and post-treatment steps that can be required need to be taken into consideration. Application for Vietnam: The limitations listed above also raise serious concerns, especially regarding health and safety issues with the ammonia and sodium, which can be toxic and dangerous if not handled by highly qualified personnel in combination with exhaustive security procedures. Additionally, reliable power supplies and bulk chemical deliveries (anhydrous ammonia and sodium metal) are required. For these reasons, this technology is not recommended. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 40 of 119 2.5.3 Sodium Reduction Sodium reduction technology is based on a similar concept as SET but seems to be mostly used for PCB removal from oil transformers. PCBs are destroyed with dispersed metallic sodium in mineral oil. The sodium reacts with the chlorine atoms in the PCBs to form salt and biphenyls. Treatment systems using this technology are both transportable and fixed. Although largely used for treating transformer oils, a unit has been developed for treating fluorescent lighting ballasts. Powertech, a subsidiary of BC Hydro, has developed, patented and commercialized such a PCB destruction technology. The process has received regulatory approvals in Canada and Japan. The Powertech process uses sodium dispersion at low temperature as the active ingredient for destroying PCBs. Since 1987, 16 million litres of transformer oil have been decontaminated. The process does not destroy the transformer oil (can be recycled). One mobile system in operation has a capacity of 15,000 litres of oil per day. Another unit can treat fluorescent lighting ballasts at a rate of 10,000 kg/day. This process is suitable for PCB contaminated transformer oil and solids (ballast, capacitors). Since the Powertech process is patented, the applicability to other media was not evaluated. No information was available on destruction efficiency. To our best knowledge, the Powertech process should vary, in this regard, from 95% to 99%. Kinectrics of Canada also developed sodium-based portable treatment process to treat PCB-containing transformer oil and has treated nearly 10 million litres of contaminated mineral oil since commencing operations in 1985. Sodium is a hazardous, reactive element and the reagents involved in the treatment process are challenging to manage safely. Application for Vietnam: This technology is well developed and proven and will application in Vietnam to treat transformer mineral oils. 2.5.4 Other Alkali Reduction Techniques Similar in approach to the above, dechlorination of organic compounds can be undertaken by alkalis other than sodium. As with sodium reduction, the use of this technique is largely limited to mineral oils. The use of potassium tert-butoxide (t-BuOK) has been commercialized in Japan since 2004 with one operating plant treating 36,000 L/day (Kansai Electric Power Company and Kanden-Engineering Co.). Destruction efficiencies of 99.98% to 99.99% were reported. Application for Vietnam: Similar to sodium reduction, this technology may have application in Vietnam treated transformer mineral oils. 2.5.5 Based Catalyzed Decomposition Process (BCD or BCDP) The Based Catalyzed Decomposition process treats liquid and solid wastes in the presence of a reagent mixture consisting of a high boiling point hydrocarbon, an alkali (sodium hydroxide or sodium bicarbonate) and a proprietary catalyst. When heated (315 to 500ºC), the reagent produces highly reactive atomic hydrogen, which reacts with organochlorines and other wastes. The residues produced from decomposition are an inert carbon I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 41 of 119 residue and sodium salts. After the reaction, solid residues are separated from the residual oil by gravity or centrifugation. The oil and catalyst may be recovered for reuse. The operation of this process can be either on a continuous basis or by batch. In practice, the contaminated liquid is pumped into a heated reactor containing the hydrocarbon oil, sodium hydroxide and the catalyst. The reaction is rapid. For solid waste treatment, the waste needs to be premixed with the catalyst and fed into a heated thermal desorption unit. Depending on the pollutant concentration in the feed, some can be collected from the thermal desorption condensate. If the contaminant level is high and the decomposition is not complete, then the resulting condensate is treated in a liquid BCD reactor. Some pre-treatment may be required depending on the waste to be treated. The possible pre-treatment steps include premixing, shredding, screening and dewatering. This is a proven technology that has undergone commercialization since 1993 in both the USA and other countries. The destruction efficiency of the BCD process for the treatment of DDT, PCBs, dioxin and furans is very high (99.9999%). This process could also be used for most other POPs. The treatable matrices are liquids and solids as mentioned above. This process can treat from 100 kg/h to 20 t/h for solid wastes on a continuous basis and from 1 to 5 t/batch with 2 to 4 batches a day for solids on a batch basis. For liquid waste, the capacity is typically 4,500 to 9,000 L with 2 to 4 batches a day. Higher concentrations in the waste require longer reaction time. The possible configuration of the technology ranges from modular to transportable units as well as fixed plants. Since this technology can be found on a mobile scale this could present an advantage. As for a lot of other technologies using chemical products in large quantities, some skilled operators and a well-defined safety procedure are required. Further analysis of the material could be required since the condensate has to be treated if concentrated in the contaminants. There was a measurable discharge of dioxins and organochlorines to the atmosphere for the older plants but this problem has been addressed by the replacement of the old hydrogen donor with the hydrocarbon oils now in use. The air emissions are as low as monitoring equipment can detect and ancillary liquid and gas scrubbing units further minimize pollution risks. "Compounds such as PCBs which may react with oxygen at elevated temperature to form even more hazardous compounds such as dioxins, are specially suited to the BCD. The inert stream atmosphere in the rotary reactor and throughout the air capture system excludes most oxygen" (ICS-UNIOD, 2000). This technology could be used with highly qualified personnel and management and strict safety and inspection procedures combined with an excellent maintenance program. Application for Vietnam: This technology could be implemented in Vietnam, but it application may be constrained by its high costs and complex nature. 2.5.6 Vacuum Heating and Decomposition Adapted from metal recovery operations in Japan, the concept of vacuum heating decomposition comprises the heating of waste (soil, transformer carcasses, etc.) under vacuum conditions. Below atmospheric conditions, the boiling point of contaminants is lower, and they volatilize with lower applications of energy. In the OPERA process being developed in Japan, this pretreatment method has been combined with an alkali reactor which decomposes the chlorinated compounds. Residual dechlorinated hydrocarbons are captured in an activated carbon filter. Under these conditions, heavy metals, such as cadmium, lead and zinc, which will volatilized and must also be captured. The technology has been developed by Hoei-Shokai Company in Toyota City, Japan, who have I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 42 of 119 operated a pilot scale facility that is mobile (1 ton/day) and a fixed facility that at the Obayashi Plant it Toyota City (10 tons/day). High destruction efficiencies for trials with POP pesticides (BHC and Chlordane) were reported in trials (6 to 7-9s). Application for Vietnam: This treatment system is not proven for PCBs, although it would probably be successful. With its limited application (one vendor) and recent development, the technology is not recommended for use in Vietnam. 2.5.7 Catalytic Hydrodechlorination Research in Japan has shown that palladium as a catalyst generates the greatest degradation rate when compared to other supported metal catalysts. In a closed system, wastes react with hydrogen gas and the catalyst is dispersed in paraffin oil. Hydrogen reacts with the chlorine molecules of the waste, to generate hydrogen chloride and non-halogenated mineral oils, the former being collected for disposal and the latter being used in future reactions. This technology has been used to treat PCB-contaminated capacitors and reaches objectives of less than 0.5 mg/kg. Destruction efficiencies of 99.98% to 99.9999% have been reported for PCBs. A pilot plant operated by Kainsi Electric Power Com. and Kanden-Engineering Co. has been successful and a 1,000 kg/day plant is planned. Application for Vietnam: This technology is not recommended for Vietnam because it is not fully commercialized and has no proven track record. The requirement for bulk hydrogen is a concern with respect to supply and delivery. 2.5.8 Catalytic Dechlorination and Photochemical Dechlorination PCB-contaminated oil is mixed with sodium hydroxide and isopropyl alcohol (IPA) and dechlorinated at moderate temperatures (<75ºC) under atmospheric conditions PCB dechlorination takes place by catalyzed reaction and photochemical processes. The technology is limited to treating mineral oil. Destruction efficiencies of 99.99% to 99.99999% (4 to 6-9s) have been reported. Solvent is recycled for re-use and solid salts and spent catalysts are suitable for non-hazardous disposal. Toshiba Corporation developed this technology and it has been operated in Kawasaki, Japan since 2003. Application for Vietnam: With its limited application (one vendor) and recent development, the technology is not recommended for use in Vietnam. 2.5.9 Catalytic Hydrogenation Dehalogeniztion of organic compounds by noble metal catalysts while theoretically proven, has been limited in application due to catalyst poisoning and other practical limitations. In Australia, the Commonwealth Scientific and Industrial Research Organization (CSIRO) developed an approach using less active metal sulphides as catalysts and introducing a propriety additive to reduce the impact of hydrochloric acid scavenging on the transformer oil so that it can be re-used. A pilot-scale prototype (1,000L/day capacity) has been in operation since 1997. Destruction efficiencies of 99.99% to 99.99.99% (4 to 6-9s) have been reported. The technical rights to the process were sold to a British company and one 3,000 L/day plant is reported to be operating in Australia. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 43 of 119 Application for Vietnam: This technology has limited commercialization and is therefore not recommended for application in Vietnam. 2.5.10 SonoProcess Technology The SonoProcessTM is a low temperature process that uses low frequency sonic energy to disperse sodium that destroys PCBs. The process is used primarily for the treatment of contaminated soils and other granular materials. Soil is loaded into bins and a isopropanol alcohol (IPA) solvent percolated through to remove POPs until release criteria are met. The solvent is cleansed and recirculated and the PCB concentrate from the solvent extraction process is mixed with a hydrocarbon solvent (to increase pumpability) and pumped to Sonic Generator where PCBs are destroyed chemically by PCB SonoprocessTM. The Sonic Generator comprises two chambers connected by a steel bar. The PCB concentrate is fed into the mixing chamber along with sodium ingots. PCB liquids such as oils or concentrates from other pretreatment technologies (such as low temperature desorption) can also be fed into the chamber. The steel bar is excited electromagnetically, with the chambers transmitting the vibrational energy to the PCB waste within them. The sonic energy disperses the sodium which reacts with the PCBs. The destruction efficiency is rated as 99.9999%, with a typical throughput of 2,000 tonnes of soil per month, or 6,000 litres of PCB liquids per day. Because the process is a closed loop operation and the treatment does not involve high temperatures, the risk of creating harmful emissions such as dioxins and furans is minimal. Process salts are produced from the reaction of the PCBs with the sodium dispersion. The hydrocarbon solvent can be recovered and recycled for use as a low- grade fuel. The technology is commercially available and has been used in Canada within the private sector and in the United States, primarily by the US Armed Forces. The technology is mobile, and can be adjusted to fit the scale of the project. Application for Vietnam: While this technology may be of use at some PCB contaminated sites in Vietnam, its potential for application is limited and it does not represent a significant multi-media solution. 2.6 Thermal Methods (Combustion) As previously mentioned, combustion technologies suffer from poor public perception. There is a strong belief amongst the public that such technologies generate harmful dioxins and furans (PCDD/F) and release them to the atmosphere. Regulatory controls on emission rates have been in force to address these concerns. "Laboratory Studies as well as thermodynamic and kinetic principles indicate that virtually all organic materials will be destroyed at temperatures exceeding 1,000ºC for a reaction time of 2 seconds" (Karstensen), hence, incineration is a widely used technique to destroy PCBs. Some approaches to incineration are single stage, such as incineration in cement kilns, while others are multi-stage, generally two, where PCBs are first volatilized from a solid media, such as soil or solid waste, and then the vapour emissions are incinerated at a higher temperature, ensuring destruction. This two stage approach is undertaken in order to conserve fuel. The EC drafted Directive 94/67/EC on the incineration of hazardous waste. Special attention was paid to emissions of PCDD/F with a average value of 0.1 ng TEQ/m3 over a period between 6 and 8 hours. The emission limit had to be met by January 1997 under EN 1948. The following restrictions were also identified in the directive: I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 44 of 119 · A temperature greater than 850ºC must be maintained for at least two seconds to destroy PCDD/F and to avoid precursors; · If more than 1% of halogenated organic substances, expressed as chlorine, are incinerated, the temperature has to be raised to at least 1100ºC (this applies to PCBs); · For the first 12 months of plant operation, one measurement shall be taken every two months (6 in total); and · At lease two measurements per year shall be carried out. The new Directive 2000/76/EC for incineration came into force on December 2000, providing more details (SINTEF, March 2004). The USEPA require high efficiency incinerators that destroy PCBs must meet a number of technical requirements such at a 2 second residence time at 1200ºC and 3% excess oxygen or 1.5 second resident time at 1600ºC and 2% excess oxygen in the stake gas. The Destruction and Removal Efficiencies (DRE) for non-liquid PCBs must be at least 6-9s (99.9999%). 2.6.1 Large Scale Fixed Incinerators Large scale incinerators use heat from fuel combustion or electrical input to cause thermal decomposition of organic contaminants through cracking and oxidation reactions at high temperatures (usually between 760 to 1550°C) with a residence time in the afterburner of at least 2 seconds. The organic contaminants are primarily converted into carbon dioxide and water vapour. Other products of incineration can include: nitrite oxides, nitrates, and ammonia (for nitrogen-containing wastes); sulfur oxides and sulfate (for sulfur-containing wastes); and halogen acids, dioxins and furans (for halogenated wastes); PCBs and HCB. The nature and quantity of by- products is very dependent on the control of the incineration operations. Contaminated soils typically are treated in a rotary kiln or a fluidized bed incinerator. The most popular type of incinerator used is the rotary kiln with an after burner and various air pollution control devices. At present, in many countries, the incineration process is the preferred method of disposal for most obsolete pesticides. Recent studies have shown that undestroyed chemicals are released not only in incinerator stack gases but also in solid and liquid residues (e.g., fly ash, scrubber solids and water, bottom ash, etc). Therefore, some post-treatment is required such as gas scrubbing, water treatment and proper treatment and/or disposal of ashes, slag and scrubber residues. Also off-gas treatment is needed to neutralize the acidic gas as the products of oxidation when treating halogenated SVOCs (semi volatile organic compounds). Incineration is not generally considered suitable for large volumes of water containing low concentrations of POPs. This technology is widely commercialized and has been used for many years. The incinerators can handle solids and liquids as well as contaminated soil, materials, containers and packed waste. Their capacities vary, typically ranging from 1.5 to 7 t/h for larger units. They can handle all kinds of POP waste (including organochlorinate pesticides). The reported destruction efficiency of this process is over 99.99%. In the last few years public opinion has started to change regarding incinerators. Modern incinerators are commonly described as destroying POPs and similar chemicals very efficiently. Dioxins, furans, PCBs and HCB are released in stack gases and solid residues are also generated. In other words, an incinerator with a highly effective stack gas cleaning system could demonstrate a high DRE even if the actual levels of destruction are low. The formations of dioxins/furans emissions are very influenced by the incinerator design and control technology. Also some companies have restrictions regarding wastes containing heavy metals such as mercury or other specific elements like iodine, which is another limitation to be considered. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 45 of 119 These incinerators are only found in industrialized countries because of their capital costs and also because highly trained personnel are required. Regular maintenance and services, intensive control procedures including analytical facilities, are also necessary. A continuous supply of fresh water, large quantities of chemicals for the scrubber and a reliable supply of electricity and fuel are needed. It should also be recognized that gas scrubbers are required with a good control/treatment of the other residues like ashes and so forth. There is a substantial overcapacity of well-equipped, modern high temperature incinerators in Western Europe (GEF, 2004). As the capital investment has already been made for these facilities, new technologies (such as non- combustion technologies) and facilities are at a disadvantage to compete in this market. Shipping cost, though substantial, are a fraction to capital construction cost for a new facility and many developed nations such as the Phillipines and Thailand, have chosen to send their PCB waste to Western Europe instead of investing in indigenous technologies. Application for Vietnam: Although this technology treats wide varieties of waste types, is effective and widely used, it requires substantial capital investment and is controversial. Given the anticipated waste generation rates in Vietnam, the construction of a new incinerator would not be recommended because of the generation of by- products and the capital investment required, but the use of an existing facility with proper gas scrubbing and treatment of by-products is feasible. 2.6.2 Small Scale Fixed Incinerators The principal of incineration for small scale fixed facilities is the same as for the large scale fixed incinerators with a few differences relative to capacity (10 to 100 kg/h), number of combustion chambers, afterburner and gas scrubber requirements. As a matter of fact, the simplest small-scale model has only a single chamber without an afterburner and/or gas scrubber. The models without an afterburner and gas cleaning devices are definitively not suitable for the destruction of bulk obsolete pesticides or any quantities of waste containing chlorine, phosphorus, sulphur or nitrogen. The lack of such devices creates a high risk of severe air pollution particularly when organochlorine compounds are incinerated. Many models do not reach the required incinerating temperature, which further aggravates the risk. Please refer to the previous section for other details. Application for Vietnam: Small scale fixed incinerators are not recommended for the reasons listed above. 2.6.3 Mobile Incinerators Usually, mobile incinerators are large units with a rotary kiln and air pollution control devices. This technology is widely commercialized and has been used to clean hazardous waste sites in the USA. Incineration is suitable for large amounts of soil, water and aqueous solutions, sludge, oil, organic liquids and solids. It is not generally considered suitable for large volumes of water containing low concentrations of POPs. Destruction and removal efficiencies can be up to 99.999% with units meeting most air emissions standards. Capacities of the smaller models range from 2 to 20 tons/day. The incinerators require large quantities of fresh water, large quantities of chemicals for the scrubber, a reliable supply of electricity and highly trained staff. Like large-scale incinerators, it should be considered that a gas scrubber is required with good control/treatment of the other residues like ashes and so forth. There may be limits to the maximum chlorine content of pesticides that can be incinerated. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 46 of 119 With proper gas scrubbing and proper treatment of by-products, the mobile incinerator is recommended for large volumes and high concentration POP waste in all areas for the described matrices. Application for Vietnam: This technology is proven and may be applicable in Vietnam. 2.6.4 Cement Kiln Incineration Temperatures reach 1450°C in a cement kiln and the combustion gases stay above 1200°C for five to six seconds destroying most POPs in the process. The cement kiln is an oven that rotates to expose limestone, sand and clay evenly to make cement clinker. The clinker process includes a large quantity of lime (in excess) that will neutralize any traces of sulphur and chlorine. Mineral elements are fixed in the crystalline pattern of the clinker. Dust is produced, collected and reintroduced into the process. The cement kiln does not produce any liquid or solid waste. The use of hazardous waste as fuel, including chlorinated solvents such as PCBs, has proven to have no impact on the quality of the cement product. Furthermore, the use of the cement as a building material has shown no long term environmental or safety consequences. The lack of solid residues after treatment is a distinct advantage over other incineration technologies. Numerous trials in the USA and Europe, by cement producers and private waste management firms have demonstrated destruction efficiencies ranging between 99.95% and 99.999999 or 8-9s (JFE, 2007). Furthermore, "In a study performed for the World Business Council for Sustainable Development, data from approximately 2,200 PCDD/F measurements from wet and dry kilns, performed under normal and worst case operating conditions, and with the co-processing of a wide range of hazardous wastes fed to both the main burner and to the precalciner, shows that most cement kilns can meet an emission limit of 0.1 ng TEQ/Nm3 provided that primary measures are applied:" (Karstensen, 2005). In Europe, PCBs are not subject to regulatory monitoring in cement plants, however, 40 measurements completed at 12 kilns in Germany in 2001 identified a maximum concentration of 0.4 µg/Nm3. In 9 of the measurements, PCBs were not detected (SINTEF, March 2004). In the United States, cement kilns can only burn PCB waste that has concentrations less than 500 ppm, although this is politically motivated as combustion technologies remain suspect in public perception despite mounting evidence to the contrary. The technology will destroy POP-contaminated liquid, non aqueous waste, powder, sludge and soil. "The method of introducing liquid and solid hazardous waste into the kiln is a key facture to ensure safe and sound destruction. Liquid hazardous waste is either injected separately or blended with the primary fuel (coal). Solid waste is mixed and burned along with the primary fuel. POP waste must be introduced through a separate channel/pipe into the main burner" (IHPA). For processing in cement kilns, wastes must be blended with a fuel suited to the cement process itself. Under proper conditions, the risk to the environment and humans can be minimal. Upsets in the process may cause incomplete combustion resulting in polluting emissions. The destruction of wastes containing POPs in cement kilns has been demonstrated. Highly qualified technical personnel are necessary to operate the system. Considering the process technology, there is medium potential for exposure. The technology is commercially available and high destruction efficiencies have been demonstrated. Formerly, Cement kiln disposal (co-processing) was not an accepted technology by the Basel Convention because there is insufficient evidence that the process is "dioxin-free" (GEG, 2004). As more data is provided on emissions that prove the technology meets appropriate standards (such as those of the EU), this was be I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 47 of 119 reconsidered and cement kiln co-processing is now included on the list of acceptable destruction technologies for POPs (UNEP, undated) and PCBs (UNEP 2005). Particularly relevant to this project, the "Guidelines for the Selection and Use of Fuels and Raw Materials in the Cement Manufacturing Process" (WBCSD, December 2005) points out that in Norway cement kilns are the preferred method for hazardous material management, including the destruction of PCBs, an approach that has been used safely and successfully for more than 10 years. The environmental benefits of co-processing waste and hazardous waste in cement kilns are significant and summarized as follows: · decrease the combustion of virgin fuels; · decrease the need to extract and refine virgin fuels; · decrease the need to construct alternate treatment facilities (cement kilns are already constructed); · decrease the use of non-combustible raw materials (i.e. replacing some limestone and other precursors with slag and ash); · decrease the need to quarry and transport the non-combustible raw materials; · decrease the need to transport hazardous waste long distances (the economics of the cement industry mean that kilns are generally within 200 to 300 km of their customers, due to transportation costs, and are thus widely distributed over every country); · decrease the need to dispose of non-hazardous waste in landfills (no solid waste generated, solid residues are incorporated into the cement clinker); and · decrease the need for treating or disposing of hazardous non-combustible waste. The World Business Council for Sustainable Development and the cement industry have developed a number of guidance documents for facilities and countries that include cement co-processing as part of their waste management initiatives. These documents provide insight into the regulatory control of plants, waste selection, air emission control and monitoring amongst other elements (for particular documents, see references and the following website: http://www.wbcsdcement.org). Application for Vietnam: As with many developing countries, the cement kilns in Vietnam are a combination of old, out-dated plants and new, state-of-the-art facilities. Only the most modern plants should be considered for hazardous waste destruction (including PCBs and other POPs). The technology should only be used in cement plants that can demonstrate competent waste management systems and good kiln temperature control. 2.7 Thermal Methods (Non-combustion) There are two general approaches introduced in this section. The first is a high energy application using plasma arc. The principles of plasma arc decomposition are that an electrical arc is struck between two electrodes. Chlorinated organic compounds are transformed into their elemental states and recombined into mineral gases. The plasma arc technology directs an electric current through a low pressure gas to create a plasma. The waste is injected into the plasma at a temperature that can reach 3,000 to 15,000°C. Plasma arc decomposition is available in three processes, as described below. The other approach is the application of lower heat under vacuum, promoting volatilization at lower boiling points that occurs under atmospheric conditions. While this is a contaminant media transfer technique, and therefore a I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 48 of 119 pretreatment method, it is promoted as a package treatment known as the OPERA system, when combined with alkali reduction, as described at the end of this section. 2.7.1 Pact Process The first process (Pact process) uses heat generated by a plasma torch to melt and vitrify solid feed material in a rotating tank with centrifugal force and pushes the waste into the plasma torch's high-temperature zone. Organic components are vaporized, decomposed and ionized before passing through the off-gas treatment system. The torch runs on direct current provided by a 3-phase power supply and is cooled by a high velocity flow of distilled water. The use of two combustion chambers is required by the USEPA to ensure complete combustion and destruction. A typical gas treatment system is required. The system is hermetically sealed and operated below atmospheric pressure to prevent leakage of process gasses. This is a batch process from which waste exits the chamber by a chute when the batch is complete. The Pact process is a commercially available method. The destruction of organic compounds is greater than 99.99%. It has been demonstrated successfully under the USEPA SITE program for HCB in diesel oil. Post-treatment of gas may be required for the removal of volatile metals and particulates. A high level of energy is required. To our best knowledge, there should be low risk to health and the environment considering that air emissions were in compliance with regulatory requirements without dioxins detected under the USEPA SITE program. Highly qualified technical personnel are necessary to operate the system. Considering the process technology, there is high potential for worker exposure. Smaller units were reported to be readily relocatable by being designed to fit within standard container-sized modules. Although the technology is commercially available and high destruction efficiencies have been demonstrated, the technology is not suited to industrially remote areas. The Pact process technology is recommended for high concentration POP destruction in the described matrices. Application for Vietnam: While such treatment systems are proven, their applications are limited. The reliance on stable electrical supplies and bulk chemical supplies (argon, oxygen and caustic soda) limit it application in Vietnam. 2.7.2 Plasma Converter System Secondly, the PCS process is similar to the PACT process, varying only on the method of delivering waste to the flame of the plasma torch. PCS uses a cylinder reaction chamber where waste is fed through the plasma flame. The waste destruction takes place under pyrolytic conditions (oxygen deficient) at temperatures in the plasma as high as 16,000ºC. Off-gas treatment is required, comprising a scrubber for acid gases generating an aqueous waste stream and cyclonic separator for particulate removal generating a dust waste stream. Application for Vietnam: While such treatment systems are proven, their applications are limited. The reliance on stable electrical supplies and bulk chemical supplies (argon, oxygen and caustic soda) limit it application in Vietnam. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 49 of 119 2.7.3 Plascon In the third plasma arc process, known as Plascon, the waste is injected with argon into a plasma arc. The mixing temperature is in excess of 3,000°C where the organic material is pyrolyzed to its atomic elements, after which they recombine to form simple compounds. The resulting products include gases consisting of argon (the inert gas), carbon dioxide, water vapour and an aqueous solution of inorganic sodium salts. The Plascon process is a commercially available method. A commercial, fixed facility is operated in Queensland, Australia. Originally focused on treating PCBs, the plant has been reconfigured to treat pesticides. The technology should achieve very high destruction efficiencies (6 to 8-9s: 99.9999 to 99.999999%). The process has been demonstrated successfully for PCBs. The technology is reported to destroy most POPs in liquid and sludge matrices with high chlorine content. A pre-treatment to transform waste into a slurry will be required for solid waste. Thermal desorption is typically applied which also allows the treatment of drained electrical equipment carcasses. A high level of energy is required. To our best knowledge, there should be low risk to health and the environment considering that process control interlocks are provided to prevent the release of incompletely treated waste, in the case of power failure. Highly qualified technical personnel are necessary to operate the system. Considering the process technology (high temperature), there is high potential for worker exposure. To our knowledge, this technology has not been implemented as a mobile unit. Application for Vietnam: While such treatment systems are proven, their applications are limited. The reliance on stable electrical supplies and bulk chemical supplies (argon, oxygen and caustic soda) limit it application in Vietnam. 2.7.4 Molten Metal Media Processes Molten Metal Technology (MMT) has developed a Catalytic Extraction Process (CEP), although it is not primarily a catalytic process or an extraction process and would be more accurately defined as a "molten metal, high temperature combustor". The process uses a standard steel converter with molten iron or slag to heat waste. The Molten metal at a temperature of 1650ºC is the heat source under which chlorinated wastes will dissociate into their atomic constituents. As the waste is injected at the bottom of the molten metal bath, it must be either gas, liquid or finely divided solids, thus, some pre-treatment may be required. The MMT system has been supported by the US Department of Energy and a commercial scale research and development units were in operation in Massachusetts in 1995. Some information indicated that the company went into bankruptcy in 2002. No recent information on other molten metal technology was available. Application for Vietnam: This technology is not commercialized and is therefore not recommended for application in Vietnam. 2.7.5 In-Situ Vitrification In-situ vitrification uses electricity to melt contaminated soil or wastes at high temperature. The organic pollutants are destroyed by pyrolysis and inorganic compounds are immobilized within the vitrified glass. Large graphite electrodes are inserted into the soil. Electricity arcs from one electrode to another through the soil. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 50 of 119 Temperatures reached vary from 1,400 to 2,000°C. The heat reduces the soil into a molten form. The electrodes move deeper as the ground liquefies and continue to melt the soil until the maximum depth is reached. The estimated achievable depth is 30 feet. The electricity is then shut off and the soil solidifies into glass. The organic pollutants are reduced into gases that are collected and transported for treatment. The in-situ vitrification technology is commercially available (Geomelt, Geosafe). The technology is suitable for a wide range of soil, dewatered sludge, sediment, and wastes. Permeability and density tests should be performed for each site. The soil should have sufficient amount of glass-forming materials (silicon, aluminum oxides) and metals. The technology has been applied on matrices contaminated with PCBs, dioxins, furans, pesticides, herbicides and fuel oil. Destruction efficiencies have been reported between 90 and 99.99%. Considering that the technology applies to low and high strength organic materials, we expect that in-situ vitrification will have the same destruction efficiency for all POPs. The vitrification process is limited by the length of the electrodes and the availability of power. Volatile organic compounds and combustion products can escape from the off-gas treatment system. The soil should be dried prior to melting to prevent the release of dangerous gases. Electrodes, a transformer, off-gas collection hood, off-gas treatment system and water are the required materials. A mobile skid is available. To our best knowledge there is low risk to the environment and humans, considering that the off-gas treatment system is designed in a way to prevent leaks. Considering the process technology, there is low potential for worker exposure. The technology would be suitable for low and high concentration POPs, for the described matrices, for industrial regions. Application for Vietnam: While such treatment systems are proven, their applications are most successful at highly contaminated and mixed waste sites as they are expensive. In Vietnam, this technology would only be recommended at sites with high toxicity and would be site-specific (not a technology for general PCB waste treatment). 2.7.6 Self-propagating High-Temperature Dehalogenation POP waste can be destroyed by creating conditions where a spontaneous propagation of a combustion wave will generate, at the combustion front, severe thermochemical conditions suitable for the breakdown of hazardous organic molecules. Prior to the reaction, chlorinated organics are premixed with calcium hydride or calcium metal and placed in a sealed reaction chamber, which is pressurized with argon. An applied power pulse initiates the reaction. The main steps of the process are the following: loading the waste into the reactor, sealing and ignition, reaction, cooling, unsealing and finally unloading. No information is available as for possible pre- treatment and post-treatment requirements. This system has been operating at the lab scale in Italy and does not yet operate commercially. As for the destruction efficiency, test reports for hexachlorobenzene and the herbicide dichlorprop indicate a level of 99.999%. The gas emission characteristics are not well defined, however, some by-products would likely be hydrogen, methane, benzene, mono, di- and tri-chlorobenzene, dichloroethylene, dichloro-methane, xylene and trimethylbenzene. Not much information is available at this point in time with the exception that this process should be applicable to toxic chlorinated aromatics and that it requires low energy. Calcium hydride and calcium metal are very reactive and would require special handling. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 51 of 119 Application for Vietnam: As information is presently limited and because of the potential by-products generated, this technology is not recommended. 2.8 Bioremediation Biological processes can degrade contaminants using both non-enzymatic and enzymatic reactions brought about by micro-organisms. Enzymatic reactions bring about the most significant changes in the chemical structure of these compounds. The term "biodegradation" is often used to describe a variety of quite different microbial process that occur in natural ecosystems, such as mineralization, detoxification, co-metabolism and activation. The breakdown of organic compounds is undertaken by bacteria, yeasts, actinoycetes, fungi and other micro- organisms (Riser-Roberts, 1992). Bioremediation processes require the addition of nutrients to speed up processes in which micro-organisms breakdown organic contaminants into harmless compounds. Chlorinated compounds are generally resistant to bioremediation and PCBs particularly so, largely due to their insolubility which slow biodegradation. Both aerobic and anaerobic microbial metabolism have some biotransformation affects on PCBs. PCBs chlorinated with four or more chlorine atoms are resistant under aerobic conditions. What degradation that does occur is achieved though a number of select organisms. Higher chlorinated PCBs are only hydroxylated and not dehalogenated with the potential for degradation decreasing with the degree of chlorine substitution. The complete degradation of PCBs is complex with various microbial strains having distinct congener preferences. No confirmation of the aerobic degradation of Aroclor 1260 exists (Cookson, 1995). Under anaerobic metabolism, the degree of dechlorination decreases with the number of substituted chlorine atoms and it is influenced by the position of the chlorine atom. There are different microbial species capable of anaerobic dechlorination of PCBs. Effects vary from site to site indicating that select microbial seeding may promote degradation. The availability of electron acceptors appear to limit degradation (e.g. sulphates inhibited PCB degradation). Fungi (yeasts and filamentous) have the non-specific enzyme systems for aromatic hydrocarbons, including PCBs, and are thus more capable of biodegrading these chemicals than bacteria (Riser-Roberts, 1992). White rot fungi degrades lignin, a natural polymer which gives strength to wood. The lignin degradation enzyme system of white rot fungi is extra-cellular and unusually non-specific. This attribute has been shown to be effective in treating a number of hazardous contaminants, including all congeners of PCBs (Aust and Benson, 1993). The most effective biodegradation of PCBs occurs under a sequential anaerobic-aerobic treatment system. The anaerobic step would remove chlorine atoms that limit aerobic degradation yielding dehalogenated products with significantly less chlorine substitution. These would respond more favourably to aerobic degradation, for example, aerobic-resistant Aroclor 1260 would be dechlorinated to allow aerobic degradation. Bioremediation techniques have been implemented varying degrees of success primarily in the USA but also Japan and the Netherlands. Of 17 projects listed by Hines (http://horticulture.coafes.umn.edu/vd/h5015/99fpapers /hines.htm), PCB concentrations decreased between 10% and 98.5% using a variety of techniques including natural attenuation (7), biostimulation (6), landfarming (2) and boil-slurry reactors (2). I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 52 of 119 2.8.1 Anaerobic / Aerobic Composting This technology employs anaerobic and aerobic cycles to bioremediate contaminated soil and includes variants of land farming or land spreading. It uses the indigenous microflora associated with the contaminated soil under controlled environmental conditions. The waste can be seeded microorganism inoculants (such as white rot fungi) if desirable. An environment with high levels of nutrients is created by the addition of manure, straw or similar material. The desired conditions of temperature, oxygen, pH and nutrient availability must be maintained. Key operating parameters of the process include a pH of 5 to 9, a residence time of typically six months, temperatures of 35 to 60°C and a moisture content of 30 to 90%. The anaerobic cycle is started by covering the contaminated soil pile with a tarp. Aerobic conditions are created by either mechanically mixing or by injecting compressed air. This technology is proven and commercially available (e.g., Xenorem). Destruction efficiencies of 90% have been demonstrated for chlordane, dieldrin, toxaphene and DDT in soil. Considering the chemical similarity between the POPs that were destroyed in demonstrations and all other POPs, it is expected that anaerobic / aerobic composting should have a destruction efficiency of 90% for all POPs and 85% for PCBs. The technology was proven to be effective on high strength pesticide-contaminated soil. Excavating, screening and mixing materials are required. Nutrients, a tarp cover, and possibly a warehouse are also needed to prevent washing of the waste by rainwater. Relatively low levels of energy are necessary compared to the other technologies (energy only required for air injection). The groundwater table in the operating area must be protected from contamination. Potential odour issues must be evaluated and measures taken for their control. Monitoring of groundwater and air throughout the operations is needed to ensure that acceptable levels are maintained. To our best knowledge, there is low risk to the environment and humans. Qualified technical personnel are necessary to operate the system. Highly qualified personnel are necessary for soil and groundwater characterization and follow-up, controlling analytical methodology and maintaining anaerobic / aerobic conditions. Considering the process technology, there is low potential for worker exposure. The technology is recommended for high and low concentration PCBs in soil. It should also be suitable for PCBs in sediment and sludge. With qualified personnel and available space and time, anaerobic / aerobic composting is suitable for all areas. Application for Vietnam: In specific circumstances, such as the large quantities of soil contaminated with low concentrations of PCBs, this technology could be applied. Its potential for application is limited and it does not represent a significant multi-media solution. 2.8.2 Enhanced Bioremediation: In-Situ This technology stimulates biodegradation in soils by enhancing the primary limiting factors for such processes. The most common limiting factor is oxygen which is delivered by forced air movement (either through extraction or injection of air) in unsaturated soil or by adding oxidants in saturated soil. The former is generally termed "Bioventing" and its technologies have been successfully used to remediate soils contaminated by petroleum hydrocarbons, non-chlorinated solvents, some pesticides, wood preservatives, and other organic chemicals. The successful application of this technology for PCBs is limited. Factors that may limit the effectiveness of the process include: I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 53 of 119 A water table within several feet of the surface, saturated soil or low permeability soils reduce bioventing performance; Vapours can build-up in basements within the radius of influence of air injection wells; Extremely low soil moisture content may limit biodegradation and the effectiveness of bioventing; Aerobic biodegradation of many chlorinated compounds may not be effective unless there is a co- metabolite present or an anaerobic cycle; and Low temperatures may slow remediation. The time required to remediate a site using bioventing is highly dependant upon the specific soil and chemical properties of the contaminated media. The applicability of this method to PCBs is low and should be reviewed case by case. A likely scenario for application is an extremely large area of soil contaminated with low concentrations of PCBs in an area that is not subject to development pressure. In such a scenario, treatment times to decrease PCB concentrations to within acceptable limits could be years. Such a system could be run autonomously with only periodic inspections and maintenance. The second approach for the saturated soil environment involves injecting time-released oxidants to groundwater to promote aerobic degradation. The oxidants can be released in wells, trenches or at gates in sheet-pile isolation units. For successful application, the source of PCBs, soil conditions and groundwater must be well understood. Such a system can be applied only in very specific situations and evaluated on a case by case basis. As with bioventing, treatment times should be expected to require years to reach a successful conclusion. Application for Vietnam: While in-situ bioremediation measures may be of use at some PCB-contaminated sites in Vietnam, its potential for application is limited and it does not represent a significant multi-media solution. 2.8.3 Biological Reactors This technology involves the controlled treatment of aqueous wastes and slurries (including soil, screened and mixed with water to 10 to 30% solids by weight) in a reactor vessel mixed with oxygen (for aerobic reactors) and micro-organisms as well as an acid or alkali to maintain pH. The reactors either act as batch or continuous processes. If slurries are treated, the resulting solids must be dewatered. For PCBs, sequential reactors of anaerobic followed by aerobic treatment are required. Co-metabolites may improve treatment performance. Bioreactors are favoured over in situ biological techniques for heterogeneous soil, low permeability soil and areas where underlying ground water constrain treatment. Bioreactors have faster treatment times than in situ bioremediation methods. As with other bioremediation processes, PCB treatment is difficult and the process should only be considered where PCB concentrations are low. PCBs are hydrophobic, tending to adsorb to soil particles, making them relatively unavailable for microbial treatment. If oil is present in the waste, it should be separated prior to entering the bioreactor as PCBs will preferentially adsorb to the soil and the oil may foul the reactor. "Although a commercial technology has not been marketed for the bioremediation of PCBS using such an approach, it has been field tested in the U.S. by General Electric, ALCOA, Envirogen Inc, Oak Ridge National Laboratory, The USS EPA and several academic institutions" (Hines). Research continues in this area with new microbial inoculants showing some promise (Toro, et al, 2005). I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 54 of 119 Application for Vietnam: Because such systems are not commercialized and have had modest to limited success in field trials, this technology is not recommended for application in Vietnam. 2.8.4 Phytoremediation Phytoremediation is based on the use of growth in polluted soils to enhance bioremediation. Two approaches use plants for the phytoremediation of organic contaminants, the first being phytodegradation. This is the breakdown of organic pollutants within the plant by the actions of enzymes produced by the plant. Organic compounds are degraded into simpler molecules and are incorporated into the plant tissues. Soil aeration is improved by the roots, stimulating aerobic biodegradation processes. The second approach is rhizodegradation; the breakdown of contaminants in the soil surrounding the roots by microbial activity enhanced by the plant root. This is a much slower process. The phytoremediation process can be enhanced by adding compost or by the use of fungi in the root zone. The possible conversion of organic pollutants in the plant into more volatile organic pollutants released to the atmosphere by the leaves is called the phytovolatilization process. That effect should be considered and evaluated if phytoremediation is selected. The harvesting of the plants requires post-treatment (may be used for energy or chemicals production). Phytoremediation may require chemicals, nutrients and water management. No energy is required except during harvesting. Several different types of phytoremediation are being used already commercially. Phytoremediation is a promising technology for the remediation of large soil areas diffusely polluted. Experience from lab-scale research to large-scale field trials have been obtained with PCBs and pesticides in soils and sediments. Because PCBs are resistant to bioremediation, successful phytoremediation has been limited. A demonstration project in the US for a scrap yard contaminated with fuel and PCBs (225 ppm) was planted with bermuda grasses and red mulberry trees. Over a 2 year period this 2 acre site had PCB contamination dropping by over 90% (USEPA 2005). For PCBs, this is technology is in the research stage with no commercial application anticipated in the near future (no summary sheet provided for this reason). Application for Vietnam: Such systems are not commercialized and have had modest to limited success in field trials, therefore, this technology is not recommended for application in Vietnam. 2.9 Other Methods 2.9.1 Long Term or Permanent Storage Although this report focuses on the destruction of POPs, some issues have been raised regarding their disposal. A number of options for land disposal of hazardous wastes in general, radioactive materials, and other materials of concern have been examined in many contexts such as: · Secure landfill (isolated with liners, potentially including leachate collection); · Subterranean storage in natural, stable formations such as salt domes; and · Subterranean storage in prepared caverns in geologically stable zones. Essentially, storage means the destruction of PCBs is delayed for the future. Generally speaking, long term storage or permanent storage of POPs is unpopular with environmental regulators and local citizens, however, some commercial operations exist (Germany). More commonly, project-specific temporary, although long-term, soil storage mounds, contained with liners, have been used for low-concentration PCB-contaminated soil (less I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 55 of 119 than 50 µg/g). This is particularly common in remote areas or where large volumes of soil preclude economically viable treatment. Given a well thought out design, a restricted waste category (PCBs as only the only contaminant present) and a supportive general public, such approaches may be possible. The likelihood of meeting these criteria is not high. Application for Vietnam: This approach does not comprise PCB destruction: it delays work into the future with a risk of release until finally remediated. On a case-by-case basis, there may be some applications for solid waste with low concentrations PCBs. 2.9.2 Mechanochemical Dehalogenation (Ball Milling) Mechanochemical dehalogenation is accomplished by mixing waste material with chemical reagents in a ball mill. The process relies on the energy released at the point of collision between balls in the mill to activate a reaction between the waste and CaO (lime) or reagents, which are base metals (magnesium, sodium, aluminium, iron or alloys) and hydrogen donors (alcohols, amine, polyether and so forth) to break down the organochloride compound into a harmless inorganic chloride. The whole process may be characterized as a reductive dehalogenation promoted under mechanochemical conditions. The process operates at low temperature therefore reducing the potential for dioxin formation. No gaseous emissions are produced. The process may be combined with or may be used in addition to, other common remediation processes like soil washing or biological degradation. In fact, diluted wastes would preferably be concentrated prior to destruction with the ball mill. Some other pre-treatments may also be required depending on the contaminant and the matrix to be treated such as crushing, screening and drying. The water contained in the material inhibits the reaction between the contaminants and the reagents decreasing the efficiency of the process. At present, this technology is at the pilot scale, only even though reports from Tribochem states that scaling-up is currently underway. The process has not been commercialized so far due to two major reasons. First, some approaches generate/leave numerous intermediates and degradation products, still partly halogenated, associated with unknown, but evidently potential toxicological risk. Second, reaction times range between several hours to even days. New approaches are being investigated to reduce the time of reaction to only a few hours for PCBs. A possible way of doing this is by changing the hydrogen donor from alcohols to amine. Some reported efficiencies for PCB tests range from 20 to 99%. Excess magnesium is often required to achieve complete dechlorination. This process can be used to destroy all halogenated pollutants in general, such as PCBs, dioxins, dibenzofurans, PCP, insecticides (DDT, HCH, lindane, dieldrin), CFC, chlorinated solvents and halogenated chemical weapons. The contaminants could be found in the following treatable matrices: solid, solid/liquid and liquid contaminated material or as pure contaminants. This technology can be implemented in relatively small plants and can be set up as mobile units. Using a ball mill in the process requires low energy amounts compared to other processes. On the other hand, as mentioned above, the time required and the incomplete decontamination of the material constitutes major disadvantages and concerns regarding health and safety. Also the handling and storage of base metal and other chemicals require highly trained personnel with strong security procedures and even then it still is a cause for concern. Therefore, for these reasons, this technology is not recommended. Application for Vietnam: This technology is not commercialized and is therefore not recommended for application in Vietnam. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 56 of 119 2.10 Summary Task 1 Technology Evaluation UNEP's "Review of Emerging, Innovative Technologies for the Destruction and Decontamination of POPs and the Identification of Promising Technologies for Use in Developing Countries", GR/8000-02-02-2205 (January 2004) specified a number of principles adopting POP destruction technologies in developing countries. While the focus of the review was POP pesticides, the general concepts can be applied to PCBs as is shown below (POP substituted for PCBs). · Quantify and locate all PCB stockpiles; · Quantify and locate all PCB-contaminated soil (contaminated sites); · Consider the stockpiles and contaminated soil independently of each other (they are inherently different with different constraints); · The Destruction Efficiency should be greater than 99.99% (even higher is desirable for PCBs); · Only closed processes should be considered; · The technology must be inherently safe; · The process must be able to handle upsets, such as a power supply failure, without damage to personnel or equipment; · Handling and loading of waste material into the process must be safe, straightforward and controlled; · Equipment and controls must be simple and robust; · Operating procedures must be simple and clear; · Loading, unloading, start up and shut down must be straightforward; · The process should be able to handle waste in a variety of forms; and · The process should be able to handle a variety of contaminants, PCBs being just one. This is an extremely onerous list of requirements, however we recommend the following technologies which meet most of them. Soil and Soil-like Materials Anaerobic / aerobic composting; Based catalyzed decomposition process (BCD); Cement kiln co-processing; Enhanced bioremediation (in situ); Gas Phase Chemical Reduction (GPCR); Incineration (mobile plant); In-situ vitrification; and Plasma arc decomposition (Plascon, Pact process). Water and Aqueous Solutions Advanced Oxidation Process (AOP); Base catalyzed decomposition process (BCD); Gas Phase Chemical Reduction (GPCR); TiO2 enhanced photocatalysis (Photo-Cat, Purifics); and Wet Air Oxidation (WAO) technology, low concentrations only and requires successful waste tests. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 57 of 119 Sediment, Sludge and Slurries Base catalyzed decomposition process (BCD); Cement kiln co-processing; Gas Phase Chemical Reduction (GPCR); Plasma arc decomposition (Plascon); and Wet Air Oxidation (WAO) technology, low concentrations only and requires successful waste tests. Oily Phase and Organic Liquids Alkali Reduction including sodium; Base catalyzed decomposition process (BCD); Gas Phase Chemical Reduction (GPCR); Incineration (mobile plant); Plasma arc decomposition (Pact process); and Wet Air Oxidation (WAO) technology, low concentrations only and requires successful waste tests. Solid Waste and Electrical Equipment Base catalyzed decomposition process (BCD); Gas Phase Chemical Reduction (GPCR); and Incineration (mobile plant). Once the quantity and location of wastes are better defined and stakeholders consulted, a more detailed technology selection process can begin that includes social, economic and political considerations, as well as technical issues discussed in this report. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 58 of 119 3.0 TASK 2: IN-COUNTRY POTENTIAL DESTRUCTION TECHNOLOGIES An assessment of potential PCB-destruction technologies was undertaken between April 23 and May 4, 2007 by an assessor, Mr. Edward Lloyd, P.Eng., of SLI's Toronto Office, assisted by an "in-country expert" (see below). The organizations selected for investigation were identified by MONRE, the World Bank in their earlier in- country reconnaissance missions, from published literature (UNEP, 2004) and from recommendations by the in- country expert engaged by SLI. Five organizations were interviewed as follows: · Center for Environmental Treatment Technologies, Chemical Military Headquarters (portable incineration); · Center for Environmental Protections and Consultation (consultation for technologies); · Vietnamese Academy of Science and Technology (sodium destruction of transformer oil); · Holcim (Vietnam) Ltd. (cement kiln co-processing); · Urenco (Incineration). The findings of the interviews with each organization are described in the following sections. Photographs taken at the facilities and background information acquired are included in Appendix D. In-Country Expert In order to facilitate access to Vietnamese organizations, an in-country expert was engaged by SLI. Dr. Nguyen Thi Kim Thai (henceforth, Dr. Thai), Head of the Environmental Technology and Management Department of the Hanoi University of Civil Engineering (HUCE), was selected from a short list of candidates provided by MONRE. Dr. Thai worked with MONRE to obtain the required permission to interview each organization and then organized the meetings. During the meetings, she described the project and acted as a translator throughout the process. Dr. Thai continued to provide follow-up information after the Task 2 Mission was complete. 3.1 Center for Environmental Treatment Technologies The Vietnamese military maintains a Centre for Treatment Technologies (CTT) under the Chemical Military Headquarters (CMH). This organization has undertaken the destruction of pesticides in small, portable incinerators in a number of provinces including Lang Son, Ha Tay, Hanoi, Thai Binh, Ha Nam, Quang Ninh and Hoa Binh. At the time of the Task 2 Assessment, the equipment is currently in use in Tien Win, Thai Nguyen Province but was not available for inspection. The Deputy Director, Mr. Lam Vinh Anh and the Head of Planning, Mr. Nguyen Dac Duaong, met with Mr. Lloyd and Dr. Thai to discuss their technology (April 26, 2007). The mandate of the Center for Treatment Technologies is to conduct studies and research on toxic chemicals that have been used in wartime. This includes developing destruction technologies for the treatment of chemical residuals, for example, for dioxin residuals from the application of defoliants used in the American War (1959 to 1975). The Centre has conducted some research for the treatment of other hazardous wastes as well. Since 1999, the Center has destroyed over 300 tons of packaged pesticides that were designated as requiring urgent management. They have cleaned up, on average, two sites each year, each with an average of 20 to 30 tons of waste pesticides. The work has been in collaboration with VEPA and provincial officials, who have participated in test-burns and the approval process. Before operation, a background environmental assessment is I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 59 of 119 conducted and then followed-up with a post-assessment so that any negative impacts can be identified. To date, no significant impacts have been identified. The portable incinerator has a capacity of 20 kg/h and comprises two primary burning chambers, one with temperature between 400ºC and 600ºC and the other between 900ºC and 1,000ºC. This incinerator is used to burn pesticides in powder form, after being mixed with catalysts, as well as liquid pesticides. Another modular incinerator handles solvent based pesticides and a third, waste packaging. The end-product of the incineration process is gaseous products of combustion (H20, CO2, CO and others depending on inputs) as well as ash. The solid residue, comprising ash, is tested to verify that all toxic constituents of the waste pesticides have been destroyed, and is then landfilled. Air emissions are treated by absorption/adsorption technology or catalytic oxidation. Liquid generated from the off-gas treatment is also subject to treatment before discharge. Air emission testing conducted during the operation of the incinerators includes the parameters H2S, CO, HCN and SO2. Occasionally dioxins and furans are tested by the Russian-Vietnamese Tropical Center. Testing was also conducted to determine the destruction efficiencies observed which varied widely depending on the pesticides undergoing incineration (75% to 90%+). As the incinerator moves to waste pesticide collection centers of each province, the portability can be assessed by the following standard schedule: · Set-up: 5 days; · Typical Operation: 15 days based on 12 hours of operation per day, 4 shifts of personnel (averaging 500 to 700 kg/day at this rate); · Disassembly: 3 days. The equipment is large and its transport through Vietnam is difficult (the transportation network in the country is poor and extremely congested). Extensive maintenance is required after the operation of the equipment at each waste pesticide collection site. Corrosion from the acidic gases emitted from the catalytic oxidation off-gas treatment system requires extensive refurbishment. The Centre has a larger open flame incinerator with a capacity of 50 kg/h, however, the pesticides must be crushed to a powder before they can be destroyed in this equipment. The research conducted by the centre is not limited to incineration but also includes physical, chemical and low- temperature thermal treatment approaches. For example, the pesticide DDT was destroyed using low temperature thermal oxidation of soil with the gas-phase being treated by catalytic oxidation. Catalytic oxidation agents are being assessed. The Center is also designing and planning containment cells to store dioxin-contaminated soil in three provinces. They have constructed containment cells with off-gas treatment for destroyed domestic fowl with avian flu. Although they have not undertaken any work involving the treatment of PCBs in any media, they are interested and feel they have the technical capacity to handle such work based on their other projects. Four years ago, they had been asked by a company in Hanoi to develop procedures for the treatment of PCB oil but the company found their proposed costs to expensive to implement. With respect to the data required by the World Bank, the information is summarized below: Capital and Operating Costs: As the incinerators in operation have been designed to treat only packaged pesticides and a similar system for treating PCB wastes would be significantly different, no capital or operating I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 60 of 119 costs were available from the Center. The burning zone would require a much higher temperature for PCB waste than the pesticides currently being destroyed. More information would be required for the Center to design and estimate the costs of a portable PCB-destruction system. Human Resource Requirements for Operations: Similar to the above, without an operating system, this assessment could not be performed. Environmental Performance and Monitoring Requirements: Similar to the above, without an operating system, this assessment could not be performed. It would be expected that the environmental and monitoring requirements would be similar to those that will be undertaken by Vietnam's first PCB destruction facility, the Holcim Cement Kiln. Health and Safety Performance and Monitoring Requirements: Similar to the above, without an operating system, this assessment could not be performed. It would be expected that the health and safety performance and monitoring requirements would be similar to those that will be undertaken by Vietnam's first PCB destruction facility, the Holcim Cement Kiln. 3.2 Center for Environmental Protection and Consultation The mandate of the Center for Environmental Protection and Consultation (CEPC) is to organize and coordinate leading scientists and specialists for scientific and technological research and development and services. On April 26, 2007, Mr. Lloyd and Dr. Thai met with Dr. Nguyen Van Lam, the Deputy Director of the CEPC. As the CEPC were in the process of moving their offices, there were no facilities to inspect. Dr. Lam indicated that their organization was the equivalent of a consulting company and although they did not have hazardous waste- destruction equipment (for PCBs or any other waste), they did work with organizations who did have such facilities. CEPC has been involved with three pilot treatment demonstrations for POPs including PCBs as follows: · Incineration: Small scale, low temperature (130ºC to 140ºC) incineration with long residence times that achieved destruction efficiencies of 92.5%. · Sodium Treatment of Oil: A 50 kg capacity batch process described in more detail in the next section. The system is known as "Na-Tech". · Molten Sodium Treatment of Pesticides: This chemical treatment process was conducted in cooperation with the Thyssen Company and under the supervision of MONRE in 2002. This process would not be applicable to PCB treatment (pesticides only). Dr. Lam showed a number of reports (in Vietnamese with no copies available for distribution) that included a "Survey and Inventory of Hazardous Waste from the Handicraft Industry" (Hanoi, 12/2004). In this report, the generation of dioxins, furans and PCBs from this sector was examined. Based on this study and other work conducted by CEPC, Dr. Lam feels that the only viable options for domestic PCB waste treatment are the sodium treatment of waste soil and the cement kiln co-processing offered by Holcim (see subsequent section for more details). CEPC is participating in the first test burn to be conducted at Holcim (later this year). With respect to the data required by the World Bank, the information requested cannot be supplied without an operating system. As CEPC performs consulting-type services and does not directly undertake PCB destruction, elements related to costs, human resources, performance and monitoring (health, safety and environment) cannot be evaluated: I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 61 of 119 3.3 Vietnamese Academy of Science and Technology On May 2, 2007, Mr. Lloyd and Dr. Thai met with Dr. Pham Huu Ly, the Head of the Laboratory for Clean Materials and Technology of the Vietnamese Academy of Science and Technology. This organization is involved in the research and development of a number of technologies including: · Enhanced bioremediation of dioxin in soil using slow-release fertilizers and oxidizers (providing the enhancing agent and slow-release products); · Sodium and potassium treatment of PCB-containing dielectric fluids designated as Na-Tech. The latter technology falls directly within the scope of this technical assessment. To date, Na-Tech has one pilot scale back system with a capacity of 200 kg per batch which treats transformer oil over a period of 8 hours. The system is mobile and the cost for treatment is approximately $5,000 USD/h. The pilot scale system is operated above the boiling point of sodium (98ºC). The destruction efficiencies that have been met by their pilot testing have been limited to 30 to 40 µg/g from starting concentrations in the 10,000 to 12,000 µg/g range. They have been unable to match the claims of providers of similar technologies in achieving 2 to 3 µg/g end-point concentrations. The system is for research with efforts focused on developing fine dispersion of sodium into the oil and by examining the potential for potassium to be used with sodium to improve destruction efficiencies. Preliminary results using these alternatives have shown significantly improved destruction efficiencies. Although the technology is now limited to pilot scale operations, the Academy would like to see this technology developed and implemented as full scale commercial operations. With respect to the bioremediation of dioxin contaminated soil, the biotechnology center at the academy has developed the process described above and is conducting trials at a former US military base in Bien Hoa. The trials are to be undertaken over a two year program. To support the research and technology development work, the Academy has a gas chromatograph mass spectrophotometer (GC-MS). Supplied by a US-founded program, the GC-MS regularly undertakes the analysis of various media for both PCBs and dioxins. With respect to the data required by the World Bank, the information is summarized below: Capital and Operating Costs: The operation comprises a bench-scale research system and is not commercial. Capital and operating costs were neither available nor applicable for use to meet the project needs. Human Resource Requirements for Operations: The research conducted at the Institute will help train those who can become involved in the elimination of PCBs from Vietnam. It may be useful for MONRE to work with the Institute to develop a program that would be complimentary to the PCB elimination project. Environmental Performance and Monitoring Requirements: There are no environmental performance and monitoring requirements for the research activities conducted. Health and Safety Performance and Monitoring Requirements: There are no health and safety performance and monitoring requirements for the research activities conducted. The handling of elemental sodium and potassium is hazardous and carefully planned safety measures are in place. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 62 of 119 3.4 Holcim Cement is made by heating limestone with small quantities of other materials to 1450ºC, an energy intensive process. As mentioned in the previous section, the high temperatures, long residence times and various other issues make the co-processing of organic hazardous waste in cement kilns a viable treatment technology. Holcim, a cement manufacturer, is offering this option at many of their plants world-wide and considers this initiative an important element of their sustainable development strategy. The following is a description of Holcim Ltd. based on excerpts from their corporate website and documents provided from this source. It is followed by a description of Holcim Vietnam from similar sources and finally by observations made during the in-country site reconnaissance. Holcim: Corporate Holcim is one of the world's leading suppliers of cement and aggregates (crushed stone, sand and gravel) as well as further activities such as ready-mix concrete and asphalt including services. The Group holds majority and minority interests in more than 70 countries on all continents, and employs some 90,000 people. In 2006, Holcim recorded sales of over 23 billion Swiss Francs ($20 billion USD). Holcim was founded in 1912 in the village of Holderbank, Canton Aargau in Switzerland. From an early stage it became clear that the domestic market could offer only limited opportunities for expansion. By the early 1920's the company began investing in cement businesses in other European countries. This trend was quickly followed by investments in Egypt, Lebanon and South Africa. In the years following 1945, and particularly in the 1950s and 1960s, a network of holdings began to develop in North and Latin America. In the 1970s, ventures in the emerging markets of the Asia-Pacific began. In the 1980s, Holcim continued to expand into new markets, including Eastern Europe. A greater focus on aggregates and ready-mixed concrete production strengthened the company's position as a vertically integrated market leader. A strong focus on core business activities in cement, concrete and aggregates characterized Holcim activities during the 1990s. Entry into new markets, particularly within Asia, expanded opportunities for the Group. The name of the Group was changed from "Holderbank" Financière Glaris Ltd to Holcim Ltd in May 2001. Today, the international presence of Holcim consists of a balanced mix of companies in industrialized and emerging markets. Sustainable Development Holcim has implemented their sustainable development program across the "triple bottom line" (economic, environmental and social), thus embedding sustainable development in their vision, strategy and management systems. Sustainability priorities are: · Occupational health and safety: improve performance; · Climate and energy: reduce emissions and ecological footprint; · Community involvement: maintain their "license to operate" (earn and keep the support and trust of local residents); · Stakeholder relations: work with a variety of stakeholders; and · Sustainable construction: assure a more efficient and sustainable use of their products. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 63 of 119 Holcim and the World Business Council for Sustainable Development Holcim initiated the World Business Council for Sustainable Development's member-led Cement Sustainability Initiative (CSI) in 2000 together with two industry colleagues. The CSI now represents more than half the worldwide industry outside of China (with 16 companies operating 619 cement kilns worldwide). In 2002, the Cement Sustainability Initiative launched "Our Agenda for Action", a five year work program translating the insights from the research phase of the initiative into concrete action. Work is continuing on both collective and individual company bases. Six task forces oversee the main areas of action which are climate protection, fuels and raw materials use, employee health and safety, emissions reduction, local impacts and communications. The 2005 interim report described progress against each of the six key action areas (WBCSD, June 2005). Holcim: Responsible Use of Fuels and Raw Materials The cement industry is engaged in industrial ecology where the byproducts of one industry become the inputs for another. Cement kilns can recover and use many industrial byproducts and other materials, some being incorporated into the final product while others are used as fuel, decreasing the demand on traditional fuels. In some countries such as Norway, Switzerland and Japan, cement kilns play an important role in waste management and hazardous waste disposal (WBCSD, December 2005). Because cement manufacturing is energy and resource intensive, the WBCSD's CSI recognize a need to conserve both of these key elements. In their document, the "Guidelines for the Selection and Use of Fuels and Raw Materials in the Cement Manufacturing Process" (WBCSD, December 2005), adopted by Holcim, The WBCSD has defined a consistent approach to the selection and use of fuels and raw materials in the cement industry, built upon the principles of sustainable development. Furthermore, Holcim, in a public-private partnership with Deustsche Gesellschaft für Technische Zusammenarbeit GmbH (GTZ), developed a more expansive and detailed document for co-processing entitled "Guidelines on Co-processing Waste Materials in Cement Production" (GTZ-Holcim, 2006). Although addressed to stakeholders and decision-makers form the private and public sectors engaged in waste management and cement production, the document's focus is on developing countries and countries in transition. The objectives of the document are to provide objective and relevant information about the co-processing of waste in the cement industry with respect to the following elements: · technical and legal conditions; · environmental, safety and health standards; and · professional requirements required to ensure co-processing does not have negative environmental or human health impacts. The GTZ-Holcim Guideline is the basis on which Holcim is implementing their waste co-processing system in Vietnam. The effective and environmentally sound approach for the use of alternative fuels and resources (AFR), such as PCBs-contaminated oil and steel mill slag, in cement kilns includes the following key best practices: I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 64 of 119 · Implement a well-defined and carefully communicated policy on the use of AFR which identifies unacceptable materials; · Effective systems for emissions monitoring and reporting; · Effective engagement of local stakeholders; and · Well-defined processes and procedures for handling AFR. Holcim has developed corporate procedures to facilitate such practices and has created a corporate department to provide technical resources to support their implementation. Holcim: Vietnam In Vietnam there are 13 rotary kiln cement plants and 49 vertical kilns and 6 transformed rotary kiln plants. The proportion of plants using the more efficient dry production method is 66%, with the balance being wet or semi- dry methods. Under the Cement Sectoral Development Strategy, 40 cement factories with rotary kiln technology are under construction and 21 vertical kiln projects will be transformed into rotary kilns. Holcim and the Vietnamese National Cement Corporation, in a joint venture, constructed an integrated cement manufacturing plant in Hong Chong (southwest Vietnam). Beginning operation in 1997, the Hong Chong plant comprises 5.6 km2 with a dry suspension preheater rotary cement kiln equipped with a precalciner that has an installed annual capacity of 3.6 million tones of cement and 120,000 m3 of ready-mix concrete. The plant was designed to meet the highest international standards and was considered a best available technology plant (IPPC, 2001). In the south of Vietnam, limestone is rare, therefore the plant was located in an area with karst formations and sandstone hills rising from the coastal plane in Kien Giang province. Holcim Vietnam also operates a storage, blending and dispatch terminal at Cat Lai (near Ho Chi Minh City) and the Thi Vai clinker Grinding Plant located in Ba Ria Vung Tau. These three facilities are linked through the operation of two 8,000 ton dedicated coastal transport vessels. Holcim Vietnam Site Reconnaissance The reconnaissance of the Holcim facilities in Vietnam comprised a meeting with the Director of Business Development, Paul Hayes, in Hanoi followed by a tour of the Cat Lai terminal in Ho Chi Minh City. Mr. Hayes is in charge of the AFR program. The cement plant in Hon Chong could not be toured as Mr. Hayes was not available over the time period, however he provided extensive information and photographs regarding its operation. The Thi Vai Grinding Plant does not have AFR facilities. Hon Chong Cement Plant The dry kiln was designed to receive alternative fuel and resources including hazardous waste. Maintaining a stable temperature in the kiln is required to process cement. Due to the latent heat inherent in the massive kiln, changes in temperature generally occur slowly. A computer system directed from the control room maintains the system in a fine balance of ideal conditions. The feed point of AFR depends on the composition of the materials. Alternative fuels are generally introduced in the high-temperature combustion zone of the kiln system such as the main burner, the precalciner burner or the secondary firing at the preheater. Alternative fuels with highly stable molecules, such as chlorinated compounds and particularly PCBs, should be introduced at the main burner to ensure complete combustion. The main burner maximizes high temperatures and long retention times. The hazardous waste is introduced through an atomizer I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 65 of 119 nozzle with compressed air. The hazardous waste is introduced at a slow rate measured by a sensitive flow meter with no moving parts. The injection is monitored and adjusted from the control room of the kiln. Other feed points are appropriate only where test have shown high destruction and removal efficiency rates (WBCSD, December 2005). At the Hon Chong facility, solid non-hazardous alternative fuel is generally added at the precalciner while pesticides and most hazardous wastes are added at the main burner. PCB waste would also be added at the main burner if the planned test burn is successful and approvals are provided by the Vietnamese regulatory authorities. Occasionally and after a successful evaluation, small quantities of packaged solid pesticides are introduced at the precalciner (case-by-case basis). Security at the facility is substantial. The site is entirely fenced and includes 19 security stations and a staff of 120 guards working in shifts so that security personnel are always present at the site. Non-Hazardous Waste Non-hazardous waste used as alternative fuels comprises two main sources, rice husks (approximately 25,000 tonnes) and non-hazardous industrial waste (approximately 8,000 tonnes). The non-hazardous industrial wastes largely comprises scrap materials from the textile industry. Hazardous Waste MONRE has permitted the Hon Chong facility to dispose of ten waste categories. Hazardous waste makes up between 20% and 25% of the alternative fuels received from industrial establishments and used at the facility (based on the quantities processed over the last two years). In 2006, approximately 2,500 tonnes of hazardous waste was destroyed. Although the rate of receiving waste has stabilized, the waste types are continuously changing. The majority of hazardous waste received on a regular basis is sludge and filter cake which are added at the calciner. In addition, the disposal of paint waste, rags and empty packaging is also undertaken. Small quantities of pesticide residues have been destroyed. Most of this waste material comes from industrial plants. Receiving and Evaluation Before receiving any AFR, Holcim conducts an extensive evaluation process so that they understand the composition of the waste and its impact on the kiln system, product and emissions. For every waste type, a plan is prepared to assess any risks that may arise. Holcim requires any material information (such as Material Safety Data Sheets) followed by representative samples of the waste. The samples are assessed in their in-house production laboratory and at a third-party commercial laboratory (SGS Laboratories in HCMC is commonly used, as well as Case and Quatest). Parameters assessed at their production laboratory include calorific value, water content, density, flashpoint, chlorine and sulphur. Commercial laboratories are used to test samples for the presence of heavy metals including mercury. The commercial laboratories comply with international standards such as ASTM and participate in a round-robin assessment. Holcim is planning on commissioning additional laboratory equipment at the Cat Lai terminal including a gas chromatograph (GC) and an Induction Coupled Argon Plasma (ICP) Spectrometer for the analysis of metals and other key compounds. Once the waste has been assessed, contracts are signed. Upon delivery, each shipment of the waste must meet the specifications developed during the shipment and stipulated in the contract. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 66 of 119 Transport, Storage and Handling Due to its proximity to Ho Chi Minh City, the Cat Lai Terminal is the principal gathering point for both hazardous waste intended for destruction and nonhazardous waste intended for use as alternative fuel. Two facilities have been designed and constructed to store and handle these materials, one dedicated to hazardous waste and the other to nonhazardous waste. Similar facilities have been constructed at the Hon Chong plant. The hazardous waste storage compound at Cat Lai is fenced within the facility and locked when no active work is taking place within. The hazardous waste compound is contained with storm water directed to a sump that has to be manually emptied. Within the compound, two buildings are present to store hazardous wastes. Both buildings are separately contained and have fire protection and foam suppressions systems installed. At Cat Lai, hazardous wastes are delivered by customers under an internal manifest system. The waste is sampled to confirm that it meets the agreed-upon characteristics. Sample assessment is done at Cat Lai (basic characteristics) or at a local commercial laboratory. The packaging is inspected (rarely has the packaging needed to be replaced) and then placed into Holcim's internal transport containers. These containers are steel boxes with steel lids that can store four to six drums of waste or filled with bulk bags. Approximately 40 containers are currently in service. The packaged waste is then loaded on to one of two vessels owned by Holcim. These vessels are large 8,000 ton sea-going bulk freighters which shuttle product from Hon Chong and the grinding plant to Cat Lai, making about 20 trips per month. On the deck of the vessels, fittings have been incorporated to lock the containers in place. The facilities and vessels have been inspected by Holcim's shipping insurance company, Lloyd's, and found acceptable to maintain insurance on the vessels. Waste is containerized and placed on the cement ship as soon as possible for transfer to Hon Chong. Upon arrival, the containers are stored in the hazardous waste compound at Hon Chong, pending the completion of the verification analysis. The waste is then scheduled for destruction with the kiln operations staff. Certification All the Holcim facilities in Vietnam, including the Hon Chong plant, have environmental management systems in place that are certified to ISO 14001. Furthermore, the facility has been audited and certified by CHEWMEG, an independent hazardous waste management facility auditing organization based in the US. This certification is used by over 200 US companies to verify that their contracted disposal facilities meet acceptable regulatory requirements and environmental practices. PCBs A few years ago, VEPA had asked Holcim took look into co-processing PCBs, but this was against Holcim's policy at the time so no assessment was performed (based on public perception, not technical capability). Subsequently, Holcim has revised their policy and now plans to co-process PCB-containing waste in the kiln. Holcim believe the market for PCB wastes is small in Vietnam with EPN Power Utility being the only enterprise with a significant inventory of PCB-containing wastes. The kiln system is capable of accepting contaminated soil, and therefore could taken PCB-contaminated soil. Soil is introduced into the system through the main burner in small quantities. Soil would have to be pre-screened to remove stones and be dewatered, potentially by adding sawdust or another absorbent combustible. Holcim has proposed to treat 10,000 tonnes of oil-contaminated soil from a site. With respect to the data required by the World Bank, the information is summarized below: I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 67 of 119 Capital and Operating Costs: Given that the primary purpose of the cement kiln is to make cement, this distorts direct application of capital and operating costs. Holcim representatives did provide costs charged to those clients requiring waste disposal. For hazardous wastes cost vary between $110/ton (USD) to $300/ton (USD) and is dependent on the quantity, complexity, calorific value and level of contamination. As Holcim is planning to add the destruction of PCB waste to their permitted activities, they have anticipated, yet not finalized the costs they will charge. It is anticipated to be greater than the range for other hazardous wastes and in line with international costs for treatment. Thus, they are anticipating costs in the range of $2 to $3/litre (USD) for the destruction of PCB waste liquids. Human Resource Requirements for Operations: As Holcim already operates a cement kiln, grinding plant, distribution terminal and a transportation system (both marine and road), a significant number of staff already exist to provide some support to waste collection, evaluation and destruction. The staff has been increased to meet the demands of waste management, particularly those presented by hazardous waste. Additional staff includes those required to perform the following: · verify waste characteristics in the laboratory; · manage and maintain the waste storage compounds in both Cat Lai and Hon Chong; · prepare package and secure waste for marine transport; · unload, store and prepare waste for the cement kiln; · assess the impact of waste on kiln operations and adjust accordingly; · inject and monitor waste destruction; and · overall management of the waste system including additional monitoring and reporting. Skilled workers are required to implement the program and a separate waste team has been defined. Training is on-going, supplemented by third-party training when available and supported by Holcim's extensive corporate resources. Records of all training activities are maintained by their Human Resources Department. Environmental Performance and Monitoring Requirements: Holcim conducts an impact assessment of the surrounding area annually in a few sampling events. Soil samples are taken and analyzed in addition to monitoring the ambient air. This is conducted in compliance with Vietnamese regulatory requirements which have been in force since 1995 and have been recently updated in 2006. Continuous emission monitoring for key parameters is undertaken (including volatile organic compounds). Four times per year an Australian specialty contractor conducts stack sampling at the facility. This enhances the regulatory requirement of three times per year. Tests for dioxins and furans are conducted during one of the stack testing events per year as required by their operating permit. Stack sampling has shown that the facility does not consistently meet nitrogen oxide (NOx) standards which has been traced to the hard coal used (anthracite). As all cement kilns use the same type of coal, this is a widespread problem in Vietnam. To resolve the issue, a catalytic converter with ammonia injection is being installed at the facility. As this has proved successful in Europe, Holcim feels this issue is well on the way to being resolved. Holcim provides MONTE with semi-annual reports identifying the waste types, quantities and sources of waste destroyed. All environmental monitoring results are also included. Relationship with Regulator Holcim maintains a cordial, cooperative and constructive relationship with both the national environmental regulators (MONRE and VEPA) and the regional authorities (DONRE). Holcim fosters this relationship by being I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 68 of 119 proactive when issues are identified, such as the NOx issue discussed previously, and by being transparent, thus establishing trust and confidence. MONRE has encouraged Holcim to implement co-processing at the facility. The Hon Chong facility has over thirty operations permits with only one related to waste management activities (hazardous and nonhazardous). Hazardous Waste: Test Burn of Pesticides This section is a summary of an article prepared by SINTEF and MONRE entitled "Environmentally Sound Destruction of Obsolete Pesticides in developing countries Using Cement Kilns" and appearing in the Environmental Science and Policy Journal in 2006 (ESandP, 2006). In 2003, the facility conducted their first test burn of hazardous waste. The test burn was conducted in cooperation with the Vietnamese authorities including MONRE and the affected DONREs. The following conditions were met in order to undertake the test burn: · Define project supervision; · Undertake independent third party evaluation; · Complete and implement an environmental impact assessment (EIA) following Vietnamese requirements (Decision 1554, 1999; HCMC, 2002); · Transport and handling of hazardous waste for the test burn to comply with Vietnamese regulatory requirements (Hazardous Waste Management Regulation, Decision 155, 1999); · Emission levels should comply with Vietnamese standards (TCVN 5939-1995 and TCVN 5940-1995 as per Decision 155, 1999); · Evaluate the technical and chemical feasibility for co-processing hazardous wastes; · Confirm that the power and water supply are stable and adequate; · Confirm that hazardous waste receiving, handling, storage and introduction processes are stable, safe and robust; · Ensure that all staff and subcontractors have adequate information and training; · Ensure that the test burn has been communicated to all stakeholders transparently; · Develop and implement emergency and safety procedures including equipment and supplies; and · Develop and implement procedures for stopping waste introduction in case of equipment malfunction or emergency. A solvent-based insecticide mixture with two active ingredients, Fenobucarb and Fipronil (containing cyclohexanone and aromatic solvents), was selected as a desirable candidate. Approximately 40,000 L of the insecticides with sufficient concentrations of active ingredients to measures destruction efficiencies (DE) and destruction and removal efficiencies (DRE) were available for use. Being a free flowing liquid with a viscosity similar to water, the insecticide could be pumped to the main burner. The test burn took place over two days with the first day being devoted to a baseline (October 16 and 17, 2003). The plant operated under standard conditions. Holcim staff took the solid process samples (raw meal, clinker, fine coal and dust from the electrostatic precipitators) and an Australian specialty subcontractor conducted the stack testing. Accredited laboratories in Australia and Europe conducted the laboratory analyses of collected samples. During the test burn, 39,500 L of pesticides were destroyed in less than 20 hours. The coal feed to the primary burner was reduced from 7 to 5.5 tonnes per hour when the insecticide was introduced (subsequent analysis showed that the feed rate of coal could have been dropped by an additional 1 tonne/h). I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 69 of 119 For Fenobucarb, the destruction efficiencies achieved were greater than 99.9999997% DRE (6 9s) and greater than 99.9999969% DE (7 9s). For Fipronil, the destruction efficiencies achieved were greater than 99.9999985% DRE (5 9s) and greater than 99.9999832% DE (6 9s). No active ingredients were detected in the clinker, ESP dusts or the exit gas. Sampling for PCDD/Fs, PCBs and Hexachlorobenzeene (HCB) was conducted and no detectable concentrations of any of these parameters were noted during either the baseline or test burn. Analyses of polyaromatic hydrocarbons, benzene and volatile organic compounds (VOC) were also undertaken. All of these parameters were detected at low concentrations below applicable standards in both the baseline and trial burn. The test burn was considered successful by all stakeholders and the facility subsequently received its license for hazardous waste disposal. PCB Waste Test Burn Holcim has submitted a test burn application to MONRE and this has been approved. Holcim has identified a waste supplier and is setting up an agreement with them to arrange the transfer. Following this, a stakeholder meeting will be held. The test burn, following the same pattern as that conducted in 2003 for the other waste classes, will take place in the late summer or fall. Holcim has prepared a plan for the test burn which has been submitted to MONRE. The supplier has PCB-containing waste oil with concentrations of PCBs varying between 2,000 µg/g to 6,000 µg/g. The test burn will take place over 2 days and with the first day being the data acquisition for normal operating conditions and the second day having the PCB waste oil added at a rate of 1 ton/h. Continuous monitoring will be conducted as part of normal operations for the following: · Gas to the furnace: O2 and CO; · Gas from the preliminary burning tower: O2 and CO; and · Exhaust gas: O2, CO2, NO; NO2, SO2, HCl NH3, H2O and VOC. Stack gas sampling will be conducted. Two of these samples will be collected and tested for PCB, hexachlorobenzene, trichlorobenzene, tetra-chlorobenzene, benzene, HCl, heavy metals, particulate matter,, CO, CO2, NO; NO2, SO2, HCl NH3, H2O and VOC. Most importantly, each sample will be analyzed for PCDD/F (dioxins and furans). PCB analyses will be conducted for various process elements including the feed hazardous waste, raw materials, coal, clinker and particles trapped by the electrostatic filters. Health and Safety Performance and Monitoring Requirements: Although human health testing is not conducted, the health of employees is monitored through annual medical examinations. Holcim maintains extensive safety systems including those related to fire safety and spill response. 3.5 URENCO In Vietnam, the collection of urban solid waste (municipal and industrial) is undertaken by Urban Environment Companies (URENCO). The Hanoi URENCO is one of the largest in the country and operates multiple transfer stations, a construction debris landfill (Lamdu) and a large landfill complex, the Nam Son Municipal Solid Waste Treatment complex (Soc Son district), which includes a compound for treating and disposing of hazardous waste with multiple treatment lines. The hazardous waste treatment complex has been operating since 2003. The Nam Son Landfill Complex is planned for operation until 2018. On April 27, 2007, Mr. Lloyd and Dr. Thai met with Mr. Lé Huy Tuyén and Mr. Vú Ván Phuc, both of URENCO. They provided information and conducted a tour of the facilities. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 70 of 119 The facility includes two industrial incinerators designed and constructed by the Centre for Environmental Engineering of Towns and Industrial Areas (CEETIA) as a demonstration project funded by MONRE. The incinerators were designed to destroy used waste oil and chemicals, waste paints, adhesives and resins as well as unrecoverable solvents. Most waste comes from the garment industry. The incinerators were not designed to treat PCBs. Their technical specifications are as follows: · Capacity: Incinerator No. 1: 50 kg/h; Incinerator No. 21: 150 kg/h; · Primary burning chamber temperature: 800 to 850ºC; · Secondary burning chamber temperature: 1,000 to 1,100ºC; · Fuel consumption (diesel): 50 to70 kg/h; and · Air retention time: 1.5 seconds. Typically, the incinerators operate continuously for four days, followed by two days of maintenance and one day without any activity. Neither incinerator was in operation during the site visit. The off-gas treatment system for the incinerators comprises wet scrubber systems. Wastewater generated is further treated in the complex, as described below. The stacks do not have continuous monitoring of emissions, however stack testing is conducted quarterly. Fifteen key parameters are assessed including NOx, SOx and various heavy metals including mercury. Dioxins and furans are not part of the assessment. Ash from the incinerators is disposed of at a secure industrial hazardous waste landfill, along with other solid hazardous waste. The secure landfill cell is 10 m by 20 m by 25 m (10,000 m3 capacity) and is lined and enclosed in a building. Other treatment lines include chemical methods for wastewater treatment (pH adjustment) and physical methods for solids' removal, sludge dewatering and oil water separation. The site also has a hydraulic compaction machine for compressing waste and numerous storage buildings for waste preparation and retention. The incinerator was not designed to treat PCBs and does not meet the general combustion requirements for PCBs (1200ºC, 2 second residence time and 2% excess oxygen). URENCO had not been considering receiving PCB wastes for treatment. With respect to the data required by the World Bank, as the current facilities do not meet the minimum requirements for PCB treatment and URENCO is not considering accepting PCB waste, the assessment was not completed. URENCO did not supply enough information address all the issues raised by the World Bank. 3.6 Task 2 Summary The Holcim cement plant, using cement kiln co-processing, is the only PCB treatment technology in Vietnam that is close to the commercialization for the destruction of PCB waste. The other operations are either not focused on PCBs (Chemical Military Headquarters), not interested in treating PCBs (URENCO-Hanoi) or are at the research stage of technology development (Academy of Science and Technology). With the encouragement of the regulators and the extensive support of their international network, Holcim will likely be a significant waste disposal option in Vietnam. Regardless, this is not Holcim's core business and they do not have the capacity or flexible capability to handle all the PCB waste in Vietnam. Other options need to be examined, as discussed in the following sections. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 71 of 119 4.0 TASK 3 ­ EVALUATION OF REGIONAL PCB DISPOSAL OPTIONS 4.1 Methodology Regional PCB disposal options were examined to identify facilities within the Asia-Pacific region that would be willing to accept PCB waste from Vietnam for disposal, or alternatively, to set up treatment facilities within Vietnam. As a starting point, facilities were identified from the United Nations Environment Programme's "Inventory of World-wide PCB Destruction Capacity" (1998 and 2004 editions). Internet searches were also conducted to identify other facilities that were not listed in the UNEP inventories but were capable of treating PCB waste. Documents that were important reference sources include: · Australia's National Implementation Plan (July 2006), Australian Government Department of Heritage and Environment. · List of Registered Treatment/Storage/Disposal (TSD) Facilities for Hazardous Waste (March 2007), Department of Environment and Natural Resources, Environmental Management Bureau (Philippines). · List of Participants ­ PCB Management and Disposal under the Stockholm Convention on Persistent Organic Pollutants Consultation Meeting, Geneva (9 to 10 June, 2004), UNEP. · Country reports from the Secretariat to the Basel Convention (http://www.basel.int/convention/ secretariat.html). Identified facilities were contacted by electronic mail and telephone calls, to gather the information required for evaluation. Where no contact could be established with disposal facilities, the relevant environmental authority in the country was contacted to determine whether disposal facilities existed. In addition to the information provided by each facility, internet searches were conducted to identify supplementary information and to obtain information from third-party sources, such as community and environmental organizations. 4.2 Findings by Country The countries examined in this task included Australia, Cambodia, China, Japan, New Zealand, Malaysia, the Philippines, Singapore and Taiwan. A brief description of each country's legal and technical ability and willingness to accept waste from Vietnam is outlined below, along with a summary of each disposal facility identified. Detailed reports on each facility are presented in Appendix E. 4.2.1 Australia In Australia, imports of hazardous waste are regulated by the "Hazardous Waste (Imports and Exports) Act, 1989 and the Hazardous Waste (Regulation of Imports and Exports) Regulations 1996". Under the Hazardous Waste (Imports and Exports) Act, 1989, an application for a "Basel Import Permit" must be made to the Minister in a form approved by the Minister. All imports into and disposal within Australia must be in accordance with the Basel Convention. Permits are granted to persons within an Australian jurisdiction, indicating that the application will have to be made by the Australian disposal facility that will dispose of the waste. The permit would only be granted once the Minister is satisfied that the facility is capable of carrying out recovery operations in a manner appropriate to give effect to Australia's obligations under the Basel Convention. Facilities in Australia that are capable of treating PCB wastes were identified from Australia's National Implementation Plan (Australian Government Department of Heritage and Environment, July 2006). Companies I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 72 of 119 that were registered only as storage facilities were not contacted. Five companies were identified, as detailed below. DoloMatrix Australia Ltd. DoloMatrix Australia Ltd. (DoloMatrix) comprises three divisions ­ DoloMatrix International Ltd., SRL Plasma Pty. Ltd, and Chemsal Pty. Ltd. DoloMatrix International Ltd. responded on behalf of the company. Technologies offered by DoloMatrix include: · Plascon® plasma destruction technology; · Base catalyzed decomposition (BCD) technology; · Thermal desorption; and · Dolecrete® microencapsulation technology. The type of treatment technology selected will depend on the concentration of PCBs in the waste, and the media being treated. Average capacity throughput was cited as 500 tonnes per annum, at a destruction efficiency of 99.99999%. By-products from the technologies include carbon dioxide and water vapor off-gases, and sodium hypochlorite and sodium chloride solutions. Mr. Jon Doumbos of Dolomatrix expressed reservations regarding the importation of PCBs into Australia because of the regulatory requirements involved with PCB importation and indicated a preference for setting up a treatment facility in Vietnam, in joint-venture with the Government of Vietnam. It should be noted that for the BCD technology, use of the technology outside of Australia will depend on the conditions of the license at the time of waste disposal. Energy Services Invironmental Pty. Ltd. (ESI Group) The technology used by the ESI Group involves dechlorination using sodium reduction. PCB oils and soils are treated directly with the sodium reduction. For solids and porous materials, additional treatment is required. Non-porous materials are flushed with PCB-free oil to remove any PCBs that are present. Porous materials are placed in Hot Air Separator Units, where the PCBs are evaporated in a closed loop plant and then recondensed for treatment. Oils used in flushing and the recondensed PCBs are then treated with sodium reduction. Treatment achieves concentrations < 2 ppm. By-products of the technology include a caustic solution. Mr. Peter Gwynn of ESI Group indicated that they could either import waste into Australia for treatment, or they could set up a treatment facility in Vietnam. The latter is the preferred option, because of the risks associated with transport of hazardous waste, and because recycled oils and metals can then be reused locally. If waste is imported into Australia for treatment, a bond will likely have to be posted, to be used in the event of any release, accidental or otherwise, of PCBs into the natural environment. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 73 of 119 Entech Industries Pty. Ltd. Mr. Karl Baltpurvins from Entech Industries Pty. Ltd. (Entech) was contacted to determine whether Entech was interested and able to participate in this project. He indicated via electronic mail that their sister company, BCD Technologies (now owned by Dolomatrix) is responsible for treating PCB waste. Hydrodec Group plc Hydrodec Group plc (Hydrodec) is headquartered in the United Kingdom, with an office in Australia. This facility is considered to be a regional disposal option as Mr. Mark McNamara of Hydrodec has indicated that treatment would take place within Australia. However, Hydrodec is also open to the possibility of treating waste within Vietnam, as the treatment unit is mobile. Hydrodec treats PCB contaminated oil using catalytic hydrogenation, a process in which hydrogen is used to replace the chlorine atoms in the PCBs, allowing oil properties to be retained while the PCBs are destroyed. The process is a closed loop process, so no emissions are expected. Under abnormal conditions, the unit shuts down, so no emissions are expected at any time. In terms of waste generated, wastewater is treated using ion exchange, so periodically, ion exchange media requires disposal. Spent catalysts are returned to the manufacture for recycling. In the event that the oil is dirty, filter residues from inline strainers will also require disposal. Environmental monitoring in Australia occurs in accordance with the operating license, which requires continuous monitoring of air emissions for hydrogen, and bi-annual independent assessments for dioxins, PCB and VOCs. Processed oil is batch tested for PCB concentration. Plastech Operations Pty. Ltd. Mr. Mark Martin of Plastech Operations Pty. Ltd. (Plastech) indicated that they would not be able to import PCB waste into Australia for treatment. Tox Free Solutions Ltd. Tox Free Solutions Ltd. (Tox Free) utilizes a patented indirect thermal desorption and direct thermal desorption (also referred to as thermal destruction) system to remove and destroy PCBs. A Plasma Arc system is also available for destruction of PCB waste. Indirect thermal desorption is used to separate PCBs from contaminated solid media, resulting in reduced volumes for treatment. Treatment is accomplished via direct thermal desorption. Direct thermal desorption (thermal destruction) involves a high temperature rotary kiln with 3-stage emission treatment (alkaline scrubber), operating at 1200 °C to ensure complete destruction. The efficiency of this process is rated as 99.9999%, at a throughput of 2 tonnes per hour for indirect thermal desorption and 5 to 50 tonnes per hour for the direct thermal desorption. A 2002 article found online (Australian News, Green Left Weekly issue #484 13 March 2002; www.greenleft.org.au/2002/484/28639) by Green Left Online criticized Tox Free's operations based on a visit to the plant by Lee Bell (Contaminated Sites Alliance spokesperson) and Steve Hess (Kwinana Progress Association activist), where they described the operation as "a shambles". They claimed to have seen 20 things in half an hour that were cause for concern, which they took up with the Western Australia Department of Environmental Protection (DEP). No details were given as to what the causes for concern were, or what action was taken by the DEP, if any. No follow up articles could be found. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 74 of 119 4.2.2 Cambodia Mr. Chea Sina, a representative of the Kingdom of Cambodia's Ministry of Environment, indicated via electronic mail on May 8, 2007 that in accordance with Cambodia's environmental law (Kram dated December 24, 1996 on Environmental Protection and Natural Resources Management), PCB waste could not be imported into Cambodia. He also indicated that there were currently no disposal facilities in Cambodia at this time. 4.2.3 China Internet searches for disposal facilities in China yielded no results. The Project Appraisal Document on the Proposed Grant from the Global Environment Facility Trust Fund to the People's Republic of China for a Demonstration of PCB Management and Disposal Project (World Bank, November 2005) indicated that China had no PCB disposal facilities at that time that met the requirements of the Stockholm Convention. Under this GEF project, it is intended to complete work on the rotary kiln incinerator in Shenyang in the Liaoning Province. Work will include construction of a PCB storage facility, providing support to a waste characterization and analysis unit at an existing laboratory, completing the construction of the incinerator to meet the requirements of the Stockholm convention, and providing training to technical personnel on PCB storage and disposal, and monitoring for dioxins and furans. The State Environmental Protection Administration (SEPA) was contacted by SLI enquiring as to the current status of PCB disposal in China. An official of the SEPA indicated that treatment of PCB waste in China takes place at the Shenyang incinerator, but that importation of PCB waste into China was not a possibility. 4.2.4 Japan Relevant legislation governing the importation of hazardous waste into Japan includes the Law for the Control of Export, Import and Others of Specified Hazardous Wastes and Other Wastes, where hazardous wastes are defined as in the Basel Convention, to which Japan is a signatory. This law states that persons wishing to import specified hazardous materials etc. must receive import approval under the Law for Export, Import and Foreign Exchange. The Minister of Environment or the Minister of Economy, Trade and Industry may order the importer of the specified hazardous waste or other responsible parties to take necessary measures to dispose of the specified hazardous waste appropriately. Other relevant laws for PCB waste disposal in Japan include the Law concerning Special Measures for Promotion of Proper Treatment of PCB Wastes (PCB Special Measures Law), 2001, which states that all PCB wastes must be disposed of, or consigned to someone to dispose of them by July 2016 and the Waste Management and Public Cleansing Law. Three PCB disposal facilities were identified in Japan, as detailed below. Japan Environmental Safety Corporation The Japan Environmental Safety Corporation (JESCO) was established by the Government of Japan in 2004 to take over the PCB waste treatment programs of the former Japan Environment Corporation (JEC). I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 75 of 119 JESCO was contacted via telephone to determine whether it would be possible to assist the Government of Vietnam with the disposal of PCB waste. They were also contacted by Mr. Peter Lang of Zero Japan Co. Ltd. for this purpose. JESCO has indicated that they are restricted to treating Japanese PCB waste only. Kobelco Eco-Solutions Ltd. Kobelco Eco-Solutions Ltd. (Kobelco) was created in 2003 as a result of the merger of the Environmental Division of Kobe Steel and Shinko Pantec Co. Ltd. Kobelco manufactures PCB disposal plants for sale but does not treat or otherwise destroy PCB waste. Kobelco's technology is currently being utilized at Toyota's site in Japan. Liquid PCBs are dechlorinated using a Sodium Pulvarulent (SP) Process, which involves reaction with a sodium dispersion. By-products include NaCl and a caustic solution. PCB-contaminated solids are treated using a Solvent Extraction and Decomposition (SED) Process. Oils are removed by a vacuum. A hydrocarbon solvent is used to extract the remainder of the PCBs, which are then treated using the SP Process. Waste oil is treated to less than 0.5 mg/kg and waste acids/alkalis are treated to less than 0.03 mg/L. Plastics, metals and ceramics, using the washing method, are treated to less than 0.5 mg/kg of solvent. Sludges and other materials such as paper are treated to less than 0.003 mg/L-sample liquid. Zero Japan Co. Ltd. Mr. Peter Lang of Zero Japan Co. Ltd. (Zero) was contacted to obtain more information on their PCB-treatment process and to determine whether Zero was able to accept PCB waste from Vietnam or set up a treatment facility in Vietnam. Mr. Lang indicated via electronic mail that the technology used by Zero is suitable for removing PCBs from electrical appliances using vacuum thermal recycling, and that final treatment and disposal by another facility would be required. It would not be possible to import PCB waste to their facility into Japan as their equipment is leased to another company that is only licensed to treat their own stock. He also indicated that they are too small and inexperienced to set up a facility in Vietnam, but that they would be willing to provide their experience to a partner who would be willing to set up a facility in Vietnam. 4.2.5 Malaysia Importation of hazardous waste for recovery or final disposal into Malaysia is permitted on a restricted basis from non-OECD countries in accordance with the Environmental Quality Act, 1996, Section 34B; and the Customs (Prohibition of Export) Order 1993, Amendment 1998. The Malaysian Department of Environment was contacted regarding the possibility of importing Vietnam's PCB waste into Malaysia for treatment and final disposal. Dr. Ab. Rahman bin Awang responded via electronic mail, indicating that it was not Malaysia's policy to allow the importation of hazardous waste. 4.2.6 New Zealand In New Zealand, the import of hazardous waste is regulated by the Imports and Exports (Restrictions) Act 1988 and the Imports and Exports Prohibition Order (No. 2) 2004 which provides for the import of POPs waste for the purposes of environmentally sound disposal. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 76 of 119 The Ministry of Economic Development (MED) administers applications for imports and exports of hazardous waste in New Zealand, and ensures that imports and exports comply with the requirements of the Basel Convention, as well as other conventions to which New Zealand is a signatory. Hazardous wastes are defined as in the Basel Convention. The application to MED must include a copy of the contract between the persons shipping the waste and the persons receiving the waste, copies of insurance for the shipment, details on the proposed route that the shipment will take, a description of how the waste will be packed, information on the receiving company and how they will dispose of the waste, and evidence that the receiving company will comply with all relevant legal requirements. Permission must be sought from all countries in which the waste will be in-transit. One company was identified in New Zealand that treated PCB waste, as described below. EDL Environmental Technology. EDL Environmental Technology (EDL) uses mechano-chemical destruction (MCD) to destroy PCB-contaminated soils and sediments. Dried contaminated soil is fed into the reactor drum along with an unnamed chemical catalyst. The drum contains a rotating shaft with a number of impellers which impact with balls in the mill, causing them to move with high velocity through the reactor. As the soil moves through the reactor, the soil crystals are fragmented, creating free radicals. These free radicals react, in the presence of the catalyst, with the organic contaminants present. When treating solids, the PCBs are removed by a solvent (unnamed) which is then subjected to fractional distillation to separate the PCBs. PCBs are then mixed with soil and passed through the MCD process. PCBs are converted to a high molecular weight amorphous carbon product and inorganic chlorides during treatment. These inorganic chlorides are bound to the soil and cannot be separated. The destruction efficiency is rated as 99.5%, at a throughput of 20 tonnes per hour. EDL has indicated that they are unwilling to import waste into New Zealand for treatment due to the strict controls set by the Basel and Stockholm Conventions and the cost of transportation of hazardous waste. The preferred treatment location would be within Vietnam, as the system comprises easily transportable modular units. Projects undertaken by EDL include the cleanup of contaminated soil in Mapua, New Zealand, under the management of the Ministry of the Environment in 2004 (http://www.mfe.govt.nz/news/mapua-13aug04.html). 4.2.7 The Philippines Entry of hazardous waste into the Philippines is prohibited, in accordance with the Republic Act No. 6969 ­ The Toxic Substances and Hazardous and Nuclear Wastes Control Act 1990. One of the objectives of R.A. 6969 is "to prevent the entry, even in transit, as well as the keeping or storage and disposal of hazardous and nuclear wastes into the country for whatever purpose" (Section 4(d)). However, the 2003 Country Report to the Basel Secretariat states that "However, importation of materials containing hazardous substances as defined under RA 6969, its implementing rules and regulations and subsequent directives for the control of importation of wastes, for recovery, recycling and reprocessing, may be allowed only upon obtaining prior written approval from the Secretary of the Department of Environment and Natural Resources or his duly authorized representative". Under R.A. 6969, "hazardous waste" is defined as substances that are without any safe commercial, industrial, agricultural or economic usage and are shipped, transported or brought from the country of origin for dumping or disposal into or in transit through any part of the territory of Philippines. "Hazardous wastes" shall also refer to I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 77 of 119 by-products, side-products, process residues, spent reaction media, contaminated plant or equipment or other substances from manufacturing operations and as consumer discards of manufactured products which present unreasonable risk and /or injury to health and safety and to the environment. In 2007, the Environmental Management Bureau (EMB) published a document entitled "List of Registered Treatment/Storage/Disposal (TSD) facilities for Hazardous Wastes (EMB, March 2007), which included references to two PBC disposal facilities, as described below. Safeco Environmental Services Safeco Environmental Services (Safeco) has indicated an interest in assisting Vietnam to treat their PCB wastes by either deploying a mobile treatment unit to Vietnam to dechlorinate transformer oils and solvents, or by facilitating the transfer of all wastes to Ekokem, a Finnish incinerator (described further under Task 4). The mobile treatment unit will destroy PCBs using dechlorination. The technology is currently patent-pending, so detailed information is not available at this time. Ms. Marilyn Hoese, the President of Safeco, has indicated that the technology will use a chemical that will react with the PCB waste in a one-stage dechlorination reaction. By- products produced will include salt water and PCB-free oil. The reagent is stored in a dry form and is mixed with water as needed. Ms. Hoese indicated that no special import permits are required to bring this chemical into the Philippines. Globecare Services Inc. Efforts were made to contact Globecare Services Inc. via email and telephone but were not successful. No website was available for this company. 4.2.8 Singapore Imports, exports and transit of hazardous waste in Singapore are governed by the Hazardous Waste (Control of Export, Import or Transit) Act, 1998. Imports of hazardous waste for final disposal are prohibited in Singapore but import for recovery can be permitted on a case-by-case basis if a Basel Import Permit is obtained from the Pollution Control Department. Rohaya Saharom, a Senior Engineer at the Pollution Control Department of the National Environment Agency, indicated that Singapore does not have any facilities that can treat and dispose of PCB waste. 4.2.9 Taiwan Taiwan is not a signatory to the Basel convention. In the event that waste is to be shipped from Vietnam to Taiwan for disposal, a bilateral agreement will therefore have to be created between the Government of Taiwan and the Government of Vietnam. Handling of hazardous wastes in Taiwan is governed by the Toxic Chemical Substances Control Act, 1986. Toxic substances are defined in this act, and are divided into classes of materials depending on the characteristics of the material. The Environmental Protection Administration of Taiwan has listed PCBs as a Class 1 and 2 Toxic Chemical Substance. Importation of PCBs would therefore be subject to a permit issued by the Environmental Protection Administration, and/or municipal, county or city governments. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 78 of 119 Toxic wastes are also regulated under the Waste Disposal Act, 1974, which states that industrial waste shall be banned from importation if evidence exists that the waste will severely endanger human health or the living environment, no appropriate treatment technology and equipment is domestically available for the waste, or if the waste is to be directly solidified, landfilled, incinerated or disposed of at sea (Article 38, 1-3). Other than a reference to incinerators made during the presentation of a country paper at the 2003 PCB Symposium in Malaysia (Hwang, PCB Symposium in Malaysia, 2003), no other PCB disposal facilities were identified in Taiwan. The Taiwan Environmental Protection Administration (EPA) was contacted regarding the capacity of Taiwan to treat PCB waste. An official at the EPA indicated that importation of PCB waste into Taiwan would not be allowed. The official also indicated that Taiwan is currently exporting some of their PCB waste to France for treatment. 4.3 Summary A summary of the findings of Task 3 is presented in Table 4.1 below, from a waste acceptance perspective. With the exception of Australia, no country was identified that was willing to accept waste from Vietnam, but facilities were identified in Japan, New Zealand and the Philippines that were willing to export their technology to Vietnam to treat waste there. In Australia, three out of four facilities that are interested in the project indicated their willingness to import waste for treatment within Australia but they also expressed a preference for treating the waste in Vietnam. One Australian facility, Dolomatrix International, indicated that the permitting procedure for importation would be challenging, and would not consider importation further. Table 4.1 : Summary of Task 3: Regional Disposal Options Number of Number of Number of Willing to Accept Number of facilities willing Facilities for Facilities Waste from facilities willing to set up mobile PCB Destruction Successfully Vietnam? to import facility in Identified Contacted Vietnam Australia 6 6 Yes ­ some 3 ­ also willing to 4 (including facilities treat waste in facilities that are Vietnam. also willing to import) Cambodia 0 0 No 0 0 China 1 1* No 0 0 Japan 3 3 No 0 1 ­ willing to sell a unit(s) to the Govt. of Vietnam Malaysia 1 1* No 0 0 New Zealand 1 1 No 0 1 The Philippines 2 1 No 0 1 Singapore 0 0 No 0 0 Taiwan 0 0 No 0 0 * Response obtained from governmental authority A summary of the non-regional options for PCB disposal is presented in Table 4.2, which presents more detailed information on the facilities evaluated. In terms of technologies in use, there were a variety of options, including BCD, plasma arc, sodium reduction, catalytic hydrogenation, mechanochemical destruction and thermal desorption and destruction. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc Table 4.2 : Details of Task : Regional Disposal Options Disposal Cost (USD) Import or Destruction Non-metallic Facility Throughput Technology Treat in Constraints/ Remarks Metallic PCB Efficiency Oil PCB Transformers Capacitors Soils Sludges Vietnam? Equipment Equipment Dolomatrix 500 tpa Plascon, BCD or 99.99999% Treat in Type of technology used will $1.07/L Depends on Depends on $1,502.08/tonne $8,583.32/tonne $3,862.49/tonne $3,862.49/tonne International Thermal Vietnam. depend on the waste (<50 ppm) equipment and equipment and (<50 ppm) (<500 ppm) (<500 ppm) (Australia) Desorption. characteristics. $1.63/L degree of degree of $2,360.41/tonne $8,583.32/tonne $8,583.32/tonne (50 to 500 ppm) contamination. contamination. (50 to 500 ppm) (>500 ppm) (>500 ppm) $1.89/L $3,004.16/tonne (501 to 1000 ppm) (501 to 1000 $3.39/L ppm) (1001 to 5000 ppm) $3,862.49/tonne $7.51/L (1001 to 5000 (1001 to 5000 ppm) ppm) ESI Group Oil ­ 500 Dechlorination <2ppm (normally ND Import or treat Can treat waste up to 3000 $0.35 to $0.85/litre $800 to $850 to $800 to $1,700 to $680 to $680 to (Australia) litre/hr using sodium. <0.05) in Vietnam. ppm. $1,700/tonne $2,550/tonne $1,220/tonne $4,250/tonne $1,700/tonne $2,550/tonne Equipment ­ no limit. Tox Free 2 tonnes per Indirect Thermal 99.9999% Import or treat Removes PCB from waste. N/A $4,291 ­ $4,291 ­ $4,291 ­ $4,291 ­ $858 - $858 - (Australia) hour. Desorption. in Vietnam. Waste destroyed by Plasma $34,330/tonne $34,330/tonne $34,330/tonne $34,330/tonne $4,291/tonne $4,291/tonne Arc (subcontracted). 5-50 tonnes Direct Thermal 99.9999% Import or treat - Direct thermal desorption N/A $4,291 ­ $4,291 ­ $4,291 ­ $4,291 ­ $429 - $172 - per hour. Desorption/ in Vietnam. units are best suited to large $34,330/tonne $34,330/tonne $34,330/tonne $34,330/tonne $4,291/tonne $4,291/tonne Thermal volume jobs >2000 tonnes. Destruction. - Treating of contaminated soils and sludges via direct thermal destruction is not permitted in Australia. Hydrodec Group 20,000 L/day Catalytic 99.9999% Import or treat Oil to have maximum 5-50ppm PCB:$0.40/L N/A N/A N/A N/A N/A N/A plc. (fixed plant) or dehydrogenation. in Vietnam. concentration of silicone oil of 50-500ppm PCB: $0.80/L 3,000 L/day 7ppm. Prices are for >500ppm PCB: $4.00/L (mobile plant) treatment in Australia. Kobelco Eco Can be scaled Sodium - 0.5 mg/kg Solvent Manufactures Costs cannot be provided at this time because waste characteristics are unknown. Solutions (Japan) to suit. reduction, solvent - 0.1 micro g/100 plants for sale. wash and sq.cm for metal vacuum surface separation. - 0.01 mg/kg-material EDL 20 tonnes per High energy >99.5% Treat in $300/ton $300/ton $300/ton $300/ton $300/ton 250/ton 250/ton Environmental hour. mechano- Vietnam. Technology (New chemical Zealand) destruction (MCD). Safeco No limit. High temperature 99.99990% Can export to Cost may be higher $3,000-$4,000/tonne $3,000- $3,000- $3,000- $3,000- $3,000- $3,000- Environmental incineration Finland for depending on waste $4,000/tonne $4,000/tonne $4,000/tonne $4,000/tonne $4,000/tonne $4,000/tonne Services Inc. (The (Ekokem in incineration, or characteristics. If Philippines) Finland) and local treat in dechlorination technology is solvent and oil Vietnam using used, cost savings can be recycling using a dechlorination achieved through use of local patent-pending technology. labour and elimination of technology need for marine insurance. (dechlorination reaction). SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 79 of 119 5.0 TASK 4 ­ EVALUATION OF PCB DISPOSAL OPTIONS OUTSIDE THE REGION 5.1 Methodology PCB disposal options outside of the Asia-Pacific region were examined to identify facilities that would be willing to accept PCB waste from Vietnam for disposal, or alternatively, to set up treatment facilities within Vietnam. As with Task 3, as a starting point, facilities were identified from the United Nations Environment Programme's Inventory of World-wide PCB Destruction Capacity (1998 and 2004 editions). Internet searches were also conducted to identify other facilities that were not listed in the UNEP inventories but were capable of treating PCB waste. Important reference sources included: · List of Participants ­ PCB Management and Disposal under the Stockholm Convention on Persistent Organic Pollutants Consultation Meeting, Geneva (9 to 10 June, 2004), UNEP. · Country reports from the Secretariat to the Basel Convention (http://www.basel.int/convention/ secretariat.html). · References provided by facilities themselves. Similarly to Task 3, identified facilities were contacted by electronic mail and telephone calls, to gather the information required for evaluation. In addition to the information provided by each facility, internet searches were conducted to identify supplementary information and to obtain information from third-party sources, such as community and environmental organizations, on that facility. 5.2 Findings by Country The countries examined in this task included Belgium, Canada, Denmark, Finland, France, Germany, the Netherlands, Norway, Sweden, Switzerland, the United Kingdom and the United States of America. A brief description of each country's legal and technical ability and willingness to accept waste from Vietnam is outlined below, along with a summary of each disposal facility identified. Detailed reports on each facility are presented in Appendix F. 5.2.1 North America 5.2.1.1 Canada Import and export of hazardous waste in Canada is regulated by the federal regulation, Export and Import of Hazardous Waste and Hazardous Recyclable Material Regulations (SOR/2005-149), under the Canadian Environmental Protection Act (CEPA), 1999. Import and export is also governed by provincial legislation. Under the Export and Import of Hazardous Waste and Hazardous Recyclable Material Regulations, PCBs are listed in Schedule 5 (Environmentally Hazardous Substances) and Schedule 10 (Persistent Organic Pollutant), defined as a hazardous waste at concentrations equal to or greater than 50 mg/kg. Conditions of import into Canada are detailed in Part 3, Section 16 of the Export and Import of Hazardous Waste and Hazardous Recyclable Material Regulations. Transportation of hazardous waste within Canada is governed by the Transportation of Dangerous Goods Act and associated regulations at the federal level, and other specific regulations at a provincial level. Persons proposing to import hazardous waste into Canada must submit a notice to the Minister in writing 12 months before the import. Separate notices must be presented for hazardous materials and hazardous recyclable I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 80 of 119 materials. This notice shall serve as the application for an import permit and must contain the information specified in Part 1, Section 8. In terms of community opposition to importation of waste, the most significant issue in recent times was with regard to the importation of PCB wastes from US military bases in the Pacific (http://ban.org/ban_news/ enviros_denounce.html) in 2,000. However, this opposition seemed to stem more from the fact that the United States was capable of disposing of its own waste, and therefore should not have attempted to export the waste to Canada for disposal, than from the importation of waste in principle. Facilities identified within Canada with the capacity to treat PCB wastes, either in Canada or within Vietnam, are described below. Some of the facilities listed in the 1998 UN Inventory were no longer in the business of treating PCB waste such as Cintec Environnnement Inc. or were just licensed haulers rather than disposal facilities (e.g. RONDAR Inc.). BC Hydro In the UNEP Inventory of World-Wide PCB Destruction Capacity (2004), BC Hydro was listed as using sodium reduction to destroy PCBs in light ballast capacitors, potting compounds from light ballasts contaminated with PCBs, and mineral oils contaminated with PCBs. However, Mr. Marty Enock of the BC Hydro Oil Management Department has indicated via electronic mail that BC Hydro no longer has the capacity to accept and treat PCB waste from sources other than from BC Hydro. He also indicated that they would not be able to set up a treatment facility in Vietnam. Bennett Environmental Inc. Bennett Environmental Inc. (Bennett) utilizes various technologies to destroy PCB wastes, including high temperature thermal treatment and solvent washing. This is accomplished through its subsidiaries, Récupère Sol Inc. (RSI), Material Resource Recovery Inc. (MRRI) and Trans-Cycle Industries Ltd. (TCI). RSI is a high temperature thermal treatment facility for contaminated soil, treating 12.5 metric tonnes of soil per hour, to a maximum of 100,000 metric tonnes per year. The thermal process equipment consists of a rotary kiln primary combustion chamber (operating at temperatures between 650°C and 750°C to vaporize organic contaminants), a secondary combustion chamber (operating at temperatures greater than 1,000°C to oxidize the contaminants in the gas stream) and an emission control system. Organic compounds are destroyed to greater than 99.9999% destruction removal efficiency. The process can handle some non-soil debris, such as concrete and bricks, but these must not comprise more than 49% of the material. Non-soil materials can be destroyed at Bennett's other subsidiaries. Soils with high moisture content (> 30 wt %) must be dewatered as much as practicable before shipping. At MRRI, PCBs are destroyed using a patented thermal treatment process. This process consists of a metal reclamation furnace system, which comprises primary and secondary combustion chambers. The secondary combustion chamber is maintained at 1200°C to destroy PCBs. The destruction removal efficiency is rated as 99.9999%. The facility is equipped with a continuous emissions monitoring system for O2, CO2 and SO2. Groundwater, phytotoxicology, ambient air and source emissions are monitored annually. MRRI also owns a mobile wastewater treatment unit that is capable of destroying PCBs in water at levels up to 5,000 ppm to levels that are not detectable. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 81 of 119 TCI is not a destruction facility. Rather, the facility utilizes vapour degreasing units to clean entire transformer carcasses, using a non-ozone depleting solvent. A carbon filtration system is operated under a vacuum to capture and recover fugitive emissions. Solvents are recovered in a Solvent Vapour Recovery Module (SVRM), and the PCB-containing waste solvent is then disposed of at another Bennett subsidiary. TCI also operates as a full PCB transfer station, capable of receiving all types of PCB-contaminated waste. Hazardous waste by-products from Bennett's technologies, such as ash and soils contaminated with heavy metals, are disposed of at approved landfill sites. Treatment of PCBs from Vietnam will likely take place in Canada, although Bennett has indicated that there is a plant that could potentially be relocated to Vietnam. Hallett Environmental and Technology Group Inc. Hallett Environmental and Technology Group Inc. (Hallett), led by Dr. Douglas Hallett, uses Gas Phase Chemical Reduction (GPCR) for destruction of PCBs. This process was previously known as the Eco Logic process. Types of PCB-contaminated waste that can be treated include transformers, capacitors, liquids, and to a lesser extent, sludges and soils. The destruction capacity is rated as greater than 99.9999% at a throughput of 1,000 tonnes per annum. However, this throughput is scaleable to suit the needs of the project. The technology is mobile and can be shipped in seven sea containers. However, while it can be moved from site to site within Vietnam, it is recommended that it be set up for a minimum of one year at any given site due to the complexities of moving the equipment. All treatment will occur in Vietnam. As described in a review of the Eco Logic technology by the US EPA (http://www.epa.gov/ORD/SITE/reports/ 540ar93522/540ar93522.htm), "the ELI Eco Logic International Inc. (Eco Logic) process thermally separates organics, then chemically reduces them in a hydrogen atmosphere, converting them to a reformed gas that consists of light hydrocarbons and water. A scrubber treats the reformed gas to remove hydrogen chloride and particulates. A portion of the gas is recycled back into the reactor; the remainder is either compressed for storage or feeds a propane-fired boiler prior to release to the atmosphere. The Gas-Phase Chemical Reduction process is designed to treat aqueous and oily waste streams and soil and sludge contaminated with hazardous organic waste, such as PCB, PAHs, chlorinated dioxins and dibenzofurans, chlorinated solvents, chlorobenzenes, and chlorophenols." Hazco Environmental Services Hazco Environmental Services (Hazco) works with the Swan Hills Treatment Centre (described below) to transfer and destroy PCB wastes by high temperature incineration at the Swan Hills Treatment Centre, located in Alberta, Canada. The facility handles all types of PCB waste, including contaminated equipment, transformers, capacitors, soils, sediments, sludges and slag. Hazco provides field services for identification and inventory of PCB waste, sampling, consolidation, packaging and transportation. They can supply services for the shipment of waste to Canada for treatment but they do not have a mobile treatment system to operate in Vietnam. Kinectrics Inc. Kinectrics Inc. (Kinectrics) utilizes a batch sodium reduction process to treat PCB oils, contaminated equipment, pure PCBs and potting material from fluorescent light ballasts. Each batch takes approximately two hours to complete. Mr. Luciano Gonsalves, Environmental Technologies Manager, indicated that because of the environmental risk associated with the transport of hazardous material, Kinectrics would not import waste into Canada for treatment, but would set up a treatment facility in Vietnam. For more than 1,000 tonnes of waste, he I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 82 of 119 indicated that it would be advisable to set up a sodium dispersion plant within Vietnam, as the reagent importation costs would become prohibitively expensive at waste quantities greater than this amount. Throughputs vary, depending on the type of waste and the concentration. For oils with PCB concentrations less than 10,000 ppm, 1,500 L can be treated per batch. For oils with concentrations greater than 50,000 ppm, throughputs may be between 333 L to 555 L per batch. The throughput for capacitors is estimated at 700 kg/day, while the paper recovered from the capacitors is treated at a throughput of 100 kg/day. The throughput for metals is approximately 5 tonnes per day. By-products include sludge (generated from decontamination of oils) which can be washed to remove NaOH and used as fuel, a caustic solution and recyclable paper and metals. The process is currently approved in Ontario, Japan and Mexico. Manitoba Hydro Ms. Nancy Melnychuk of Manitoba Hydro indicated that they were unable to accept PCB waste for disposal from Vietnam, nor were they able to treat waste within Vietnam. Newalta Newalta, an industrial waste management facility based in Alberta, was identified from the website of the Swan Hills Treatment Centre, where it was listed as a partner to Swan Hills. However, Mr. Larry Brenner of Newalta has indicated that the company is not in a position to accept PCB waste from Vietnam nor is it able to set up a treatment facility in Vietnam, as it does not typically handle PCB waste. Sanexen Environmental Services Inc. Sanexen Environmental Services Inc. (Sanexen) is headquartered in Quebec, Canada. Sanexen chemically destroys PCBs using a potassium-based reagent in various types of waste including transformers, capacitors, other contaminated equipment, sludges and soils by the use of proprietary technologies (DecontaksolyTM and Ultrasorption®). Treatability using DecontaksolyTM is limited to PCB concentrations less than or equal to 3,000 ppm ­ waste containing higher concentrations would be disposed of by high temperature incineration at the Swan Hills Treatment Centre. DecontaksolyTM is also suitable for treating online transformers. PCB concentrations are reduced to less than 2 to 50 ppm in oil, and less than 10 g/100cm2 for metals. For equipment or other PCB material containing concentrations greater than 3,000 ppm, the PCBs would be collected for disposal, and the equipment washed with perchloroethylene, a hydrocarbon solvent that would remove the remainder of the PCBs. This PCB/solvent mixture is distilled to remove the solvent, which is recycled into the process, and the PCB waste concentrated to reduce the volume, prior to disposal at Swan Hills. By-products of the technology include spent catalyst and distillation residues from transformer decontamination. Mr. Eric Sauvageau, the Director of PCB Remediation at Sanexen, has indicated that air emissions from carbon filter outlets are monitored on an hourly basis during use with total concentrations less than 1 g/m3. Parameters monitored include VOCs and PCBs. Operational parameters such as temperature and pressure are also monitored to ensure that the technology is functioning as designed. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 83 of 119 Mr. Sauvageau has indicated that waste will not be imported into Quebec for disposal. Rather, a mobile treatment unit will be set up in Vietnam, or in another country if possible. Sonic Environmental Solutions Inc. Sonic Environmental Solutions Inc. (Sonic) uses low frequency sonic energy at low temperatures to remediate PCB-contaminated soils and other granular material. The technology is mobile and will be transported to Vietnam to treat the wastes there. Soils are loaded into bins, through which a solvent is percolated until the discharge limits are met. The solvent is cleaned and recirculated. The PCB waste recovered from the solvent is fed into the Sonic Generator, where it is destroyed chemically (using sodium ingots) by PCB SonoProcessTM. This process can also accept liquid waste, such as PCB oils and concentrates from other reduction technologies such as indirect thermal desorption. The destruction efficiency is 99.9999%, at a typical throughput of 2,000 tonnes of soil per month and 6,000 L of liquid PCB waste per day. However the system is scaleable to suit project requirements. Mr. Paul Austin, Vice President of Sales and Marketing, has indicated that the process is a closed loop one, with no air emissions. Monitoring conducted will depend on the requirements of the municipality in which treatment is taking place but will typically involve a continuous hydrocarbon, PCBs and particulates air emissions analyzer, and in some cases, groundwater monitoring. A low grade fuel is produced with can be recycled. Mr. Austin also indicated that some process salts will be produced which can be disposed in a municipal sewage system. Whether this can be done in Vietnam will depend on the regulatory limits for discharges. Swan Hills Treatment Centre The Swan Hills Treatment Centre (Swan Hills) is currently being operated by Earth Tech Inc. under a ten-year contract with the Government of Alberta. The facility involves a high temperature incinerator operated at about 1300°C to ensure complete destruction of waste. The destruction efficiency is 99.999999% at a throughput of 40,000 tonnes per year. A second incinerator operates by batch for electrical equipment including transformer solids. As this technology is fixed rather than mobile, waste must be exported from Vietnam for disposal. Before waste is accepted at Swan Hills, it must be characterized to determine its chemical properties and a plan developed for its treatment. Swan Hills usually works with a number of other waste management firms (such as Hazco and Sanexen) which will usually treat some of the PCB waste prior to final disposal at Swan Hills. Environmental parameters monitored include hydrogen chloride, sulphur dioxide, carbon monoxide, total particulates, dioxins, furans, and halogenated and non-halogenated organic hydrocarbonss. The type and frequency of monitoring is in accordance with the conditions of the environmental approval (approval number 1744-02-00) and involves a mixture of continuous and batch monitoring, ambient air monitoring, industrial discharge/runoff monitoring, deep well disposal monitoring, water works system monitoring, groundwater monitoring and soil monitoring. By-products produced include bottom and fly ash and slag. If heavy metals are present they are subjected to further treatment until the waste can pass a TCLP analysis before disposal at Swan Hills Treatment Centre's secure onsite landfill. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 84 of 119 5.2.1.2 United States of America As of July 20, 1997, the EPA closed the United States' border to the importation of PCBs (Federal Register/Vol. 63, No. 124/Monday, June 29, 1998/Rules and Regulations). The EPA can now only allow imports of PCBs by issuing exemptions to importers via the petition process under Section 6(e)(3)(B) of the Toxic Substances Control Act (TSCA). In light of this, facilities that were listed in the UN Inventories for PCB Waste Disposal Capacity as operating fixed facilities, such as chemical landfills, were not contacted. Efforts were made to contact all of the other facilities, though some did not return calls or email. Some, such as Safety Kleen, Laidlaw and TerraKleen had merged with other companies. Safety Kleen (Aragonite) and Laidlaw (Tucker, Georgia) have become Clean Harbors Environmental Services. Terra-Kleen Response is now merged with Sonic Environmental of Canada. Chemical Waste Management (Port Arthur, Texas) and Salesco Systems USA are now Veolia Environmental. Five facilities indicated an interest in the project. However, Trans-Cycle Industries and Full Circle Ballast Recyclers could not export their technologies to Vietnam, so declined to participate further. Veolia Environmental and Clean Harbors also indicated an interest. Veolia (United Kingdom) has indicated that it will partner with Orion B.V. (of the Netherlands) to dispose of PCB waste from Vietnam in the Netherlands. Mr. Cory Cook of Clean Harbors indicated an interest in the project but was not certain whether the technology could be imported to Vietnam. He passed on the request to Mr. Wes Wesolowski but no further information was submitted. Of the five facilities that were interested in the project, two were identified that could export their technology to Vietnam. These are described below. Commodore Applied Technologies Commodore Applied Technologies (Commodore) uses a cold chemical process involving a sodium-ammonia mixture to dehalogenate PCBs. Sodium is used because it is most readily available, but potassium, lithium and a sodium/potassium mix can also be used. The process is suitable for treating all types of PCB waste, and can destroy PCBs to levels less than 1 ppm, at a throughput of 10 tonnes per day (this is scaleable to meet the project's needs). No gaseous emissions are expected from the process, but the plant is monitored continuously for ammonia emissions in the event of a malfunction. Hydrogen may also be produced in theory if the water content in the waste is too high (typically, the water content should be less than 15% by weight), but Mr. James DeAngelis, Director and Senior Vice President, has indicated that this has never been observed in practice. He further indicated that the process is the only cold chemical process that has been authorized by the US EPA as a mobile process. This mobile process could be operated in Vietnam. By-products of the technology include sodium chloride and other inert salts, and biphenyls, which are produced in the form of a gummy paste, which has to be incinerated. SD Meyrs Inc. SD Meyers Inc. uses sodium for dechlorination of PCBs via the patented PCBX process, as well as solvent rinsing (using the Materials Recovery Process). The facility treats oils and other fluids that are contaminated up to 10,000 ppm (Askarel cannot be treated) as well as solids that are contaminated up to 5,000 ppm. The levels of I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 85 of 119 destruction vary according to the waste characteristics - PCB in oil is destroyed to "none-detected" as defined by less than 2 ppm, while metal surfaces are cleaned to 10µg/100cm2 and porous materials are cleaned to less than 50 ppm. The throughputs for PCB liquid are 600 to 700 gallons per hour (227L to 2650 L per hour). Mr. Joe Faherty, Project Manager at SD Myers, has indicated that there are no PCB emissions from the process. However, he has indicated that there is an oil fired heater that has acceptable emissions for most places. By- products include PCB free oil, PCB free solids and caustic water (non-PCB). Monitoring involves continuous monitoring for di-electric oil qualities and PCB content. A mobile Gas Chromatograph is used to determine PCB content in their containerized laboratory. The facility is transportable and can be operated in Vietnam. 5.2.2 Europe Beginning with the Single European Act (SEA) in 1987, environmental issues were formally introduced in law to the European Union. The SEA required all laws that may affect the environment to include safeguards for protection. With the signing of the Masstricht Treaty in 1992/3, environmental issues were further promoted by adopting the concepts of sustainable development. The EU issues directives to provide harmonized environmental legislation throughout the community. These directives clearly specify goals to be met by adjusting existing national legislation and implementing new legislation. Thus, the national legislation addressing each directive has the same foundation. With respect to hazardous waste management, some member-countries have their own regulatory regimes that have been developed over last few decades, but all are subject to meeting EU requirements as specified in various directives. For Germany and the United Kingdom, separate regulations have adopted EU requirements such as Direction 75/442/EEC respecting the definition of wastes and Regulation 259/932 respecting transboundary movements of waste. 5.2.2.1 Belgium Importation of hazardous wastes into Belgium is governed under the Council Regulation (EEC) No. 259/93 on the supervision and control of shipments of waste within, into and out of the European Community. Article 19 indicates that imports of hazardous waste are allowed from countries that are parties to the Basel Convention. These countries "shall be required to present a duly motivated request beforehand to the competent authority of the Member State of destination on the basis that they do no have and cannot reasonably acquire the technical capacity and the necessary facilities in order to dispose of the waste in an environmentally sound manner" (Article 19, Section 3). An internet search did not identify any news articles on public concerns arising out of waste importation into Belgium. One disposal company was identified in Belgium that was willing to accept waste from Vietnam for disposal, described below. SITA Decontamination N.V. SITA Decontamination n.v. (SITA) uses solvent flushing to clean transformers of PCB contamination. The oils that are drained from the transformers prior to flushing, capacitors and contaminated soils and sediments are also accepted by SITA but they are subcontracted for disposal to other European facilities, such as SITA Remediation (for PCB-contaminated soil), Indaver in Belgium (a shareholder of SITA Decontamination), and Akzo Nobel, in the Netherlands. Once the transformers are flushed, the solvent is recovered through distillation, and the recovered PCB waste is sent for incineration. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 86 of 119 SITA has indicated that if there are more than 10,000 tonnes of transformer waste, it may be worthwhile to set up a treatment facility in Vietnam. Failing that, waste would have to be imported into Belgium for treatment. Air quality monitoring is conducted by SITA for volatile organic carbons (VOCs) and PCBs. VOCs are monitored once a month and PCBs are monitored twice a year. 5.2.2.2 Denmark Importation of hazardous wastes into Denmark is governed under the Council Regulation (EEC) No. 259/93 on the supervision and control of shipments of waste within, into and out of the European Community. Article 19 indicates that imports of hazardous waste are allowed from countries that are parties to the Basel Convention. Kommunekemi a/s Kommunekemi a/s is a rotary kiln incinerator (involving three incineration plants) operated by Danish municipalities, established in 1971 to treat hazardous waste in Denmark. PCB destruction is undertaken by two incinerators, the first being a continuous operation for soil and liquids, and the second being a batch operation for electrical equipment including transformer solids. As this technology is fixed rather than mobile, waste must be exported from Vietnam for disposal. The throughput is 200,000 tonnes per year, with final products fulfilling EU requirements for incineration. Energy provided by incineration is used to provide electricity and heat for the plant and the district. Residual products are landfilled at Kommunekemi's landfill, except for filter dusts, which are landfilled in Norway. Emissions that are continuously monitored from each plant include dust/particulate matter, total organic carbon, hydrogen chloride, carbon monoxide, sulphur dioxide, and oxides of nitrogen. Twice yearly, hydrogen fluoride, metals, mercury, dioxins and furans are measured. Wastewater generated from the facility, including water from the flue gas cleaning, is discharged to the Nyborg wastewater treatment plant. 5.2.2.3 Finland Importation of hazardous wastes into Finland is governed under the Council Regulation (EEC) No. 259/93 on the supervision and control of shipments of waste within, into and out of the European Community. Article 19 indicates that imports of hazardous waste are allowed from countries that are parties to the Basel Convention. According to Section 6 of Government Decision 495/1998, imports of all wastes to disposal operations D2, D3, D4, D6, D7 and D11 are totally prohibited. Imports of all wastes to disposal operations D1, D5, D8, D9, and D10 are prohibited with certain exceptions (Country Report to the Secretariat of the Basel Convention, 2003). One facility was identified in Finland that disposes of PCB wastes, and was willing to accept waste from Vietnam, as described below. Ekokem Oy Ab Ekokem Oy Ab (Ekokem) is a high temperature incineration facility that treats transformers, capacitors, and contaminated oils and equipment. The main shareholders in Ekokem are the Finnish state, municipalities and a large number of industrial companies. The destruction efficiency of PCBs is rated as 99.9999%. As this technology is fixed rather than mobile, waste must be exported from Vietnam for disposal. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 87 of 119 Ekokem has three high temperature kilns, two of which are designed for incineration of organic hazardous waste, and one which is designed for treatment of contaminated soil as well as electronic scrap. Energy from incineration is recovered to provide electricity, district heat and steam for process operations. Byproducts produced include slag, ash and some wastewater. Slag is not considered to be hazardous and is either landfilled or used in road construction. Metal components extracted from the slag are sent for recycling. Ash is landfilled in Ekokem's own landfill, and wastewater is treated in Ekokem's water treatment plant. Some water is reclaimed as process water and the rest is sent to the Riihimäki Wastewater Treatment Plant. Environmental monitoring includes continuous monitoring of flue gases, as well as annual monitoring in accordance with the EU waste incineration directive, EC/2000/76. Parameters monitored include CO, SO2, dust, hydrocarbons, HCl, HF, Hg, other metals, dioxins and furans. Fugitive emissions and workplace hygiene are also monitored. 5.2.2.4 France According to France's country report to the Secretariat of the Basel Convention, "France has no restrictions on the transit and import of hazardous wastes and other wastes for final disposal and for recovery". Internet searches for opposition to the importation of hazardous waste identified one case where the Basel Action Network (BAN) opposed France's consideration of the importation of hazardous waste from Formosa Plastics, a Taiwanese company (http://ban.org/Library/france.html). The opposition was based on many factors, including the following: · The assumption that Formosa Plastics had the capability to stabilize the waste themselves; · The fact that the waste was not fully characterized so the Government of France could not state with certainty that it could be disposed of by Tredi; and · That no bilateral agreement with Taiwan, as required by the Basel Convention, was in place. The Government of France subsequently refused to allow the importation of this waste (http://repositories.cdlib.org/cgi/viewcontent.cgi?article=1004andcontext=uciaspubs/editedvolumes), which was finally disposed of in the Netherlands (http://archive.greenpeace.org/pressreleases/toxics/2000mar202.html). Facilities identified in France that were able to treat PCB wastes are included below. Elf Atochem (Arkema) Mr. Patrick de la Brosse from Elf Atochem indicated that Elf Atochem (Arkema) operates an incinerator for destruction of PCB oils and liquids and confirmed that waste could be accepted by Arkema for disposal if they are loaded in bulk, either in 20 MT isocontainers or in road-tankers. However, no further information was provided to SLI. Septra Septra is only able to remove oils from the transformers in Vietnam. Ms. Valerie Levy of Septra indicated that they would not be able to treat the wastes, either in Vietnam or in France. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 88 of 119 Aprochim SA Aprochim SA (Aprochim) uses a vacuum to remove oil from transformers (EnerVac technology), after which sodium is used to dechlorinate the PCBs. Soils are also accepted by Aprochim but they are placed into storage and sent for destruction by a sub-contractor (name withheld) in Germany. Pure PCBs are sent to Arkema for destruction. By-products include PCB contaminated clothing (incinerated by Bayer in Germany, concentrated PCBs from transformers and other equipment (sent to Arkema) and very small quantities of caustic liquid solution and salt. Tredi/GEP Mr. Hugh Levasseur and Mr. Boyne Drummond responded on behalf of both Tredi and GEP. As indicated by Mr. Drummond (the Asia Pacific Region Manager), the primary disposal option for PCBs, and in particular high strength askerals in transformers and capacitors, is the Tredi Saint-Vulbas High Temperature Incineration Facility located near Lyon in France. Depending on the quantity of waste and the degree of contamination, an in-country solution can also be developed. For electrical equipment from which there are salvageable components, solutions other than incineration could be considered, such as an autoclave to decontaminate metal components i.e. transformers, together with a chemical dechlorination plant to deal with the oil. For contaminated soil, an in-country solution is typical, and may entail mechano-chemical dechlorination or thermal desorption. The mechano-chemical option will dechlorinate the soil in situ, whereas the thermal desorption only removes and concentrates the PCB. The concentrate would then be treated either in country by the chemical plant, or exported to Tredi Saint-Vulbas. Daffos and Baudasse Daffos and Baudasse operate a sodium dechlorination facility in France that treats PCB oils. Mr. Serge Bouvier indicated that Daffos and Baudasse would be willing to accept PCB oils from Vietnam, for treatment in France, as long as PCB concentrations are less than 10,000 ppm. Mr. Bouvier has indicated that the facility is authorized by DRIRE, in France, but no environmental monitoring is conducted. 5.2.2.5 Germany Importation of hazardous wastes into Germany is governed under the Council Regulation (EEC) No. 259/93 on the supervision and control of shipments of waste within, into and out of the European Community. Article 19 indicates that imports of hazardous waste are allowed from countries that are parties to the Basel Convention. Most of the PCB disposal facilities in Germany utilize high temperature incineration technology. A recent article in Spiegel Online International in February 2007 (http://www.spiegel.de/international/spiegel/ 0,1518,467239,00.html) criticized the waste incineration industry in Germany, initiated by the importation of 22,000 tonnes of hexachlorobenzene from Orica, an Australian company, to be stabilized by 2008. The writer cited scientists who were of the opinion that even if emissions from the incinerators met discharge standards, small particles of carcinogenic substances (e.g. dioxins) emitted to the atmosphere eventually return to the ground, to be assimilated into the food chain. The article quotes Sigmar Gabriel, the German Environmental Minister from the Social Democrat Party (SPD), as stating "With its very good facilities for incinerating I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 89 of 119 hazardous waste, Germany is assuming a part of the general environmental responsibility." Mr. Gabriel was of the opinion that disposing of the waste in Germany was safer than letting it be improperly deposited elsewhere. PCB destruction facilities were identified in Germany from the 1998 and 2004 UN Inventories of Worldwide PCB Destruction Capacity. Several German facilities were listed in the 1998 inventory as being able to destroy PCBs but did not return completed questionnaires. Most were listed without names. Efforts were made to contact all of the facilities by the telephone numbers listed. It was found that some were repetitions of facilities already included in the main text of the questionnaire, while some, such as BASF and Wacker Chemicals, were unable to accept PCB waste for disposal. Some telephone numbers were also no longer in service. Facilities that were identified that could accept PCB waste from Vietnam or could set up a treatment facility within Vietnam are described below. Remondis Industrie Service Remondis Industrie Service (Remondis) is a waste management company with subsidiaries such as SAVA GmbH and TRV. Dr. Ramacher of Remondis indicated that SAVA would likely be the most appropriate disposal facility, given its proximity to Hamburg, a major port in Germany. As this technology is fixed rather than mobile, waste must be exported from Vietnam for disposal. SAVA uses high temperature incineration to dispose of transformers, capacitors, other contaminated equipment, soils and sludges, with a destruction efficiency of greater than 99.99%, at a throughput of 50,000 tonnes per annum. Pretreatment required includes dismantling and shredding, which is carried out by SAVA. By-products include slag, ash, and wastewater from the scrubbers. Slag and ash are disposed of and further treated to reclaim inorganic material and then landfilled, while wastewater is treated at the on-site wastewater treatment plant and incinerated in the plant. Environmental monitoring includes continuous monitoring for carbon monoxide, oxides of nitrogen, sulphur dioxide, hydrogen chloride, mercury, total carbon and particulates, and annual stack testing for hydrogen fluoride, metals, benzo[a]pyrene and dioxins and furans. AVG Hamburg AVG Hamburg (AVG) is a high temperature incineration facility operating a destruction facility of 100% at a throughput of 150,000 tonnes per annum. Waste treated includes transformers (< 20 cm), capacitors, oils, soils and sludges. As this technology is fixed rather than mobile, waste must be exported from Vietnam for disposal. Waste is accepted in accordance with AVG's General Conditions of Acceptance ­ Terms of Business ­ for the acceptance of wastes from abroad by the AVB Abfall-Verwertungs-Gesellshaft mbH. Assistance in transportation and packaging is only provided in collaboration with partner companies (names withheld). No pretreatment is required but containers are sometimes perforated prior to incineration to prevent the formation of carbon dioxide at concentrations greater than regulatory limits. By-products include fly ash, slag and gypsum, which are disposed of by landfilling, and steam, which is used for local heating. Emissions monitoring is conducted in accordance with the German federal emission legislation. Flue gases from the incineration unit are continuously analyzed prior to entry into the stack. After the stack, emissions are measured on a thirty-minute and daily basis. Monitoring data is transmitted directly to the AEHH Office for Emission Protection and Plants, allowing exceedances to be identified both by the plant and the regulatory office. Historically, exceedances of the limits for carbon monoxide have been identified by the 30-minute monitoring but I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 90 of 119 management has since instituted operational controls to limit the formation of carbon monoxide, including correlation of the waste inputs to oxygen demand. Bayer Industry Services GmbH and Co. OGH Bayer Industry Services (Bayer) operates a high temperature waste incinerator in Germany that treats small capacitors and transformers, other metallic and non-metallic equipment and soils and sludges. The destruction efficiency is 99.9999% at a capacity of 175,000 tonnes per year. As this technology is fixed rather than mobile, waste must be exported from Vietnam for disposal. Assistance with packaging and transportation is provided. By-products from the technology include ash and slag, which are disposed of in the Bayer landfill, and filter cake from the wastewater treatment, which is disposed of in Bayer's sludge incinerator. Environmental monitoring results are transmitted directly to the regulatory authority. One organization has been identified that is opposed to Bayer's activities ­ the Coordination Against Bayer Dangers. Dr. Bilger Umweltconsulting GmbH Dr. Bilger, President of Dr. Bilger Umweltconsulting GmbH, was contacted to determine whether his facility was able to treat PCB waste from Vietnam in Germany, or whether he would be interested in setting up a treatment facility there. Dr. Bilger has indicated that it would not be possible to import PCB waste into Germany due to the risk of transport of hazardous material, but that he would be willing to offer his sodium reduction technology along with associated hardware to a company that is willing to treat PCB waste in Vietnam, using either a mobile unit or a central treatment facility. Dr. Bilger's technology utilizes sodium to reduce PCBs present in oil and sludge, with a destruction efficiency of greater than 99.9999%, at a throughput of 2 tonnes per day in a mobile unit. Some pretreatment may be required, depending on the water content of the waste ­ sludge must be free of water and must be dispersed in oil. Water concentrations must be less than 150 ppm. No gaseous emissions are expected, with by-products produced including sodium chloride and small quantities of tar. No environmental monitoring is conducted. Dr. Bilger has indicated that several units, both stationary and mobile, have been constructed and placed into operation, with the oldest unit located in France, where it has been in operation since 1989. This unit is working in Villeurbanne, at the company, Daffos et Baudassée, where the sodium reduction process was combined with a continuous dechlorination step using a pipe reactor. The final PCB content is less than 2 ppm or 5 ppm, depending on the flowrate. Other units have been set up and implemented successfully in the Netherlands (treating to less than 50 ppm as requested) and in England (treating to less than 1 ppm as requested). Envio Recycling GmbH and Co. Envio Recycling GmbH (Envio) utilizes high temperature incineration, solvent washing and sodium reduction to clean transformers, capacitors, contaminated equipment and sludges and soils. The destruction efficiency is 99.9999% for both technologies (incineration and reduction) at a throughput of 6,000 tonnes per annum. Waste is initially washed using solvents to remove PCB contamination. The metals are separated, and the remaining solid materials and Askarel are destroyed in the incinerator. Low level PCBs are destroyed using solvent reduction. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 91 of 119 Waste can be imported into Germany for treatment, or a treatment facility can be set up in Vietnam. However, in order to set up treatment in Vietnam, at least 1,000 tonnes of waste is required. Transportation and packaging services are provided if required. Environmental monitoring is conducted by the local authorities. Mr. Helmut Bergel of Envio has indicated that there has never been a non-compliance with their environmental authorization and other environmental standards. GSB Sonderabfall-Entsorgung Bayern GmbH Mr. Matthias Krämer of GSB Sonderabfall-Entsorgung Bayern (GSB) has indicated via electronic mail that by a decision of its supervisory board, GSB has restricted its activities to waste generated in Europe and the Mediterranean and as such, is not in a position to accept waste for disposal from other regions. HIM GmbH HIM GmbH (HIM) operates a high temperature incineration plant using two rotary kilns that are able to treat transformers, capacitors, and contaminated oils, soils and equipment at a destruction capacity of 99.9999% at a throughput of 120,000 tonnes per year. As this technology is fixed rather than mobile, waste must be exported from Vietnam for disposal. Transportation and packaging services are provided if required. By-products include slag, boiler ash, dust from electrostatic filters and material recovered from flue gas purification, which are disposed of in underground salt mines. Energy produced is used to generate electricity. Environmental monitoring is conducted in accordance with the Federal Immission Control Act. Parameters monitored include dioxins and furans, PCBs, dust, fluoride, chloride, hydrogen sulphide and metals (intermittent measurements) and dust, carbon monoxide, sulphur dioxide, mercury, NOx, total hydrocarbons, ammonia, temperature and oxygen. K+S Entsorgung GmbH K+S Entsorgung GmbH (K+S) disposes of waste in an underground salt mine, the Herfa-Neurode underground waste disposal plant which began operations in 1972. The disposal cavity is located in a 300 m thick rock salt formation, at a depth of 800 m. Cavities that are used for storage of waste have been rendered safe by scaling the ceilings and installing steel bolts in the top rock to reinforce it. Floors have also been constructed to enable forklifts and trucks to travel safely. The mining is conducted using a "room and pillar system", in which salt columns are left standing to hold the overlying rock in its original position. Once the salt mining is complete, the shafts connecting the underground chambers and the surface will be filled with solid material, creating a watertight seal, separating the stored material from the surface environment. As this technology is fixed rather than mobile, waste must be exported from Vietnam for disposal. The types of waste that are accepted include transformers (once they are emptied and treated), capacitors and contaminated soils and sludges (must contain no liquids). Packaging will depend on the type and characteristics of the waste, but the standard disposal plant packaging is a 200 L steel drum lined with a thick-walled polyethylene bag. Transformers can be stored without packaging or wrapped in a protective plastic film if they have been cleaned and made safe beforehand. K+S will provide packaging advice on the waste, and will supply materials for packaging. K+S will also provide advice on transportation, and will coordinate and handle the transportation of the waste, if required. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 92 of 119 Industrial safety is monitored at the facility to ensure the safety of its personnel. Gas collected by gas tubes, gas pumps, and air samples taken directly with gas containers, are tested using gas chromatography. Workplace measurements are also carried out by independent testing institutes. Prantner Dr. Ulrich Korherr of Prantner was contacted to determine whether PCB waste from Vietnam could be disposed of at Prantner's facility in Germany, or if a treatment facility could be set up in Vietnam. Dr. Korherr initiated contact with Dr. Roland Weber of POPs Environmental Consulting, a partner of Prantner, who indicated via a telephone conversation that POPs Environmental Consulting would not be able to accept waste from Vietnam or set up a treatment facility there. The reason for this is that the technology in use is not suitable for treatment of PCB waste on a commercial scale. 5.2.2.6 Italy Importation of hazardous wastes into Italy is governed under the Council Regulation (EEC) No. 259/93 on the supervision and control of shipments of waste within, into and out of the European Community. Article 19 indicates that imports of hazardous waste are allowed from countries that are parties to the Basel Convention. Two facilities were identified in Italy that are involved in PCB waste treatment. Neither facility is able to import waste into Italy for treatment, but both can set up mobile units within Vietnam to treat waste there. Ecolsir SRL Ecolsir SRL (Ecolsir) decontaminates solid materials contaminated with PCBs using solvent washing under a vacuum autoclave. PCBs are extracted from the solvents using vacuum distillation and dehalogenated. Transformers, capacitors, PCB liquids and oils, and contaminated soils and sludges can be treated using this technology. Throughputs vary, depending on the technology in use ­ 2000 tpa can be extracted using the vacuum autoclave unit and fractional distillation to remove the solvent, and 3000 tpa can be dehalogenated. Destruction efficiencies vary depending on the type of material ­ non-porous materials can be cleaned to less than 5 ppm while porous materials can be cleaned to less than 50 ppm. Mineral oil can be cleaned to less than 1 ppm while water and other fluids can be cleaned to less than 0.5 ppm. All treatment units are equipped with a laboratory. Environmental monitoring consists mainly of monitoring incoming and outgoing materials for PCB concentration. Sea Marconi Technologies SAS Sea Marconi Technologies SAS (Sea Marconi) treats PCB-contaminated oil from transformers using mobile units in the country in which the waste is generated. Transformers are treated while on-line, using a dehalogenation reaction (D5-CHEDCOS and CDP Process) in a continuous, closed loop process. The patented reagent reacts with the PCBs to form inert salts. Transformers with PCB concentrations of 1,000 ppm can be treated to less than 20 ppm. 5.2.2.7 Netherlands Importation of hazardous wastes into the Netherlands is governed under the Council Regulation (EEC) No. 259/93 on the supervision and control of shipments of waste within, into and out of the European Community. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 93 of 119 Article 19 indicates that imports of hazardous waste are allowed from countries that are parties to the Basel Convention. PCB destruction facilities identified in the Netherlands include: Akzo Nobel Base Chemicals Akzo Nobel Base Chemicals (Akzo Nobel) operates a high temperature incineration facility coupled with the recovery of hydrogen chloride gas. The unit is located in Rotterdam-Botlek. As this technology is fixed rather than mobile, waste must be exported from Vietnam for disposal. Transportation and packaging services are not provided. Contaminated waste is treated with a destruction efficiency of 99.999% at a throughput of 40,000 tonnes per annum. Pre-treatment is not required. By-products of the technology include a 30 to 33% HCl solution, which is sold for various industrial applications, such as for pH adjustment in wastewater treatment plants. Total organic carbon, HCl, oxides of nitrogen, oxygen, carbon monoxide and dust are measured in the flue gas by online analyzers to meet the requirements of the permit issued by the authorities. AVR Mr. Marco Kortland, Director of Corporate Relations, indicated via electronic mail that AVR has closed its facilities for the incineration of hazardous waste using rotary kilns, making it impossible for them to accept PCB waste for disposal. Orion b.v. Orion b.v. (Orion) operates a cold rinsing technology to extract PCB waste from transformers, capacitors and other contaminated equipment. PCB-contaminated solids waste (such as sludges), soils and oils are also accepted but the destruction of these wastes is subcontracted to other partners in Rotterdam and in other parts of Europe. Orion has indicated a preference for treatment of waste in the Netherlands, rather than in Vietnam. Capacitors are cleaned with approximately 60% efficiency, whereas transformers are cleaned with 95% efficiency. Components of capacitors that cannot be cleaned are sent to other treatment facilities for treatment (including incineration). Orion's partners include SAVA and AVG in Germany and Veolia Environmental in the United Kingdom. Once the equipment has been dismantled and washed with solvents, the solvents are subjected to fractional distillation to recover the solvents. The concentrated wastes are sent to partner treatment facilities in Europe for ultimate destruction. Approximately 95% of transformer materials and 50% of capacitor materials are recovered for recycling. Air monitoring and water quality monitoring is conducted in accordance with the conditions of Orion's environmental permit. Cleaned materials are also analyzed prior to release from the plant. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 94 of 119 5.2.2.8 Norway In Norway's 2003 country report to the Secretariat of the Basel Convention, Norway indicated that it restricts the transit, import of hazardous wastes and other wastes for final disposal and for recovery. The Norwegian regulation of December 30, 1994 on transboundary movement of waste, implementing EU Regulation no. 259/93, was amended April 1, 2003. The amendments include country lists taken from the two EU Regulations 1420/1999 and 1547/1999. Norway may give consents for import of waste for disposal, mainly landfilling, but normally only to waste originating from Nordic countries. The restrictions apply to all states except members of OECD, EC and Liechtenstein, see annex VII of the Basel Convention. One company, Norcem, was identified as having the ability to treat PCB waste. Mr. David Verdu of Norcem forwarded the details of the project to Mr. Per Brevik, of Heidelberg Cement, which accepts waste from Norcem for alternative disposal via cement kiln co-processing. Mr. Brevik, in an electronic mail, indicated that they were not interested in the project. 5.2.2.9 Sweden Importation of hazardous wastes into Sweden is governed under the Council Regulation (EEC) No. 259/93 on the supervision and control of shipments of waste within, into and out of the European Community. Article 19 indicates that imports of hazardous waste are allowed from countries that are parties to the Basel Convention. Other relevant regulations include the Swedish Ordinance on Transboundary Movements of Waste (SFS 1995:701). One facility was identified in Sweden that is able to accept waste from Vietnam for treatment, as described below. Sakab Sakab operates a high temperature rotary kiln incinerator for the destruction of PCB wastes, as well as biological treatment for low-level contaminated soils. Sakab indicated that disposal of PCB-contaminated transformers, capacitors and other contaminated equipment, solids, liquids and soils at their facility would be allowed, but was unable to give definitive destruction efficiencies, for either the incineration or the biological testing. Mr. Häkan Hagström of the Marketing and Sales Department indicated that to provide this information, a pilot plant would have to be set up. The throughput of the facility is 2,000 tonnes per annum. As the incineration technology is fixed rather than mobile, waste to be incinerated must be exported from Vietnam for disposal. However, for biological treatment, Mr. Häkan indicated that this may be done in Vietnam. No information was provided on the characteristics of the biological treatment. By-products of the incineration technology include material generated from flue gas purification, which is a dry ash, and filter cake from a wet scrubber. Water is evaporated and recirculated, resulting in a zero liquid discharge. Ashes are landfilled in a hazardous waste landfill in accordance with the EU directive on landfills. Environmental monitoring involves continuous monitoring of mercury, hydrogen chloride, carbon dioxide, oxides of nitrogen, carbon monoxide, total organic carbon, sulphur dioxide and dioxins and furans. Annual monitoring is conducted on cadmium, TI, hydrogen fluoride, mercury and dioxins and furans. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 95 of 119 5.2.2.10 Switzerland In the 2003 country report to the Secretariat of the Basel Convention, Switzerland indicated that it has no restrictions for the import of hazardous wastes and other wastes for final disposal and for recovery, but that imports require notification and consent. Importation is governed by the Basel Convention. The regulation requiring consent is the VeVA ­ Verordnung über den Verkehr mit Abfällen. Two facilities were identified that are able to treat PCB waste from Vietnam, as described below. Novartis (a pharmaceutical company) was contacted to determine whether it was possible to import waste from Vietnam for disposal. Mr. Hassan Nekoui indicated that the incinerator is used for Novartis waste only. EMS-Dottikon EMS-Dottikon operates a high temperature incinerator suitable for the treatment of transformers, capacitors and contaminated soils, oils and equipment. No pretreatment is required and the destruction efficiency is rated as 100% at a throughput of 8,500 tonnes per annum. As this technology is fixed rather than mobile, waste must be exported from Vietnam for disposal. Packaging services are provided by Dottikon ­ only waste that is packaged with dimensions 90 cm height and 60 cm diameter is accepted. Transportation services are not provided but the company recommends the use of 3E Logistic AG, which is experienced in international shipment of waste. By-products include wastewater, slag, filter ash and filter cake. Wastewater is subjected to physical and chemical treatment, with the resulting filter- cake stabilized and disposed of in a salt mine in Germany. Ash is stabilized and also disposed of at a salt mine in Germany. Slag is disposed at a surface landfill in Switzerland. Continuous air monitoring is conducted for oxides of nitrogen, and carbon monoxide. Annual monitoring is conducted for solids, oxides of nitrogen, carbon monoxide, oxides of sulphur, volatile organic carbons, hydrogen chloride, bromine, fluorine, ammonia, and metals. Wastewater monitoring is conducted for non-purgeable organic carbon (NPOC), mercury and fluorides. Valorec Services AG Valorec Services AG (Valorec) operates a high temperature incinerator that is able to treat capacitors and PCB oils, as well as contaminated soils and equipment. The destruction efficiency is 99.9999% at a throughput of 25,000 tonnes per year. No pretreatment is required. As this technology is fixed rather than mobile, waste must be exported from Vietnam for disposal. Transportation and packaging services are provided in collaboration with an external company. By-products of the technology include superheated steam, electricity, cleaned flue gas, wastewater from flue gas cleaning, slag and sludge. Wastewater is subjected to physical/chemical treatment after which it is released in the river. Slag is disposed of in a Swiss landfill while sludge is disposed of in a salt mine in Germany. Liquid effluents, air emissions (treated flue gas), and the slag and metal hydroxide sludge are monitored. 5.2.2.11 United Kingdom Importation of hazardous wastes into the United is governed under the Council Regulation (EEC) No. 259/93 on the supervision and control of shipments of waste within, into and out of the European Community. Article 19 indicates that imports of hazardous waste are allowed from countries that are parties to the Basel Convention. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 96 of 119 The United Kingdom's Country Report to the Secretariat of the Basel Convention (2003) indicated that the United Kingdom of Great Britain and Northern Ireland restricts the import of hazardous wastes and other wastes for final disposal. The general policy is that wastes should not be imported for disposal in the UK and imports of all wastes for disposal are prohibited, except in limited circumstances. Importation may be permitted where the exporting country does not have and cannot be expected to acquire suitable disposal facilities, and from countries where wastes cannot realistically be dealt with in an environmentally sound manner. Three facilities were identified that are capable of treating PCB waste, Shanks, Veolia and Celtic Recycling. It was not possible to obtain information from Shanks as the company does not release contact information for personnel, and Mr. Bowen, the contact person listed in the UN Inventories, was no longer on staff. It was advised to send an email to the general delivery mailbox, which was done, but after a subsequent follow-up email requesting more information, which was provided, no further communication was received. Celtic Recycling Since 1997, Celtic Recycling has operated a solvent washing process to remove PCBs from contaminated equipment. In 2003, they acquired the hardware and intellectual property rights to Grosvenor Power's "Poly- Gon" mobile dechlorination plant. This process has since been developed further by Celtic Recycling into a process known as "Draigful". The destruction efficiency is 100%, at a throughput that is scaleable to meet the project's needs. The treatment is a two-stage process ­ the Draigful unit treats the liquid PCBs while the solvent wash process is used to decontaminate equipment. Solvent that has reached the end of its useful life, along with non-recoverable solid waste components are sent for incineration. Spent catalyst from the Draigful unit as well as sludge generated is also currently sent for incineration. However, Celtic Recycling is now investigating the possibility of using these materials as fuel, as they have a calorific value similar to coal. Due to the nature of the process, Celtic Recycling is not required to monitor emissions, although they are required to implement waste management controls in accordance with conditions of their waste management licence. Mr. James, the Managing Director of Celtic Recycling, has indicated that importation of waste for treatment into the UK would be possible. However, they would also be interested in setting up a treatment facility in Vietnam. Veolia Environmental Mr. Neil Revera of Veolia Environmental has indicated that Veolia can assist with disposal of PCB waste from Vietnam through one of its European partners, Orion B.V., as described above. 5.3 Summary European Union Many of the facilities identified within the European Union as capable of treating PCB waste are willing to assist with the disposal of PCBs from Vietnam. The majority of the facilities indicated a preference for importing waste for treatment (20 facilities) while some (6 facilities) indicated they were interested in treating waste in Vietnam. It should be noted that some facilities, such as Sita Decontamination (solvent flushing and sub-contracted incineration), Tredi Seche Global Solutions (various technologies), Celtic Recycling (catalytic dehalogenation) and Sakab (high temperature incineration and biological remediation) are capable of both importation and treatment in Vietnam, depending on the waste volumes and characteristics. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 97 of 119 In terms of technology, incineration was the predominant method of disposal, which accounts for the marked preference for importation, as these plants are not mobile. Other technologies include sodium reduction, catalytic dehalogenation and long term disposal in a salt mine. One facility in France (Tredi Seche Global Solutions) offered a variety of technologies, the selection of which will depend on the waste characteristics. North America In accordance with federal law, PCBs cannot be imported into the United States except under special exemption in accordance with the TSCA. This eliminated many fixed treatment facilities in the United States who are not able to export their technologies to Vietnam. However, two facilities were identified that are able to treat waste in Vietnam. One uses solvated electron technology while the other uses sodium reduction. In Canada, importation of PCBs is legally permissible. However, of the seven Canadian facilities that expressed an interest in this project, three (Swan Hills Treatment Centre, Hazco Environmental Services (which works closely with the Swan Hills Treatment Centre), and Bennett Environmental Inc.) indicated that waste will be imported for treatment within Canada while four (Sonic Environmental Solutions Inc., Kinectrics Inc., Hallett Environmental and Technology Group Inc. and Sanexen Environmental Services Inc.) indicated a preference for treatment within Vietnam. The Swan Hills Treatment Centre and Bennett Environmental Inc. both employ high temperature thermal destruction facilities. With the exception of Hallet Environmental and Technology Group, which uses GPCR, the other facilities use alkali reduction (sodium or potassium). A summary of the findings of Task 4 is presented in Table 5.1 below, from a waste acceptance perspective. A summary of the non-regional options for PCB disposal is presented in Table 5.2, which presents more detailed information on the facilities evaluated. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 98 of 119 Table 5.1 : Summary of Task 4: European and North American Disposal Options Number of Number of Willing to Number of facilities Facilities for Facilities Accept Number of facilities willing to set up PCB Successfully Waste from willing to import mobile facility in Destruction Contacted Vietnam? Vietnam Identified Europe Belgium 1 1 Yes 1 (also willing to treat 1 (also willing to waste in Vietnam, import) depending on volumes). Denmark 1 1 Yes 1 0 Finland 1 1 Yes 1 0 France 5 5 Yes 4 (one facility also willing 1 (also willing to to treat waste in Vietnam) import) Germany 13* 12 Yes 6 1 Italy 2 2 No 0 2 The Netherlands 2 2 Yes 2 0 Norway 1 1 No 0 0 Sweden 1 1 Yes 1 ­ may also treat some 1 ­ also willing to waste in Vietnam import for incineration Switzerland 3 3 Yes 2 0 United Kingdom 3 2 Yes 2 (one facility also willing 1 (also willing to to treat waste in Vietnam) import) Task 4: North America Canada 10 10 Yes 3 4 United States 16** 8 No 0 2 * Some facilities could not be contacted because no names were listed in the UN Inventories, and contact information was invalid. **Chemical waste landfills were not considered due to prohibition of imports of PCB wastes into the United States. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc Table 5.2 : Details of Task 4: European and North American Disposal Options Page 1 of 5 Disposal Cost (USD) Import or Destruction Constraints/ Non-metallic Facility Throughput Technology Treat in Metallic PCB Efficiency Remarks Oil PCB Transformers Capacitors Soils Sludges Vietnam? Equipment Equipment Sita 7500 tons/year. SITA uses solvent flushing to 100% Import. $613/ton $1200/ton $2250/ton $1023/ton $1636/ton Depends on Depends on Decontamination clean transformers of PCB waste waste N.V. (Belgium) contamination. The oils that characteristics. characteristics. are drained from the transformers prior to flushing, capacitors and contaminated soils and sediments are also accepted by SITA but they are subcontracted to other European facilities. Bennett Récupère Sol Inc.: 1. High temperature thermal 99.9999% Import. $2668/tonne (< 500 Disposal of Disposal of $1049/tonne (< $4050/tonne (PF $572/tonne $4955/tonne Environmental 100,000 tpa treatment. ppm) shreddable shreddable 500 ppm) capacitors) (Canada) Material Resource 2. Solvent washing. $4955/tonne (> 500 debris: debris: $1430/tonne (> $ 3335/tonne Recovery Inc: 0.5 ppm) $4479/tonne $4479/tonne 500 ppm) (potheads) tonnes/hour Disposal of non-Disposal of > 50 ppm priced $2668/tonne Transcycle Industries: shreddable non- on application. (standard not determined. debris: $5927 shreddable fluorescent debris: $5927 ballasts) Hallet 1000 tonnes per year ­ Gas Phase Chemical >99.9999% Treat in $2,300/tonne - $1,300/tonne - Depends on $1,300/tonne - $1,300/tonne - $500/tonne $500/tonne Environmental can be scaled to suit. Reduction (GPCR) Vietnam. assumes 100% assumes 40% the organic assumes 40% assumes 40% (assumes low (assumes low and Technology PCB PCB content, not PCB. PCB. concentrations concentrations Group (Canada) just the PCB of PCBs) of PCBs) content Hazco 40,000 tpa. High temperature incineration. 100.00000% Import. Hazco collects $3330/tonne (< 500 $6270/tonne $6270/tonne Evaluated on a $6270/tonne $1430/tonne $6600/tonne Environmental and diverts PCB ppm PCB) (shreddable (shreddable case by case Services and waste to Swan $6600/tonne (> 500 solids) solids) basis, depending Swan Hills Hills ppm PCB) $8650 (non- $8650 (non- on size, residue, Treatment Facility shreddable shreddable etc. (Canada) solids) solids) Kinectrics Inc. low level oils: (<10,000 Sodium Reduction >99.9999% Treat in Price cannot be $0.9 - $7/L $400 - $500 - $500 - $500 - Is not treated. Is not treated. (Canada) ppm) = 1500 l/batch; (measured in pure Vietnam. accurately quoted $1200/tonne $1500/tonne $1500/tonne $1500/tonne High level oils: PCBs) because waste (>50,000 ppm) = 600 to characteristics are 1000 kg/batch (approx. unknown. 330 to 550 L per batch). Paper from capacitors = 100 kg of paper per day. Total capacitors = 700 kg/day Metals: 5 metric tonnes per day. Sanexen Custom according to Chemical destruction of PCBs PCB concentrations Treat in $3140/tonne (< $2850/tonne $2850/tonne $2850/tonne $6180/tonne $950/tonne $6180/tonne (Canada) needs. (reduction using potassium) are reduced to less Vietnam or 10,000 ppm) Decontamination of than 2 or 50 ppm in oil import into $6180/tonne (> transformers for metal as desired and another 10,000 ppm) recovery. surfaces are brought country (to be to less than 10 µg/100 determined). cm2 for transformers. Table 5.2 : Details of Task 4: European and North American Disposal Options Page 2 of 5 Disposal Cost (USD) Import or Destruction Constraints/ Non-metallic Facility Throughput Technology Treat in Metallic PCB Efficiency Remarks Oil PCB Transformers Capacitors Soils Sludges Vietnam? Equipment Equipment Sonic Scaleable system. Solvent extraction and PCB 99.99990% Treat in $4/L Not treated. Not treated. Depends on size Not treated. $620/tonne $620/tonne Environmental Typical size is 2000 destruction by SonoprocessTM Vietnam. of transformer. Solutions Inc. tonne/soil/ month treatment chain for PCB (Canada) contaminated soils, waste and liquids. Kommunekemi as 200000 tpa High temperature incineration. Meets EU directive Import. Actual cost will $540/tonne $1000/tonne $1000/tonne $6100/tonne $6100/tonne $1000/tonne $1000/tonne (Denmark) EC/2000/76. depend on the chloride content. Ekokem Oy Ab 90,000 tpa High temperature incineration. 99.9999% Import. Cost depends on $272 - $1904/tonne $680 - No price $925 - $1088 - $136 - $136 - (Finland) PCB concentration $1360/tonne provided. $1088/tonne $1360/tonne $1360/tonne $1360/tonne (higher concentrations = higher price) and waste volumes (greater volumes = lower price). Aprochim Solid waste: 30,000 tpa Vacuum removal of PCBs from Less than 5 ppm and Import. Prices depend on $160 ­ $820/tonne $1090 - $1020 - $200 ­ $1360 - $1090/tonne $950 - (France) Oil: transformers, followed by can reach zero on concentration of $2040/tonne $1630/tonne $1360/tonne $1630/tonne $2040/tonne 10,000 tpa dechlorination (sodium). Some solid parts. PCBs, and in the Pure PCB: PCBs sent for incineration. case of sludges, 5,000 tpa also on the water content. Tredi Seche Thermal: 40,000+ Thermal, Autoclave, Thermal: better than Import or treat Prices do not $2,250/tonne $ 2,550/tonne $ 2,550/tonne $ 2,550/tonne $ 2,750/tonne Analysis Analysis Global Solutions tonnes/year desorption, filtration, Biological, 99.9999% in Vietnam. include VAT. The required before requried before (France) Chemical dechlorination, type of technology pricing. pricing. Mechano-chemical destruction. selected, and hence the pricing, will depend on the waste characteristics. Daffos and 2000 tpa Sodium dechlorination. < 2ppm Import. Maximum PCB $150/tonne Not treated. Not treated. Not treated. Not treated. Not treated. Not treated. Baudasse concentration (50 99,9999% Import. Prices depend on $136 - $1088/tonne $544 - $544 - $748 - $476 - $544 - $544 - Services GmbH & concentration of $1088/tonne $1088/tonne $884/tonne $2108/tonne $884/tonne $884/tonne Co. OHG PCBs and (Germany) packaging required. Dr. Bilger 2 tons per day in mobile Sodium reduction. >99.9999% Treat in Need a partner $400/tonne Not treated. Not treated. Not treated. Not treated. Not treated. Not treated. Umweltconsulting unit Vietnam. company to work GmbH (Germany) with. Envio Recycling 6000 tpa Solvent washing, sodium High temperature Import. $1360 - $1360 - $1360 - $1360 - $1360 - $1360 - $1360 - GmbH & Co. KG reduction and high temperature incineration: $3400/tonne $3400/tonne $3400/tonne $3400/tonne $3400/tonne $3400/tonne $3400/tonne (Germany) incineration. 99.9999% or Sodium reduction: 99.9999% HIM GmbH 120000 tpa High temperature incineration 99.9999% Import. Acceptance of $136-$1088/tonne $816/tonne $136- Cost not $816/tonne $340-$680/tonne $340- (Germany) capacitors limited $680/tonne provided. $680/tonne to those less than 5kg. K+S Entsorgung 200000 tonnes total Long term storage - N/A Import. Accepts material Not accepted. $354/tonne $354/tonne $354/tonne $354/tonne $354/tonne $354/tonne GmbH (Germany) capacity underground salt mine. that does not contain liquid. SAVA/Remondis 50,000 tpa High temperature incineration. >99.99% Import. $272-$680/tonne $680/tonne $816/tonnne $1360/tonne $1632/tonne $816/tonne $816/tonne (Germany) ECOLSIR Srl 2000 tpa Dehalogenation and < 5 ppm (non porous Treat in Pure liquid PCBs: $30/ton Non-porous Containing 25% 45% of liquid $900/ton after $900/ton after (Italy) incineration (subcontracted). material) Vietnam. $1200/ton (for the solid materials: of liquid PCB PCB (askarel): water removal. water removal. <50 ppm (porous Import pure (included the cost of materials) $30/ton (askarel): $1200/ton; material) PCBs to the transport to + $1200/ton +$1200/ton (for $30/ton < 1ppm (mineral oil) incinerator. incinerator) (for liquid PCB extracted liquid + $1200/ton (for 35% of porous < 0,5 ppm (water, extracted) PCB) extracted liquid materials: solvent and other Mineral oils (up to PCB) $500/ton fluids) 1% PCBs) Porous $0.30/ton materials: Containing 25% 20% of 500 $/ton of PCB recuperating +1200$/ton (for contaminated material: $30/ton extracted liquid mineral oil: PCB) $30/ton + $0.30/ton (for the treatment of extracted oil) Sea Marconi Can be scaled to suit Dehalogenation of transformers 99.9% Treat in Reagent Not treated. $8.16-$9.52/kg Not treated. Not treated. Not treated. Not treated. Not treated. (Italy) online. Vietnam. consumption is of reagent. approximately 5% the weight of the oil. Akzo Nobel Base 40,000 tpa High temperature incineration 99.999% Import. $374-$408/tonne Not treated. Not treated. Not treated. Not treated. Not treated. Not treated. Chemicals (The with recovery of hydrochloric Netherlands) acid gas. Table 5.2 : Details of Task 4: European and North American Disposal Options Page 4 of 5 Disposal Cost (USD) Import or Destruction Constraints/ Non-metallic Facility Throughput Technology Treat in Metallic PCB Efficiency Remarks Oil PCB Transformers Capacitors Soils Sludges Vietnam? Equipment Equipment Orion B.V (the 4,000-20,000 tpa Cold-Rinsing with solvents and 60-95% depending on Import. Actual cost will $1360/tonne $1700/tonne $2040/tonne $1360/tonne $2040/tonne $1360/tonne $1360/tonne Netherlands) PCB extraction; incineration type of PCB-waste depend on the and final recycling of metals (60% for PCB waste and oils subcontracted. capacitors and 95% characteristics. for full PCB- transformers). Sakab (Sweden) 2000 tpa Primarily by high temperature The destruction Import. $1000/tonne $1200/tonne $1000/tonne $250/tonne $1000/tonne $700/tonne $1000/tonne incineration (rotary kiln at efficiency is up to the (depends on the 1400C); to a lesser extent by EU-directive on price of copper) biological treatment of low incineration. The contaminated soils. destruction efficiency for biological treatment depends on the initial concentration level, the type and density of the matrix and the time of treatment. A pilot test will give more details. EMS-Dottikon 8500 tpa High temperature incineration. 100% Import. $1143/tonne $1905/tonne $1715/tonne $1905/tonne $1905/tonne $1651/tonne $1651/tonne (Switzerland) Valorec Services 25,000 tpa High temperature incineration. 99.9999% Import. Delivery in drums $164-$1230/tonne $164- $164- $164- $164- $164- $164- AG (Switzerland) (max 0.6 m $1230/tonne $1230/tonne $1230/tonne $1230/tonne $1230/tonne $1230/tonne diameter, 0.9 m height) or IBC (1 m3). The prices depend on the type of waste, its concentration of contamination and its conditioning. The largest possible packaging will be defined for each waste category in order to offer lowest incineration price. Celtic Recycling Scaleable to project Catalytic destruction ('Poly-gon' 100% Import. De-sludging of Unable to quantify ­ disposal projects encompass variable factors which preclude the possibility of generic pricing. (United Kingdom) needs mobile de-chlorination plant, contaminated oil is further upgraded to the preferred, but not Draigufel version). necessarily mandatory. Veolia See Orion b.v., a partner company of Veolia Environmental (United Kingdom). Table 5.2 : Details of Task 4: European and North American Disposal Options Page 5 of 5 Disposal Cost (USD) Import or Destruction Constraints/ Non-metallic Facility Throughput Technology Treat in Metallic PCB Efficiency Remarks Oil PCB Transformers Capacitors Soils Sludges Vietnam? Equipment Equipment Commodore 10 tonnes per day Cold Chemical Process ­ Destroyed to less than Treat in If the waste $5512 - $5512 - $5512 - Whole Whole $5512 - $5512 - Applied (scaleable to project dehalogenation reaction ­ 1 ppm. Vietnam. comprises large $6614/tonne $6614/tonne $6614/tonne transfomers not capacitors not $6614/tonne $6614/tonne Technologies needs). reduction. Sodium mixed with PCB-soaked treated to date. treated to date. (United States) ammonia, which is mixed with rocks, they have For dismantled For dismantled waste. to be crushed. transformers, capacitors same Capacitors and same price as price as metallic transformers will metallic PCB PCB equipment have to be equipment ($5512 - dismantled. ($5512 - $6614/tonne) SD Myers Inc.- 2271 ­ 2650 L per Sodium dechlorination. PCB in oil is Treat in If the oil is in $6614/t been found economically advantageous to other means of ) Upon specialized request only. The costs for processing have Tallmadge, Ohio hour. destroyed to "none- Vietnam. storage tank treatment due to the efficiency of the processing. (United States) detected" as defined farms, there is a by less than 2 ppm. high possibility of Metal surfaces are water cleaned to contamination that 10µg/100cm2. Porous hinders efficiency. materials must be This oil would less than 50 ppm. need to first be dehydrated by SDMI Equipment. SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 99 of 119 6.0 INTERIM SUMMARY 6.1 Technologies for PCB Destruction by Waste Matrix Selecting remedial technologies for a national environmental clean-up program of PCBs is a complex exercise that includes the technical issues discussed in this report, but also economic, political and social issues that were not the subject of this report. The technical constraints applied to these recommendations were discussed in Section 2 and each technology must meet the following attributes: 1. proven for PCBs; 2. commercialized; 3. a good track record for PCB treatment; 4. robust enough to deliver in Vietnam without significant limitations; 5. safe with respect to human health and the environment; and 6. local and international regulatory required. Furthermore, it would be desirable if the technology had the following attributes: · Treats a wide variety of contaminated media; · Not limited by contaminant concentration; · Efficient use of inputs (electricity, bulk chemicals, etc.); · Minimal hazardous outputs including air emissions. After applying these constraints, the following technologies have the potential for near-term successful application in Vietnam. 6.1.1 Soil and Soil-like Materials PCB contaminated soils may be efficiently handled by: Anaerobic / aerobic composting; Based catalyzed decomposition process (BCD); Cement kiln co-processing; Enhanced bioremediation (in situ); Gas Phase Chemical Reduction (GPCR); Incineration (mobile plant) In-situ vitrification; Plasma arc decomposition (Plascon, Pact process). 6.1.2 Water and Aqueous Solutions Aqueous liquid waste contaminated with PCBs may be efficiently processed by: Advanced Oxidation Process (AOP); Base catalyzed decomposition process (BCD); Gas Phase Chemical Reduction (GPCR); TiO2 enhanced photocatalysis (Photo-Cat, Purifics); Wet Air Oxidation (WAO) technology, low concentrations only and requires successful waste tests. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 100 of 119 6.1.3 Sediment, Sludge and Slurries Slurries contaminated with PCBs may be destroyed by: Base catalyzed decomposition process (BCD); Cement kiln co-processing; Gas Phase Chemical Reduction (GPCR); Plasma arc decomposition (Plascon); Wet Air Oxidation (WAO) technology, low concentrations only and requires successful waste tests. 6.1.4 Oily Phase and Organic Liquids Oily phase matrices contaminated by PCBs may be efficiently processed by: Alkali Reduction including sodium; Base catalyzed decomposition process (BCD); Gas Phase Chemical Reduction (GPCR); Incineration (mobile plant); Plasma arc decomposition (Pact process); Wet Air Oxidation (WAO) technology, low concentrations only and requires successful waste tests. 6.1.5 Solid Waste and Electrical Equipment Solid phase matrices contaminated by PCBs may be efficiently destroyed by: Base catalyzed decomposition process (BCD); Gas Phase Chemical Reduction (GPCR); Incineration (mobile plant). 6.1.6 Technology Summary The technologies that are flexible enough to work on multiple waste matrices and that are not limited to site- specific constraints are the base catalyzed decomposition process (BCD), cement kiln co-processing, gas phase chemical reduction (GPCR) and plasma arc decomposition. Incinerators, while flexible, are expensive to construct and operate and have poor public perceptions. Cement kiln co-processing may not be as flexible as incinerators (they cannot accept most electrical equipment) but they require little capital investment and generate negligible waste streams. As PCB wastes comprise a large amount of transformer dielectric fluid, recovery of this oil after dehalogenation may be economical for utilities. While the oil could be used as a substitute for fuel in cement kilns, utilities may find the treatment and reuse of dielectric fluid more to their advantage. Thus, an alkali reduction technology that allows the reuse of the oil for transformer dielectric fluid would be advantageous for large utilities. Some technologies are more suited for individual site applications such as vitrification and biodegradation methods for contaminated soil, or advanced oxidation or photocatalysis processes for groundwater contaminated with PCBs. These technologies should be considered on a site-by-site basis but won't likely provide a significant contribution to PCB destruction overall. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 101 of 119 6.2 Operating PCB Waste Disposal Facilities 6.2.1 Rationale for Selection The review of the facilities capable of PCB disposal, both in and outside of the Asia-Pacific region, has confirmed that disposal of PCBs from Vietnam will require a combination of approaches in order to arrive at a solution that is cost effective and efficient at disposal of PCBs in an environmentally sound and safe manner. This is because of limitations on the type of waste each facility can accept (either because the facility will not treat a particular type of waste or because there is a more suitable technology available for the waste type somewhere else), or because of cost prohibitions. The technologies in use at the various facilities examined can be categorized in various ways. In terms of the process, they can be broadly divided into incineration, chemical dechlorination, mechanochemical destruction, plasma arc destruction and storage. Incineration technologies are capable of treating a wide variety of waste, but they also require stringent controls, particularly with regard to air emissions, and have attracted public criticism in many countries. Non-incineration based technologies have less risk associated with air emissions, however, may involve hazardous materials (such as alkalis) or produce liquid wastes and other by-products that have to be disposed of, as well as require specific procedures with regard to chemical handling and storage. In terms of location, they can be subdivided into technologies that will allow the waste to be treated in Vietnam, and technologies that will require waste to be exported overseas for treatment. The export of waste from Vietnam will present risks that are intrinsic to the transport of hazardous material over land and water, but will also allow for disposal in countries where the technologies are well-established and environmental and health and safety is closely controlled. Disposal of waste within Vietnam will eliminate some of the hazards associated with waste transport, but may present different challenges in terms of disposal of technology by-products and monitoring capability. Those technologies that were subject to a more detailed assessment were selected after taking into consideration the published costs of disposal (and transportation, if applicable), the risks associated with export versus treatment in Vietnam, and the risks associated with the technologies themselves, from an environmental and health and safety point of view. For facilities that only treat certain types of waste and sub-contract the other waste types to other facilities, the facility was evaluated on the basis of the waste that is actually treated there. Some facilities were not forthcoming with the information requested. Where significant information was lacking, the facility was not considered as a viable option. All of the facilities indicated that costs provided were only indicative and could only be finalized once the waste characteristics are known. 6.2.2 Treatment within Vietnam Of the in-country options proposed, only the Holcim plant is close to the commercialization of a treatment process for PCBs. The rest are either not focused on PCBs (Chemical Military Headquarters), not interested in focusing on PCBs (URENCO-Hanoi) or are at the research stage of technology development (Academy of Science and Technology). Holcim is likely to be involved with the destruction of PCBs in Vietnam to a significant degree. With the encouragement of the regulators and the extensive support of their international network, Holcim will meet the obligations effectively and efficiently, however, they do not have the capability to handle all the PCB waste in Vietnam. Other options need to be examined, as discussed in the following sections. With respect to facilities currently operating outside of Vietnam, of those that were interested in treating Vietnam's PCB waste, most were more interested in the potential for relocating mobile and transportable systems, I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 102 of 119 and treating wastes in-country. As treated oils can be reused, treatment of oil within Vietnam may be the option that provides the most benefit to waste oil holders, providing that reaction by-products can be disposed of safely. · Soil and Soil-like Materials: ESI Group (Australia), using sodium dechlorination, treats soils as well as other waste types, which would make the set up of a treatment facility of this nature in Vietnam more worthwhile than one that treats only one type of waste. Hallet Environmental and Technology Group (Canada) using the Eco-Logic Process (gas phase chemical reduction - GPCR) also treats soils, if contamination is less than 500 ppm, and uses technology that has been proven to be effective. Like ESI, Hallett is also capable of treating a variety of waste types. Tredi Seche Global Solutions (using the Tredco thermal desorption process as well as other technologies) is also experienced in treating soils, but indicative pricing provided was higher than the other technologies mentioned. However, because of their worldwide experience, it would be worth considering Tredi as a viable option. · Water and Aqueous Solutions: Water and aqueous solutions can be reliably treated using GPCR (provided by Hallet Environmental and Technology Group) and base catalyzed chemical decomposition (provided by Dolomatrix International). However, the pricing initially provided by Dolomatrix was considerably higher than the pricing provided by Hallet. · Sediment, Sludge and Slurries: All of the technologies mentioned for soil above are applicable to sediment, sludge and slurries. · Oil and Organic Liquids: For oils with concentrations less than 3,000 ppm, ESI Group of Australia is recommended as a viable possibility. The facility uses sodium dechlorination and can also treat a variety of other waste types at prices that are competitive to other facilities (see Tables 4.2 and 5.2). Hallet Environmental and Technology Group of Canada, using the Eco-Logic process, is another viable alternative, particularly for the treatment of pure PCBs. As with ESI, Hallet Environmental and Technology can also treat a variety of waste besides contaminated oils, at prices that are competitive to other facilities. Tredi Seche Global Solutions is also recommended, partially based on their extensive experience in hazardous waste management, and their ability to treat a variety of wastes. Hydrodec of the UK and Australia have both fixed and mobile systems using catalytic hydrogenation that can treat transformer oil which can be subsequently reused. · Solid Waste and Electrical Equipment: ESI Group, Hallet Environmental and Kinectrics Inc. (Canada), using sodium reduction, are recommended as viable alternatives for treatment of contaminated equipment within Vietnam, such as transformers, capacitors and metallic and non-metallic equipment. 6.2.3 Treatment outside of Vietnam If treatment is to be conducted outside of Vietnam, treatment in Europe would be the best option, particularly in consideration of track records (previous waste acceptance from developing countries), political willingness to accept waste, and the stringency of environmental permits in Western Europe. Most of the treatment in Europe comprises high temperature incineration, with a few facilities offering solvent washing and dechlorination, and one facility (K+S Entsorgung GmbH) offering long term disposal of non-liquid PCB waste in a salt mine. Facilities that are viable possibilities for the disposal of waste from Vietnam, taking into account cost, capacity, information provided on environmental monitoring, health and safety data, and public response are: I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 103 of 119 · Ekokem Oy Ab ­ high temperature incineration (Finland); · Tredi Seche Global Solutions ­ high temperature incineration as well as other technologies as appropriate (France); · HIM GmbH ­ high temperature incineration (Germany); · SAVA/Remondis ­ high temperature incineration (Germany); · K+S Entsorgung GmbH ­ long term storage (Germany); · EMS Dottikon ­ high temperature incineration (Switzerland); and · Valorec Services AG ­ high temperature incineration (Switzerland). The cost of disposal at K+S Entsorgung GmbH is low compared to other facilities. Non-liquid PCB wastes will be stored in a rock salt cavity 800 m within the earth, which will be sealed once mining is complete. Although wastes are not destroyed, there is also no chance of forming hazardous by-products such as dioxins and furans. This is a viable alternative to disposal of soil and other dry PCB materials such as transformer carcasses. It should be recognized, however, that such wastes are heavy and bulky and not economical to transport. In terms of the incineration facilities, Germany has a large number of incinerators, and the environmental controls appeared to be quite stringent. HIM and SAVA were recommended based on the considerations mentioned above, as well as their willingness to share information on their facilities so that a meaningful evaluation could be made. The Swiss incinerators were also recommended for these reasons. In terms of cost, Tredi Seche was the most expensive, but was recommended for consideration because of the extent of their experience in handling hazardous waste and their operation of non-combustion technologies. 6.3 Summary of Promising Technologies A summary of most promising technologies based on our assessment is provided in Table 6.1. The matrix on which the technology can be applied is provided and the vendor or commercial operator for each technology is shown. For those fixed facilities outside of Vietnam, the country of operation is shown. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 104 of 119 Table 6.1 : Summary of Recommendations Technology Commercial Vendor will treatment take place in If no, where take place? treatment Vietnam? Equipment Will Sediment Water Soil Oil Broad Application Alkali reduction * * * ESI Group Yes Also in AU (sodium) Kinectrics** Yes Tredi Seche Global Yes Also in FR Solutions Base catalyzed Dolomatrix International Yes decomposition (BCD) Cement kiln co- Holcim Vietnam Ltd. Yes processing Gas Phase Chemical Hallett Environmental and Yes Reduction (GPCR) Technology Group Incineration Ekokem Oy Ab No FI Tredi Seche Global No FR Solutions No DE HIM GmbH No DE SAVA/Remondis No CH EMS Dottikon No CH Valorec Services AG Plasma arc Dolomatrix International Yes decomposition Site-by-Site Application Photocatalysis Photo-Cat Yes Purifics Yes Wet air oxidation Zimpro Systems, a Division Yes (WAO) of Siemens Vitrification AMEC's Geomelt Yes * combined with other technologies ** does not treat soil I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 105 of 119 7.0 TREATMENT CAPACITY COMPARISON There is a tremendous variability in treatment capacities and the various technological approaches for PCB waste treatment, destruction and management. This was demonstrated in Section 2, the PCB Destruction Technology Overview, as well as in Sections 3 and 4, where treatment capacities were reported from the Vendors identified. This section more fully develops this issue in the Vietnamese context by estimating treatment timelines based on the quantity of materials estimated to be present in Vietnam. The basis of comparison was developed from information provided by the National Implementation Plan and World Bank Records. The following was assumed with respect to the contaminated media: · 10,000 tonnes of PCB-containing oil (61,500 drums) require treatment. Half of this quantity has been assumed to contain concentrations of PCBs greater than 500 ppm and half has been assumed to contain PCB concentrations less than 500 ppm. · 75,000 tonnes of transformers (10,000 units of varying size) require treatment. Again, it has been assumed that half of the transformers contain oil with concentrations of PCBs greater than 500 ppm and half contain oil with concentrations of PCBs less than 500 ppm. · 5,500 tonnes of PCB-containing ballasts require treatment. The total amount of waste is 90,500 tonnes. Based on the treatment capacities of facilities alone, the time to treat all of the above waste was estimated for comparison. The treatment capacities as reported for each vendor, when provided, were standardized as metric tonnes per annum. The results of the comparison are provided on Table 7.1. Whether the vendor had a fixed facility outside or Vietnam, or a mobile/relocatable facility that could be relocated, the estimate was made. This is identified in the third column of Table 7.1 with "import" indicated that wastes would have to be shipped from Vietnam to the treatment facility in the host country. Not all technologies can treat all PCB wastes types, with some being limited only to PCBs in oil and others to PCB contaminated soils. This is indicated in Table 7.1 by shading the media which cannot be treated. The table has been sorted by the estimated overall treatment time for the waste in Vietnam from shortest duration to longest duration by the Vendors who provided capacity data. At the bottom of the table are the vendors who did not provide capacity information and who therefore could not be evaluated. In order to interpret the results Table 7.1 has been sorted, adjusted and presented, with the same data, as follows: · Table 7.2: Treatment throughput sorted by total treatment duration; · Table 7.3: Treatment throughput sorted by treatment duration of oil waste only (those technologies that do not treat oil have been removed); · Table 7.4: Treatment throughput sorted by treatment duration of equipment waste only (those technologies that do not treat equipment have been removed); · Table 7.5: Treatment throughput sorted by treatment duration of soil waste only (those technologies that do not treat soil have been removed). The estimate was based completely on treatment technology capacity and did not estimate other constraints and PCB waste elimination. Other likely constraints include internal and external transportation capacities, bureaucratic processes (both internal and external) and funding availability. All treatment systems are scalable. Mobile or relocatable systems as they are presently available, would likely be modified for the requirements of Vietnam. Relocatable systems are usually sited at a location for periods of time I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 106 of 119 number in years and are essentially rebuilt when brought to a new location, providing opportunity of scaling operations to meet the needs of the new project. The capacities of fixed facilities can be used to estimate the treatment facility if one or more fixed facility is constructed in Vietnam. Construction and commissioning time is dependant on the size and type of technology used but is longer than mobile or relocatable facilities, usually measured in months to years. Treatment throughput for any technology is also affected by the quality of the input material. Other contaminants and debris, adversely affect productivity and may require pretreatment operations. 7.1 Discussion of Results: Oil Treatment After applying the quantity of oil estimated to be present in Vietnam to the 26 vendors with technologies that can remove PCBs from oil, the durations of treatment varied from 0.13 years (1.6 months) to 396 years (Table 7.3). Of these, 12 vendors could treat the oil with relocatable or portable facilities in Vietnam and the balance would require importation of waste to fixed facilities in their country of origin. The larger fixed facilities tended to be able to treat the oil in shorter duration while the relocatable or portable as shown in Table 7.6 below: Table 7.6 : Summary of Oil Treatment Durations Minimum Duration Maximum Duration Average Duration Treatment Location No. Vendors (year) (year) (year) Fixed Facility 15 0.13 51.3 6.23 Outside of Vietnam Relocatable to 11 0.15 69.5 17.57 Vietnam Overall 26 0.13 69.5 11.03 Assuming that treatment times above a five-year duration are not practical, only 19 vendors (6 with relocatable systems) could be considered with their current facilities. The top three performing vendors for importable waste oil are Kommunekemi (Denmark), Bayer Industry Services (Germany) and AVG Hamburg (Germany). The top three performing relocatable facilities are Hydrodec Group plc (United Kingdom), Tox Free (Australia) and Hallet (Canada). 7.2 Discussion of Results: Equipment Treatment After applying the quantity of equipment estimated to be present in Vietnam to the 26 vendors with technologies that can destroy PCBs in electrical equipment, the durations of treatment varied from 0.3 years (3.6 months) to 428 years (Table 7.3). Of these, 10 vendors could treat the equipment with relocatable or portable facilities in Vietnam and the balance would require importation of waste to fixed facilities in their country of origin. The larger fixed facilities tended to be able to treat the electrical equipment in shorter duration while the relocatable or portable as shown in Table 7.7 below: I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc Table7.1: Treatment and Destruction Capacities: Timelines for Treatment (Sorted by Vendor Name) Page 1 of 4 Detailed Throughput (if variable) Import Waste to Throughput Treatment Host Site or Set- Throughput (as Oil: low Oil: high Non-metallic Facility (tonnes/year): Metallic PCB Technology up Treatment in provided by Vendor) Total (years) concentration concentration PCB Soils See Note 1 Equipment Vietnam (years) (years) Equipment Basis of Estimated Throughput 90,500 12,750 12,750 44,545 8,448 10,000 Akzo Nobel Base High temperature Import. 40,000 tpa 40,000 2.21 0.32 0.32 1.11 0.21 0.25 Chemicals (The incineration with Netherlands) recovery of Aprochim Vacuum removal Import. Solid waste: 30,000 tpa 5.59 1.28 2.55 1.48 0.28 (France) of PCBs from Oil: transformers, 10,000 tpa followed by Pure PCB: dechlorination 5,000 tpa (sodium). AVG Hamburg High temperature Import. 150,000 tpa 150,000 0.59 0.09 0.09 0.30 0.06 0.07 (Germany) incineration. Bayer Industry High temperature Import. 175,000 tpa 175,000 0.51 0.07 0.07 0.25 0.05 0.06 Services GmbH & incineration. Co. OHG (Germany) Bennett High temperature Import. Récupère Sol Inc.: 100,000 0.10 0.10 Environmental thermal treatment. 100,000 tpa (Canada) Bennett High temperature Import. Material Resource 1,750 44.85 7.29 7.29 25.45 4.83 Environmental thermal treatment. Recovery Inc: 0.5 (Canada) tonnes/hour Bennett Solvent washing. Import. Transcycle Industries: not available - Environmental not determined. (Canada) Celtic Recycling Catalytic Import. Scaleable to project not provided - (United Kingdom) destruction ('Poly- needs gon' mobile de- chlorination plant). Commodore dehalogenation Treat in Vietnam. 10 tonnes per day 1,978 31.85 22.52 4.27 5.06 Applied reaction ­ (scaleable to project Technologies reduction. needs). (United States) Sodium mixed with ammonia . Daffos and Sodium Import. 2,000 tpa 2,000 12.75 6.38 6.38 Baudasse dechlorination. (France) Dolomatrix Plascon, BCD or Treat in Vietnam. 500 tpa 500 176.99 25.50 25.50 89.09 16.90 20.00 International Thermal (Australia) Desorption. Dr. Bilger Sodium reduction. Treat in Vietnam. 2 tons per day in mobile 396 64.47 32.24 32.24 Umweltconsulting unit GmbH (Germany) ECOLSIR Srl Dehalogenation Treat in Vietnam. 2,000 tpa 2,000 44.25 6 6 22 4 5 (Italy) and incineration Import pure PCBs (subcontracted). to incinerator. Table7.1: Treatment and Destruction Capacities: Timelines for Treatment (Sorted by Vendor Name) Page 2 of 4 Detailed Throughput (if variable) Import Waste to Throughput Treatment Host Site or Set- Throughput (as Oil: low Oil: high Non-metallic Facility (tonnes/year): Metallic PCB Technology up Treatment in provided by Vendor) Total (years) concentration concentration PCB Soils See Note 1 Equipment Vietnam (years) (years) Equipment Basis of Estimated Throughput 90,500 12,750 12,750 44,545 8,448 10,000 EDL High energy Treat in Vietnam. 20 tonnes per hour. 70,000 1.26 0.18 0.18 0.64 0.12 0.14 Environmental mechano- Technology (New chemical Zealand) destruction (MCD). Ekokem Oy Ab High temperature Import. 90,000 tpa 90,000 0.98 0.14 0.14 0.49 0.09 0.11 (Finland) incineration. EMS-Dottikon High temperature Import. 8,500 tpa 8,500 10.41 1.50 1.50 5.24 0.99 1.18 (Switzerland) incineration. Envio Recycling Solvent washing, Import. 6,000 tpa 6,000 14.75 2.13 2.13 7.42 1.41 1.67 GmbH & Co. KG sodium reduction (Germany) and high temperature incineration. ESI Group Dechlorination Import or treat in Oil ­ 500 litre/hr 1,330 66.54 9.59 9.59 33.49 6.35 7.52 (Australia) using sodium. Vietnam. Equipment ­ no limit. Hallet Gas Phase Treat in Vietnam. 1000 tonnes per year ­ 100,000 0.88 0.13 0.13 0.45 0.08 0.10 Environmental Chemical can be scaled to suit. and Technology Reduction Group (Canada) (GPCR) HIM GmbH High temperature Import. 120,000 tpa 120,000 0.74 0.11 0.11 0.37 0.07 0.08 (Germany) incineration Hydrodec Group Catalytic Import or treat in 20,000 L/day (fixed 497 51.30 25.65 25.65 plc. dehydrogenation. Vietnam. plant) or 3,000 L/day (mobile plant) K+S Entsorgung Long term storage Import. 200,000 tonnes total 200,000 0.44 0.06 0.06 0.22 0.04 0.05 GmbH (Germany) - underground salt capacity mine. Kinectrics Inc. Sodium Reduction Treat in Vietnam. low level oils: (<10,000 2,629 465.57 13 24 41 388 (Canada) ppm) = 1500 l/batch; High level oils: (>50,000 ppm) = 600 to 1000 kg/batch (approx. 330 to 550 L per batch). Paper from capacitors = 100 kg of paper per day. Total capacitors = 700 kg/day Metals: 5 metric tonnes per day. Kobelco Eco Sodium reduction, Manufactures Can be scaled to suit. not provided - Solutions (Japan) solvent wash and plants for sale. vacuum separation. Kommunekemi as High temperature Import. 200,000 tpa 200,000 0.44 0.06 0.06 0.22 0.04 0.05 (Denmark) incineration. Table7.1: Treatment and Destruction Capacities: Timelines for Treatment (Sorted by Vendor Name) Page 3 of 4 Detailed Throughput (if variable) Import Waste to Throughput Treatment Host Site or Set- Throughput (as Oil: low Oil: high Non-metallic Facility (tonnes/year): Metallic PCB Technology up Treatment in provided by Vendor) Total (years) concentration concentration PCB Soils See Note 1 Equipment Vietnam (years) (years) Equipment Basis of Estimated Throughput 90,500 12,750 12,750 44,545 8,448 10,000 Orion B.V (the Cold-Rinsing with Import. 4,000-20,000 tpa 20,000 2.65 2.23 0.42 Netherlands) solvents and PCB extraction (no destruction). Safeco High temperature Can export to No limit. not provided - Environmental incineration Finland for Services Inc. (The (Ekokem in incineration, or Philippines) Finland) and local treat in Vietnam solvent and oil using recycling using a dechlorination patent-pending technology. technology (dechlorination reaction). Sakab (Sweden) High temperature Import. 2,000 tpa 2,000 5.00 5.00 incineration (rotary kiln) Sanexen Chemical Treat in Vietnam Custom according to not provided - (Canada) destruction or import into needs. (reduction using another country potassium). (to be determined). SAVA/Remondis High temperature Import. 50,000 tpa 50,000 1.77 0 0 1 0 0 (Germany) incineration. SD Myers Inc.- Sodium Treat in Vietnam. 2,271 ­ 2,650 L per 7,049 3.62 1.81 1.81 Tallmadge, Ohio dechlorination. hour. (United States) Sea Marconi Dehalogenation of Treat in Vietnam. Can be scaled to suit not provided - (Italy) transformers online. Sita solvent flushing Import. 7,500 tons/year. 6,800 9.26 6.55 1.24 1.47 Decontamination (no destruction; N.V. (Belgium) equipment & soil) Sonic Solvent extraction Treat in Vietnam. Scaleable system. 24,000 0.42 0 Environmental and PCB Typical size is 2000 Solutions Inc. destruction by tonne/soil/ month (Canada) TM Sonoprocess treatment chain. Swan Hills High temperature Import. 40,000 tpa. 40,000 2.21 0.32 0.32 1.11 0.21 0.25 Treatment Facility incineration. (Canada) Tox Free Indirect Thermal Import or treat in 2 tonnes per hour. 7,000 12.64 1.82 1.82 6.36 1.21 1.43 (Australia) Desorption. Vietnam. Tox Free Direct Thermal Import or treat in 5-50 tonnes per hour. 175,000 0.51 0.07 0.07 0.25 0.05 0.06 (Australia) Desorption/ Vietnam. Thermal Table7.1: Treatment and Destruction Capacities: Timelines for Treatment (Sorted by Vendor Name) Page 4 of 4 Detailed Throughput (if variable) Import Waste to Throughput Treatment Host Site or Set- Throughput (as Oil: low Oil: high Non-metallic Facility (tonnes/year): Metallic PCB Technology up Treatment in provided by Vendor) Total (years) concentration concentration PCB Soils See Note 1 Equipment Vietnam (years) (years) Equipment Basis of Estimated Throughput 90,500 12,750 12,750 44,545 8,448 10,000 Tredi Seche Thermal, Import or treat in Thermal: 40,000+ 40,000 2.21 0.32 0.32 1.11 0.21 0.25 Global Solutions Autoclave, Vietnam. tonnes/year (France) desorption, Valorec Services High temperature Import. 25,000 tpa 25,000 3.54 0.51 0.51 1.78 0.34 0.40 AG (Switzerland) incineration. Assumptions 1. All capacity of the facility is relegated to PCB wastes from Vietnam until all wastes treated/destroyed. Quantity Estimates for Waste in Vietnam Electrical Equipment (assuming 75000 tonnes of transformers and 5500 tonnes of capacitors) Oil (assuming 10000 tonnes) Total Oil (tonnes): 10,000 Transformers (tonnes): 75,000 Capacitors (tonnes): 5,500 Assumptions of quantity estimate: 50% of total weight is less than 500 ppm and 50% of total weight is greater than 500 ppm Transformers contain 34% oil by weight, 58% metals by weight and 8 % cellulosic material by weight. Capacitors contain 36.5% oil by weight, 19% metals by weight and 44.5% cellulosic material by weight. Waste Quantity/ tonnes Transformer (oil) 25,500 (includes oil drained from capacitors and transformers) Transformer (Cellulosic 6,000 Mateiral) Transformer 43,500 (Metal) Capacitors (Oil) 2,008 Capacitors (Cellulosic 2,448 Material) Capacitors 1,045 (Metal) Oil 10,000 Total: 90,500 Conversions When throughputs are provided in: L assume treatment is all oil, and conversion rate is to tonnes: 0.76 /hour assume operations at 70% of the time, 52 weeks per year, 6 days per week 16 ho 3500 /year /day assume operations at 70% of the time, 52 weeks per year, 6 days per week 16 ho 218 /year Table 7.2: Treatment and Destruction Capacities: Timelines for Treatment: Sorted by Total Treatment Duration Page 1 of 2 Detailed Throughput (if variable) Import Waste to Throughput Host Site or Set- Throughput (as provided Oil: low Oil: high Non-metallic Facility Treatment Technology (tonnes/year): Metallic PCB up Treatment in by Vendor) Total (years) concentration concentration PCB Soils See Note 1 Equipment Vietnam (years) (years) Equipment Basis of Estimated Throughput 90,500 12,750 12,750 44,545 8,448 10,000 Bennett Environmental High temperature thermal treatment. Import. Récupère Sol Inc.: 100,000 100,000 0.10 0.10 (Canada) tpa Sonic Environmental Solvent extraction and PCB Treat in Vietnam. Scaleable system. 24,000 0.42 0 Solutions Inc. (Canada) TM Typical size is 2,000 destruction by Sonoprocess treatment chain. tonne/soil/ month K+S Entsorgung GmbH Long term storage - underground Import. 200,000 tonnes total 200,000 0.44 0.06 0.06 0.22 0.04 0.05 (Germany) salt mine. capacity Kommunekemi as High temperature incineration. Import. 200,000 tpa 200,000 0.44 0.06 0.06 0.22 0.04 0.05 (Denmark) Bayer Industry Services High temperature incineration. Import. 175,000 tpa 175,000 0.51 0.07 0.07 0.25 0.05 0.06 GmbH & Co. OHG (Germany) Tox Free (Australia) Direct Thermal Desorption/ Thermal Import or treat in 5-50 tonnes per hour. 175,000 0.51 0.07 0.07 0.25 0.05 0.06 Destruction. Vietnam. AVG Hamburg (Germany) High temperature incineration. Import. 150,000 tpa 150,000 0.59 0.09 0.09 0.30 0.06 0.07 HIM GmbH (Germany) High temperature incineration Import. 120,000 tpa 120,000 0.74 0.11 0.11 0.37 0.07 0.08 Hallet Environmental and Gas Phase Chemical Reduction Treat in Vietnam. 1,000 tonnes per year ­ can 100,000 0.88 0.13 0.13 0.45 0.08 0.10 Technology Group (GPCR) be scaled to suit. (Canada) Ekokem Oy Ab (Finland) High temperature incineration. Import. 90,000 tpa 90,000 0.98 0.14 0.14 0.49 0.09 0.11 EDL Environmental High energy mechano-chemical Treat in Vietnam. 20 tonnes per hour. 70,000 1.26 0.18 0.18 0.64 0.12 0.14 Technology (New Zealand) destruction (MCD). SAVA/Remondis High temperature incineration. Import. 50,000 tpa 50,000 1.77 0 0 1 0 0 (Germany) Akzo Nobel Base High temperature incineration with Import. 40,000 tpa 40,000 2.21 0.32 0.32 1.11 0.21 0.25 Chemicals (The recovery of hydrochloric acid gas. Netherlands) Swan Hills Treatment High temperature incineration. Import. 40,000 tpa. 40,000 2.21 0.32 0.32 1.11 0.21 0.25 Facility (Canada) Tredi Seche Global Thermal, Autoclave, desorption, Import or treat in Thermal: 40,000+ 40,000 2.21 0.32 0.32 1.11 0.21 0.25 Solutions (France) filtration, Biological, Vietnam. tonnes/year Chemical dechlorination, Mechano- chemical destruction. Orion B.V (the Netherlands) Cold-Rinsing with solvents and PCB Import. 4,000-20,000 tpa 20,000 2.65 2.23 0.42 extraction (no destruction). Valorec Services AG High temperature incineration. Import. 25,000 tpa 25,000 3.54 0.51 0.51 1.78 0.34 0.40 (Switzerland) SD Myers Inc.- Tallmadge, Sodium dechlorination. Treat in Vietnam. 2,271 ­ 2,650 L per hour. 7,049 3.62 1.81 1.81 Ohio (United States) Table 7.2: Treatment and Destruction Capacities: Timelines for Treatment: Sorted by Total Treatment Duration Page 2 of 2 Detailed Throughput (if variable) Import Waste to Throughput Host Site or Set- Throughput (as provided Oil: low Oil: high Non-metallic Facility Treatment Technology (tonnes/year): Metallic PCB up Treatment in by Vendor) Total (years) concentration concentration PCB Soils See Note 1 Equipment Vietnam (years) (years) Equipment Basis of Estimated Throughput 90,500 12,750 12,750 44,545 8,448 10,000 Sakab (Sweden) High temperature incineration (rotary Import. 2,000 tpa 2,000 5.00 5.00 kiln) Aprochim (France) Vacuum removal of PCBs from Import. Solid waste: 30,000 tpa 5.59 1.28 2.55 1.48 0.28 transformers, followed by Oil: 10,000 tpa dechlorination (sodium). Pure PCB: 5,000 tpa Sita Decontamination N.V. solvent flushing (no destruction; Import. 7,500 tons/year. 6,800 9.26 6.55 1.24 1.47 (Belgium) equipment & soil) EMS-Dottikon (Switzerland) High temperature incineration. Import. 8,500 tpa 8,500 10.41 1.50 1.50 5.24 0.99 1.18 Tox Free (Australia) Indirect Thermal Desorption. Import or treat in 2 tonnes per hour. 7,000 12.64 1.82 1.82 6.36 1.21 1.43 Vietnam. Daffos and Baudasse Sodium dechlorination. Import. 2,000 tpa 2,000 12.75 6.38 6.38 (France) Envio Recycling GmbH & Solvent washing, sodium reduction Import. 6,000 tpa 6,000 14.75 2.13 2.13 7.42 1.41 1.67 Co. KG (Germany) and high temperature incineration. Commodore Applied dehalogenation reaction ­ reduction. Treat in Vietnam. 10 tonnes per day (scaleable 1,978 31.85 22.52 4.27 5.06 Technologies (US) Sodium mixed with ammonia . to project needs). ECOLSIR Srl (Italy) Dehalogenation and incineration Treat in Vietnam. 2,000 tpa 2,000 44.25 6 6 22 4 5 (subcontracted). Import pure PCBs to incinerator. Bennett Environmental High temperature thermal treatment. Import. Material Resource Recovery 1,750 44.85 7.29 7.29 25.45 4.83 (Canada) Inc: 0.5 tonnes/hour Hydrodec Group plc. Catalytic dehydrogenation. Import or treat in 20,000 L/day (fixed plant) or 497 51.30 25.65 25.65 Vietnam. 3,000 L/day (mobile plant) Dr. Bilger Umweltconsulting Sodium reduction. Treat in Vietnam. 2 tons per day in mobile unit 396 64.47 32.24 32.24 GmbH (Germany) ESI Group (Australia) Dechlorination using sodium. Import or treat in Oil ­ 500 litre/hr 1,330 66.54 9.59 9.59 33.49 6.35 7.52 Vietnam. Equipment ­ no limit. Dolomatrix International Plascon, BCD or Thermal Treat in Vietnam. 500 tpa 500 176.99 25.50 25.50 89.09 16.90 20.00 (Australia) Desorption. Kinectrics Inc. (Canada) Sodium Reduction Treat in Vietnam. low level oils: (<10,000 ppm) 2,629 465.57 13 24 41 388 = 1500 l/batch; High level oils: (>50,000 ppm) = 600 to 1,000 kg/batch (approx. 330 to 550 L per batch). Paper from capacitors = 100 kg of paper per day. Total capacitors = 700 kg/day Metals: 5 metric tonnes per day. Page 1 of 2 Table 7.3: Treatment and Destruction Capacities: Timelines for Treatment: Oil Treatment Only - Sorted by Treatment Duration Detailed Throughput (if variable) Import Waste to Throughput Host Site or Set- Throughput (as Oil: low Oil: high Facility Treatment Technology (tonnes/year): up Treatment in provided by Vendor) Total (years) concentration concentration See Note 1 Vietnam (years) (years) Basis of Estimated Throughput 90,500 12,750 12,750 Kommunekemi as High temperature incineration. Import. 200,000 tpa 200,000 0.13 0.06 0.06 (Denmark) Bayer Industry Services High temperature incineration. Import. 175,000 tpa 175,000 0.15 0.07 0.07 GmbH & Co. OHG (Germany) AVG Hamburg (Germany) High temperature incineration. Import. 150,000 tpa 150,000 0.17 0.09 0.09 HIM GmbH (Germany) High temperature incineration Import. 120,000 tpa 120,000 0.21 0.11 0.11 Ekokem Oy Ab (Finland) High temperature incineration. Import. 90,000 tpa 90,000 0.28 0.14 0.14 SAVA/Remondis High temperature incineration. Import. 50,000 tpa 50,000 0.51 0 0 (Germany) Akzo Nobel Base High temperature incineration with recovery Import. 40,000 tpa 40,000 0.64 0.32 0.32 Chemicals (The of hydrochloric acid gas. Netherlands) Swan Hills Treatment High temperature incineration. Import. 40,000 tpa. 40,000 0.64 0.32 0.32 Facility (Canada) Valorec Services AG High temperature incineration. Import. 25,000 tpa 25,000 1.02 0.51 0.51 (Switzerland) EMS-Dottikon (Switzerland) High temperature incineration. Import. 8500 tpa 8,500 3.00 1.50 1.50 Aprochim (France) Vacuum removal of PCBs from Import. Oil: 10,000 tpa 3.83 1.28 2.55 transformers, followed by dechlorination Pure PCB: 5,000 tpa (sodium). Envio Recycling GmbH & Solvent washing, sodium reduction and Import. 6,000 tpa 6,000 4.25 2.13 2.13 Co. KG (Germany) high temperature incineration. Daffos and Baudasse Sodium dechlorination. Import. 2,000 tpa 2,000 12.75 6.38 6.38 (France) Bennett Environmental High temperature thermal treatment. Import. Material Resource 1,750 14.57 7.29 7.29 (Canada) Recovery Inc: 0.5 t /h Page 2 of 2 Table 7.3: Treatment and Destruction Capacities: Timelines for Treatment: Oil Treatment Only - Sorted by Treatment Duration Detailed Throughput (if variable) Import Waste to Throughput Host Site or Set- Throughput (as Oil: low Oil: high Facility Treatment Technology (tonnes/year): up Treatment in provided by Vendor) Total (years) concentration concentration See Note 1 Vietnam (years) (years) Basis of Estimated Throughput 90,500 12,750 12,750 Hydrodec Group plc. Catalytic dehydrogenation. Import or treat in 20,000 L/day (fixed 497 51.30 25.65 25.65 (United Kingdom) Vietnam. plant) or 3,000 L/day Tox Free (Australia) Direct Thermal Desorption/ Thermal Import or treat in ( bil l t) hour. 5-50 tonnes per 175,000 0.15 0.07 0.07 Destruction. Vietnam. Hallet Environmental and Gas Phase Chemical Reduction (GPCR) Treat in Vietnam. 1,000 tonnes per year 100,000 0.26 0.13 0.13 Technology Group ­ can be scaled to (Canada) suit. EDL Environmental High energy mechano-chemical destruction Treat in Vietnam. 20 tonnes per hour. 70,000 0.36 0.18 0.18 Technology (New Zealand) (MCD). Tredi Seche Global Thermal, Autoclave, desorption, filtration, Import or treat in Thermal: 40,000+ 40,000 0.64 0.32 0.32 Solutions (France) biological, chemical dechlorination, Vietnam. tonnes/year mechano-chemical destruction. SD Myers Inc.- Tallmadge, Sodium dechlorination. Treat in Vietnam. 2271 ­ 2650 L per 7,049 3.62 1.81 1.81 Ohio (United States) hour. Tox Free (Australia) Indirect Thermal Desorption. Import or treat in 2 tonnes per hour. 7,000 3.64 1.82 1.82 Vietnam. ECOLSIR Srl (Italy) Dehalogenation and incineration Treat in Vietnam. 2,000 tpa 2,000 12.75 6 6 (subcontracted). Import pure PCBs to incinerator. ESI Group (Australia) Dechlorination using sodium. Import or treat in Oil ­ 500 litre/hr 1,330 19.17 9.59 9.59 Vietnam. Equipment ­ no limit. Kinectrics Inc. (Canada) Sodium Reduction Treat in Vietnam. low level oils: 2,629 37.20 13 24 (<10,000 ppm) = 1500 l/batch; High level oils: (>50,000 ppm) = 600 to 1000 Dolomatrix International Plascon, BCD or Thermal Desorption. Treat in Vietnam. 500 tpa 500 51.00 25.50 25.50 (Australia) Dr. Bilger Umweltconsulting Sodium reduction. Treat in Vietnam. 2 tons per day in 396 64.47 32.24 32.24 GmbH (Germany) mobile unit Page 1 of 2 Table 7.4: Treatment and Destruction Capacities: Timelines for Treatment: Equipment Treatment - Sorted by Total Treatment Duration Import Waste to Throughput Host Site or Set- Throughput (as provided by Non-metallic Facility Treatment Technology (tonnes/year): Metallic PCB up Treatment in Vendor) Total (years) PCB See Note 1 Equipment Vietnam Equipment Basis of Estimated Throughput 90,500 44,545 8,448 K+S Entsorgung GmbH Long term storage - underground salt mine. Import. 200,000 tonnes total capacity 200,000 0.26 0.22 0.04 (Germany) Kommunekemi as High temperature incineration. Import. 200,000 tpa 200,000 0.26 0.22 0.04 (Denmark) Bayer Industry Services High temperature incineration. Import. 175,000 tpa 175,000 0.30 0.25 0.05 GmbH & Co. OHG (Germany) AVG Hamburg (Germany) High temperature incineration. Import. 150,000 tpa 150,000 0.35 0.30 0.06 HIM GmbH (Germany) High temperature incineration Import. 120,000 tpa 120,000 0.44 0.37 0.07 Ekokem Oy Ab (Finland) High temperature incineration. Import. 90,000 tpa 90,000 0.59 0.49 0.09 SAVA/Remondis High temperature incineration. Import. 50,000 tpa 50,000 1.06 1 0 (Germany) Akzo Nobel Base High temperature incineration with recovery Import. 40,000 tpa 40,000 1.32 1.11 0.21 Chemicals (The of hydrochloric acid gas. Netherlands) Swan Hills Treatment High temperature incineration. Import. 40,000 tpa. 40,000 1.32 1.11 0.21 Facility (Canada) Aprochim (France) Vacuum removal of PCBs from Import. Solid waste: 30,000 tpa 1.77 1.48 0.28 transformers, followed by dechlorination (sodium). Valorec Services AG High temperature incineration. Import. 25,000 tpa 25,000 2.12 1.78 0.34 (Switzerland) Orion B.V (the Cold-Rinsing with solvents and PCB Import. 4,000-20,000 tpa 20,000 2.65 2.23 0.42 Netherlands) extraction (no destruction). EMS-Dottikon (Switzerland) High temperature incineration. Import. 8,500 tpa 8,500 6.23 5.24 0.99 Sita Decontamination N.V. solvent flushing (no destruction; Import. 7,500 tons/year. 6,800 7.79 6.55 1.24 (Belgium) equipment & soil) Envio Recycling GmbH & Solvent washing, sodium reduction and Import. 6,000 tpa 6,000 8.83 7.42 1.41 Co. KG (Germany) high temperature incineration. Page 2 of 2 Table 7.4: Treatment and Destruction Capacities: Timelines for Treatment: Equipment Treatment - Sorted by Total Treatment Duration Import Waste to Throughput Host Site or Set- Throughput (as provided by Non-metallic Facility Treatment Technology (tonnes/year): Metallic PCB up Treatment in Vendor) Total (years) PCB See Note 1 Equipment Vietnam Equipment Basis of Estimated Throughput 90,500 44,545 8,448 K+S Entsorgung GmbH Long term storage - underground salt mine. Import. 200,000 tonnes total capacity 200,000 0.26 0.22 0.04 (Germany) Bennett Environmental High temperature thermal treatment. Import. Material Resource Recovery Inc: 1,750 30.28 25.45 4.83 (Canada) 0.5 tonnes/hour Tox Free (Australia) Direct Thermal Desorption/ Thermal Import or treat in 5-50 tonnes per hour. 175,000 0.30 0.25 0.05 Destruction. Vietnam. Hallet Environmental and Gas Phase Chemical Reduction (GPCR) Treat in Vietnam. 1,000 tonnes per year ­ can be 100,000 0.53 0.45 0.08 Technology Group scaled to suit. (Canada) EDL Environmental High energy mechano-chemical destruction Treat in Vietnam. 20 tonnes per hour. 70,000 0.76 0.64 0.12 Technology (New Zealand) (MCD). Tredi Seche Global Thermal, autoclave, desorption, filtration, Import or treat in Thermal: 40,000+ tonnes/year 40,000 1.32 1.11 0.21 Solutions (France) biological, chemical dechlorination, Vietnam. mechano-chemical destruction. Tox Free (Australia) Indirect Thermal Desorption. Import or treat in 2 tonnes per hour. 7,000 7.57 6.36 1.21 Vietnam. ECOLSIR Srl (Italy) Dehalogenation and incineration Treat in Vietnam. 2,000 tpa 2,000 26.50 22 4 (subcontracted). Import pure PCBs to incinerator. Commodore Applied dehalogenation reaction ­ reduction. Treat in Vietnam. 10 tonnes per day (scaleable to 1,978 26.80 22.52 4.27 Technologies (United Sodium mixed with ammonia . project needs). States) ESI Group (Australia) Dechlorination using sodium. Import or treat in Oil ­ 500 litre/hr 1,330 39.84 33.49 6.35 Vietnam. Equipment ­ no limit. Dolomatrix International Plascon, BCD or Thermal Desorption. Treat in Vietnam. 500 tpa 500 105.99 89.09 16.90 (Australia) Kinectrics Inc. (Canada) Sodium Reduction Treat in Vietnam. Paper from capacitors = 100 kg 2,629 428.37 41 388 of paper per day. Total capacitors = 700 kg/day Metals: 5 metric tonnes per day. Page 1 of 2 Table 7.5: Treatment and Destruction Capacities: Timelines for Treatment: Soil Only - Sorted by Total Treatment Duration Import Waste to Throughput Host Site or Set- Throughput (as provided by Facility Treatment Technology (tonnes/year): Total (years) up Treatment in Vendor) See Note 1 Vietnam Basis of Estimated Throughput 10,000 Kommunekemi as High temperature incineration. Import. 1 200,000 tpa 200,000 0.05 (Denmark) Bayer Industry Services High temperature incineration. Import. 1 175,000 tpa 175,000 0.06 GmbH & Co. OHG (Germany) AVG Hamburg (Germany) High temperature incineration. Import. 1 150,000 tpa 150,000 0.07 HIM GmbH (Germany) High temperature incineration Import. 1 120,000 tpa 120,000 0.08 Bennett Environmental High temperature thermal treatment. Import. 1 Récupère Sol Inc.: 100,000 tpa 100,000 0.10 (Canada) Ekokem Oy Ab (Finland) High temperature incineration. Import. 1 90,000 tpa 90,000 0.11 SAVA/Remondis High temperature incineration. Import. 1 50,000 tpa 50,000 0.20 (Germany) Akzo Nobel Base High temperature incineration with recovery Import. 1 40,000 tpa 40,000 0.25 Chemicals (The of hydrochloric acid gas. Netherlands) Swan Hills Treatment High temperature incineration. Import. 1 40,000 tpa. 40,000 0.25 Facility (Canada) Valorec Services AG High temperature incineration. Import. 1 25,000 tpa 25,000 0.40 (Switzerland) EMS-Dottikon (Switzerland) High temperature incineration. Import. 1 8,500 tpa 8,500 1.18 Sita Decontamination N.V. solvent flushing (no destruction; Import. 1 7,500 tons/year. 6,800 1.47 (Belgium) equipment & soil) Envio Recycling GmbH & Solvent washing, sodium reduction and Import. 1 6,000 tpa 6,000 1.67 Co. KG (Germany) high temperature incineration. Sakab (Sweden) High temperature incineration (rotary kiln) Import. 1 2,000 tpa 2,000 5.00 Tox Free (Australia) Direct Thermal Desorption/ Thermal Import or treat in 2 5-50 tonnes per hour. 175,000 0.06 Destruction. Vietnam. Hallet Environmental and Gas Phase Chemical Reduction (GPCR) Treat in Vietnam. 2 1,000 tonnes per year ­ can be 100,000 0.10 Technology Group scaled to suit. (Canada) EDL Environmental High energy mechano-chemical destruction Treat in Vietnam. 2 20 tonnes per hour. 70,000 0.14 Technology (New Zealand) (MCD). Page 2 of 2 Table 7.5: Treatment and Destruction Capacities: Timelines for Treatment: Soil Only - Sorted by Total Treatment Duration Import Waste to Throughput Host Site or Set- Throughput (as provided by Facility Treatment Technology (tonnes/year): Total (years) up Treatment in Vendor) See Note 1 Vietnam Basis of Estimated Throughput 10,000 Tredi Seche Global Thermal, autoclave, desorption, filtration, Import or treat in 2 Thermal: 40,000+ tonnes/year 40,000 0.25 Solutions (France) biological, chemical dechlorination, Vietnam. mechano-chemical destruction. Sonic Environmental Solvent extraction and PCB destruction by Treat in Vietnam. 2 Scaleable system. 24,000 0.42 Solutions Inc. (Canada) SonoprocessTM treatment chain. Typical size is 2,000 tonne/soil/ month Tox Free (Australia) Indirect Thermal Desorption. Import or treat in 2 2 tonnes per hour. 7,000 1.43 Vietnam. ECOLSIR Srl (Italy) Dehalogenation and incineration Treat in Vietnam. 2 2,000 tpa 2,000 5.00 (subcontracted). Import pure PCBs to incinerator. Commodore Applied dehalogenation reaction ­ reduction. Treat in Vietnam. 2 10 tonnes per day (scaleable to 1,978 5.06 Technologies (United Sodium mixed with ammonia . project needs). States) ESI Group (Australia) Dechlorination using sodium. Import or treat in 2 Oil ­ 500 litre/hr 1,330 7.52 Vietnam. Equipment ­ no limit. Dolomatrix International Plascon, BCD or Thermal Desorption. Treat in Vietnam. 2 500 tpa 500 20.00 (Australia) SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 107 of 119 Table 7.7 : Summary of Equipment Treatment Durations Treatment Location No. Vendors Minimum Duration Maximum Duration Average Duration (year) (year) (year) Fixed Facility Outside 16 0.26 30.3 4.10 of Vietnam Relocatable to Vietnam 10 0.3 428 63.8 Overall 26 0.26 428 27.1 Assuming that treatment times above a five-year duration are not practical, only 17 vendors (5 with relocatable systems) could be considered with their current facilities. The top three performing vendors for importable waste equipment are K&S Entsorgung (Germany), Kommunekemi (Denmark) and Bayer Industry Services (Germany), the first being a salt mine disposal option (no destruction). The top three performing relocatable facilities are Tox Free (Australia), Hallet (Canada) and ELD (New Zealand). 7.3 Discussion of Results: Soil Treatment As there is no estimated quantity of PCB-contaminated soil in Vietnam, a quantity of 10,000 m3 was selected for comparison. This would be the equivalent of one large remediation site or a number of medium-sized sites. After applying this quantity of soil to the 24 vendors with technologies that can destroy PCBs in soil, the durations of treatment varied from 0.05 years (2.5 weeks) to 20 years (Table 7.5). Of these, 10 vendors could treat the soil with relocatable or portable facilities in Vietnam and the balance would require importation of the soil to fixed facilities in their country of origin. The larger fixed facilities tended to be able to treat the soil in shorter duration while the relocatable or portable as shown in Table 7.8 below: Table 7.8 : Summary of Equipment Treatment Durations Minimum Duration Maximum Duration Average Duration Treatment Location No. Vendors (year) (year) (year) Fixed Facility Outside 14 0.05 5 0.78 of Vietnam Relocatable to Vietnam 10 0.06 20 4 Overall 25 0.05 20 2.12 Assuming that treatment times above a one year duration are not practical, only 14 vendors (5 with relocatable systems) could be considered with their current facilities (a lower acceptable duration compared to previous sections was selected due to the smaller quantity if material applied in the calculations). The top three performing vendors for importable waste equipment are Kommunekemi (Denmark), Bayer Industry Services (Germany) and AVG Hamburg (Germany). The top three performing relocatable facilities are Tox Free (Australia), Hallet (Canada) and ELD (New Zealand). I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 108 of 119 7.4 Summary of Treatment Capacity Durations The top performing vendors in the analysis discussed above were identical in most cases whether the material treated was oil, equipment or soil, as shown below: Relocatable Oil Equipment Soil · Hydrodec Group plc (UK) · Tox Free (Australia), · Tox Free (Australia), · Tox Free (Australia), · Hallet (Canada) · Hallet (Canada) · Hallet (Canada) · ELD (New Zealand) · ELD (New Zealand) Importation Required Oil Equipment Soil · Kommunekemi (Denmark) · K&S Entsorgung (Germany) · Kommunekemi (Denmark) · Bayer Industry Services · Kommunekemi (Denmark) · Bayer Industry Services (Germany) · Bayer Industry Services (Germany) · AVG Hamburg (Germany) (Germany) · AVG Hamburg (Germany) For relocatable systems, Tox Free of Australia with a combination of thermal desorption and off-gas incineration and Hallet of Canada with Gas Phase Chemical Reduction (GPCR) can treat all waste types with the fastest treatment rates (all Vietnamese waste types, 0.51 years and 0.88 years respectively) based on the information provided by the vendors. For fixed facilities, Kommunekemi of Denmark and Bayer Industry Services of Germany, both using high temperature incineration, can treat all waste types with the shortest treatment durations of 0.44 years and 0.51 years respectively (exclusive of shipping). I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 109 of 119 8.0 COST ASSESSMENT AND COMPARISON The information compiled in the previous sections needs to be assessed on a common basis in order to allow a comparison of the various options available. Only those options identified that meet project goals have been subject to the detailed cost assessment. As in the previous section, the basis of comparison was developed from information provided by the National Implementation Plan and World Bank Records. The following was assumed with respect to the contaminated media: · 10,000 tonnes of PCB-containing oil (61,500 drums) require treatment. Half of this quantity has been assumed to contain concentrations of PCBs greater than 500 ppm and half has been assumed to contain PCB concentrations less than 500 ppm. · 75,000 tonnes of transformers (10,000 units of varying size) require treatment. Again, it has been assumed that half of the transformers contain oil with concentrations of PCBs greater than 500 ppm and half contain oil with concentrations of PCBs less than 500 ppm. · 5,500 tonnes of PCB-containing ballasts require treatment. The total amount of waste is 90,500 tonnes. Several costing scenarios were developed in order to provide a basis for discussion and decision-making. The scenarios considered overseas treatment of PCB waste, local treatment and various combinations of the two. For scenarios involving an overseas treatment and/or disposal component, shipping costs were obtained from the facilities where possible. Where this was not possible, approximate shipping costs were provided by Palalpina Inc. of Canada. The costing scenarios focused on facilities that were identified as preferred facilities in Section 6, based on cost, experience and track record of the facility, health and safety, and public acceptance. The costing scenarios are described as follows: Scenario 1: This scenario assumes that all waste is shipped to overseas facilities, with no waste treated in Vietnam. Some facilities were able to provide updated pricing, based on the waste concentrations being considered (i.e. 500 ppm and > 500 ppm) while some were not. For those facilities that did not provide revised pricing, the generic pricing provided in their questionnaires was used as a basis. The results of the comparison are shown in Table 1. Scenario 2: This scenario assumes that oils are shipped to overseas facilities for disposal and that drained electrical equipment (transformers and large capacitors) are sent to K+S in Germany for disposal in the salt mine. Only cellulosic material (wood and paper) recovered from the transformers and capacitors are treated in Vietnam (Holcim Vietnam). In addition to the assumptions made regarding waste quantities and contaminant concentrations, the following assumptions applied to this scenario: · Transformers contain 34% oil by weight, 58% metals by weight and 8% cellulosic material by weight; · Capacitors contain 36.5% oil by weight, 19% metals by weight and 44.5% cellulosic material by weight. The cost of local labour to dismantle the transformers and capacitors and separate their components, and internal transport costs within Vietnam to local treatment facilities have not been included in the costing for this scenario. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 110 of 119 The results of the comparison are shown in Table 2. Scenario 3: This scenario assumes that all oil waste (including oils recovered from transformers and capacitors) and cellulosic material are treated in Vietnam by Holcim Vietnam, while the transformer and capacitor carcasses are disposed of by K+S in Germany (in the salt mine). Shipping costs were unavailable from Vietnam to Kassel, where K+S is located in Germany. However, costs were available for shipment to Biebesheim, located approximately 235 km south, which were used in these calculations. Internal transport costs within Vietnam to local treatment facilities have also not been included. The results of the comparison are shown in Table 3. Scenario 4: This scenario assumes that all waste is treated within Vietnam by relocatable units supplied by overseas contractors. Only two of the preferred facilities (ESI Group of Australia and Hallet of Canada) provided set up costs. ESI's costs were built into their treatment estimates, whereas Hallet provided separate costs. Of all of the preferred facilities, only Hallet provided operating costs (built into their treatment costs). It should be noted that internal transport costs within Vietnam to local treatment facilities have not been included. As the waste will be treated in Vietnam, the potential exists to recover the scrap metal from transformers and capacitors. The price for the metals will vary depending on the quantity and grade of material present, so no definite pricing could be obtained at this time on the value of this material. Estimates for the sale of these materials were obtained from Ambey Traders Inc., a recycling company based in India with a branch in Canada. The assumptions were as follows: · Metal from transformers and capacitors comprise approximately 50% aluminum, 40% steel and 10% copper. · Prices for copper and aluminum vary from $1200 USD to $1800 USD per tonne, while prices for steel vary from $150 to $180 USD per tonne (September 2007 prices). The value of the recovered metal can be used to offset the cost of local treatment. The results of the comparison are shown in Table 4. . Scenario 5: This scenario assumes that all oils and cellulosic materials are treated by Holcim Vietnam, while the transformer and capacitor carcasses are cleaned by relocatable facilities in Vietnam supplied by overseas contractors. The scenario considered sodium reduction, supplied by ESI Group of Australia, and gas phased chemical reduction, supplied by Hallet of Canada. As in Scenario 4, the value of the recovered metal can be used to offset the cost of treatment. It should be noted that internal transport costs within Vietnam to local treatment facilities have not been included. The results of the comparison are shown in Table 5. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 111 of 119 8.1 Comparison of Cost Estimate Scenarios The scenarios presented above have been based largely on the assumptions outlined, and should not be treated as definite costs. However, they are useful in presenting for comparison the various options available for treatment of Vietnam's PCB waste. The most expensive options appear to be the complete export of all wastes for overseas disposal (Scenario 1) and the complete retention of all waste in Vietnam for treatment by relocatable units provided by overseas contractors (Scenario 4). The costs of treatment in Vietnam by overseas contractors will be offset by the value of the recoverable material. One of the primary benefits of overseas treatment is that waste disposal can take place in facilities with established track records, with process and environmental safeguards built in. The regulatory environment in these countries is also fully developed to manage the disposal of hazardous waste including PCB waste. Drawbacks of the overseas treatment approach include the risk associated with the transport of waste, and the loss of recoverable material such as metals. Local treatment minimizes transport risks to those within Vietnam and ensures that recoverable materials are available to the people of Vietnam. Additionally, Vietnamese technical specialists will gain skill and knowledge working with facilities operating in their own country. These technical specialists will be useful in fully developing Vietnam's domestic hazardous waste management industry. Operating treatment plants in Vietnam may be faced with difficulties with relatively unreliable utility supplies and a lack of regulatory capacity and experience to manage these facilities efficiently. Scenarios 2 and 3 comprise a mixture of local treatment by Holcim Vietnam and overseas treatment and/or disposal. Scenario 3, which involved local treatment of oils and cellulosic material by Holcim Vietnam and disposal of transformer and capacitor carcasses by K+S in Germany, was significantly cheaper than Scenario 2, which involved overseas treatment of oils, treatment of cellulosic material by Holcim Vietnam and disposal of the carcasses by K+S. These findings are expected. Drawbacks to this approach are primarily related to the loss of recoverable material, which will be deposited and sealed in a salt mine in Germany. Holcim Vietnam is well established in Vietnam, and if waste is treated in modern cement kilns, irregularities in utility supplies should not be an issue. Other cement kilns in Vietnam with similar modern designs may also be prepared to accept hazardous waste, allowing competition to reduce costs of disposal. Scenario 5 involves a mixture of local treatment options, involving treatment of oils and cellulosic material by Holcim Vietnam, and local treatment of carcasses by overseas contractors in Vietnam. This solution ensures that recoverable materials remain in Vietnam, but issues may arise during the operation of the relocatable units due to irregularities in utility supply and lack of regulatory capacity. However, based on the assumptions made, Scenarios 3 and 5 are the most financially viable at this time. 8.1.1 Scenario 1 There are seven different options for the treatment of all the transformers, capacitors and oil at overseas facilities listed below. It should be noted that comparisons between the facilities are not straightforward due to differences in operation. For example, Valorec (Switzerland) does not treat transformers so it cannot be accurately compared to the other facilities. Also, ESI Group (Australia) does not include 40ft containers for shipment so only 20ft container prices will be compared. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 112 of 119 Table 8.1 : Cost Comparison ­ Scenario 1 Total Waste Total Shipping Total Shipping Total Total Cost of Total Cost of Facility/Waste Quantity Costs (USD)/20 Costs (USD)/40 Treatment Disposal (USD) Disposal (USD) Type (tonnes) foot containers foot containers Costs (USD) (using 20 foot (using 40 foot containers) containers) ESI Group 90,500 18,617,963 - 107,173,611 125,791,574 - (Australia) Tredi Seche 90,500 19,946,200 26,821,938 228,875,000 248,821,200 255,696,938 (France) Ekokem 90,500 21,151,143 26,199,750 100,368,750 121,519,893 126,568,500 (Finland) HIM 90,500 22,159,571 28,243,542 145,350,000 167,509,571 173,593,542 (Germany) SAVA 90,500 20,727,086 25,370,167 71,332,000 92,059,086 96,702,167 (Germany) Dottikon 90,500 62,784,375 48,870,000 164,782,500 227,566,875 213,652,500 (Switzerland) Valorec 90,500 7,128,450 5,783,438 13,591,250 20,719,700 19,374,688 (Switzerland) For this scenario the most financially viable option is SAVA in Germany, which will cost approximately $92,059,086 (USD) for incineration. The only viable non-incineration option is ESI Group, which uses sodium reduction. See Appendix G for more information of the cost calculations. 8.1.2 Scenario 2 For this scenario only the cost for 20ft containers will be compared because some facilities do not use the 40ft containers. All the cellulosic waste (8,448 tonnes) will be disposed of by Holcim (Vietnam). This will cost $6,220,980 (USD). All the transformer and capacitor carcasses (44,545 tonnes) will be disposed of by K+S (Germany). This will cost $26,676,091 (USD). Therefore only the options for the disposal of the oil waste (37,508 tonnes) by the overseas facilities will be compared. Table 8.2 : Cost Comparison ­ Scenario 2 Total Waste Total Shipping Total Shipping Total Total Cost of Total Cost of Facility/Waste Quantity Costs (USD)/20 Costs (USD)/40 Treatment Disposal (USD) Disposal (USD) Type (tonnes) foot containers foot containers Costs (USD) (using 20 foot (using 40 foot containers) containers) Oil Waste (from transformers, capacitors and used mineral oil) ESI Group 37,508 6,424,896 - 13,544,375 19,969,271 - (Australia) Tredi Seche 37,508 8,266,653 11,116,285 84,391,875 92,658,528 95,508,160 (France) Ekokem 37,508 8,766,039 10,858,421 56,111,220 64,877,259 66,969,641 (Finland) HIM 37,508 9,183,979 11,705,466 12,752,550 21,936,529 24,458,016 (Germany) SAVA 37,508 8,590,289 10,514,603 20,234,590 28,824,879 30,749,193 (Germany) Dottikon 37,508 26,020,828 20,254,050 42,871,073 68,891,901 63,125,123 (Switzerland) Valorec 37,508 17,249,699 13,994,986 26,150,229 43,399,928 40,145,215 I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 113 of 119 Table 8.2 : Cost Comparison ­ Scenario 2 Total Waste Total Shipping Total Shipping Total Total Cost of Total Cost of Facility/Waste Quantity Costs (USD)/20 Costs (USD)/40 Treatment Disposal (USD) Disposal (USD) Type (tonnes) foot containers foot containers Costs (USD) (using 20 foot (using 40 foot containers) containers) Oil Waste (from transformers, capacitors and used mineral oil) (Switzerland) Cellulosic Waste (Disposed of by Holcim (Vietnam)) Holcim 8448 96,543 - 6,124,438 6,220,980 - (Vietnam) Transformer and Capacitor Carcasses K+S (Germany) 44,545 10,907,161 13,901,752 15,768,930 26,676,091 29,670,682 The most financially viable option for this scenario is ESI Group in Australia. The total cost of this option is $52,866,342 (USD). The most viable incineration option is HIM in Germany. See Appendix G for more information of the cost calculations. 8.1.3 Scenario 3 There are no options to compare for this scenario. All the oil waste (37,508 tonnes) and cellulosic waste (8,448 tonnes) will be disposed of by Holcim (Vietnam). All the transformer and capacitor carcasses will be disposed of by K+S (Germany). Table 8.3 : Cost Comparison ­ Scenario 3 Total Waste Total Shipping Total Shipping Total Total Cost of Total Cost of Facility/Waste Quantity Costs (USD)/20 Costs (USD)/40 Treatment Disposal (USD) Disposal (USD) Type (tonnes) foot containers foot containers Costs (USD) (using 20 foot (using 40 foot containers) containers) Oil Waste Holcim 37,508 428,657 - 27,192,938 27,621,595 - (Vietnam) Cellulosic Material Holcim 8,448 96,543 - 6,124,438 6,220,980 - (Vietnam) Transformer and Capacitor Carcasses K+S (Germany) 44,545 10,907,161 13,901,752 15,768,930 26,676,091 29,670,682 The total cost of this scenario is $60,518,666 (USD). See Appendix G for more information of the cost calculations. 8.1.4 Scenario 4 In this scenario all materials will be treated locally by overseas contractors. There are six facilities to compare. This will allow Vietnam to keep the scrap metal which will help to offset the cost of this scenario. The savings from the scrap metal can range between $34,745,100 (USD) and $51,315,840 (USD). I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 114 of 119 Table 8.4 : Cost Comparison ­ Scenario 4 Transportation Total Cost of Total Waste Total Facility/Waste Costs (USD) Set Up Cost Operating Cost Transportation Quantity Treatment Type (20 foot (USD) (USD) plus Treatment (tonnes) Costs (USD) container) (USD) provided in ESI Group 90,500 1,034,286 treatment not provided. 41,295,833 42,330,119 (Australia) estimate. Tredi Seche 90,500 1,034,286 not provided. not provided. 228,875,000 229,909,286 (France) Dolomatrix International 90,500 1,034,286 Not provided. not provided. 258,157,413 259,191,698 (Australia) Hallet (Canada) included in 90,500 1,034,286 $4,000,000 143,310,000 148,344,286 (Vietnam) treatment cost. Hallet (Canada) included in 90,500 1,034,286 $4,000,000 157,580,000 162,614,286 (Hallet) treatment cost. Kinectrics 90,500 1,034,286 not provided. not provided. 112,847,222 113,881,508 (Canada) Scrap Metal Total Steel Price/tonne Copper price/tonne Aluminum price/tonne Recovery (tonnes) $150 $180 $1,200 $1,800 $1,200 $1,800 Transformer 43,500 $2,610,000 $3,132,000 $5,220,000 $7,830,000 $26,100,000 $39,150,000 Carcasses Capacitor 1,045 $62,700 $75,240 $125,400 $188,100 $627,000 $940,500 Carcasses The most financially viable facility for this scenario is the ESI Group from Australia, at a cost of $42,330,119 (USD). However, only generic pricing information was available from Tredi Seche, which may not reflect the true cost of disposal. See Appendix G for more information of the cost calculations. 8.1.5 Scenario 5 For this scenario the oil waste (37,508 tonnes) will be treated by Holcim (Vietnam). The cellulosic waste (8,448 tonnes) will also be treated by Holcim (Vietnam). There are three facilities that will be located in Vietnam and will clean the transformer and capacitor carcasses (44,545 tonnes). As in Scenario 4, the scrap metal can be recovered and sold, saving between $34,745,100 (USD) and $51,315,840 (USD). Table 8.5 : Cost Comparison ­ Scenario 5 Transportation Total Cost of Total Waste Total Facility/Waste Costs (USD) Set Up Cost Operating Cost Transportation Quantity Treatment Type (20 foot (USD) (USD) plus Treatment (tonnes) Costs (USD) container) (USD) Oil Waste Holcim 37,508 428,657 - - 27,192,938 27,621,595 (Vietnam) Cellulosic Material Holcim 8,448 96,543 - - 6,124,438 6,220,980 (Vietnam) I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 115 of 119 Transportation Total Cost of Total Waste Total Facility/Waste Costs (USD) Set Up Cost Operating Cost Transportation Quantity Treatment Type (20 foot (USD) (USD) plus Treatment (tonnes) Costs (USD) container) (USD) Transformer and Capacitor Carcasses Provided in ESI Group 44,545 509,086 treatment not provided 14,460,750 14,969,836 (Australia) estimate. Hallet (Canada) included in 44,545 509,086 4,000,000 20,490,700 24,999,786 (Vietnam) treatment cost. Hallet (Canada) included in 44,545 509,086 4,000,000 22,272,500 26,781,586 (Hallet) treatment cost. Scrap Metal Total Steel Price/tonne Copper price/tonne Aluminum price/tonne Recovery (tonnes) $150 $180 $1,200 $1,800 $1,200 $1,800 Transformer 43,500 $2,610,000 $3,132,000 $5,220,000 $7,830,000 $26,100,000 $39,150,000 Carcasses Capacitor 1,045 $62,700 $75,240 $125,400 $188,100 $627,000 $940,500 Carcasses The most financially viable facility to use would be the ESI Group (Australia). This would result in a total cost of $48,812,411 (USD). However, the operating costs are not provided, which will impact the final overall cost. See Appendix G for more information of the cost calculations. 8.1.6 Summary As summary of the costs of the five scenarios developed is included in the table below. Only the preferred option is provided from each scenario. Table 8.6 : Cost Comparison Summary Scenario Lowest Viable Vendor Offering Methods of Description No. Price (USD) Best Alternative Disposal All waste shipped to an overseas 1 $96,059,086 SAVA (Germany) Incineration facility for disposal. All oil shipped to an overseas facility for disposal, all drained transformer ESI Group (Australia) 2 $52,866,342 Sodium dechlorination and capacitor hulks disposed of in a salt mine in Germany. All oil and cellulosic material Holcim (Vietnam) Cement kiln co- destroyed at Holcim in Vietnam, all 3 $60,518,666 processing drained transformer and capacitor hulks K+S (Germany) Salt mine storage disposed of in a salt mine in Germany. All waste materials treated in Vietnam, by relocatable treatment systems 4 $42,330,119 ESI Group (Australia) Sodium dechlorination provided and operated by overseas vendors. Oils and cellulosic material treated by Holcim (Vietnam), carcasses cleaned Holcim (Vietnam) Cement kiln co- 5 using relocatable treatment systems $48,812,411 processing operated by overseas vendors but ESI Group (Australia) Sodium dechlorination located in Vietnam. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 116 of 119 The most attractive scenario financially is Scenario 4, which treats all waste material in Vietnam by relocatable facilities provided and operated by overseas vendors. Costs will also be recovered by recycling scrap materials within Vietnam. 8.2 Comparison of Cost Estimates Scenarios: Soil As in the previous sections, the cost for treating soil using applicable technologies, some the same as for oil, transformers and capacitors, was estimated according to the five selected scenarios. For comparison, the treatment of 10,000 tonnes of PCB contaminated soil was used as a basis. For all the costs provided in this section, Appendix H has more information regarding the cost calculations. 8.2.1 Scenario 1 In this scenario, all the soil will be shipped to overseas facilities for disposal. Since there is one facility that does not ship with 40ft containers, only the 20ft container prices will be compared. Table 8.7 : Soil Cost Comparison ­ Scenario 1 Total Cost of Total Cost of Total Waste Total Shipping Total Shipping Total Disposal (USD) Disposal (USD) Facility Quantity Costs (USD)/20 Costs (USD)/40 Treatment (using 20 foot (using 40 foot (tonnes) foot containers foot containers Costs (USD) containers) containers) ESI Group 10,000 1,850,000 - 17,000,000 18,850,000 - (Australia) Ekokem 10,000 2,337,143 2,895,000 13,600,000 15,937,143 16,495,000 (Finland) HIM 10,000 2,448,571 3,120,833 4,080,000 6,528,571 7,200,833 (Germany) SAVA 10,000 2,290,286 2,803,333 6,800,000 9,090,286 9,603,333 (Germany) Dottikon 10,000 6,937,500 5,400,000 16,510,000 23,447,500 21,910,000 (Switzerland) Valorec 10,000 4,599,000 3,731,250 4,980,000 9,579,000 8,711,250 (Switzerland) The most financially optimal disposal facility was HIM (Germany) at a cost estimated to be $6,528,571 (USD). 8.2.2 Scenario 2 For this case all the soil is shipped to K+S (Germany), a salt mine in Germany. There are no options allowing comparison and the total cost is estimated to be $5,988,571 (USD). The cost for using 40 foot shipping containers is larger ($6,60,833 USD) due to increased transportation cost for the larger containers. 8.2.3 Scenario 3 Similar to the previous section there is only one facility evaluated for disposing of the soil at an existing facility in Vietnam (cement kiln co-processing at Holcim, Vietnam). This scenario will cost $5,583,333 (USD). I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 117 of 119 8.2.4 Scenario 4 In Scenario 4, overseas facilities will be relocated in Vietnam to treat the soil. There are four different options, provided by three facilities. Table 8.8 : Soil Cost Comparison ­ Scenario 4 Total Cost of Total Waste Transportation Total Facility/Waste Set Up Cost Operating Cost Treatment Plus Quantity Costs (20 foot Treatment Type (USD) (USD) Transportation (tonnes) container) Costs (USD) (USD) provided in ESI Group 10,000 114,286 treatment not provided. 7,000,000 7,114,286 (Australia) estimate. Dolomatrix 10,000 114,286 not provided. not provided. 19,312,450 19,426,736 (Australia) Hallet (Canada) operated by included in 10,000 114,286 4,000,000 4,600,000 8,714,286 Government of treatment cost. Vietnam Hallet (Canada) included in 10,000 114,286 4,000,000 5,000,000 9,114,286 operated by Hallet treatment cost. The most economic technology would be provided by the ESI Group (Australia). This option would cost $7,114,286 (USD), however, the operating costs have not provided. 8.2.5 Scenario 5 In this scenario the soil will be treated on-site by in situ or other on site methods. A positive aspect of this scenario is that there will be no transportation costs. There are four different providers that were evaluated as follows: Table 8.9 : Soil Cost Comparison ­ Scenario 5 Total Waste Total Total Cost of Transportation Set Up Cost Unit Cost Treatment Type Quantity Treatment Treatment Plus Costs: None (USD) (USD/tonne) (tonnes) Costs (USD) n (USD) In Situ Vitrification 10,000 0 4,000,000 750 7,500,000 11,500,000 (AMEC Geomelt) Anaerobic/Aerobic 10,000 0 n/a 32 320,000 320,000 Composting In Situ Enhanced 10,000 0 n/a 32 320,000 320,000 Bioremediation Thermally enhanced Soil 10,000 0 n/a 59 590,000 590,000 Vapour Extraction (SVE) Even though In Situ Vitrification is the most expensive option, it might have to be used depending on the PCB levels in the soil and time constraints. The other three choices may be more financially attractive, but treatment completion times can range from months to years, and they only work on soil with low levels of PCBs. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 118 of 119 8.2.6 Summary A summary of the costs of the five scenarios developed for PCB-contaminated soil treatment is included in the table below. Only the preferred option is provided from each scenario. Table 8.10 : Soil Cost Comparison Summary Scenario Lowest Viable Vendor Offering Methods of Description No. Price (USD) Best Alternative Disposal Soil shipped to an overseas facility for 1 $6,528,571 HIM (Germany) Incineration disposal. Soil shipped to German salt mine for 2 $5,988,571 K+S (Germany) Storage disposal. Cement kiln co- 3 Soil treated by Holcim (Vietnam). $5,583,333 Holcim (Vietnam) processing Soil treated in Vietnam, by relocatable ESI Group Sodium 4 treatment systems provided and operated $7,114,286 (Australia) dechlorination by overseas vendors. Soil treated in situ (in place) by AMEC Geomelt 5a $11,500,000 In situ Vitrification purchasing a Geomelt system. (USA, Australia) Soil treated ex situ (post excavation) Many vendors Anaerobic/Aerobic 5b $320,000 anaerobic and aerobic composting. possible. bioremediation If the PCB levels are low and there are no constraints for time then the best option would be Scenario 5b (soil treated ex-situ by a combination of anaerobic and aerobic composting). Otherwise, the most financially viable option would be Scenario 3 (treatment of soil by co-processing at a cement kiln in Vietnam). In general, soil remediation is very site-specific and remedial approaches need to be made individually. 8.3 Next Steps The information provided in this report can be used as the first step for decision-makers in Vietnam to determine what approach they should take to implement their PCB destruction program. The next step is developing a methodology for selecting the preferred approach. This requires consultation with key stakeholders as to what is important to them and then develop a selection process to weight key criteria on a relative basis and score the most promising technologies based on this selection process. Key stakeholders include regulators, funding agencies, principle owners of PCB-containing equipment and domestic waste disposal industries. With respect to regulators, both central and regional bodies need to be involved and ministries beyond those related directly to the environment consulted. Discussions with local governments is also advisable. Some examples of which issues may be important to stakeholders include: · cost; · schedule including meeting required deadlines; · technical capacity; · supply of inputs (electricity, industrial chemicals, etc.); · domestic employment; I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 119 of 119 · skills development; · international obligations; · environmental impact, examples below (not exclusive list): o air emissions; o solid waste produced; o hazardous waste produced; o handling of residuals and by-products; · protection of human health; · institutional capacity. Scoring Technologies: The above list would need to be embellished, each criteria defined with the scores being provided for each technology according to each of the criteria. Relative Weighting: Each stakeholder should provide their opinion regarding the relative importance of each defined criteria. By applying the relative weightings to the scores, a total score can be developed for each technology/approach and a prioritized list developed. The last step in the process is requiring the top 5 to 10 technological approaches to submit proposals for implementation. Only with their responses can significantly more accurate cost estimates be received. I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 Appendix Appendix A Acronyms I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 Appendix Appendix B References I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 Appendix Appendix C Task 1 Forms I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 Appendix Appendix D Task 2 Supporting Information I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc D-1 Centre for Environmental Treatment Technologies Dear Edward! This is information as per requested by WB: THÔNG T Hng dn iu kin hành ngh và th tc lp h s, ng ký, cp phép hành ngh, mã s qun lý cht thi nguy hi Ques. 1: The procedures that the facilities have gone through apply to obtain a permit ? Vietnam Government has issued a circular No. 12/2006/TT-BTNMT dated 26 December 2006 on Guideline for permit conditions and procedures for preparation of permit application, registration, permit issuance, codding of hazardous waste management. This is extracted from the Circular: 3 The procedures for permit for hazardous waste management: 3.1. Organizations and individuals register for treatment and disposal of hazardous waste have to prepare 03 ( three) sets of permit application whic are included registrate application and other neccessary documents and submit to authorities. 3.2. Within 12 days from the date of submitting the documents, the permitting agency will identify shortcomings then inform the submitting facility so that they can complete it. Within 7 days, the facility will complete the application as requirements and submit it again. Permitting agency will inform about application completion. If the application does not meet the requirements, the process can not continue, the application will be returned. 3.3. Based on application completion , the Permittee have to set up a plan for test running of the treatment facilities. The Permitting agency will colaborate with other stakehoders to inspect and evaluating the test results. . The Environemntal Authority will grant a certify in writen within 12 days . This certification will be attached with application documents. If not, it is needed to modify or adjust and complete the option for test running. Permit can only be issued before the issuance of decision on EIA approval. EIA report specifies the potential impacts on environment and human health as well as their mitigation measures. Based on these, the permit writer could compile the permit conditions that facility should comply with, with the eventual goal to protect human health and environment. The content of an EIA shall be adopted with the Circular No. 08/2006/TT-BTNMT dated 09/08/2006 of the Ministry of Natural Resource and Environment providing guidelines on Strategic Environmental Assessment, EIA and commit to environmental protection. 3.5. Within 30 days from the date of issueing the test running certification, permitting agency make the final decision on permitting. 3.8. The Permittee will receive a code of hazadous waste management together with permit. After being permitted, the facility must self-monitor their activities to ensure the compliance with environmental requirements and permit conditions. Self-monitoring can be carried out by the very facility, or preferably by independent environmental auditors (consultants) who have work permit There must not be the absence of environmental inspector, self-monitoring needs to combine closely with environmental inspection. The results of self-monitoring need to be recorded in periodic reports and submitted to appropriate authority and published to the public. 3.9. The permit is legally valid in the period of 3 years. This validity is decided by the permitting agency based on the practical operation situation. After this period expired, the facility must ask for extension, or new permit. Ques. 2: For test run, who participate in the test run, what kind of parameters are required to collect, who collect it, the relationship between teast run and permits and the future inspection? An independent environmental auditor (consultant organization) who have work permit will conduct the test run. The DONRE / MONRE officers will be inspect the test run Emission monitoring is for identifying pollution level in all components: air, water, noise, radioactivity, norms that need to be monitored in each environmental component (depending on type of activity). It is necessary to clearly specify requirements for frequency and monitoring data. there are specific pollutant emissions depending on each type of activity. Based on that, there are emission limits for those pollutants. In case of treating hazardous waste in cement kiln, there are emission limits for dust, dioxin/furan, mercury, metal... These emissions must comply with Vietnamese Standards (TCVN). System of TCVN environmental standards is a very important condition, especially in Vietnam. The initial inspection for teast run and the future inspection shall be conducted with the same parameters. Ques. 3: Reporting and monitoring requirement,what kind of parameters will be reported, who collect information, what is reporting frequency ? As same as Ques. 2: reporting frequency : every 6 month Ques. 4: How waste are trasfered to the facilities, role of DONRE, MONRE in this process for both in province and cross-province trasfers? The trasfer of hazardous waste shall be conducted by permited waste transpoters. DONRE will have responsibilities to grant, Modification , inspection of permited waste transpoters who conduct the trasfer of hazardous waste for waste generators within province. MONRE will have responsibilities to grant, Modification , inspection of permited waste transpoters who conduct the trasfer of hazardous waste cross from two/ more than two provinces Ques. 6. Environmental inspection of the facilities will be conducted by the inspectors (belonging to DONRE/MONRE). The inspector will carry out re-permitting inspection for the facility after the permit expired. In the inspection process, the facility is obligated to cooperate closely with permitting agency. If a facility denies cooperation or causes problem in the inspection process, permitting agency can reject the environmental permitting for that facility. S ¬ ® å q uy t r × h c « ng ng hÖ n t iª u h u û t h u è c BVTV t å n ®ä n g , c Êm s ö d ô n g Th u è c BV TV Ph © n l o ¹ i Th u è c d ¹ n g Th u è c d u n g Th u è c d ¹ n g v á ba o b× bé t c dÞ h n- í c d un g m« i p h è i l iÖu x ó c x ö l ý s¬ bé x ö l ý s¬ bé x ö l ý s¬ bé t ¸ c & p h ô g ia KhÝth¶i Lß ® è t 2 c Ê p Lß ® è t t h u è c Lß ® è t v á b a o b × d ¹ n g d un g m« i Tro xØ N- í c th¶i n æn ®Þ h Xö l ý HÊ p t h ô , h Ê p ph ô n - í c th¶ i Ch« n lÊp t h ¶ i bá th ¶ i r a kh « n g kh Ý D-2 Centre for Environmental Protections and Consultation D-3 Vietnamese Academy of Science and Technology SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 App D-1 Academy of Sciences and Technology Photograph 1 : Alkali reduction reactor vessel. Photograph 2 : Sampling ports of reactor. Sodium Technology ( Na-Tech) Developed by the Institute of Chemistry of the National Centre for Natural Sciences and Technology of Vietnam 1.The Basic Principle of the "Na-Tech" The use of Na-Tech for the reduction of chlorinated organic compounds is based on the Wurtz-Vittig reaction reactions ( discovered in 1850s, 1860s) as below (Equation 1 & 2): 2R-X + 2Na R-----R + 2NaX (1) where R is the alkyl radical X is the halide ( Cl, Br, F...) R-X + Ar-X + 2Na R-----Ar + 2NaX (2) where Ar is the aryl group, and other terms have been previously defined. As indicated by Equation (1) and (2), the residues from the treatment process include: · Sodium salts · Saturated aliphatic hydrocarbons · Aromatic hydrocarbons · Mixed aliphatic-aromatic hydrocarbon · Unreacted metallic sodium +The organic byproducts are either combusted or recovered following refinement for appropriate post-treatment uses, e.g., energy recovery; +The inorganic byproducts, e.g., andsodium salts, are typically recovered as sludge or ash and disposed of in an appropriate manner; +The unreacted metallic sodium are removed by the reaction with high aliphatic alcohol Some Important Features of the Wurtz-Vittig Reaction: · The reaction is not reversible. The formation enthalpy of carbon-chloride bond is 328kJ/ mol, while that of a sodium-chloride bond which exists following destruction of a chlorinated compound is 411 kJ/mol. This situation eliminates the formation of toxic halogenated byproducts from the treatment process; · The reaction is exothermic · The reaction usually takes place at comparatively low temperature and at atmospheric pressure; · The Wurtz-Vittig reaction could be applicable to many non-halogenated compounds, since these compounds contain reactive groups that are sensitive to attack by sodium. For example, sulfur hexafluoride, tributyl phosphate etc. 2.Types of Wastes Treated · For the treatment of liquid and solid waste streams of halogenated hydrocarbons: * Metallic sodium should be dispersed into an appropriate liquid media that has low volatility with an inert gas, e.g., argon, The liquid waste stream of halogenated hydrocarbon is then added directly to the sodium dispersion under suitable reaction conditions (temperature, pressure etc.); * In the case of the solid waste stream of halogenated hydrocarbon, it should be pretreated to make the waste stream have a large surface for the reaction with sodium. · For the treatment of gaseous waste streams of halogenated hydrocarbons: -The metallic sodium should be immobilized either as a thin film or bound in another manner, such as on ceramic beads, that allows a large surface of sodium over which the gas can be passed. The gaseous waste stream of halogenatated hydrocarbon is the passed through the column, causing the compounds to be reduced 3. Operating Conditions: · The technology is applied at relatively low temperatures, generally ranging from 100 -140 0C depending on the chemicals to be destroyed; · The reaction time required: 2-3 hrs · The Na-Tech operates at atmospheric pressure providing an important safety feature; · The rate of the reaction and hence, the rate of exothermic heat generated by the reaction, can be controlled by the rate at which the waste and the sodium dispersion are mixed. In an emergency, the reaction can be quickly halted be ceasing the addition of waste, removing the applied heat, and flushing the outside of the reactor with cooling water; · Strong enthalpy of formation preclude a reversal of the reaction once the original chemical has been reduced. · Reagents used to operate the Na-Tech are relatively inexpensive and can be recycled. Similarly, capital investments are relatively low; · The chemicals used in the technology are not corrosive to metal, allowing construction of large-scale reaction vessels with common materials 4. Types of by-Products: The by products maybe oils, solids, powders or gases but not water effluents, depending on what kinds of wastes to be treated ( See Point 2 above). 5. Performance of the Na-Technology: All the treated samples by the " Na-Tech" have been analysed by GC/MS. The results indicated that almost all the amount (95-98%) of PCBs in transformer oils, chlorinated benzenes, pestisides etc. were destroyed following treatment. 6.Scale of Present Plant: Pilot-scale applications in form of mobile equipments with a capacity of 200kg per 8hrs each, have already been installed at the Institute of Chemistry of NCST of Vietnam for the destruction of PCBs in transformer oils. 7. Estimated Costs The approximately estimated cost per tonne of PCBs in transformer oils to be treated by the " Na-Tech" is about 5,000 USD. The above-described Na-Tech is the common technology based on the use of metallic sodium to dechlorinate the PCB molecules and yield an oil which can be reuesd, whether in the transformer or in some other use. The technology presents the advantage over incineration, not only of lower costs, but also of allowing recovery of the oil for re-use. Sodium is reactive metal which is easily oxidised; is reacts violently with water to give hydrogen gas, crating a potential fire hazard. It ha a strong affinity for certain elements, however, including chlorine. It is this property which is exploited in the metallic sodium decontamination technology: the sodium reacts with the chlorine atoms on the PCB molecules to give sodium chloride. The introduction of metallic sodium into a PCB oil leads to a reaction whose rate is dependent on the metal-oil interface. The rate of reaction between the solid metal and the PCB-containing oils depends on the extent of this interface, in that the finer the metal particles, the faster will be the reaction. The dispersion is used at a temperature which is above that of the melting point of the sodium, i.e., 980C. Being a liquid, the metal surface can be renewed continuously. In this way a reasonable reaction rate can be achived, thus decreasing the cost of the decontamination process. Secondary reactions can occur when PCBs react with Na. During the dechlorination step, the intermediate chrorinated molecules can polymerise and lead to the formation of solid polymers containing chlorine. This product can no longer be dechlorinated and settles out of the reaction as a solid. The Na-Tech therefore either must avoid the formation of this polymer, or must take the formation of this solid into accaount and introduce a separation step to yield the pure ­reusable oil. THere are several variants of this Na technology, and full technical details are not always available. The use od Na-Tech to dechlorinate PCBs has been known for a long time. It is only with more recent technologies related to the preparation of very fine dispersions of the metallic sodium, however, that use of this active metal has become economically possible, and also possible from the point of view of fire risk reduction. Companies which operate processes for oil decontamination based on the use od solium are: · Bilger; · Fluidex; · Manitoba Hydro; · Ontario Power; · Powertech; · Safty-Kleen; · SAnexen; · Shinko Pantec; · Tassaco. Sodium+ Potasium Alloys Technology (Na+K Tech) Developed by the Institute of Chemistry of the National Centre for Natural Sciences and Technology of Vietnam Cl Cl 3' 3 2' 2 1' 1 4 + Na Cl 4' Cl 6' 6 5' Cl Cl Cl Cl 3' 3 2' 2 2 Cl 4' 1' 1 . + NaCl 4 6' 6 5' Cl Cl Gèc tù do PCB Cl Cl Cl Cl 3' 3 3' 3 2' 2 2' 2 1' 1 4' 1' 1 Cl 4' Cl 4 4 6' 6 6' 6 5' 5' Cl Cl Cl Cl T- ¬ng tù a n éc Polyme ® nh© th¬m cã chøa clo. Lo¹ i polyme nµy v« cï ng ® h¹ i vµ kü thuËt Ó p - "Na-Tech" trªn kh«ng thÓ¸ p dông ® xö lý tiÕ ® î c S¬ ®å 2: Ph¶n øng Aldolphe Wurtz -Fittig xö lý PCBs C=O + Na . C - + O,Na Benzophenone (BP) Gèc tù do anion S S . C -+ O,Na + dung m«i Solvat . - S + hãa CH O Na S S S Gèc tù do anion Gèc tù do anion ®- î c solvat hãa C=O + Na . C - + O,Na Benzophenone (BP) Gèc tù do anion t liªn kÕ ví i gèc tù do n Ph© huû PCB cña PCB ( Ar ) + Ar-X Ar C - + O,Na + . C O Ar + NaX C C O O Ar Ar D-4 Holcim SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 App D-2 Holcim Photograph 1 : Holcim's Cat Lai Terminal. Photograph 2 : Hazardous waste storage yard and warehouses. SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 App D-3 Holcim (cont'd) Photograph 3 : Interior of hazardous waste storage warehouse. Photograph 4 : Hazardous waste storage containers for marine transport. SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 App D-4 Holcim (cont'd) Photograph 5 : Hazardous waste storage containers (close-up). Photograph 6 : Dock for ships transporting the hazardous waste storage containers. Summary Guidelines on Co-processing Waste Materials in Cement Production The GTZ-Holcim Public Private Partnership Summary Greenhouse gases and global warming, the efficient logical progress and an increasing social and political use of non-renewable fossil fuels, toxic residues, and awareness, the problem of growing waste streams per- the contamination of water and soil are in the fore- sists. The "zero waste society" is a worthy vision, but we front of ecological concerns and public discussions. are far from realizing it. Modern incineration plants and Cost competitiveness, global competition and profita- secure landfills are common disposal options in OECD bility are the concerns of business. The challenge fac- countries but have high investment and operating costs ing today's society is to balance environmental protec- and need qualified personnel. tion and economic interest. One proved alternative and possible solution is the Poor waste management is an issue in developing coun- co-processing of selected waste materials in the cement tries and in countries in transition. In many of these countries, waste is discharged to sewers, buried or burned on company premises, illegally dumped at unsuitable Co-processing refers to the use of waste materials locations, or taken to landfills that fail to meet require- in industrial processes, such as cement, lime, or steel pro- ments for the environmentally sound final disposal of duction and power stations or any other large combus- waste. This can cause contamination of soil, water re- tion plant. In a few cases this process is also called sources, and the atmosphere, leading to the sustained co-incineration, but we recommend to name it co- deterioration of the living conditions and health of the processing as the main objective is not the final disposal adjacent populations. Toxic substances and persistent of waste, but rather the substitution of primary fuel and compounds escape into the environment, are spread raw material by waste. It is a recovery of energy and ma- through the air over large areas, and can enter the food terial from refuse. chain, affecting human and animal health. Several factors can cause these problems: industry. An efficient cement kiln can provide an environ- Y Not all developing countries have an integrated mentally sound and cost-effective treatment/recovery waste management strategy and only a few can of- option for a number of wastes. fer an appropriate technical infrastructure for dis- posing of waste in a controlled and environmentally Different types of wastes have been successfully sound manner co-processed as alternative fuels and raw materials Y Although in many cases laws concerning the control- (AFR) in cement kilns in Europe, Japan, USA, Canada and led handling of waste exist, they are often not properly Australia since the beginning of the 1970s. The use of enforced AFR can decrease the environmental impacts of wastes, Y Uncontrolled disposal is usually the cheapest way to safely dispose of hazardous wastes, decrease green- get rid of the waste, and the waste generators tend to house gas emissions, decrease waste handling costs and be unwilling to pay much for adequate disposal save money in the cement industry. It will help in achiev- Y Policy makers rarely pay enough attention to the sub- ing the targets set in Agenda 21 of the "Earth Summit" in ject of waste management, and may know little about Rio de Janeiro (1992), the Johannesburg Declaration on the consequences for human health or the high cost of Sustainable Development (2002) and the Millennium the remediation of the damage caused by uncontrolled Development Goals. waste disposal. To promote co-processing of waste in cement kilns There is general agreement that there is an urgent the Deutsche Gesellschaft für Technische Zusammenar- need to improve waste management, and different solu- beit GmbH (GTZ), and Holcim Group Support LTD (Hol- tions are being discussed. Waste avoidance, cleaner pro- cim) have formed a strategic alliance. Holcim Group duction, producer responsibility, supply chain manage- Support LTD (Holcim) is a worldwide leading supplier of ment or sustainable use of natural resources are only a cement and aggregates as well as value-adding activi- few of the strategies being promoted. In spite of techno- ties such as ready-mix concrete and asphalt, including 2 General Principles for co-processing In order to ensure sustainably sound co-processing, we must understand and respect the following general principles: Co-processing respects the waste hierarchy: Y Co-processing does not hamper waste reduction efforts, and waste shall not be used in cement kilns if ecologically and economically better ways of recovery are available. Principle I Y Co-processing shall be regarded as an integrated part of modern waste management, as it provides an environmentally sound resource recovery option for the management of wastes. Y Co-processing is in line with relevant international environmental agreements, namely the Basel and Stockholm Conventions. Additional emissions and negative impacts on human health must be avoided: Y To prevent or keep to an absolute minimum the negative effects of Principle II pollution on the environment as well as risks to human health. Y On a statistical basis, emissions into the air shall not be higher than those from cement production with traditional fuel. The quality of the cement product remains unchanged: Y The product (clinker, cement, concrete) shall not be abused as a sink for heavy metals. Principle III Y The product should not have any negative impact on the environment as e.g. demonstrated with leaching tests. Y The quality of cement shall allow end-of-life recovery. Companies engaged in co-processing must be qualified: Y Have good environmental and safety compliance track records and to provide relevant information to the public and the appropriate authorities. Y Have in place personnel, processes, and systems demonstrating commitment to the protection of the environment, health, and safety. Principle IV Y Assure that all requirements comply with applicable laws, rules and regulations. Y Be capable of controlling inputs and process parameters required for the effective co-processing of waste materials. Y Ensure good relations with the public and other actors in local, national and international waste management schemes. Implementation of co-processing has to consider national circumstances: Y Country specific requirements and needs must be reflected in regulations and procedures. Y A stepwise implementation allows for the build-up of required capacity Principle V and the set-up of institutional arrangements. Y Introduction of co-processing goes along with other change processes in the waste management sector of a country. services. GTZ is an international cooperation enterprise This means AFR use should respect the waste hi- for sustainable development with worldwide operations. erarchy, be integrated into waste management pro- The objective of this joint initiative is to prepare interna- grams, support strategies for resource efficiency and tionally recognized Guidelines on "Co-processing of not hamper waste reduction efforts. Following certain Waste Materials in Cement Production" and its model basic rules assures that the use of AFR does not have application in selected countries. The Guidelines devel- negative impacts on cement kiln emissions. Co- oped by this cooperation include some basic rules and processing should not harm the quality of the cement principles that should be observed when co-processing produced. waste materials. 3 Summary Specific Principles for co-processing Furthermore the Guidelines include specific principles ture zone only, and avoiding materials that contain pol- and requirements for co-processing of waste in cement lutants which kilns cannot retain, such as mercury. kilns including the observation of and compliance with Emissions must be monitored, some only once a year all applicable laws and regulations, environmental as- and others continuously. Environmental impact assess- pects of cement production and AFR pre-processing, op- ments (EIA) should be done to confirm compliance with erational issues, occupational health and safety as well environmental standards; risk assessments can identify as communication and corporate social responsibility. any weaknesses in the system, and material flux and energy flow analyses help to optimize the use of re- sources. Principles related to legal aspects (Y See principles 1-3 on page 5) Principles related to operational issues Countries considering co-processing need appropriate (Y See principles 8-12 on page 6) legislative and regulatory frameworks. National laws Cement plant operators using AFR shall ensure their should define the basic principles under which co- traceability from reception up to final treatment. Trans- processing takes place and define the requirements port of wastes and AFR must comply with regulations. and standards for co-processing. Regulators and opera- Plants must have developed, implemented and com- tors should conduct baseline tests with conventional municated to employees adequate spill response and fuels and materials so they can compare AFR results to emergency plans. For start-up, shut-down and condi- these. Some wastes should never be co-processed; tions in between, strategies for dealing with AFR must these range from unsorted municipal garbage and cer- be documented and available to plant operators. Plants tain hospital wastes to explosives and radioactive need well-planned and functioning quality control sys- waste. Other wastes will need pre-processing before tems, as well as monitoring and auditing protocols. they can be used, and approaches to AFR use should take account of the need to effectively regulate and manage these pre-processing plants. Principles related to environmental aspects (Y See principles 4-7 on page 5) Following certain basic rules assures that the use of AFR does not change the emissions of a cement kiln stack. These include feeding alternative fuels into the most suitable zones of the kiln, feeding materials that contain a lot of volatile matter into the high tempera- 4 An appropriate legislative and regulatory framework shall be set up: Y Co-processing shall be integrated into the overall legislation concerning environmental protection and waste management before it can be accepted as a viable waste management alternative. Principle 1 Y Legally-binding regulations and standards are necessary to guarantee legal security and to assure a high level of environmental protection. Principles related to legal aspects Y Law enforcement is the key to successful AFR implementation and marketing. Baselines for traditional fuels and raw materials shall be defined: Y Control and monitor inputs, outputs, and emissions during the operation of the cement plant with virgin fuel and primary raw materials. Principle 2 Y Evaluate the given environmental situation prior to starting waste co-processing. Y Use this baseline data to define potential impacts of AFR on the environment based on standardized Environmental Impact Assessments (EIA). All relevant authorities should be involved during the permitting process: Y Build credibility with open, consistent, and continuous communications with the authorities. Y Consider and strive to apply Best Available Technology (BAT). Principle 3 Y The cement plant operator shall provide necessary information to enable authorities to evaluate the option of co-processing. Y Install community advisory panels early, including the authorities, to facilitate the exchange of information, opinion and know-how. Rules must be observed Y The use of AFR does not have a negative impact on the emissions from a cement kiln stack, if the following rules are observed: ­ all alternative fuels must be fed directly into the high-temperature zones of a kiln system (i.e. via main burner, mid kiln, transition chamber, secondary (riser duct) firing, precalciner firing) Principles related to environmental aspects Principle 4 ­ the same is true for alternative raw materials with elevated amounts of volatile matter (organics, sulfur) ­ the concentration of pollutants in alternative materials for which the cement process has insufficient retention capability (like Hg) shall be limited Y Cement production lines shall be equipped with a system capable of feeding operation filter dust directly to the cement mills. Emission monitoring is obligatory: Y Emissions must be monitored in order to demonstrate: Principle 5 ­ compliance with the national regulations and agreements ­ compliance with corporate rules ­ the reliability of the initial quality control of the process input materials. Pre-processing of waste is required for certain waste streams: Y For optimum operation, kilns require very uniform raw material and fuel flows Principle 6 in terms of quality and quantity. This can only be achieved for certain types of waste by pre-processing the waste. Environmental impact assessments (EIA) confirm compliance with environmental standards: Principle 7 Y Risk assessments are an efficient way to identify weaknesses in the system. Y Material flux and energy flow analyses help to optimize the use of resources. 5 Summary The sourcing of waste and AFR is essential: Y Traceability of waste helps to avoid undesired emissions, to minimize operational risks and to ensure final product quality. Y Traceability shall be ensured at the pre- or co-processing facility from reception up to final treatment. Principle 8 Y Business agreements with regular customers (waste producers, waste handling companies) shall include quality and delivery criteria to allow for a uniform waste stream. Y Waste categories unsuitable for co-processing should be refused. Y All candidate (new) wastes will be subject to a detailed source qualification test procedure prior to acceptance. Materials transport, handling, and storage must be monitored: Y General Guidelines for waste and AFR transportation must comply with regulatory requirements. Principles related to operational issues Y Instructions and adequate equipment for transport, handling, and storage of solid and liquid wastes and AFR are provided and maintained regularly. Principle 9 Y Conveying, dosing, and feeding systems are designed to minimize fugitive dust emissions, to prevent spills, and to avoid toxic or harmful vapors. Y Adequate spill response and emergency plans must be developed, implemented, and communicated to plant employees. Operational aspects must be considered: Y AFR will be fed to the kiln system only at appropriate introduction points determined by the characteristics of the AFR. Principle 10 Y The technical conditions of the plant that influence emissions, product quality, and capacity will be carefully controlled and monitored. Y For start-up, shut-down, or upset conditions of the kiln, the strategy dealing with the AFR feed has to be documented and must be accessible to operators. Quality control system is a must: Y Documented control plans for wastes and AFR must be developed and implemented at each pre-processing or co-processing site. Principle 11 Y Procedures, adequate equipment, and trained personnel for the control of wastes and AFR must be provided. Y Appropriate protocols in case of non-compliance with given specifications must be implemented and communicated to operators. Monitoring and auditing allow transparent tracing: Y Monitoring and auditing protocols for waste and AFR management in pre- and co-processing Principle 12 installations are developed and implemented. Y Instructions and adequate training of company staff in performing internal audits are provided. Principles related to occupational health and safety (Y See principles 13-17 on page 7) Risks can be minimized by properly locating plants in Management and employees must be trained in terms of environmental setting, proximity to populations handling and processing of AFR. Hazardous operations and settlements, and the impact of logistics and trans- training for new workers and subcontractors should be port. Cement and pre-processing plants will require good completed before starting with co-processing. Periodic infrastructure in terms of technical solutions for vapors, re-certification should be done for employees and sub- odors, dust, infiltration into ground or surface waters, and contractors. All visitors and third parties should receive fire protection. All aspects of using AFR must be well an induction training. Understanding risks and how to documented, as documentation and information are the mitigate them are keys to training. Training authorities basis for openness and transparency about health and is the basis for building credibility. safety measures, inside and outside the plant. 6 Site suitability avoids risks: Y Proper location (environmental, proximity to populations of concern, impact of logistics/transport); Principle 13 good infrastructure (technical solutions for vapors, odors, dust, infiltration into ground or surface waters fire protection etc.) and properly trained management and employees with regard to the Principles related to occupational health and safety handling and processing of AFR can all minimize risks. Safety and security: Principle 14 Y Each site must have a unit for safety and security. Y A risk manager is responsible for the arrangement and performance of the unit. Documentation and information is a must: Y Documentation and information are the basis for openness and Principle 15 transparency about health and safety measures. Y Information must be available for employees and authorities before starting any co-processing activity. Training should be provided at all levels: Y Management should be trained before starting with co-processing at a new facility or site. Field visits at already existing facilities are strongly recommended. Y Hazardous operations training for new workers and sub-contractors should be completed before Principle 16 starting with co-processing. Periodic re-certification should be done for employees and sub-contractors. Include induction training for all visitors and third parties. Y Understanding risks and how to mitigate them are key to training. Y Training and information of authorities is the basis for building credibility. Emergency and spill response plans: Principle 17 Y Good, regular emergency and spill response planning and emergency response simulations, including the neighboring industries and the authorities, contribute to the safe use of AFR. Openness and transparency: Y Provide all necessary information to allow stakeholders to understand the purpose of co-processing, Principle 18 the context, the function of parties involved and decision-making procedures . Principles related to communication Y Open discussions about good and bad experiences / practices are part of transparency. Credibility and consistency: and social responsibility Y Build credibility by being open, honest and consistent. Rhetoric must be matched with Principle 19 demonstrated facts and good performance. Gaps between what you say and what you currently do must be avoided. Cultivating a spirit of open dialogue, based on mutual respect and trust: Y Communication also means seeking feedback and dialog with stakeholders and integrating external Principle 20 views. Participants in stakeholder engagement activities must be able to express their views without fear of restriction or discipline. Cultural sensitivity: Principle 21 Y Take into account the different cultural environments in which we operate. Be target-oriented and truthful. Continuity: Principle 22 Y Start early; and once you start, never stop. Principles related to communication and social responsibility (Y See principles 18-22 above) Introducing AFR requires open communication with all sions about good and bad experiences are part of stakeholders. Provide all the information stakeholders transparency, leading to corrective actions. Be credible need to allow them to understand the purposes of co- and consistent, cultivating a spirit of open dialogue and processing, the context, the functions of parties in- respect for differing cultures. volved, and decision-making procedures. Open discus- 7 Summary Conclusion As populations increase in the developing world, so do The Guidelines have been prepared by experts waste management problems, and so does the need for from Holcim and GTZ. Support and advice was given by more cement and concrete for housing and the infra- a variety of external stakeholders from public and pri- structure of development. The properly managed use of vate sector as well as from the cement industry and wastes as fuels and raw materials in cement kilns can from organizations working in international develop- help manage wastes while contributing to the sustain- ment cooperation. The elaboration of the document able development of our world. was coordinated by the Institute for Ecopreneurship (IEC) of the University of Applied Sciences Northwest- These Guidelines on co-processing waste materi- ern Switzerland (FHNW). als in cement production are meant to gather the les- sons of the gained experience from industrialized countries and offer it particularly to developing coun- tries that need to improve approaches to waste man- agement. They encourage the private sector to develop techniques and know-how regarding co-processing GTZ and Holcim would like to express their sincere and engage the public sector to apply and maintain gratitude to all involved parties for their engagement environmental as well as occupational health and and comments. Our thanks also go to BMZ for financ- safety regulation standards. ing the public part of the project. For further information contact: www.coprocem.com Deutsche Gesellschaft für Technische Holcim Group Support Ltd Fachhochschule Zusammenarbeit GmbH (GTZ) B. Dubach, J-P. Degré Nordwestschweiz FHNW D. Ziegler, W. Schimpf Hagenholzstr. 85 D. Mutz P.O. Box 5180 8050 Zürich Gründenstrasse 40 65726 Eschborn Switzerland 4132 Muttenz Germany Tel. ++41 58 858 82 30 Switzerland Tel. ++49 6196 79 0 Fax ++41 58 858 82 34 Tel. ++41 61 467 42 42 Fax ++49 6196 79 11 15 environment@holcim.com Fax ++41 467 44 60 umwelt-infrastruktur@gtz.de www.holcim.com info@coprocem.com www.gtz.de www.fhnw.ch The public part is being financed by: Holcim Vietnam Waste Co-Processing ISO 9001 and ISO 14001 Certified Cement Kiln Co-processing Holcim Co processing in Asia Pacific Cement plant Kiln Waste Coprocssing Cement capacity Group (Asia Pacific): 32.4 million t; additionally with partners: 16.8 million t 2 Holcim Vietnam Co-Processing Holcim Co-processing in Europe Cement plant Kiln Waste Co-processing Cement capacity Group (Europe): 40.3 million t; additionally with partners: 11.9 million t 3 Holcim Vietnam Co-Processing Holcim Co-processing in North America Cement plant Kilns Using Waste Mat Cement capacity Group (North America): 21.3 million t 4 Holcim Vietnam Co-Processing Holcim Vietnam Holcim in Vietnam since 1996. Hon Chong Plant operating since 1998. Total Invested Capital: $445 million Total Employees: 1,000 5 Holcim Vietnam Co-Processing Holcim Vietnam operation overview CAMBODIA Phnom Penh CAT LAI CEMENT TERMINAL Ho Chi Minh city Vung Tau Vung Tau Grinding Station HON CHONG PLANT Rach Gia Can Tho XMAnGiang Bulk Cement 6 Holcim Vietnam Co-Processing Cement Kiln 7 Holcim Vietnam Co-Processing Waste transported to Hon Chong by Holcim's Cement ship 8 Holcim Vietnam Co-Processing Hon Chong Plant Purpose built hazardous liquids installation at Hon Chong Cement plant from where the liquids are pumped directly to the main burner. 9 Holcim Vietnam Co-Processing Hon Chong Plant Hon Chong plant is also equipped to prepare and treat solid wastes at specially designed waste treatment facility. 10 Holcim Vietnam Co-Processing Hon Chong Plant, Haz Waste Infrastructure Central control room at Hon Chong plant from where the entire plant operation is monitored and controlled using state of the art process control equipment and continuous emission monitoring equipment giving a real time analysis of stack gases. The burning zone of the kiln, into which the wastes are injected. 11 Holcim Vietnam Co-Processing Hon Chong Trial Burn Oct 03 In Oct 2003, Holcim Vietnam contracted with Bayer Cropscience Vietnam in a disposal of 40tons of pesticides at our Hon Chong Plant. Witnessed by representatives from Bayer Cropscience Vietnam, Vepa, Monre, Donre from: Kien Giang, HCMC, Dong Nai, Binh Duong, Vung Tau and also invited scientific experts. Independent testing agency from Australia, present to take samples and emission readings Results proved a DRE (Destruction and Removal Efficiency) of greater than 99.99998% with no influence on emissions and product quality 12 Holcim Vietnam Co-Processing Shipping Containers for Drums and Boxes of Haz Waste Waste drums or boxes are transferred directly to specially manufactured sealed shipment containers suitable for ship transport. Drums are placed directly inside the shipping boxes thereby providing a double protection. Even if there is any leakage from the drums or leakage into the boxes (eg rain water) it is contained by the box and treated when it arrives at the Hon Chong facility. 13 Holcim Vietnam Co-Processing Securing of the shipping Boxes Box securing arrangement certified by Llyods of London Marine classification society according to international marine transport specifications. 14 Holcim Vietnam Co-Processing Ships Transport onboard Holcim cement ships which travel back and forth to the plant on a continuous basis. 15 Holcim Vietnam Co-Processing 5. Holcim Cement Plant in Hon Chong Holcim is one of the world's leading suppliers of cement, aggregates, concrete and construction-related services and having its representative in more than 70 countries worldwide. The Hon Chong Cement Plant locates in the Western coastal area of Vietnam, in Binh An Ward, Kien Luong District, Kien Giang Province, which is 300 km far from HoChi Minh city to the West. The cement plant has applyed modern technology, equipped with product quality control facilities and latest technology for air quality control and monitoring. The typical limestone for the cement plant is quarried from three mountains named Cay Xoai, Bai Voi and Khoe La. The clay - another material for the cement plant, is taken from a deep clay mine in the plant. Limestone is extracted by drilling (using Atlas Copco drilling equipment) and blasting techniques. It is scoop up by shoveller and is then continuously transported to crusher by 40 ton- Caterpillar trucks. The capacity of the shoveller is 200 tons clay per hour. Other materials are shipped to the cement plant including 70,000 tons of laterite, 70,000 tons of gypsum and 150,000 tons of coal per year from Dong Nai, Thai Lan and Northern Vietnam, respectively. The coal is reduced in size (less than 120 mm) by mechanical crushers with Hazemag rotor, which has the capacity of 750 tons/day. The crushed limestone and clay are transported from the quarry to intermediate station and are analysed by the PGNA Gamametric equipment. Before mixing bed, main materials are stacked (2 x 31,000 tons) in a roofed area the high quality limestone is laid outdoors. The laterite storehouse with capacity of 10,000 tons is located near the stockpile before mixing bed. After mixing bed, the mixture of course materials, which is ready in chemical equilibrium, is milled and dried in a raw mill. The raw mill has the capacity of 350 tons/h with a 2000 kW- motor. The mixture is dried in raw miller by hot air from the kiln to get the moisture content of less than 1%. The dried mixture is carried by air trough to a blending silo ­ IBAU Hamburg with capacity of 8000 tons. The content of material mixture is precise by the homogenizing continuously in the blending silo. The clinker production is carried out in a dry cement kiln combined with a hanging preheater tower which has a precalciner. The rotating rate of the kiln is 3.5 cycles/minute. The diameter and the length of the kiln is 4.6 m and 72m, respectively. The 110 m- long preheater tower is constructed with 5 stages including 2 branches. The productivity of the kiln is about 4400 tons of clinker per day. The molten cement clinker is then cooled as rapidly as possible by a grate cooler which is 21 m x 4.2 m in side. Maximum productivity of clinker is 287 tons per hour and the content of free lime is in range of 1 to 1.5 %. The maximum loading capacity of materials from the top of the tower to the second stage is 305 tons per hour. The precalciner is about 29.1 m in length and 6.6 m in inside diameter . The kiln and the precalciner are heated by coal through two burners ­ the main burner and the precalciner burner. The main burner, labeled Pillard Rotaflam, has 3 channels and consumes 7 tons of coal per hours. The precalciner burner consumes 13 tons of coal per hours. The average calorie value of a common fuel such as antraxite is 29,792 Joule per kilogram. A stainless steel tank with volume of 16 m3 is built next to the preheater tower to store waste used for the burning test. The storage tank is connected to a light oil pump which can be automatically dose adjusted and switched on/off at the central control system. The 1 storage tank is equipped with a membrane pump in order to withdraw pesticides from barrels. The storage tank locates in the area surrounded by a concrete edge in order to recover the waste in case of spilling. The waste from storage tank is pumped through a stainless steel pipe combined with a meter to the main burner and it is introduced to the flame in the main burner together with coal. The storage tank and pumping system are designed with feeding capacity up to 3000 litters per hour for storage and pumping liquid hazardous waste. The ambient air used to cool the clinker is then fed into the main burner and the precalciner burner as combustion air - ensuring high utilization of the heat produced. The clinker production requires an oxidizing condition, i.e. the excess of oxygen. The normal content of oxygen at the entry of the kiln ranges from 2 to 5% and air flow exhausted from the stack is about 350,000 m3 per hour (no adjustment for moisture content and oxygen). During operation time, the gas from the kiln is utilized for drying the raw material and coal in the raw mills. A small part of the gas (8%) can be introduced into the bypass system to reduce chlorine and alkali accumulation. After drying, dust is removed from the gas stream by the high ­ efficiency Electro static precipitator (ESP) before coming to the main stack. When the mills run, the gas from the kiln passes through the raw mills and then flow to the ESP. It is called the "combination operation" emitting about 11 tons of dust per hour. In case of turn of the raw mills (no longer than 10% of time), the gas flow directly to the ESP without passing the mills. It is called the "direct operation" and the dust emitted in this case is about 16.8 tons per hour. All amount of emitted dust collected in the filter can be fed back to the process, either by introducing it to the blending silo in case of "combination operation" or by feeding to the kiln in case of "direct operation". The ABB Advant OCS ­ technology control system is used for monitoring and controlling the manufacture procedure. The content of oxygen (O2), carbon mono-oxide (CO) and nitrogen oxides (NOx) in the entry gas of the kiln and in the exit gas from the preheater tower are online monitored. The gas exhausted from the stack is collected to analyse content of O2, CO, CO2, NO2, SO2, HCl, NH3, HO and VOC. The exhaust gas is collected in the main stack which has the height of 122 m and the diameter of 4 m. Sampling point is setup at the top of the preheater tower with electric and water supply. Figure 4. Scheme of kiln, preheater tower, precalciner, raw mill, electro static precipitator and stack. 6. The trial burn program The main objective of this study is to develop the capacity of Vietnam itself in the field of hazardous waste management by implementation of hazardous waste co-processing in cement kiln, and to help Vietnam fulfill the Basel Convention and the Stockholm Convention. PCB-containing transformer oil is a hazardous waste stockpiled in Vietnam and need to be eliminated. PCBs are the most persistent organic pollutants. Since PCBs are such thermally stable compounds, the ability of a cement kiln to destroy these compounds indicates the overall ability to destroy organic constituents in hazardous wastes. The trail 2 burn program will be a scientific demonstration of the ability of Holcim cement kiln in Honchong to co-processing PCB -containing transformer oil (thermally stable compounds) in a thorough and environmentally safe manner. The results of this trail burn program, in which the fossil fuel is partly replcaced by hazardous wastes, will be compared with the emission in normal operation of the cement kiln using only fossil fuel. The results of this trail burn program and the observance of emission limit of Vietnam will be submitted to get a permission on hazardous waste co-processing following the strict regulation of EPA. According to this regulation, if the trial burn is successful, the company will get a permission on hazardous waste co-processing for all hazardous wastes which are classified at the lower level (i.e. less thermally stable) compared with PCBs in the burning ability scale. 6.1. Prerequisite conditions The trial burn program depends on the ensuring of following prerequisite conditions: 1) The feasibility for PCB/hazardous waste co-processing of the technical and chemical process is affirmed 2) The water and electric supply is stable and appropriate 3) The receiving, handling, storage and feeding of waste processes are stable, safe and clear. 4) All people directly related to the trial burn program receive appropriate information and are well educated. The project objectives are informed to all partners. 5) The action plan for urgent cases is implemented and obeyed, for examples: using permanent safety working facilities, the firefighting equipment and cleaning equipment/material in case of spilling are available. 6) The procedure to stop feeding waste when the system is not in good working conditions or in urgent cases. The values of operation parameters, which could cause stop feeding waste, need to be defined and consented. The legal issues related to PCB handling, transportation, sending back the empty barrels... have to be specified within partners before conducting trail burn. 6.2. Preparation of feeding mixture The trial burn is performed in order to prove that the system Destruction Dfficiency (DE) and the Destruction and Removal Efficiency (DRE) is higher than 99.9999%. The constitution of final feeding mixture is very important. Both DE and DRE are the functions of initial PCB content in feeding mixture and it does not include the POP formed unintentionally in the complete destroy or removal. If the content is too low, the required value of DE and DRE can not be achieved.. The oil containing PCB for the trial burn was received from the Thu Duc Water plant in Thu Duc district belonging to the Water Supply Company of Hochiminh city. The plant has a storehouse keeping: 162 barrels of transformer oil containing PCB, which are taken from 06 Westinghouse transformer equipments, 29 barrels of diesel oil used for transformer cleaning, some rust empty barrels and some barrels with a little oil containing PCB inside. Although the way lead to the storehouse are covered by rank plants, the storage are kept in good conditions. The storehouse is locked and sealed. No signs of leaking from the roof and occurrence of water on the floor were found. All barrels are in good condition and are put in pallets. However the barrels are not labeled so it is impossible to distinguish between diesel oil barrels and transformer oil barrels. 3 Recently, oil from 4 barrels has been analysed for PCB. The results are shown in table 1. Table 1. Content of PCB in original oil (examples) Barrel No. PCB (ppm) Chlorobenzene (%) No. LT 069 5.73 No. LT 118 5.549 1.7 No. LT 124 3.051 No. LT 129 2.940 The low content of PCB in the barrel No.069 reveals that it contained cleaning oil. The oil in other barrels was not confirmed as the original PCB containing transformer oil due to the low value of PCB content. As usual this value is up to 60% (i.e. 600,000 ppm) PCB note for original PCB containing transformer oil. Therefore additional analysis and also calorimetric measurement need to be carried out for such oil. The calorie of fine coal is 30 mega joules per kilogram. The PCB containing transformer oil will be diluted by diesel oil and fuel to form the feeding mixture appropriate to the requirements of the trial burn and compatible with: 1. The required temperature at the kiln inlet 2. The required values of DRE/DE (A minimum amount of mixture need to be fed to obtain the efficient DRE/DE) 3. The variation of chlorine during the burn The PCB/diesel mixture will be fed to the main burner through a individual channel to ensure that they are well dispersed and homogenized. The precalciner consumes about 13 tons of coal per hour. Coal added to the main burner is adjusted to the level of 7 tons per hour as the supplement of heat provided by the PCB/diesel mixture. According to the plan, 02 tons of PCB/diesel mixture will be introduced to the main burner and exhaust gas will be collected during 8 hours. The mixture feeding need to be implemented in 2 ­ 4 hours before sampling to gain the stable working conditions of the kiln. The flow rate of gas exhausted from main stack is about 450,000 Nm3 per hour (drying with 10% O2). PCB in exhaust gas could be detected in range of 0.1 ng per m3 (maximum level) to 0.1 pg per m3. In accordance with safety factor in the following table, the DRE can achieve the value of 99.9999% or higher if the content of PCB in feeding mixture is 5000 ppm. However, the final calculation will be defined when information of barrels and content of chlorobenzene are fulfilled. Table 2. mg PCB fed mg/m3 in mg/m3 in Minimum into kiln/hour exhaust gas exhaust gas detection limit (5000 mg/l & from stack (if from stack (if for analysis of 2000 l/h) PCB was not 99.999% PCB PCB in exhaust destroyed) was destroyed) gas from stack (ng/m3) PCBs 10,000,000 mg 22 0.000022 22 or 10 kg/h 4 6.3. Trial burn program The trial program is planned to be carried out within 2 days, in April 2007, depending on the approval. In the first day, the base-line study will be conducted without PCB feeding. In the second day, during the trail burn, one ton of oil mixture will be introduced through the main burner in each hour. In both days the process will run in "combination operation" mode, i.e. the operational conditions are consistent. Before running program, the feeding have to calibrate and the technology control system must be checked. The company responsible for sampling and validation will come to the plant one day before trail starting in order to prepare and check sampling and monitoring equipments. Frame 1 Program for the testing incineration April 1, 2007 April 2, 2007 Basic study Testing incineration Operation at the combining state and normal Operation at the combining state, loading of material loading mixture of PCBs/diesel (1 ton/hr) The polluted oil contained truck should arrive to the plant before the testing incineration is implemented. At the plant, the polluted oil is transferred to the storage and material-loading system, and then they are efficiently mixed and homogenized. Those steps will be done by the staff that are equipped with the specified safety working materials and be followed by the responsible emergency staff. The responsible staff will practice the procedures for the precautionary and overflow preventative measures, and standby measure in the case of emergency before the testing incineration is implemented. The schedule for the company to collect/analyze samples is provided as follows. The schedule is corrected in order to include the field visiting date when testing date is specified. 1st Date Visit the plant/ short introduction/ equipment setting up; 2nd Date Basic study/correlate measurement 3rd Date Testing incineration using PCB/diesel mixture 3rd & 4th Date Sending of samples for analysis/interview/equipment packing up and movement 10th Date Samples arrive to laboratory and sample registration 20-40th Date Sample analysis watching at the laboratory 60th Date Sample analysis complement/primarily evaluation of analytical results 80th Date Submission of final report to the authorized office 5 100th Date Seminar Important items need to be taken into account along the testing incineration program Loading basin o Thoroughly rinsing and preparation of loading basin o Checking for the leak (loading basin, pump and tube) o Identification of the loading level (use of diesel) o Pouring out of the PCBs from the oil drum and mix with diesel o Safety and accurate loading of the PCBs/diesel mixture o Operation control Sampling equipment setting up o Setting up the sampling sequence o Sampling of the loading mixture o Preparation for technical sampling Preliminary checking o Velocity o Vortex checking o Humidity measurement Definite test o Collecting of the loaded mixture o Technical and loading rate checking o Collecting of samples from the stack o Samples gathering o Samples labeling, parking/storage Equipment disassemble and packing up Those important items are extremely needed to be taken into account along the preparation testing steps. 6.4 Destroy efficiency (DE), destroy and reject efficiency (DRE) DE is an important factor that is used to evaluate the complete of the destroy and treatment technology; however, it is difficult to comparatively measure. The DE is measured based on the difference of the amount of loaded PCBs and the amount of PCBs in exhaust gas, liquid and solid waste divided by the amount of PCBs in the loaded material. DRE is measured based on the difference of the amount of loaded PCBs and the amount of PCBs in the waste matters in exhaust gas divided by the amount of PCBs in the loaded material. DRE is only related to the exhaust gas and calculated as follows: DRE = [(Win ­ Oout)/ Win] x 100 Necessary information for the calculation of DRE is shown in Table 3. 6 Table 3. Necessary information for the calculation of DRE Measured parameters Unit Method of measurement Loading rate/loading amount l/kg/h Measurement along the testing program Amount of PCBs in the loading mg/kg Analysis of loading material material Amount of PCBs in the exhaust gas mg/Nm3 Sampling and analysis of exhaust gas from the stack from the stack Total amount of PCBs in the blank mg Analysis of blank sample sample Exhaust gas rate Nm3/h Reported as a pitot traverse value The homogeneity and accurate amount of PCBs are needed to be measured before implementing the testing incineration. The following steps on the identification and quantification are required: o Identification and quantification of classes of PCBs, tri-chloro-benzene and tetrachloro- benzene; o Concentration of chlorine; o Heating energy 6.5 Monitoring and technical operation The technical staff will be trained focusing on the operation with the hazard waste, including health, safety and environment factors. All of the related technical parameters such as temperature, coal and electrical utilities, and raw material loading, etc. will be specified, recorded and continuously evaluated. The technology will be continuously measured for following parameters: o Gas to the furnace: O2 and CO; o Gas from the preliminary burning tower: O2 and CO; o Exhaust gas: O2, CO2, NO, NO2, SO2, HCl, NH3, H2O and VOC. The following measures for the control and technical safety are designed in order to ensure hazard wastes are efficiently destroyed in the cement furnace. o Effect of the PCBs mixture on the total input of the volatile elements such as chlorine, sulphur, alkali will be evaluated before the testing incineration because they could result to the problems on the operation. o Technical instruction on the turn on, turn off, or change of working parameters of the furnace as well as steps for the stop of PCBs loading are needed to be documented and equipped with the furnace operators. o It is requirement that the furnace is operated under the oxidized condition in order to ensure that oxygen level in the exhaust gas is always remained not lower than 5%. o PCBs are not allowed to be loaded into the furnace unless the furnace is operating at the normal input temperature of > 900 oC. o PCBs are loaded (and monitored) directly into the main burning room of the furnace in order to ensure that the temperature is high enough for the safety incineration. PCBs are not allowed to be loaded during start and stop time of the furnace or during considerable changes are occurred. The material loading step will be monitored and controlled. 7 o By conducting a system controlling manner, the loading of PCBs will be automatically stopped when one of the following errors is met: burning gas is interrupted; furnace temperature decreases to lower than 1.300 oC; the loading of PCBs or fuel is interrupted; positive pressure in the burning area; furnace rate is lower than 60 round/hr; released oxygen amount is lower than 0.5%;circle creation or spiral block in the furnace; damage of fire-resistant bricks. 6.6 Tentative program for sampling and monitoring Two (2) air samples will be collected from the stack, and the sample collection must obey one of three methods described in the EN 1948 or US 23 method. The analysis of PCDD/F in the air particles and gas from the stack will be done following the EN 1948. The US 23 (A), or 1613 method is followed for the analysis of PCB, hexachlorobenzene, tri- chlorobenzene, tetra-chlorobenzene, benzene, HCl, paricles, CO, CO2, O2, H2O, SO2, NOx, HN3, VOC, and heavy metals. Solid samples will be collected in two-hour intervals by a staff that is trained by Holcim. The samples are packed and stored for at least three months. Samples are separated and relative part of samples will be thoroughly mixed then sent for analysis. The PCBs are identified and quantified in the following solid samples: 2 mixed PCBs/diesel samples 2 raw material samples 2 coal samples 2 clinke samples 2 air particle samples from the electrostatic filters Table 4. Analytical parameters for different samples Exhaust gas PCBs PCDD/Fs HCB Benzene, tri-chlorobenzene, tetra-chlorobenzene VOC Temperature Volume and humidity CO, O2, CO2 HCl Particles Heavy metals PCBs/diesel mixture PCBs, tri-chlorobenzene, and tetra-chlorobenzene Heating energy (kcal/kg) Chlorine Raw material PCBs Chlorine Alkali, sulphur, phosphorous Heavy metals Coal PCBs Heating energy Chlorine Ash level 8 Particles from electrostatic PCbs and chlorine filters Clinke PCBs and chlorine Alkali, sulphur, phosphorous Heavy metals Table 5. Technical requirements Temperature (furnace input, Clinke cooling unit, (xilo), ESP, and stack) Fuel loading rate Raw material loading rate/clinke-production rate PCBs loading rate Burning gas rate (air volume) All of the online screens for gas measurement Loading rate of cooling water RPM furnace 6.7 Heating resistance of PCBs In general, the compounds present at the highest concentrations and are in the highest rank of the categories of the burnable compounds of US EPA are selected for the testing incineration. The PCBs compounds are in the higher rank of these categories, meaning they are heating resistance and are difficult to be destroyed. An additional reason for the selection of the heating resistant compounds for the testing incineration is the furnaces will be certified for simultaneous treatment of lower heating resistant compounds in those categories when they could successfully destroy higher heating resistant compounds. Heating energy parameter is the most normal chemical and physical characters in order to evaluate the heating resistance of a compound; if the heating energy is high, the compound is chemical and physical resistance. PCBs are aromatic compounds, which are formed by the replacement of the hydrogen elements by the chlorine elements in the biphenyl molecule (two benzene rings conected together by a carbon-carbon bond). Theoretically, the PCBs comprise 209 congeners of which those heating energies are different. In general, higher chlorinated compounds are more resistant. The heating energies of mono-chloro-PCB and deca-chloro-PCB are 7.75 kcal/gram and 2.31 kcal/gram, respectively. 6.8 Chlorine resistance of the technology PCBs, tri- and tetra-chlorobenzene contain 65% chlorine, which is needed to be taken into account for designing of the chlorine resistance in the technology. Beside, the chlorine levels in raw material and coal is not ignorable. Table 6. Chlorine levels in the loading mixture PCB Chlorobenzenes % Around 0.5 Around 1.7 6.9 Operation and stabilization of furnace 9 The furnace should be in stabilization in 24 hrs before the testing incineration in the basic conditions is implemented. The PCBs/diesel mixture should be loaded into the furnace in 4- 8 hrs before the sample collection is conducted. The technology has to be operated with the by-pass tube and in two days, meaning in the normal conditions when the raw material grinder is operated. Silo raw material will also need to be prepared for two days operating. 6.10 Quality assurance and quality control The quality assurance and quality control (QA/QC) will be an integral part of the testing incineration program, from the beginning to the end. 6.11 Reporting of the testing incineration The final report comprises documents, which demonstrate the results of the testing incineration and the operation of the furnace as well as provide valuable scientific information on the suitability of the cement furnace for the safe, environmental and sustainable treatment of PCBs. 7. Organization of the testing incineration The Holcim Vietnam manages the testing incineration project and Mr. Paul Hayes is the project director. Mr. Aidan Lynam is leader of project from the Holcim side. Mr. Ian M Campbell is in charged of the plant and the operation of the furnace along the testing incineration, and responded for the stop of the loading in the case of errors or parameters are out of allowable values. The Ministry of Environment and Resources, Department of Environment and Resources of Kien Giang Province and Department of Environment and Resources of Ho Chi Minh city will be the authorized representative organization in this testing incineration. Mr. kre Helge Karstensen, independent expert of SINTEF Norway is in charged of investigation and testing incineration result reporting. 10 ANNEX 2. Handling, collection, packaging, labeling, transport and storage of Persistent Organic Pollutants (POPs) and POPs wastes Extracted from the technical guidelines on the handling, collection, packaging, labelling, transport and storage of POPs and POPs wastes, in accordance with the provisions of the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and Their Disposal and the Stockholm Convention on Persistent Organic Pollutants Handling, collection, packaging, labeling, transport and storage are very important steps as risks of leakages and spills are equal or higher than those of operating conventional equipment. For the technical guidelines of transboudary movement of hazardous wastes, the readers should consult reference materials published by Basel Convention: Guidance of Implementation (UNEP 1995), the International Maritime Dangerous Goods Code (IMO, 2002), the International Air Transport Association (IATA) Dangerous Good Regulations and the United Nation Recommendations on Transport of Dangerous Goods (UN Orange Book). Wastes consisting of, containing or contaminated with POPs must be handled as dangerous substances to prevent spills and leaks leading to worker exposure, releases to the environment and exposure to the community. Handling The main concerns when handling wastes consisting of, containing or contaminated with POPs are human exposure and accidental release to the environment. POPs wastes must be handled separately from other kinds of wastes to avoid POPs contamination to these wastes. A set of procedures should be prepared by each organization that handles POPs wastes and workers should be trained in the procedures. Collection Care must be taken in establishing and operating waste collection programs, depots and transfer stations in order to: a. advertise the program, depot locations and collection time periods to all potential holders of POPs wastes; b. ensure enough time of operation of collection program for the complete collection of all potential POPs wastes. c. include all possible POPs wastes in the program d. provide acceptable containers and safe-transport materials available to waste owners for those waste materials that may need to be re-packed or made safe for transport; e. establish simple, low-cost mechanisms for collection; f. ensure the safety of both those delivering waste to depots and workers at the depots; g. ensure that the operators of depots use an accepted method of disposal; h. ensure that the program and facilities meet all the relevant legislative requirements. i. ensure that all kinds of POPs wastes are separated from other waste streams. Packaging All wastes should be properly packaged for ease of transport and as a safety measure to reduce the risk of leaks and spills. Packaging of hazardous wastes falls into two categories: packaging for storage, and packaging for transport. Packaging for transport is often controlled by national transportation of dangerous goods legislation. For packaging specifications for transport, the reader should consult reference materials published by International Air Transport Association (IATA), 11 International Maritime Organization (IMO), the United Nations Economic and Social Council (UNESC) and publications from national governments. Some general principals for POPs waste packaging for storage are as follow: a. Packaging that is acceptable for transport is, in most cases, suitable for storage. b. POPs wastes in their original product containers are generally safe for storage if the packaging is in good conditions. c. POPs wastes should never be stored in product containers that were not intended to contain POPs wastes or have labels incorrectly identify the contents. d. Containers that are deteriorating or are deemed to be unsafe should be emptied or placed inside a sound outer package (over pack). When unsafe containers are emptied, the contents should be placed in appropriate new or refurbished containers that are clearly labeled as to the contents. e. Smaller containers can be packed together by placing them in appropriate or approved larger containers containing absorbent material. f. Out-of-service equipment containing POPs may or may not constitute suitable packaging for storage. The determination of safety must be made on a case-by-case basis. Labeling Labeling of POPs wastes is critical for the success of inventories and is a basic safety feature of any waste management system. Each waste container must be labeled to identify the container (e.g, ID number) and the presence of POPs, and to indicate the hazard level. Transport Wastes consisting of, containing or contaminated with POPs must be transported in an environmentally sound manner to avoid accidental spills and leaks and to appropriately track their movement and ultimate destination. Proper planning is necessary prior to transport in urgent situations to reduce impacts of spills, fire and other emergency circumstances during transportation. POPs wastes should be handled, packed and transported following technical guidelines of the United Nation Recommendations on the Transport of Dangerous Goods (i.e. UN Orange Book). All persons transporting wastes within their own country should be qualified and/or certified as a shipper of hazardous materials and wastes. Guidance on the safe transport of hazardous materials can be obtained from the IATA, IMO, UNESC and the International Civil Aviation Organization (ICAO). Storage Wastes consisting of, containing or contaminated with POPs must be safely stored safely and preferably in dedicated areas away from other materials and wastes. Storage areas must be designed to prevent the release of POPs to the environment by all routes. Storage rooms, areas or buildings should be designed by professionals with expertise in the fields of waste management and occupational health and safety or should be purchased in pre-fabricated form from reputable suppliers. Some basic principles of safe storage of POPs wastes are as follows: a. Storage sites inside multi-purpose buildings should be in a locked dedicated room or partition that is not in an area of extensive use. b. Outdoor dedicated storage buildings or containers (often shipping containers are used) should be stored inside a lockable fenced enclosure. c. Separate storage areas, rooms or buildings should be used for each type of POPs waste, unless specific approval is given for joint storage. 12 d. Wastes should not be stored at the delicate areas such as hospitals and other medical units, schools, houses, food processing units, areas for processing and storage of the cattle-feeds, agriculture sectors and sites that are located in or near the environmentally delicate areas. e. Storage rooms, buildings and containers for waste storage should be kept in the conditions to minimize evaporation such as cool temperature, reflection roof and wall, etc and these conditions should be maintained. Rooms and buildings should be conditioned with the minus pressure and waste gases should be ventilated through activated carbon; and the followings conditions should be considered: (i) Ventilating a site to the outside air is considered when exposure to vapors for those who work in the site and live in the surrounding areas is a concern. (ii) Completely sealing a site so that no vapors can escape to outside air is considered when environmental concerns are paramount, and there is minimal entry into the site by humans. f. Dedicated buildings or containers should be in good condition and made of hard plastic or metal, not wood, fiberboard, drywall, plaster or insulation. g. The roof of dedicated buildings or containers and surrounding land should be sloped so as to provide drainage away from the site. h. Dedicated buildings or containers should be set on asphalt, concrete or durable plastic sheets (i.e. 6 mm depth). i. The floors of storage sites inside buildings should be concrete or durable plastic sheeting (i. e. 6 mm depth). Concrete should be coated with a durable epoxy. j. Storage sites should have a fire alarm system. k. Storage sites inside buildings should have a fire suppression system; preferably a non- water system. If the fire suppressant is water, then the floor of the storage room should be curbed and the floor drainage system should not lead to the sewer or storm- sewer or directly to surface water but should have its own collection system, such as a pump. l. Liquid wastes should be placed in containment trays or a curbed, leak-proof area. The liquid containment volume should be at least 125% of the liquid waste volume, taking into account the space taken up by stored items in the containment area. m. Contaminated solids should be stored in containers such as barrels or pails, steel waste containers or in specifically constructed trays or containers. Large volumes of soil or other contaminated materials may be stored in bulk in dedicated shipping containers, buildings or vaults, so long as they meet the safety and security requirements as described herein. n. A complete inventory of the POPs wastes in the storage site should be created and updated when the wastes are added or disposed. o. The outside of the storage site should be labeled as a POPs waste storage site. p. The site should be subjected to routine inspection for leaks, degradation of container materials, vandalism, integrity of fire alarms and fire suppression systems and general status of the site. 13 ANNEX 3. Personal protection, health and safety Personal Protection Equipment (PPE) The PPE listed below should be used for handling PCB contaminated material (to be done before removing damaged or leaking components) The minimum safety requirements are: · Tyvek or similarly chemically impervious disposable · Gloves ­ Splash proof - Mid arm (with gauntlets if required). Suitable material for gloves includes Viton, polyethylene, polyvinyl alcohol (PVA), polytetrafluoroethlyene (PTFE), butyl rubber, nitrite rubber or neoprene disposable gloves [NOTE do not use PVC or latex gloves] · Full face shield and hair protection if working overhead (e.g. light fixtures). If not working overhead safety glasses should be used as a minimum; · If vapors are suspected, twin type A cartridge type respirator suitable for chlorinated vapors should be used. A quantity of an absorbent material should be accessible nearby for use if a spill occurs. Personal hygiene is very important after handling PCBs, even if gloves are worn, wash hands well before eating, drinking, smoking or using the toilet Spill Response If a spill occurs, every effort should be made to prevent the spill from spreading. If a minor spill occurs: · Use absorbent materials to cover the spill if possible. Otherwise form a bund wall at the downstream of the spill. Suitable absorbent material includes commercial absorbents, kitty litter or a diatomaceous earth. · Non - porous surfaces should be cleaned with an organic solvent and the solvent collected and disposed of as PCB containing liquid. Kerosene is suggested as the organic solvent by ANZECC but care should be taken during usage and storage as it has a low flash point and thus will readily ignite if sources of heat or ignition are present. · Use protective equipment as listed above, place absorbent in a strong sealed polythene bag, which is then placed in a sound sealable metal drum and labeled as follows: If a major spill occurs: · Remove peoples from the area likely to come into contact with the spill. · If there is no risk of contact with the waste materials, use any available absorbent to prevent (as much as possible) PCB materials from entering stormwater drains, gullies, etc until security arrives. · Follow the directions of security once they arrive. · If a large scale spill happens, there may be an inhalation risk and in such cases, local exhaust ventilation may be needed. 14 D-5 URENCO SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 App D-5 URENCO Photograph 1 : Special waste treatment and storage buildings (background) and expansion under construction (foreground). Photograph 2 : Looking toward incinerator building. Empty drum storage in the foreground. SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 App D-6 URENCO (cont'd) Photograph 3 : Drums of waste material stored prior to processing. Photograph 4 : Solidified sludge being dried prior to landfilling. SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 App D-7 URENCO (cont'd) Photograph 5 : Incinerator. Photograph 6 : Incinerator stack. SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 App D-8 URENCO (cont'd) Photograph 7 : Off-gas treatment system. Photograph 8 : Scrubber effluent treatment. SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 App D-9 URENCO (cont'd) Photograph 9 : Effluent lagoon. Photograph 10 : Covered solid waste disposal landfill. Type of incinerator: industrial incinerator Dear Ed Wards! This is information on incinerator designed by our Center - Centre for environmental Engineering of Towns and Industrial Areas (CEETIA) This is a demonstration project funded by MONRE and done by CEETIA Type of incinerator: Industrial Incinerator multi-zones with gas cleaning system Brand name: CEETIA-CN150 Started operating: 2003 Technical Specification: - Capacity : 125-150 kg/h; - Temp. in Primary chamber: 800-8500C; - Temp in secondary chamber: 1000-11000C; - Fuel comsumption: 50-70 kg/h (tuú lo¹i chÊt th¶i); - Air retention time 1,5 sec; - Max. air flow rate:: 2000m3/h; Size: 9000 x x 2200 x 3900 mm; Weight: 12 tones Diameter of stack : 600 mm Height of stack: 17 m Heat value: 2000 - 3500 kcal/kg; Gas cleaning system made from stainless steel. Waste accepted for incinerator: Used oil, chemicals Waste from paints, glues, resins etc. Solvent waste not suitable for recovery NhiÖt Test results from emmision gases Dust mg/m3 66 SO2, mg/m3 1,0 HCl, mg/m3 43 HF, mg/m3 0,1 CO, mg/m3 0,8 NOx, mg/m3 80 Cd, mg/m3 0.04 Hg, mg/m3 0.01 Temperature at the out let of staks, 0C 120 - 140 ; waste disposal complex in namson, hanoi Geographic location: - In Nam Son commune, Soc Son, Hanoi. - 53 km away from Hanoi. - Borders Vinh Phuc, Thai Nguyen, Bac Ninh. Area: - Total: 130ha - 1st phase: 83ha - 2nd phase: 47ha Planning in 1st phase: - 09 dumping cells for domestic waste: 45ha - Domestic waste incineration are: 06ha - Composting area: 10ha - Industrial waste treatment area: 05ha - Waste water treatment area: 03ha - Administration area: 04ha treatment of industrial waste by incineration method Industrial waste (IW) oil, grease B-íc 1, 2,3 loading KiÓm tra, thu gom, vËn chuyÓn Check, collect, transport Separation and pack in drums Transportation Closed specialised vehicles Transportation by specialised vehicles to ensure storage environmental safety. In IW storage In Nam Son IW Treatment Facility B-íc 4, 5 Storage, neutral treatment additives mixture Apply additives: muds, clouts, etc B-íc 6 Incineration method incineration) Capacity: 5tons/day - Burning temperature: 800 B-íc 7 Xö lý cuèi cïng 1,2000C Final treatment ashes discharged gases Make concrete to meet standard TCVN 6560:1999 recycle treatment of industrial waste by physical-chemical method n- í c t h¶i axit M¸ y nÐn khÝ B¬m n- í c th¶i B¬m ®Þnh l- î ng Pol yme H2SO4 Ca(OH)2 NaClO FeSO4 chÊt t h¶i l áng Tõ kho chøa n- í c t h¶i kiÒm BÓ g¹ n BÓ ph¶n øng BÓ l ä c t han ho¹ t t Ýnh n- í c t h¶i cr om BÓ l ä c c¸ t BÓ chøa BÓ chøa sa u xö l ý 1 sa u xö l ý2 N- í c t h ¶ i n- í c t h¶i Cyanua Bï n Ho ¸ c h Êt BÓ chøa bï n B¬m bÓ chøa sau xö lý1, 2 ®- ê n g k h Ý X ¶ c Æn b å n h ã a c h Ê t B¬m n- í c th¶i BÓ ph¶n øng n- í c t h¶i chÊt t h¶i kh¸ c B¬m bï n ®Æc M¸ y nÐn khÝ Treatment of 12 kinds of liquid waste: - Liquid waste containing alkali - Liquid waste containing acid - Liquid waste containing crom - Liquid waste containing cyanua - Other kinds of liquid waste Treatment of industrial waste by solidification & recycling methods Industrial waste (Sludge) Adjust hydrated volume - Produce blocks from industrial waste - Forceproof intensity: #75, #100, #150 Immediate treatment - Use in production area by chemical method (add additives) Maintenance Low uqality construction materials and/or dumping treatment of industrial solutions containing metal Recover metal, reuse as production materials (3R) Post-treatment water reach TCVN: 6984-2001 Post-treatment sludge is solidified to make blocks and reused and/or dumped treatment of special industrial waste n Qu i t r × h x ö l ý ®Ì n n eo n Re c y c l i n g f l o w o f w a s t e f l u o r e s c e n t t u b es C¾ t khÝhydro t iÖ C¾ hai ® n cùc KhÝnÐn Thu håi thuû tinh Thu bét Fluorescent (chøa Hg) M¸ y nghiÒn Thuû tinh ®· nghiÒn Ng- ng n Lß ch© kh«ng Röa n § iÖ cùc Thuû tinh vôn Kim lo¹ i Hg Bét kh«ng cã Hg N h « m , s ¾t , nhù a Th u û t i n h Hg Ch « n l Ê p n Qu i t r × h x ö l ý n Ti v i & m µ n h × h m ¸ y n v i t Ý h Re c y c l i n g f l o w o f w a s t e TV s e t a n d PC M o n i t o r TV nh Vi tÝ p Ð thuû lùc C¾ t khÝhydro Vá B¶ng m¹ ch nh Bãng h× M¸ y nghiÒn T¸ ch kim lo¹ i nh Thuû tinh ho¹ t tÝ · ® nghiÒ n T¸ ch kim lo¹ i ? ? Þ ¤ n ® nh nh Thuû tinh ho¹ t tÝ Nhùa t, S¾ § ång, Nh«m ® ãng r¾n Nhùa y ång D© ® Nh ù a S¾t , ® « n g , n h « m § å n g Ch « n l Ê p Nhùa T¸ i c h Õ t ¸ i c hÕ T¸ i c h Õ treatment industrial waste by special dumping controled method Dumping tank is totally built by concrete, anti-leakage Solid waste is dumped in separated areas based on waste components - 1st phase: 08 dumping tanks - Capacity: 15,000 m3/tank SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 Appendix Appendix E Task 3 Forms and Supporting Information I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 Appendix Appendix F Task 4 Forms and Supporting Information I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 Appendix Appendix G PCB Destruction Technologies in Vietnam Oil and Equipment Directions for Use I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc 1 Directions for Use PCB Destruction Technologies in Vietnam: Oil and Equipment Directions for Use This is a working cost estimate spreasheet. Only the summaries (work sheet nos. 2 & 3) are meant for use as hard copies. The remaining spreadsheets are used in the calculation of the cost estimates and show how these figures were developed. Applicable assumptions are also shown on the various work sheets. This spreadsheet comprises 12 worksheets, all linked. They are as follows: No. Name Description The intent of this spreadsheet is to describe how to use the 1 Directions for Use information provided most effectively. This provides the best price for each scenario and leads to a 2 Best simplified comparison. It has been formatted for print-out. This worksheet summarizes the costs of all disposal vendors 3 Summary organized by scenario. It has been formatted for print-out. This is the working spreadsheet for calculating the costs for 4 Full Overseas Treat disposal at overseas fixed facilities. It is not formatted for print-out. This is the working spreadsheet for calculating the costs for 5 Overseas Oil Treat disposal of only the PCB-contaminated oil at overseas fixed facilities. It is not formatted for print-out. This is the working spreadsheet for calculating the costs for Salt Mine Carcas disposal of drained transformer hulks in a commercial disposal 6 Disposal faclity in Germany (salt mine long term storage). It is not formatted for print-out. This is the working spreadsheet for calculating the costs for Local Treatment- 7 disposal of oil and celluloic materails at the Holcim cement kiln in Holcim Vietnam. It is not formatted for print-out. This is the working spreadsheet for calculating the costs for Relocatable Local 8 relocating mobile facilities to Vietnam for treatment of waste at a Treat-all number of centralized areas. It is not formatted for print-out. This is the working spreadsheet for calculating the costs for Relocatable Local relocating mobile facilities to Vietnam for treatment of only the 9 Treat-Carc transfomer carcasses at a number of centralized areas. It is not formatted for print-out. Cost recovery table for scrap metal. It is not formatted for print-out. 10 Scrap Metal Pricing Calculation sheet for quantity estimates of waste components. It is 11 Backup not formatted for print-out. Background calculations for the shipping cost estimate. It is not 12 Shipping formatted for print-out. 2 Best Comparison of the Optimal Vendors against Different Project Strategies Vietnam PCB Technlolgy Review Project Lowest Viable Price Vendor Offering Scenario No. Description (Total Cost rounded to Methods of Disposal Best Alternative 100 thousands of USD) 1 All waste shipped to an overseas facility for disposal $96,700,000 SAVA (Germany) Incineration All oil shipped to an overseas facility for disposal, all ESI Group 2 drained transformer and capacitor hulks disposed of in $52,866,343 Sodium dechlorination (Australia) a salt mine in Germany. All oil and cellulosic material destroyed at Holcim in Cement kiln co- Holcim (Vietnam) 3 Vietnam, all drained transformer and capacitor hulks $60,518,666 processing and salt mine K + S (Germany) disposed of in a salt mine in Germany. storage All waste materials treated in Vietnam, by relocatable ESI Group 4 treatment systems provided and operated by overseas $42,330,119 Sodium dechlorination (Australia) vendors. Oils and cellulosic material trated by Holcim Vietnam, Holcim (Vietnam) Cement kiln co- 5 carcasses cleaned using relocatable treatment system $48,303,325 ESI Group processing and sodium operated by overseas vendors but located in Vietnam. (Australia) dechlorination 3 Summary Page 1 of 4 Scenario 1 Assumptions: All waste shipped to overseas facilities. 50% of total weight is less than 500 ppm and 50% of total weight is greater than 500 ppm Total Cost of Total Cost of Total Waste Total Shipping Total Shipping Total Facility/Waste Disposal (USD) Disposal (USD) Quantity Costs (USD)/20 Costs (USD)/40 Treatment Assumptions Type (using 20 foot (using 40 foot (tonnes) foot containers foot containers Costs (USD) containers) containers) Oils: Facility provided pricing for a 24,000 L ISO container rather than a 20 foot container. Ground transportation costs provided in Panalpina. Disposal cost per litre for <500 ppm assumed to be $0.45 and for >500 ppm assumed to be $0.85 Transformers: Facility provided pricing for a 20 foot container carrying ESI Group 20 tonnes. Ground transportation costs provided in Panalpina. Assumed 90500 18,617,963 - 107,173,611 125,791,574 - (Australia) price of treating transformer with < 500 ppm is $1010 USD/tonne and $1220 USD/tonne for > 500 ppm Capacitors: Facility provided pricing for a 20 foot container carrying 20 tonnes. Ground transportation costs provided in Panalpina. Assumed price of treating capacotpr with < 500 ppm is $3000 USD/tonne and $4250 USD/tonne for > 500 ppm Shipping costs provided by Palalpina. Assumptions: a 20 ft container can carry 17.5 tonnes, and a 40 ft container can carry 24 tonnes. Transformers: Assumed same price for treating waste of > 500 ppm and Tredi Seche < 500 ppm ($2550 USD/tonne). 90500 19,946,200 26,821,938 228,875,000 248,821,200 255,696,938 (France) Capacitors: Assumed same price for treating waste of > 500 ppm and < 500 ppm ($2750 USD/tonne). Oils: Assumed same price for treating waste of > 500 ppm and < 500 ppm ($2250 USD/tonne). Shipping costs provided by Palalpina. Assumptions: a 20 ft container can carry 17.5 tonnes, and a 40 ft container can carry 24 tonnes. Transformers: Assumed price for treating transformers of > 500 ppm is $1088 USD/tonne and < 500 ppm, $1000 USD/tonne Ekokem (Finland) 90500 21,151,143 26,199,750 100,368,750 121,519,893 126,568,500 Capacitors: Assumed price for treating capacitors of > 500 ppm is $1360 USD/tonne and < 500 ppm, $1088 USD/tonne Oils: Assumed price for treating waste of > 500 ppm is $1904 USD/tonne and < 500 ppm, $1088 USD/tonne Shipping costs provided by Palalpina. Assumptions: a 20 ft container can carry 17.5 tonnes, and a 40 ft container can carry 24 tonnes. Oils: For < 500 ppm, cost is 100 Euro/tonne. For > 500 ppm, cost is 400 Euro/tonne. Price of pure askarel (not included in estimates) is 800 Euro/tonne. HIM (Germany) 90500 22,159,571 28,243,542 145,350,000 167,509,571 173,593,542 Transformers: Pricing provided for transformers with copper cores (1300 Euros/tonne). For transformers with aluminum cores, the price will be 1000 Euros/tonne. Capacitors: Pricing provided for capacitors > 5 kg (1250 Euros/tonne). For capacitors less than 5 kg, the price is 600 Euros/tonne. Facility provided shipping costs. Cost of ground transportation provided by Panalpina. VAT is not included in pricing. Assumptions: a 20 ft container can carry 17.5 tonnes, and a 40 ft container can carry 24 tonnes. Oils: Facility indicated that cost of treating oil at concentrations > 100,000 SAVA (Germany) 90500 20,727,086 25,370,167 71,332,000 92,059,086 96,702,167 ppm is 450 Euro/tonne. Transformers: Pricing provided for transformers with copper cores (600 Euros/tonne). For transformers with aluminum cores, the price will be 850 Euros/tonne. Capacitors: Facility indicated that cost of treating capacitors (900 Euros/tonne) does not depend on concentration of PCBs. Shipping pricing provided by facility. Ground transportation costs provided by Panalpina. Assumption was that 20 ft container can carry 8 tonnes, Dottikon 90500 62,784,375 48,870,000 164,782,500 227,566,875 213,652,500 and 40 ft container can carry 16 tonnes. Pricing does not include return of (Switzerland) containers. Assumed same price for treating waste of > 500 ppm and < 500 ppm. Transformers are not treated. Shipping pricing provided by facility. Ground transportation costs provided by Panalpina. Assumption was that 20 ft container can carry 10 tonnes, Valorec and 40 ft container can carry 20 tonnes. 90500 7,128,450 5,783,438 13,591,250 20,719,700 19,374,688 (Switzerland) Oils: Facility indicated that cost of treating oil at concentrations > 500 ppm is 1140 CHF/tonne and < 500 is 540 CHF/tonne. Notification costs and VAT are not included in pricing. Capacitors: Facility indicated a single price for treatment of capacitors. 3 Summary Page 2 of 4 Scenario 2 Assumptions: All oils shipped out to overseas facilities. Cellulosic material treated by Holcim Vietnam. Transformer and capacitor hulks disposed of in German salt mine. 50% of total weight is less than 500 ppm and 50% of total weight is greater than 500 ppm Transformers contain 34% oil by weight, 58% metals by weight and 8 % cellulosic material by weight. Capacitors contain 36.5% oil by weight, 19% metals by weight and 44.5% cellulosic material by weight. Total Cost of Total Cost of Total Waste Total Shipping Total Shipping Total Facility/Waste Disposal (USD) Disposal (USD) Quantity Costs (USD)/20 Costs (USD)/40 Treatment Assumptions Type (using 20 foot (using 40 foot (tonnes) foot containers foot containers Costs (USD) containers) containers) Oil Waste (from transformers, capacitors, and used mineral oil) Facility provided pricing for a 24,000 L ISO container rather than a 20 foot ESI Group container. Ground transportation costs provided in Panalpina. Disposal 37508 6,424,896 - 13,544,375 19,969,271 - (Australia) cost per litre for <500 ppm assumed to be $0.45 and for >500 ppm assumed to be $0.85 Shipping costs provided by Palalpina. Assumptions: a 20 ft container can Tredi Seche 37508 8,266,653 11,116,285 84,391,875 92,658,528 95,508,160 carry 17.5 tonnes, and a 40 ft container can carry 24 tonnes. Assumed (France) same price for treating waste of > 500 ppm and < 500 ppm Shipping costs provided by Palalpina. Assumptions: a 20 ft container can carry 17.5 tonnes, and a 40 ft container can carry 24 tonnes. Assumed Ekokem (Finland) 37508 8,766,039 10,858,421 56,111,220 64,877,259 66,969,641 price for treating waste of > 500 ppm is $1904 USD/tonne and < 500 ppm, $1088 USD/tonne Shipping costs provided by Palalpina. Assumptions: a 20 ft container can carry 17.5 tonnes, and a 40 ft container can carry 24 tonnes. For < 500 HIM (Germany) 37508 9,183,979 11,705,466 12,752,550 21,936,529 24,458,016 ppm, cost is 100 Euro/tonne. For > 500 ppm, cost is 400 Euro/tonne. Price of pure askarel (not included in estimates) is 800 Euro/tonne. Facility provided shipping costs. Cost of ground transportation provided by Panalpina. Assumptions: a 20 ft container can carry 17.5 tonnes, and a SAVA (Germany) 37508 8,590,289 10,514,603 20,234,590 28,824,879 30,749,193 40 ft container can carry 24 tonnes. Facility indicated that cost of treating oil at concentrations > 100,000 ppm is 450 Euro/tonne. VAT is not included in pricing. Shipping pricing provided by facility. Ground transportation costs provided by Panalpina. Assumption was that 20 ft container can carry 8 tonnes, Dottikon 37508 26,020,828 20,254,050 42,871,073 68,891,901 63,125,123 and 40 ft container can carry 16 tonnes. Pricing does not include return of (Switzerland) containers. Assumed same price for treating waste of > 500 ppm and < 500 ppm. Shipping pricing provided by facility. Ground transportation costs provided by Panalpina. Assumption was that 20 ft container can carry 10 tonnes, Valorec 37508 17,249,699 13,994,986 26,150,229 43,399,928 40,145,215 and 40 ft container can carry 20 tonnes. Facility indicated that cost of (Switzerland) treating oil at concentrations > 500 ppm is 1140 CHF/tonne and < 500 is 540 CHF/tonne. Notification costs and VAT are not included in pricing. Cellulosic Waste (Disposed by Holcim Vietnam) Assumed price of treating cellulosic material with < 500 ppm is $650 Holcim (Vietnam) 8448 96,543 6,124,438 6,220,980 USD/tonne and $800 USD/tonne for > 500 ppm Transformer and Capacitor Carcasses Shipping costs assumed to be the same as to Biebesheim, Germany. K+S (Germany) 44,545 10,907,161 13,901,752 15,768,930 26,676,091 29,670,682 Cost of disposal assumed to be $354/tonne. Scenario 3 Assumptions: Oils and cellulosic materials treated by Holcim Vietnam. Transformer and capacitor carcasses disposed in German salt mine. 50% of total weight is less than 500 ppm and 50% of total weight is greater than 500 ppm Total Cost of Total Cost of Total Waste Total Shipping Total Shipping Total Facility/Waste Disposal (USD) Disposal (USD) Quantity Costs (USD)/20 Costs (USD)/40 Treatment Assumptions Type (using 20 foot (using 40 foot (tonnes) foot containers foot containers Costs (USD) containers) containers) Oily Waste Assumed price of treating oil with concentration < 500 ppm is $650 Holcim Vietnam 37508 428657 27,192,938 27,621,595 USD/tonne and $800 USD/tonne for > 500 ppm Cellulosic Material Assumed price of treating cellulosic material with < 500 ppm is $650 Holcim Vietnam 8448 96543 6,124,438 6,220,980 USD/tonne and $800 USD/tonne for > 500 ppm Transformer and Capacitor Carcasses Shipping costs assumed to be the same as to Biebesheim, Germany. K+S (Germany) 44,545 10,907,161 13,901,752 15,768,930 26,676,091 29,670,682 Cost of disposal assumed to be $354/tonne. 3 Summary Page 3 of 4 Scenario 4 Assumptions: All materials treated locally by relocatable units 50% of total weight is less than 500 ppm and 50% of total weight is greater than 500 ppm Total cost of Total Waste Transportation Facility/Waste Operating Total Treatment Transportation Quantity Costs (20 foot Set Up Cost (USD) Assumptions Type Cost (USD) Costs (USD) plus Treatment (tonnes) container) (USD) (USD) Set up and demobilization prices included in cost of treatment. Assumed cost of transportation = $200 US per container, each container carrying 17.5 tonnes. Oils: Disposal cost per litre for <500 ppm assumed to be $0.25/L and for ESI Group provided in 90500 1034286 not provided. 41,295,833 42,330,119 >500 ppm assumed to be $0.50/L. (Australia) treatment estimate. Transformers: Assumed price of treating transformer with < 500 ppm is $300 USD/tonne and $500 USD/tonne for > 500 ppm. Capacitors: Asumed price of treating capacotpr with < 500 ppm is $1350 USD/tonne and $2000 USD/tonne for > 500 ppm. Assumed cost of transportation = $200 US per container, each container carrying 17.5 tonnes. Local pricing not provided by facility (French Tredi Seche 90500 1034286 not provided. not provided. 228,875,000 229,909,286 disposal prices used). Pricing will likely be lower for treatment in Vietnam. (France) Assumed same price for treating waste at concentration < 500 ppm as waste at concentration > 500 ppm. Assumed cost of transportation = $200 US per container, each container carrying 17.5 tonnes. Transformers: Assumed price for treating transformers of > 500 ppm is Dolomatrix $3004.16 USD/tonne and < 500 ppm, $2360.41 USD/tonne International 90500 1034286 not provided. not provided. 258,157,413 259,191,698 Capacitors: Assumed price for treating capacitors is the same at any (Australia) concentration, i.e. $8583.32 USD/tonne. Oils: Assumed price for treating waste of > 500 ppm is $1.63 USD/L and < 500 ppm, $1.89 USD/L. $4,000,000 Assumed cost of transportation = $200 US per container, each container (accounts for two carrying 17.5 tonnes. locations at $1M included in Assuming the plant is owned and operated by the Govt. of Vietnam each, plus site Hallet (Canada) 90500 1034286 treatment 143,310,000 148,344,286 (assuming $1M royalties and 10% processing fee). preparation and cost. Price of treating waste of concentration < 500 ppm is the same as supply of utilities concentration > 500 ppm. Cost includes labour, utilities, maintenance, and equipment, also capital depreciation $1M each location). $4,000,000 (accounts for two Assumed cost of transportation = $200 US per container, each container locations at $1M carrying 17.5 tonnes. included in each, plus site Assuming the plant is owned and operated by Hallet (20% fee). Hallet (Canada) 90500 1034286 treatment 157,580,000 162,614,286 preparation and Price of treating waste of concentration < 500 ppm is the same as cost. supply of utilities concentration > 500 ppm. Cost includes labour, utilities, maintenance, and equipment, also capital depreciation. $1M each location). Assumed cost of transportation = $200 US per container, each container carrying 17.5 tonnes. Transformers: Assumed price for treating transformers of > 500 ppm is Kinectrics $1500 USD/tonne and < 500 ppm, $1000 USD/tonne 90500 1034286 not provided. not provided. 112,847,222 113,881,508 (Canada) Capacitors: Assumed price for treating capacitors of > 500 ppm is $1500 USD/tonne and < 500 ppm, $1000 USD/tonne Oils: Disposal cost per litre for <500 ppm assumed to be $0.90/L and for >500 ppm assumed to be $3.50/L. Scrap Metal Recovery Total Steel Price/tonne Copper price/tonne Aluminum price/tonne (tonnes) $150 $180 $1200 $1800 $1200 $1800 Transformer Carca 43500 $2,610,000 $3,132,000 $5,220,000 $7,830,000 $26,100,000 $39,150,000 Capacitor Carcasse1045 $62,700 $75,240 $125,400 $188,100 $627,000 $940,500 3 Summary Page 4 of 4 Scenario 5 Assumptions: Oils and cellulosic material treated by Holcim Vietnam. Carcasses cleaned using solvent washing or GPCR in Vietnam. 50% of total weight is less than 500 ppm and 50% of total weight is greater than 500 ppm Total Cost of Total Waste Transportation Facility/Waste Operating Total Treatment Treatment Plus Quantity Costs (20 foot Set Up Cost (USD) Assumptions Type Cost (USD) Costs (USD) Transportation (tonnes) container) (USD) Oily Waste Assumed cost of transportation = $200 US per container, each container Holcim (Vietnam) 37,508 428,657 27,192,938 27,621,595 carrying 17.5 tonnes. Assumed price of treating oil with concentration < 500 ppm is $650 Cellulosic Material Assumed cost of transportation = $200 US per container, each container Holcim (Vietnam) 8,448 96,543 6,124,438 6,220,980 carrying 17.5 tonnes. Assumed price of treating cellulosic material with < 500 ppm is $650 Transformer and Capacitor Carcasses Assumed cost of transportation = $200 US per container, each container carrying 17.5 tonnes. Transformers: Assumed price of treating drained transformer is $300 Provided in ESI Group 44,545 509,086 not provided 14,460,750 14,969,836 USD/tonne. Set up and demobilization prices included in cost of treatment. treatment estimate. Capacitors: Assumed price of treating drained capacitor is $1350 USD/tonne. Set up and demobilization prices included in cost of treatment. Hallet (Assuming 4,000,000 (accounts the plant is owned for two locations at and operated by Assumed cost of transportation = $200 US per container, each container $1M each, plus site included in the Govt. of carrying 17.5 tonnes. 44,545 509,086 preparation and treatment 20,490,700 24,999,786 Vietnam Price of treating drained metal parts is $460/tonne. Cost includes labour, supply of utilities cost. (assuming $1M utilities, maintenance, and capital depreciation. equipment, also royalties and 10% $1M each location. processing fee) 4,000,000 (accounts for two locations at Hallet (Assuming Assumed cost of transportation = $200 US per container, each container $1M each, plus site included in the plant is owned carrying 17.5 tonnes. 44,545 509,086 preparation and treatment 22,272,500 26,781,586 and operated by Price of treating drained metal parts is $500/tonne. Cost includes labour, supply of utilities cost. Hallet (20% fee)) utilities, maintenance, and capital depreciation. equipment, also $1M each location. Scrap Metal Recovery Total Steel Price/tonne Copper price/tonne Aluminum price/tonne (tonnes) $150 $180 $1200 $1800 $1200 $1800 Transformer Carca 43500 $2,610,000 $3,132,000 $5,220,000 $7,830,000 $26,100,000 $39,150,000 Capacitor Carcasse1045 $62,700 $75,240 $125,400 $188,100 $627,000 $940,500 4 Full Overseas Treat Page 1 of 4 Case Study: Oil (tonnes): 10,000 Transformers (tonnes): 75,000 Capacitors (tonnes): 5,500 Assumptions: Transformers will be drained prior to shippment. Only contaminated oil will be shipped. Metal components will be recovered and cellulosic material will be disposed of in Vietnam Unless otherwise specified by the facility, it will be assumed that a 20ft container can carry 17.5 tonnes of material and a 40ft container can carry 24 tonnes of material 50% of total weight is less than 500 ppm and 50% of total weight is greater than 500 ppm Cost of Treatment Ground Ground Dangerous Dangerous Total transportation Total Cost of Total Cost of transportation costs Shipping Costs Shipping Costs Goods Fee (if not Goods Fee (if Transportation Total Transportation Facility/Waste Waste Quantity/ Est. Number of Est. Number of costs in Vietnam Total Cost of Transport (20 foot Transport (40 foot in Vietnam to port (20 foot (40 foot included in not included in Cost (assuming Cost (assuming 40 foot Exclusions/ Comments Type tonnes 20ft containers 40ft containers to port (40ft Treatment containers) and containers) and (20ft containers) container) container) shipping cost)/ shipping cost)/ 20 foot containers) containers) Treatment Treatment (USD) 20 foot container 40 foot container containers) (USD) < 500 ppm > 500 ppm ESI Group, Mitchell Group, Australia Facility provided pricing for a 20 foot container carrying 20 tonnes. Ground assumed assumed transportation costs provided in included in cost Transformers 75,000 3,750 750,000 - 15,000,000 - included in cost 15,750,000 - 37,875,000 45,750,000 83,625,000 99,375,000 - Panalpina. Assumed price of treating provided by provided by facility transformer with < 500 ppm is $1010 facility USD/tonne and $1220 USD/tonne for > 500 ppm Facility provided pricing for a 20 foot container carrying 20 tonnes. Ground assumed assumed transportation costs provided in included in cost Capacitors 5,500 275 55,000 1,100,000 included in cost 1,155,000 - 8,250,000 11,687,500 19,937,500 21,092,500 - Panalpina. Assumed price of treating provided by provided by facility capacotpr with < 500 ppm is $3000 facility USD/tonne and $4250 USD/tonne for > 500 ppm Facility provided pricing for 24000 L iso assumed tanker carrying 21.6 tonnes. Ground assumed included in cost transportation costs provided in Oil 10,000 463 92,593 - 1,620,370 - included in cost 1,712,963 - 1,250,000 2,361,111 3,611,111 5,324,074 - provided by Panalpina. Disposal cost per litre for provided by facility facility <500 ppm assumed to be $0.45/L and for >500 ppm assumed to be $0.85/L Tredi Seche, Lagnieu, France Shipping costs provided by Palalpina. Assumptions: a 20 ft container can carry 17.5 tonnes, and a 40 ft container Transformers 75,000 4,286 3,125 857,143 625,000 14,022,857 19,196,875 1,650,000 2,406,250 16,530,000 22,228,125 95,625,000 95,625,000 191,250,000 207,780,000 213,478,125 can carry 24 tonnes. Assumed same price for treating waste of > 500 ppm and < 500 ppm Shipping costs provided by Palalpina. Assumptions: a 20 ft container can carry 17.5 tonnes, and a 40 ft container Capacitors 5,500 314 229 62,857 45,833 1,028,343 1,407,771 121,000 176,458 1,212,200 1,630,063 7,562,500 7,562,500 15,125,000 16,337,200 16,755,063 can carry 24 tonnes. Capacitors must be drained before shipment. Assumed same price for treating waste of > 500 ppm and < 500 ppm Shipping costs provided by Palalpina. Assumptions: a 20 ft container can carry 17.5 tonnes, and a 40 ft container Oil 10,000 571 416.67 114,286 83,333 1,869,714 2,559,583 220,000 320,833 2,204,000 2,963,750 11,250,000 11,250,000 22,500,000 24,704,000 25,463,750 can carry 24 tonnes.Assumed same price for treating waste of > 500 ppm and < 500 ppm Ekokem, Riihimaki, Finland Shipping costs provided by Palalpina. Assumptions: a 20 ft container can carry 17.5 tonnes, and a 40 ft container Transformers 75,000 4,286 3,125 857,143 625,000 15,021,429 18,681,250 1,650,000 2,406,250 17,528,571 21,712,500 37,500,000 40,800,000 78,300,000 95,828,571 100,012,500 can carry 24 tonnes. Assumed price for treating transformers of > 500 ppm is $1088 USD/tonne and < 500 ppm, $1000 USD/tonne 4 Full Overseas Treat Page 2 of 4 Case Study: Oil (tonnes): 10,000 Transformers (tonnes): 75,000 Capacitors (tonnes): 5,500 Assumptions: Transformers will be drained prior to shippment. Only contaminated oil will be shipped. Metal components will be recovered and cellulosic material will be disposed of in Vietnam Unless otherwise specified by the facility, it will be assumed that a 20ft container can carry 17.5 tonnes of material and a 40ft container can carry 24 tonnes of material 50% of total weight is less than 500 ppm and 50% of total weight is greater than 500 ppm Cost of Treatment Ground Ground Dangerous Dangerous Total transportation Total Cost of Total Cost of transportation costs Shipping Costs Shipping Costs Goods Fee (if not Goods Fee (if Transportation Total Transportation Facility/Waste Waste Quantity/ Est. Number of Est. Number of costs in Vietnam Total Cost of Transport (20 foot Transport (40 foot in Vietnam to port (20 foot (40 foot included in not included in Cost (assuming Cost (assuming 40 foot Exclusions/ Comments Type tonnes 20ft containers 40ft containers to port (40ft Treatment containers) and containers) and (20ft containers) container) container) shipping cost)/ shipping cost)/ 20 foot containers) containers) Treatment Treatment (USD) 20 foot container 40 foot container containers) (USD) < 500 ppm > 500 ppm Shipping costs provided by Palalpina. Assumptions: a 20 ft container can carry 17.5 tonnes, and a 40 ft container Capacitors 5,500 314 229 62,857 45,833 1,101,571 1,369,958 121,000 176,458 1,285,429 1,592,250 3,368,750 3,740,000 7,108,750 8,394,179 8,701,000 can carry 24 tonnes. Assumed price for treating capacitors of > 500 ppm is $1360 USD/tonne and < 500 ppm, $1088 USD/tonne Shipping costs provided by Palalpina. Assumptions: a 20 ft container can carry 17.5 tonnes, and a 40 ft container Oil 10,000 571 416.67 114,286 83,333 2,002,857 2,490,833 220,000 320,833 2,337,143 2,895,000 5,440,000 9,520,000 14,960,000 17,297,143 17,855,000 can carry 24 tonnes. Assumed price for treating waste of > 500 ppm is $1904 USD/tonne and < 500 ppm, $1088 USD/tonne HIM, Biebesheim, Germany Shipping costs provided by Palalpina. Assumptions: a 20 ft container can carry 17.5 tonnes, and a 40 ft container Transformers 75,000 4,286 3,125 857,143 625,000 15,857,143 20,375,000 1,650,000 2,406,250 18,364,286 23,406,250 51,000,000 51,000,000 102,000,000 120,364,286 125,406,250 can carry 24 tonnes. Price of treating (aluminum) transformers of concentration < 500 ppm is the same as concentration > 500 ppm. Price depends on materials. Shipping costs provided by Palalpina. Assumptions: a 20 ft container can carry 17.5 tonnes, and a 40 ft container Transformers 75,000 4,286 3,125 857,143 625,000 15,857,143 20,375,000 1,650,000 2,406,250 18,364,286 23,406,250 66,300,000 66,300,000 132,600,000 150,964,286 156,006,250 can carry 24 tonnes. Price of treating (copper) transformers of concentration < 500 ppm is the same as concentration > 500 ppm. Price depends on materials. Shipping costs provided by Palalpina. Assumptions: a 20 ft container can carry 17.5 tonnes, and a 40 ft container Capacitors (< 5 5,500 314 229 62,857 45,833 1,162,857 1,494,167 121,000 176,458 1,346,714 1,716,458 2,244,000 2,244,000 4,488,000 5,834,714 6,204,458 can carry 24 tonnes. Price of treating kg) capacitors of concentration < 500 ppm is the same as concentration > 500 ppm. Price depends on materials. Shipping costs provided by Palalpina. Assumptions: a 20 ft container can carry 17.5 tonnes, and a 40 ft container Capacitors (> 5 can carry 24 tonnes. Price of treating 5,500 314 229 62,857 45,833 1,162,857 1,494,167 121,000 176,458 1,346,714 1,716,458 4,675,000 4,675,000 9,350,000 10,696,714 11,066,458 kg) capacitors of concentration < 500 ppm is the same as concentration > 500 ppm. Price depends on materials. Must be drained. Shipping costs provided by Palalpina. Assumptions: a 20 ft container can carry 17.5 tonnes, and a 40 ft container can carry 24 tonnes. For < 500 ppm, Oil 10,000 571 416.67 114,286 83,333 2,114,286 2,716,667 220,000 320,833 2,448,571 3,120,833 680,000 2,720,000 3,400,000 5,848,571 6,520,833 cost is 100 Euro/tonne. For > 500 ppm, cost is 400 Euro/tonne. Price of pure askarel (not included in the estimate) is $800 Euro/tonne 4 Full Overseas Treat Page 3 of 4 Case Study: Oil (tonnes): 10,000 Transformers (tonnes): 75,000 Capacitors (tonnes): 5,500 Assumptions: Transformers will be drained prior to shippment. Only contaminated oil will be shipped. Metal components will be recovered and cellulosic material will be disposed of in Vietnam Unless otherwise specified by the facility, it will be assumed that a 20ft container can carry 17.5 tonnes of material and a 40ft container can carry 24 tonnes of material 50% of total weight is less than 500 ppm and 50% of total weight is greater than 500 ppm Cost of Treatment Ground Ground Dangerous Dangerous Total transportation Total Cost of Total Cost of transportation costs Shipping Costs Shipping Costs Goods Fee (if not Goods Fee (if Transportation Total Transportation Facility/Waste Waste Quantity/ Est. Number of Est. Number of costs in Vietnam Total Cost of Transport (20 foot Transport (40 foot in Vietnam to port (20 foot (40 foot included in not included in Cost (assuming Cost (assuming 40 foot Exclusions/ Comments Type tonnes 20ft containers 40ft containers to port (40ft Treatment containers) and containers) and (20ft containers) container) container) shipping cost)/ shipping cost)/ 20 foot containers) containers) Treatment Treatment (USD) 20 foot container 40 foot container containers) (USD) < 500 ppm > 500 ppm SAVA, Brunsbuttel, Germany Facility provided shipping costs. Cost of ground transportation provided by Assumed Panalpina. Assumptions: a 20 ft Assumed Transformers included in cost container can carry 17.5 tonnes, and a 75,000 4,286 3,125 857,143 625,000 16,320,000 20,400,000 included in cost 17,177,143 21,025,000 43,350,000 43,350,000 86,700,000 103,877,143 107,725,000 (aluminum) provided by 40 ft container can carry 24 tonnes. provided by facility facility Facility indicated that cost of treating transformers depends on material of coils rather than concentration of PCBs. Facility provided shipping costs. Cost of ground transportation provided by Panalpina. Assumptions: a 20 ft Assumed Assumed container can carry 17.5 tonnes, and a Transformers included in cost 75,000 4,286 3,125 857,143 625,000 16,320,000 20,400,000 included in cost 17,177,143 21,025,000 30,600,000 30,600,000 61,200,000 78,377,143 82,225,000 40 ft container can carry 24 tonnes. (copper) provided by provided by facility Facility indicated that cost of treating facility transformers depends on material of coils rather than concentration of PCBs. VAT is not included in pricing. Facility provided shipping costs. Cost of ground transportation provided by Panalpina. Assumptions: a 20 ft Assumed Assumed container can carry 17.5 tonnes, and a included in cost Capacitors 5,500 314 229 62,857 45,833 1,196,800 1,496,000 included in cost 1,259,657 1,541,833 3,366,000 3,366,000 6,732,000 7,991,657 8,273,833 40 ft container can carry 24 tonnes. provided by provided by facility Facility indicated that cost of treating facility capacitors does not depend on concentration of PCBs. VAT is not included in pricing. Facility provided shipping costs. Cost of ground transportation provided by Panalpina. Assumptions: a 20 ft Assumed Assumed container can carry 17.5 tonnes, and a included in cost Oil 10,000 571 416.67 114,286 83,333 2,176,000 2,720,000 included in cost 2,290,286 2,803,333 680,000 2,720,000 3,400,000 5,690,286 6,203,333 40 ft container can carry 24 tonnes. provided by provided by facility Facility indicated that cost of treating oil facility at concentrations > 100,000 ppm is 450 Euro/tonne. VAT is not included in pricing. 4 Full Overseas Treat Page 4 of 4 Case Study: Oil (tonnes): 10,000 Transformers (tonnes): 75,000 Capacitors (tonnes): 5,500 Assumptions: Transformers will be drained prior to shippment. Only contaminated oil will be shipped. Metal components will be recovered and cellulosic material will be disposed of in Vietnam Unless otherwise specified by the facility, it will be assumed that a 20ft container can carry 17.5 tonnes of material and a 40ft container can carry 24 tonnes of material 50% of total weight is less than 500 ppm and 50% of total weight is greater than 500 ppm Cost of Treatment Ground Ground Dangerous Dangerous Total transportation Total Cost of Total Cost of transportation costs Shipping Costs Shipping Costs Goods Fee (if not Goods Fee (if Transportation Total Transportation Facility/Waste Waste Quantity/ Est. Number of Est. Number of costs in Vietnam Total Cost of Transport (20 foot Transport (40 foot in Vietnam to port (20 foot (40 foot included in not included in Cost (assuming Cost (assuming 40 foot Exclusions/ Comments Type tonnes 20ft containers 40ft containers to port (40ft Treatment containers) and containers) and (20ft containers) container) container) shipping cost)/ shipping cost)/ 20 foot containers) containers) Treatment Treatment (USD) 20 foot container 40 foot container containers) (USD) < 500 ppm > 500 ppm Dottikon, Dottikon, Switzerland Shipping pricing provided by facility. Ground transportation costs provided by Panalpina. Assumption was that 20 Assumed Assumed ft container can carry 8 tonnes, and 40 included in cost Transformers 75,000 9,375 4,688 1,875,000 937,500 50,156,250 39,562,500 included in cost 52,031,250 40,500,000 71,437,500 71,437,500 142,875,000 194,906,250 183,375,000 ft container can carry 16 tonnes. provided by provided by facility Pricing does not include return of facility containers. Assumed same price for treating waste of > 500 ppm and < 500 ppm. Shipping pricing provided by facility. Ground transportation costs provided by Panalpina. Assumption was that 20 Assumed Assumed ft container can carry 8 tonnes, and 40 included in cost Capacitors 5,500 688 344 137,500 68,750 3,678,125 2,901,250 included in cost 3,815,625 2,970,000 5,238,750 5,238,750 10,477,500 14,293,125 13,447,500 ft container can carry 16 tonnes. provided by provided by facility Pricing does not include return of facility containers. Assumed same price for treating waste of > 500 ppm and < 500 ppm. Shipping pricing provided by facility. Ground transportation costs provided by Panalpina. Assumption was that 20 Assumed Assumed ft container can carry 8 tonnes, and 40 included in cost Oil 10,000 1,250 625.00 250,000 125,000 6,687,500 5,275,000 included in cost 6,937,500 5,400,000 5,715,000 5,715,000 11,430,000 18,367,500 16,830,000 ft container can carry 16 tonnes. provided by provided by facility Pricing does not include return of facility containers. Assumed same price for treating waste of > 500 ppm and < 500 ppm. Valorec, Basel, Switzerland Transformers Not treated. Shipping pricing provided by facility. Ground transportation costs provided by Panalpina. Assumption was that 20 Assumed Assumed ft container can carry 10 tonnes, and 40 included in cost Capacitors 5,500 550 275 110,000 55,000 2,419,450 1,997,188 included in cost 2,529,450 2,052,188 3,309,625 3,309,625 6,619,250 9,148,700 8,671,438 ft container can carry 20 tonnes. provided by provided by facility Facility indicated a single price for facility treatment of capacitors. Notification costs and VAT are not included in pricing. Shipping pricing provided by facility. Ground transportation costs provided by Panalpina. Assumption was that 20 Assumed ft container can carry 10 tonnes, and 40 Assumed included in cost ft container can carry 20 tonnes. Oil 10,000 1,000 500.00 200,000 100,000 4,399,000 3,631,250 included in cost 4,599,000 3,731,250 2,241,000 4,731,000 6,972,000 11,571,000 10,703,250 provided by Facility indicated that cost of treating oil provided by facility facility at concentrations > 500 ppm is 1140 CHF/tonne and < 500 is 540 CHF/tonne. Notification costs and VAT are not included in pricing. 5 Overseas Oil Treat Page 1 of 4 Case Study: Oil (tonnes): 10,000 Transformers (tonnes): 75,000 Capacitors (tonnes): 5,500 Assumptions: Transformers and capacitors will be drained prior to shippment. Only contaminated oil will be shipped. Metal components will be recovered and cellulosic material will be disposed of in Vietnam Unless otherwise specified by the facility, it will be assumed that a 20ft container can carry 17.5 tonnes of material and a 40ft container can carry 24 tonnes of material 50% of total weight is less than 500 ppm and 50% of total weight is greater than 500 ppm Transformers contain 34% oil by weight, 58% metals by weight and 8 % cellulosic material by weight. Capacitors contain 36.5% oil by weight, 19% metals by weight and 44.5% cellulosic material by weight. Ground Total Cost of Total Cost of Ground Dangerous Goods Total Total transportation Shipping Costs Dangerous Goods Transport (20 Transport (40 Waste transportation Shipping Costs Fee (if not included in Transportation Transportation Cost of Treatment (USD) Total Cost of Est. Number of Est. Number of costs in Vietnam (20 foot Fee (if not included foot foot Facility/Waste Type Quantity/ costs in Vietnam (40 foot shipping cost)/ 40 Cost (assuming 20 Cost (assuming 40 Treatment Exclusions/Comments 20ft containers 40ft containers to port (20ft container) in shipping cost)/ 20 containers) containers) tonnes to port (40ft container) (USD) foot container foot containers) foot containers) (USD) containers) (USD) foot container (USD) and Treatment and Treatment containers) (USD) (USD) (USD) (USD) (USD) (USD) (USD) < 500 ppm > 500 ppm ESI Group, Mitchell Group, Australia Facility provided pricing for a 24,000 L ISO container assumed included in rather than a 20 foot container. Ground transportation assumed included in Transformer (oil) 25,500 1,181 236,111 - 4,131,944 - cost provided by 4,368,056 - 3,187,500 6,020,833 9,208,333 13,576,389 - costs provided in Panalpina. Disposal cost per litre for cost provided by facility facility <500 ppm assumed to be $0.45 and for >500 ppm assumed to be $0.85 Transformer (Cellulosic 6,000 Will be treated by Holcim Vietnam Mateiral) Transformer (Metal) 43,500 Will be treated in Vietnam by sodium reduction Facility provided pricing for a 24,000 L ISO container assumed included in rather than a 20 foot container. Ground transportation assumed included in Capacitors (Oil) 2,008 93 18,588 325,289 cost provided by 343,877 250,938 473,993 724,931 1,068,808 costs provided in Panalpina. Disposal cost per litre for cost provided by facility facility <500 ppm assumed to be $0.45 and for >500 ppm assumed to be $0.85 Capacitors (Cellulosic 2,448 Will be treated by Holcim Vietnam Material) Capacitors (Metal) 1,045 Will be treated in Vietnam by sodium reduction Facility provided pricing for a 24,000 L ISO container assumed included in rather than a 20 foot container. Ground transportation assumed included in Oil 10,000 463 92,593 - 1,620,370 - cost provided by 1,712,963 - 1,250,000 2,361,111 3,611,111 5,324,074 - costs provided in Panalpina. Disposal cost per litre for cost provided by facility facility <500 ppm assumed to be $0.45 and for >500 ppm assumed to be $0.85 Tredi Seche, Lagnieu, France Shipping costs provided by Palalpina. Assumptions: a 20 ft container can carry 17.5 tonnes, and a 40 ft Transformer (oil) 25,500 1,457 1,063 291,429 212,500 4,767,771 6,526,938 561,000 818,125 5,620,200 7,557,563 28,687,500 28,687,500 57,375,000 62,995,200 64,932,563 container can carry 24 tonnes. Assumed same price for treating waste of > 500 ppm and < 500 ppm Transformer (Cellulosic 6,000 Will be treated by Holcim Vietnam Material) Transformer (Metal) 43,500 Will be treated in Vietnam by sodium reduction Shipping costs provided by Palalpina. Assumptions: a 20 ft container can carry 17.5 tonnes, and a 40 ft Capacitors (Oil) 2,008 115 84 22,943 16,729 375,345 513,836 44,165 64,407 442,453 594,973 2,258,438 2,258,438 4,516,875 4,959,328 5,111,848 container can carry 24 tonnes. Assumed same price for treating waste of > 500 ppm and < 500 ppm Capacitors (Cellulosic 2,448 Will be treated by Holcim Vietnam Material) Capacitors (Metal) 1,045 Will be treated in Vietnam by sodium reduction Shipping costs provided by Palalpina. Assumptions: a 20 ft container can carry 17.5 tonnes, and a 40 ft Oil 10,000 571 416.67 114,286 83,333 1,869,714 2,559,583 220,000 320,833 2,204,000 2,963,750 11,250,000 11,250,000 22,500,000 24,704,000 25,463,750 container can carry 24 tonnes. Assumed same price for treating waste of > 500 ppm and < 500 ppm 5 Overseas Oil Treat Page 2 of 4 Case Study: Oil (tonnes): 10,000 Transformers (tonnes): 75,000 Capacitors (tonnes): 5,500 Assumptions: Transformers and capacitors will be drained prior to shippment. Only contaminated oil will be shipped. Metal components will be recovered and cellulosic material will be disposed of in Vietnam Unless otherwise specified by the facility, it will be assumed that a 20ft container can carry 17.5 tonnes of material and a 40ft container can carry 24 tonnes of material 50% of total weight is less than 500 ppm and 50% of total weight is greater than 500 ppm Transformers contain 34% oil by weight, 58% metals by weight and 8 % cellulosic material by weight. Capacitors contain 36.5% oil by weight, 19% metals by weight and 44.5% cellulosic material by weight. Ground Total Cost of Total Cost of Ground Dangerous Goods Total Total transportation Shipping Costs Dangerous Goods Transport (20 Transport (40 Waste transportation Shipping Costs Fee (if not included in Transportation Transportation Cost of Treatment (USD) Total Cost of Est. Number of Est. Number of costs in Vietnam (20 foot Fee (if not included foot foot Facility/Waste Type Quantity/ costs in Vietnam (40 foot shipping cost)/ 40 Cost (assuming 20 Cost (assuming 40 Treatment Exclusions/Comments 20ft containers 40ft containers to port (20ft container) in shipping cost)/ 20 containers) containers) tonnes to port (40ft container) (USD) foot container foot containers) foot containers) (USD) containers) (USD) foot container (USD) and Treatment and Treatment containers) (USD) (USD) (USD) (USD) (USD) (USD) (USD) < 500 ppm > 500 ppm Ekokem, Riihimaki, Finland Shipping costs provided by Palalpina. Assumptions: a 20 ft container can carry 17.5 tonnes, and a 40 ft Transformer (oil) 25,500 1,457 1,063 291,429 212,500 5,107,286 6,351,625 561,000 818,125 5,959,714 7,382,250 13,872,000 24,276,000 38,148,000 44,107,714 45,530,250 container can carry 24 tonnes. Assumed price for treating waste of > 500 ppm is $1904 USD/tonne and < 500 ppm, $1088 USD/tonne Transformer (Cellulosic 6,000 Will be treated by Holcim Vietnam Material) Transformer (Metal) 43,500 Will be treated in Vietnam by sodium reduction Shipping costs provided by Palalpina. Assumptions: a 20 ft container can carry 17.5 tonnes, and a 40 ft Capacitors (Oil) 2,008 115 84 22,943 16,729 402,074 500,035 44,165 64,407 469,181 581,171 1,092,080 1,911,140 3,003,220 3,472,401 3,584,391 container can carry 24 tonnes. Assumed price for treating waste of > 500 ppm is $1904 USD/tonne and < 500 ppm, $1088 USD/tonne Capacitors (Cellulosic 2,448 Will be treated by Holcim Vietnam Material) Capacitors (Metal) 1,045 Will be treated in Vietnam by sodium reduction Shipping costs provided by Palalpina. Assumptions: a 20 ft container can carry 17.5 tonnes, and a 40 ft Oil 10,000 571 416.67 114,286 83,333 2,002,857 2,490,833 220,000 320,833 2,337,143 2,895,000 5,440,000 9,520,000 14,960,000 17,297,143 17,855,000 container can carry 24 tonnes. Assumed price for treating waste of > 500 ppm is $1904 USD/tonne and < 500 ppm, $1088 USD/tonne HIM, Biebesheim, Germany Shipping costs provided by Palalpina. Assumptions: a 20 ft container can carry 17.5 tonnes, and a 40 ft container can carry 24 tonnes. For < 500 ppm, cost is Transformer (oil) 25,500 1,457 1,063 291,429 212,500 5,391,429 6,927,500 561,000 818,125 6,243,857 7,958,125 1,734,000 6,936,000 8,670,000 14,913,857 16,628,125 100 Euro/tonne. For > 500 ppm, cost is 400 Euro/tonne. Price of pure askarel (not included in estimates) is 800 Euro/tonne. Transformer (Cellulosic 6,000 Will be treated by Holcim Vietnam Mateiral) Transformer (Metal) 43,500 Will be treated in Vietnam by sodium reduction Shipping costs provided by Palalpina. Assumptions: a 20 ft container can carry 17.5 tonnes, and a 40 ft container can carry 24 tonnes. For < 500 ppm, cost is Capacitors (Oil) 2,008 115 84 22,943 16,729 424,443 545,371 44,165 64,407 491,551 626,507 136,510 546,040 682,550 1,174,101 1,309,057 100 Euro/tonne. For > 500 ppm, cost is 400 Euro/tonne. Price of pure askarel (not included in estimates) is 800 Euro/tonne. Capacitors (Cellulosic 2,448 Will be treated by Holcim Vietnam Material) Capacitors (Metal) 1,045 Will be treated in Vietnam by sodium reduction Shipping costs provided by Palalpina. Assumptions: a 20 ft container can carry 17.5 tonnes, and a 40 ft container can carry 24 tonnes. For < 500 ppm, cost is Oil 10,000 571 416.67 114,286 83,333 2,114,286 2,716,667 220,000 320,833 2,448,571 3,120,833 680,000 2,720,000 3,400,000 5,848,571 6,520,833 100 Euro/tonne. For > 500 ppm, cost is 400 Euro/tonne. Price of pure askarel (not included in estimates) is 800 Euro/tonne. 5 Overseas Oil Treat Page 3 of 4 Case Study: Oil (tonnes): 10,000 Transformers (tonnes): 75,000 Capacitors (tonnes): 5,500 Assumptions: Transformers and capacitors will be drained prior to shippment. Only contaminated oil will be shipped. Metal components will be recovered and cellulosic material will be disposed of in Vietnam Unless otherwise specified by the facility, it will be assumed that a 20ft container can carry 17.5 tonnes of material and a 40ft container can carry 24 tonnes of material 50% of total weight is less than 500 ppm and 50% of total weight is greater than 500 ppm Transformers contain 34% oil by weight, 58% metals by weight and 8 % cellulosic material by weight. Capacitors contain 36.5% oil by weight, 19% metals by weight and 44.5% cellulosic material by weight. Ground Total Cost of Total Cost of Ground Dangerous Goods Total Total transportation Shipping Costs Dangerous Goods Transport (20 Transport (40 Waste transportation Shipping Costs Fee (if not included in Transportation Transportation Cost of Treatment (USD) Total Cost of Est. Number of Est. Number of costs in Vietnam (20 foot Fee (if not included foot foot Facility/Waste Type Quantity/ costs in Vietnam (40 foot shipping cost)/ 40 Cost (assuming 20 Cost (assuming 40 Treatment Exclusions/Comments 20ft containers 40ft containers to port (20ft container) in shipping cost)/ 20 containers) containers) tonnes to port (40ft container) (USD) foot container foot containers) foot containers) (USD) containers) (USD) foot container (USD) and Treatment and Treatment containers) (USD) (USD) (USD) (USD) (USD) (USD) (USD) < 500 ppm > 500 ppm SAVA, Brunsbuttel, Germany Facility provided shipping costs. Cost of ground transportation provided by Panalpina. Assumptions: a Assumed included in Assumed included in 20 ft container can carry 17.5 tonnes, and a 40 ft Transformer (oil) 25,500 1,457 1,063 291,429 212,500 5,548,800 6,936,000 cost provided by 5,840,229 7,148,500 7,803,000 7,803,000 15,606,000 21,446,229 22,754,500 cost provided by facility container can carry 24 tonnes. Facility indicated that facility cost of treating oil at concentrations > 100,000 ppm is 450 Euro/tonne. VAT is not included in pricing. Transformer (Cellulosic 6,000 Will be treated by Holcim Vietnam Mateiral) Transformer (Metal) 43,500 Will be treated in Vietnam by sodium reduction Facility provided shipping costs. Cost of ground transportation provided by Panalpina. Assumptions: a Assumed included in Assumed included in 20 ft container can carry 17.5 tonnes, and a 40 ft Capacitors (Oil) 2,008 115 84 22,943 16,729 436,832 546,040 cost provided by 459,775 562,769 614,295 614,295 1,228,590 1,688,365 1,791,359 cost provided by facility container can carry 24 tonnes. Facility indicated that facility cost of treating oil at concentrations > 100,000 ppm is 450 Euro/tonne. VAT is not included in pricing. Capacitors (Cellulosic 2,448 Will be treated by Holcim Vietnam Material) Capacitors (Metal) 1,045 Will be treated in Vietnam by sodium reduction Facility provided shipping costs. Cost of ground transportation provided by Panalpina. Assumptions: a Assumed included in Assumed included in 20 ft container can carry 17.5 tonnes, and a 40 ft Oil 10,000 571 416.67 114,286 83,333 2,176,000 2,720,000 cost provided by 2,290,286 2,803,333 680,000 2,720,000 3,400,000 5,690,286 6,203,333 cost provided by facility container can carry 24 tonnes. Facility indicated that facility cost of treating oil at concentrations > 100,000 ppm is 450 Euro/tonne. VAT is not included in pricing. Dottikon, Dottikon, Switzerland Shipping pricing provided by facility. Ground transportation costs provided by Panalpina. Assumed included in Assumed included in Assumption was that 20 ft container can carry 8 tonnes, Transformer (oil) 25,500 3,188 1,594 637,500 318,750 17,053,125 13,451,250 cost provided by 17,690,625 13,770,000 14,573,250 14,573,250 29,146,500 46,837,125 42,916,500 cost provided by facility and 40 ft container can carry 16 tonnes. Pricing does facility not include return of containers. Assumed same price for treating waste of > 500 ppm and < 500 ppm. Transformer (Cellulosic 6,000 Will be treated by Holcim Vietnam Mateiral) Transformer (Metal) 43,500 Will be treated in Vietnam by sodium reduction Shipping pricing provided by facility. Ground transportation costs provided by Panalpina. Assumed included in Assumed included in Assumption was that 20 ft container can carry 8 tonnes, Capacitors (Oil) 2,008 251 125 50,188 25,094 1,342,516 1,058,956 cost provided by 1,392,703 1,084,050 1,147,286 1,147,286 2,294,573 3,687,276 3,378,623 cost provided by facility and 40 ft container can carry 16 tonnes. Pricing does facility not include return of containers. Assumed same price for treating waste of > 500 ppm and < 500 ppm. Capacitors (Cellulosic 2,448 Will be treated by Holcim Vietnam Material) Capacitors (Metal) 1,045 Will be treated in Vietnam by sodium reduction Shipping pricing provided by facility. Ground transportation costs provided by Panalpina. Assumed included in Assumed included in Assumption was that 20 ft container can carry 8 tonnes, Oil 10,000 1,250 625.00 250,000 125,000 6,687,500 5,275,000 cost provided by 6,937,500 5,400,000 5,715,000 5,715,000 11,430,000 18,367,500 16,830,000 cost provided by facility and 40 ft container can carry 16 tonnes. Pricing does facility not include return of containers. Assumed same price for treating waste of > 500 ppm and < 500 ppm. 5 Overseas Oil Treat Page 4 of 4 Case Study: Oil (tonnes): 10,000 Transformers (tonnes): 75,000 Capacitors (tonnes): 5,500 Assumptions: Transformers and capacitors will be drained prior to shippment. Only contaminated oil will be shipped. Metal components will be recovered and cellulosic material will be disposed of in Vietnam Unless otherwise specified by the facility, it will be assumed that a 20ft container can carry 17.5 tonnes of material and a 40ft container can carry 24 tonnes of material 50% of total weight is less than 500 ppm and 50% of total weight is greater than 500 ppm Transformers contain 34% oil by weight, 58% metals by weight and 8 % cellulosic material by weight. Capacitors contain 36.5% oil by weight, 19% metals by weight and 44.5% cellulosic material by weight. Ground Total Cost of Total Cost of Ground Dangerous Goods Total Total transportation Shipping Costs Dangerous Goods Transport (20 Transport (40 Waste transportation Shipping Costs Fee (if not included in Transportation Transportation Cost of Treatment (USD) Total Cost of Est. Number of Est. Number of costs in Vietnam (20 foot Fee (if not included foot foot Facility/Waste Type Quantity/ costs in Vietnam (40 foot shipping cost)/ 40 Cost (assuming 20 Cost (assuming 40 Treatment Exclusions/Comments 20ft containers 40ft containers to port (20ft container) in shipping cost)/ 20 containers) containers) tonnes to port (40ft container) (USD) foot container foot containers) foot containers) (USD) containers) (USD) foot container (USD) and Treatment and Treatment containers) (USD) (USD) (USD) (USD) (USD) (USD) (USD) < 500 ppm > 500 ppm Valorec, Basel, Switzerland Shipping pricing provided by facility. Ground transportation costs provided by Panalpina. Assumed included in Assumption was that 20 ft container can carry 10 Assumed included in Transformer (oil) 25,500 2,550 1,275 510,000 255,000 11,217,450 9,259,688 cost provided by 11,727,450 9,514,688 5,714,550 12,064,050 17,778,600 29,506,050 27,293,288 tonnes, and 40 ft container can carry 20 tonnes. Facility cost provided by facility facility indicated that cost of treating oil at concentrations > 500 ppm is 1140 CHF/tonne and < 500 is 540 CHF/tonne. Notification costs and VAT are not included in pricing. Transformer (Cellulosic 6,000 Will be treated by Holcim Vietnam Mateiral) Transformer (Metal) 43,500 Will be treated in Vietnam by sodium reduction Assumed included in Assumed included in Capacitors (Oil) 2,008 201 100 40,150 20,075 883,099 728,973 cost provided by 923,249 749,048 449,881 949,748 1,399,629 2,322,878 2,148,677 cost provided by facility facility Capacitors (Cellulosic 2,448 Will be treated by Holcim Vietnam Material) Capacitors (Metal) 1,045 Will be treated in Vietnam by sodium reduction Shipping pricing provided by facility. Ground transportation costs provided by Panalpina. Assumed included in Assumption was that 20 ft container can carry 10 Assumed included in Oil 10,000 1,000 500.00 200,000 100,000 4,399,000 3,631,250 cost provided by 4,599,000 3,731,250 2,241,000 4,731,000 6,972,000 11,571,000 10,703,250 tonnes, and 40 ft container can carry 20 tonnes. Facility cost provided by facility facility indicated that cost of treating oil at concentrations > 500 ppm is 1140 CHF/tonne and < 500 is 540 CHF/tonne. Notification costs and VAT are not included in pricing. 6 Salt Mine Carcas Disposal Total Transportation Total Total Cost of Total Cost of Cost (assuming 20 Transportation Cost Cost of Disposal Transport (20 foot Transport (40 foot Waste Type Weight/tonne Exclusions/Comments foot containers) (assuming 40 foot (USD) containers) and containers) and (USD) containers) (USD) Treatment (USD) Treatment (USD) Shipping costs assumed to be Transformer carcasses 43,500 10,651,286 13,575,625 15,399,000 26,050,286 28,974,625 the same as to Biebesheim. Shipping costs assumed to be Capacitor carcasses 1,045 255,876 326,127 369,930 625,806 696,057 the same as to Biebesheim. 7 Local Treatment-Holcim Ground Ground Cost of Treatment Total Cost of Total Cost of Waste Est. Number Est. Number transportation costs transportation costs Total Transportation Total Transportation Total Cost of Transport (20 foot Transport (40 Facility/Waste Type Quantity/ of 20ft of 40ft in Vietnam to port in Vietnam to port Cost (assuming 20 foot Cost (assuming 40 Exclusions/ Comments Treatment containers) and foot containers) tonnes containers containers (20ft containers) (40ft containers) containers) foot containers) Treatment and Treatment (USD) (USD) < 500 ppm > 500 ppm Holcim Ground transportation costs provided in Oils from Panalpina. Assumed price of treating 25,500 1,457 1,063 291,429 212,500 291,429 212,500 8,287,500 10,200,000 18,487,500 18,778,929 18,700,000 Transformers transformer oils with < 500 ppm is $650 USD/tonne and $800 USD/tonne for > 500 ppm Ground transportation costs provided in Cellulosic Material Panalpina. Assumed price of treating 6,000 343 250 68,571 50,000 68,571 50,000 1,950,000 2,400,000 4,350,000 4,418,571 4,400,000 from Transformers transformer material with < 500 ppm is $650 USD/tonne and $800 USD/tonne for > 500 ppm Ground transportation costs provided in Panalpina. Assumed price of treating capacitor Oils from Capacitors 2,008 115 84 22,943 16,729 22,943 16,729 652,438 803,000 1,455,438 1,478,380 1,472,167 oils with < 500 ppm is $650 USD/tonne and $800 USD/tonne for > 500 ppm Ground transportation costs provided in Cellulosic Material Panalpina. Assumed price of treating capacitor 2,448 140 102 27,971 20,396 27,971 20,396 795,438 979,000 1,774,438 1,802,409 1,794,833 from Capacitors material with < 500 ppm is $650 USD/tonne and $800 USD/tonne for > 500 ppm Ground transportation costs provided in Panalpina. Assumed price of treating Oil 10,000 571 417 114,286 83,333 114,286 83,333 3,250,000 4,000,000 7,250,000 7,364,286 7,333,333 transformer oils with < 500 ppm is $650 USD/tonne and $800 USD/tonne for > 500 ppm Case Study: Oil (tonnes): 10,000 8 Relocatable Local Treat-all Page 1 of 2 Transformers (tonnes): 75,000 Capacitors (tonnes): 5,500 Assumptions: Transformers will be drained prior to shippment. Only contaminated oil will be shipped. Metal components will be recovered and cellulosic material will be disposed of in Vietna Unless otherwise specified by the facility, it will be assumed that a 20ft container can carry 17.5 tonnes of material and a 40ft container can carry 24 tonnes of material 50% of total weight is less than 500 ppm and 50% of total weight is greater than 500 ppm Cost of Treatment Waste Facility/Waste Operating Total Cost of Quantity/ Set-Up Cost Exclusions/ Comments Type Cost Treatment tonnes < 500 ppm > 500 ppm ESI Group, Australia provided in Assumed price of treating transformer with < 500 ppm is $300 USD/tonne Transformers 75,000 treatment not provided. 11,250,000 18,750,000 30,000,000 and $500 USD/tonne for > 500 ppm. Set up and demobilization prices estimate. included in cost of treatment. provided in Assumed price of treating capacotpr with < 500 ppm is $1350 USD/tonne Capacitors 5,500 treatment not provided. 3,712,500 5,500,000 9,212,500 and $2000 USD/tonne for > 500 ppm. Set up and demobilization prices estimate. included in cost of treatment. provided in Disposal cost per litre for <500 ppm assumed to be $0.25/L and for >500 Oil 10,000 treatment not provided. 694,444 1,388,889 2,083,333 ppm assumed to be $0.50/L. Set up and demobilization prices included in estimate. cost of treatment. Tredi Seche, France Assumed same price for treating waste of > 500 ppm and < 500 ppm; Transformers 75,000 not provided. not provided. 95,625,000 95,625,000 191,250,000 assumed same price for treating waste in Vietnam as in France. Assumed same price for treating waste of > 500 ppm and < 500 ppm; Capacitors 5,500 not provided. not provided. 7,562,500 7,562,500 15,125,000 assumed same price for treating waste in Vietnam as in France. Assumed same price for treating waste of > 500 ppm and < 500 ppm; Oil 10,000 not provided. not provided. 11,250,000 11,250,000 22,500,000 assumed same price for treating waste in Vietnam as in France. Dolomatrix International, Australia Assumed price for treating transformers of > 500 ppm is $3004.16 Transformers 75,000 not provided. not provided. 88,515,375 112,656,000 201,171,375 USD/tonne and < 500 ppm, $2360.41 USD/tonne Assumed price for treating capacitors is the same at any concentration, Capacitors 5,500 not provided. not provided. 23,604,130 23,604,130 47,208,260 i.e. $8583.32 USD/tonne. Assumed price for treating waste of > 500 ppm is $1.63 USD/L and < 500 Oil 10,000 not provided. not provided. 4,527,778 5,250,000 9,777,778 ppm, $1.89 USD/L. Hallet, Canada Assuming the plant is owned and operated by the Govt. of Vietnam (assuming $1M royalties and 10% processing fee): 4,000,000 Price of treating transformers of concentration < 500 ppm is the same as included in Transformers 75,000 (accounts for 53,250,000 53,250,000 106,500,000 concentration > 500 ppm. Cost includes labour, utilities, maintenance, treatment cost. two locations and capital depreciation at $1M each, Price of treating capacitors of concentration < 500 ppm is the same as included in Capacitors 5,500 plus site 3,905,000 3,905,000 7,810,000 concentration > 500 ppm. Cost includes labour, utilities, maintenance, treatment cost. preparation and capital depreciation and supply of Price of treating oil of concentration < 500 ppm is the same as included in Oil 10,000 utilities 14,500,000 14,500,000 29,000,000 concentration > 500 ppm. Cost includes labour, utilities, maintenance, treatment cost. equipment, and capital depreciation Case Study: Oil (tonnes): 10,000 8 Relocatable Local Treat-all Page 2 of 2 Transformers (tonnes): 75,000 Capacitors (tonnes): 5,500 Assumptions: Transformers will be drained prior to shippment. Only contaminated oil will be shipped. Metal components will be recovered and cellulosic material will be disposed of in Vietna Unless otherwise specified by the facility, it will be assumed that a 20ft container can carry 17.5 tonnes of material and a 40ft container can carry 24 tonnes of material 50% of total weight is less than 500 ppm and 50% of total weight is greater than 500 ppm Cost of Treatment Waste Facility/Waste Operating Total Cost of Quantity/ Set-Up Cost Exclusions/ Comments Type Cost Treatment tonnes < 500 ppm > 500 ppm Assuming the plant is owned and operated by Hallet (20% fee): 4,000,000 Price of treating transformers of concentration < 500 ppm is the same as included in Transformers 75,000 (accounts for 58,500,000 58,500,000 117,000,000 concentration > 500 ppm. Cost includes labour, utilities, maintenance, treatment cost. two locations and capital depreciation. at $1M each, Price of treating capacitors of concentration < 500 ppm is the same as included in Capacitors 5,500 plus site 4,290,000 4,290,000 8,580,000 concentration > 500 ppm. Cost includes labour, utilities, maintenance, treatment cost. preparation and capital depreciation. and supply of Price of treating oil of concentration < 500 ppm is the same as included in Oil 10,000 utilities 16,000,000 16,000,000 32,000,000 concentration > 500 ppm. Cost includes labour, utilities, maintenance, treatment cost. equipment, and capital depreciation. Kinectrics, Canada Assumed price for treating transformers of > 500 ppm is $1500 Transformers 75,000 not provided. not provided. 37,500,000 56,250,000 93,750,000 USD/tonne and < 500 ppm, $1000 USD/tonne Assumed price for treating capacitors of > 500 ppm is $1500 USD/tonne Capacitors 5,500 not provided. not provided. 2,750,000 4,125,000 6,875,000 and < 500 ppm, $1000 USD/tonne Disposal cost per litre for <500 ppm assumed to be $0.90/L and for >500 Oil 10,000 not provided. not provided. 2,500,000 9,722,222 12,222,222 ppm assumed to be $3.50/L. 9 Relocatable Local Treat-Carc Waste Cost of Treatment Facility/Waste Operating Total Cost of Quantity/ Set-Up Cost Exclusions/ Comments Type Cost Treatment tonnes < 500 ppm > 500 ppm ESI Group, Australia Assumed price of treating drained transformer is $300 Transformer provided in treatment 43,500 not provided. 6,525,000 6,525,000 13,050,000 USD/tonne. Set up and Carcasses estimate. demobilization prices included in cost of treatment. Assumed price of treating drained capacitor is $1350 Capacitor provided in treatment 1,045 not provided. 705,375 705,375 1,410,750 USD/tonne. Set up and Carcasses estimate. demobilization prices included in cost of treatment. Hallet, Canada Assuming the plant is owned and operated by the Govt. of Vietnam (assuming $1M royalties and 10% processing fee): Price of treating drained metal parts is $460/tonne. Cost Transformer included in 43,500 4,000,000 (accounts for 10,005,000 10,005,000 20,010,000 includes labour, utilities, Carcasses treatment cost. two locations at $1M maintenance, and capital each, plus site depreciation. preparation and supply of Price of treating drained metal utilities equipment, also parts is $460/tonne. Cost Capacitor included in 1,045 $1M each location. 240,350 240,350 480,700 includes labour, utilities, Carcasses treatment cost. maintenance, and capital depreciation. Assuming the plant is owned and operated by Hallet (20% fee): Price of treating drained metal parts is $500/tonne. Cost Transformer included in 43,500 4,000,000 (accounts for 10,875,000 10,875,000 21,750,000 includes labour, utilities, Carcasses treatment cost. two locations at $1M maintenance, and capital each, plus site depreciation. preparation and supply of Price of treating drained metal utilities equipment, also parts is $500/tonne. Cost Capacitor included in 1,045 $1M each location. 261,250 261,250 522,500 includes labour, utilities, Carcasses treatment cost. maintenance, and capital depreciation. 10 Scrap Metal Pricing Total 40 10 50 Steel Price/tonne Copper price/tonne Aluminum price/tonne (tonnes) % Steel % Copper % Aluminum $150 $180 $1200 $1800 $1200 $1800 Transformer Carcasses 43500 17400 4350 21750 $2,610,000 $3,132,000 $5,220,000 $7,830,000 $26,100,000 $39,150,000 Capacitor Carcasses 1045 418 104.5 522.5 $62,700 $75,240 $125,400 $188,100 $627,000 $940,500 11 Backup Total Weight Oil Weight % Weight of Oil 7200 1600 22.2 8400 1900 22.6 10800 3100 28.7 9800 2300 23.5 12200 3300 27.0 17500 6300 36.0 11700 2500 21.4 13600 3700 27.2 18900 6600 34.9 14000 3300 23.6 15900 4200 26.4 21500 7300 34.0 16600 3900 23.5 18200 4700 25.8 25000 8600 34.4 Average: % 27.4 12 Shipping Dangerous Total Other shipping Total Shipping Goods Fee Comments Cost/tonne quotes Cost/tonne Australia (Mitchell) Maximum mass for a 20' container is 21600 kg. Can carry 40 drums (assume 200 kg/drum) = 20 ft container 4107 385 8000 kg = 8 tonnes 561.50 Maximum mass for a 40' container is 26500 kg. Can carry 80 drums (assume 200 kg/drum) = 40 ft container 6024 770 16000 kg = 16 tonnes 424.63 France (Lagnieu) 20 ft container 3272 385 457.13 40 ft container 6143 770 432.06 Finland (Riihimaki) 20 ft container 3505 385 486.25 40 ft container 5978 770 421.75 Germany (Biebesheim) 20 ft container 3700 385 510.63 40 ft container 6520 770 455.63 Germany (Brunsbuttel) 20 ft container 3355 385 467.50 3780 40 ft container 5828 770 412.38 6480 Switzerland (Dottikon) 20 ft container 5015 385 675.00 5350 40 ft container 7823 770 537.06 8440 Switzerland (Basel) 20 ft container 4740 385 640.63 40 ft container 7763 770 533.31 SOCIALIST REPUBLIC OF VIETNAM Revision Analysis of PCB Treatment and Disposal No. Date Page Options 333051-0000-4EER-0001 02 2008-07-29 Appendix Appendix H PCB Destruction Technologies in Vietnam Soil Contamination Directions for Use I:\333051\40 - Eng Mgmt\4E - Env\ER - Env-Eng Reports\Format Report\333051-0000-4EER-0001 Ver01 PCB FinalDraft Report - Additional Sections-No 2.doc 1 Directions of Use PCB Destruction Technologies in Vietnam: Soil Contamination Directions for Use This is a working cost estimate spreasheet. Only the summaries (work sheet nos. 2 & 3) are meant for use as hard copies. The remaining spreadsheets are used in the calculation of the cost estimates and show how these figures were developed. Applicable assumptions are also shown on the various work sheets. Assumptions for Cost Comparison Scenario: Soil Treatment For a basis of comparison, it has been assume that 10,000 tonnes of soil require treatment and this soil has PCB concentrations between 50 ppm and 500 ppm. It is rare that soil is contaminated extensively in concentrations greater than 500 ppm, although individual samples may be contaminated at such levels. Below 50 ppm, the soil is not considered hazardous in many jurisdictions. Even when remediation is considered between 5 ppm and 50 ppm, alternative more inexpesive methods are usually considered such as isolation in containment cells (such as project specfic landfills). This spreadsheet comprises 9 worksheets, all linked. They are as follows: No. Name Description The intent of this spreadsheet is to describe how to use the 1 Directions for Use information provided most effectively. This provides the best price for each scenario and leads to a 2 Best simplified comparison. It has been formatted for print-out. This worksheet summarizes the costs of all disposal vendors 3 Summary organized by scenario. It has been formatted for print-out. This is the working spreadsheet for calculating the costs for 4 Full Overseas Treat disposal at overseas fixed facilities. It is not formatted for print-out. This is the working spreadsheet for calculating the costs for 5 Salt Mine Disposal disposal of soil in a commercial disposal faclity in Germany (salt mine long term storage). It is not formatted for print-out. This is the working spreadsheet for calculating the costs for Local Treatment- 6 disposal of soil at the Holcim cement kiln in Vietnam. It is not Holcim formatted for print-out. This is the working spreadsheet for calculating the costs for Relocatable Local 7 relocating mobile facilities to Vietnam for treatment of soil at a Treat-all number of centralized areas. It is not formatted for print-out. Cost estimate for technololgies that are in-situ or on-site without In Situ or On-Site considering site characteristics. More accurate estimates should 8 Treatment be conducted on individual sites that take these details into account. Background calculations for the shipping cost estimate. It is not 9 Shipping formatted for print-out. 2 Best Comparison of the Optimal Vendors against Different Project Strategies Vietnam PCB Technlology Review Project Lowest Viable Price Vendor Offering Scenario No. Description (Total Cost rounded to Methods of Disposal Best Alternative 100 thousands of USD) 1 Soil shipped to an overseas facility for disposal $6,528,571 HIM (Germany) Incineration 2 Soil shipped to German salt mine for disposal $5,988,571 K+S (Germany) Storage Cement kiln co- 3 Soil treated by Holcim Vietnam $5,614,286 Holcim (Vietnam) processing Soil treated in Vietnam, by relocatable treatment ESI Group 4 $7,114,286 Sodium dechlorination systems provided and operated by overseas vendors. (Australia) Soil treated in situ (in place) by purchasing a Geomelt AMEC Geomelt 5a system. $11,500,000 (USA, Australia) In Situ vitrifcation Soil treated ex situ (post excavation) anaerobic and Many vendors Aerobic/anaerobic 5b aerobic composting. possible. bioremediation $320,000 Note: For Scenario 5, two separate technologies recommended for two different situations: 5a: High PCB concentrations in the soil and quick completion timelines required. 5b: Low PCB concentration in the soil and not time constraints on completion. For contaminated sites, physical and contaminant characteristics among other factors are too importation for general recommendations. 3 Summary Page 1 of 2 Scenario 1 - All soil shipped to overseas disposal facilities Total Cost of Total Shipping Total Cost of Total Shipping Total Disposal Total Waste Costs (USD)/40 Disposal (USD) Facility Costs (USD)/20 Treatment (USD) (using Assumptions Quantity (tonnes) foot (using 40 foot foot containers Costs (USD) 20 foot containers containers) containers) ESI Group, Australia 10,000 1,850,000 17,000,000 18,850,000 Facility provided pricing for a 20 foot container carrying 20 tonnes. Ground transportation costs provided in Panalpina. Assumed price of treating soil of concentration up to 500 ppm is 1700 UDS/tonnne Ekokem, Finland 10,000 2,337,143 2,895,000 13,600,000 15,937,143 16,495,000 Shipping costs provided by Palalpina. Assumptions: a 20 ft container can carry 17.5 tonnes, and a 40 ft container can carry 24 tonnes. Assumed price for treating soil up to concentration 500 ppm is 1360 USD/tonne HIM, Germany 10,000 2,448,571 3,120,833 4,080,000 6,528,571 7,200,833 Shipping costs provided by Palalpina. Assumptions: a 20 ft container can carry 17.5 tonnes, and a 40 ft container can carry 24 tonnes. Assumed price for incinerating soil up to concentration 500 ppm is 408 USD/tonne SAVA, Germany 10,000 2,290,286 2,803,333 6,800,000 9,090,286 9,603,333 Facility provided shipping costs. Cost of ground transportation provided by Panalpina. Assumptions: a 20 ft container can carry 17.5 tonnes, and a 40 ft container can carry 24 tonnes. Assumed price for treating soil up to concentration 500 ppm is 680 USD/tonne Dottikon, Switzerland 10,000 6,937,500 5,400,000 16,510,000 23,447,500 21,910,000 Shipping pricing provided by facility. Ground transportation costs provided by Panalpina. Assumption was that 20 ft container can carry 8 tonnes, and 40 ft container can carry 16 tonnes. Pricing does not include return of containers. Assumed price for treating soil up to concentration 500 ppm is 1651 USD/tonne Valorec, Switzerland 10,000 4,599,000 3,731,250 4,980,000 9,579,000 8,711,250 Shipping pricing provided by facility. Ground transportation costs provided by Panalpina. Assumption was that 20 ft container can carry 10 tonnes, and 40 ft container can carry 20 tonnes. Assumed price for treating soil up to concentration 500 ppm is 498 USD/tonne. Notification costs and VAT are not included in pricing. Scenario 2 - All soil shipped to German salt mine Total Cost of Total Shipping Total Cost of Total Shipping Total Disposal Total Waste Costs (USD)/40 Disposal (USD) Facility Costs (USD)/20 Treatment (USD) (using Assumptions Quantity (tonnes) foot (using 40 foot foot containers Costs (USD) 20 foot containers containers) containers) K+S, Germany 10,000 2,448,571 3,120,833 3,540,000 5,988,571 6,660,833 Shipping costs assumed to be the same as to Biebesheim. Scenario 3: All soil treated at Holcim Vietnam Total Cost of Total Shipping Total Cost of Total Shipping Total Disposal Total Waste Costs (USD)/40 Disposal (USD) Facility Costs (USD)/20 Treatment (USD) (using Assumptions Quantity (tonnes) foot (using 40 foot foot containers Costs (USD) 20 foot containers containers) containers) Holcim, Vietnam 10,000 114,286 83,333 5,500,000 5,614,286 5,583,333 Ground transportation costs provided in Panalpina. Assumed price of treating soil up to concentration 500 ppm is 800 USD/tonne 3 Summary Page 2 of 2 Scenario 4: All soil treated by relocatable facilities provided by overseas suppliers Total Cost of Transportation Total Total Waste Set Up Cost Operating Cost Treatment Plus Facility/Waste Type Costs (20 foot Treatment Assumptions Quantity (tonnes) (USD) (USD) Transportation container) Costs (USD) (USD) ESI Group, Australia 10,000 114,286 provided in not provided. 7,000,000 7,114,286 Assumed price of treating soil up to treatment concentration 500 ppm is $700 USD/tonne. Set estimate. up and demobilization prices included in cost of treatment. Total cost of transportation plus treatment does not include operating costs. Dolomatrix, Australia 10,000 114,286 not provided. not provided. 19,312,450 19,426,736 Assumed price of treating soil up to concentration 500 ppm is $3862.49 USD/tonne. Total cost of transportation plus treatment does not include set up costs or operating costs. Hallet, Canada, 10,000 114,286 4,000,000 included in 4,600,000 8,714,286 Assumed price of treating soil up to assuming plant will be (accounts for treatment cost. concentration 500 ppm is $460 USD/tonne. Cost operated by two locations at includes labour, utilities, maintenance, and Government of Vietnam $1M each, plus capital depreciation. Total cost of transportation site preparation plus treatment does not include set up costs, and supply of royalties or fees. utilities equipment, also $1M each location. Hallet, Canada, 10,000 114,286 4,000,000 included in 5,000,000 9,114,286 Assumed price of treating soil up to assuming plant will be (accounts for treatment cost. concentration 500 ppm is $500 USD/tonne. Cost operated by Hallet two locations at includes labour, utilities, maintenance, and $1M each, plus capital depreciation. Total cost of transportation site preparation plus treatment does not include set up costs or and supply of fees. utilities equipment, also $1M each location. Scenario 5: All soil treated by In Situ or On-site treatment methods Total Total Cost of Total Waste Transportation Set Up Cost Unit Cost Treatment Type Treatment Treatment Plus Assumptions Quantity (tonnes) Costs: None (USD) (USD/tonne) Costs (USD) n (USD) In Situ Vitrification 10,000 0 4,000,000 750 7,500,000 11,500,000 No restrictions on PCB concentration or time of (AMEC Geomelt) remediation. Anaerobic/Aerobic 10,000 0 n/a 32 320,000 320,000 Low concentrations of PCBs and no restrictions Composting on time of treatment (months to years. In Situ Enhanced 10,000 0 n/a 32 320,000 320,000 Low concentrations of PCBs and no restrictions Bioremediation on time of treatment (months to years. Thermally enhanced 10,000 0 n/a 59 590,000 590,000 Low concentrations of PCBs and no restrictions Soil Vapour Extraction on time of treatment (months to years. (SVE) 4 Full Overseas Treat Case Study: Soil: 10,000 Assumptions: Soil contains PCB concentrations greater than 50 ppm and less than 500 ppm. Unless otherwise specified by the facility, it will be assumed that a 20ft container can carry 17.5 tonnes of material and a 40ft container can carry 24 tonnes of material 498 Cost of Treatment Ground Ground Dangerous Dangerous Total transportation Total Cost of Total Cost of Est. Number Est. Number transportation Shipping Costs Shipping Costs Goods Fee (if Goods Fee (if Transportation Total Transportation Soil Quantity/ costs in Vietnam Total Cost of Transport (20 foot Transport (40 foot Facility/Waste Type of 20ft of 40ft costs in Vietnam (20 foot (40 foot not included in not included in Cost (assuming Cost (assuming 40 Exclusions/ Comments tonnes to port (40ft Treatment containers) and containers) and containers containers to port (20ft container) container) shipping cost)/ shipping cost)/ 20 foot foot containers) containers) Treatment Treatment containers) (USD) 20 foot container 40 foot container containers) 50 ppm < Soil < 500 (USD) ppm ESI Group, Mitchell Group, Australia Facility provided pricing for a 20 foot assumed assumed container carrying 20 tonnes. Ground included in cost included in cost transportation costs provided in Soil 10,000 500 100,000 - 1,750,000 - 1,850,000 - 17,000,000 17,000,000 18,850,000 - provided by provided by Panalpina. Assumed price of treating facility facility soil of concentration up to 500 ppm is 1700 UDS/tonnne Ekokem, Riihimaki, Finland Shipping costs provided by Palalpina. Assumptions: a 20 ft container can carry 17.5 tonnes, and a 40 ft container Soil 10,000 571 417 114,286 83,333 2,002,857 2,490,833 220,000 320,833 2,337,143 2,895,000 13,600,000 13,600,000 15,937,143 16,495,000 can carry 24 tonnes. Assumed price for treating soil up to concentration 500 ppm is 1360 USD/tonne HIM, Biebesheim, Germany Shipping costs provided by Palalpina. Assumptions: a 20 ft container can carry 17.5 tonnes, and a 40 ft container Soil 10,000 571 417 114,286 83,333 2,114,286 2,716,667 220,000 320,833 2,448,571 3,120,833 4,080,000 4,080,000 6,528,571 7,200,833 can carry 24 tonnes. Assumed price for incinerating soil up to concentration 500 ppm is 408 USD/tonne SAVA, Brunsbuttel, Germany Facility provided shipping costs. Cost of ground transportation provided by Assumed Assumed Panalpina. Assumptions: a 20 ft included in cost included in cost container can carry 17.5 tonnes, and a Soil 10,000 571 417 114,286 83,333 2,176,000 2,720,000 2,290,286 2,803,333 6,800,000 6,800,000 9,090,286 9,603,333 provided by provided by 40 ft container can carry 24 tonnes. facility facility Assumed price for treating soil up to concentration 500 ppm is 680 USD/tonne Dottikon, Dottikon, Switzerland Shipping pricing provided by facility. Ground transportation costs provided by Panalpina. Assumption was that 20 Assumed Assumed ft container can carry 8 tonnes, and 40 included in cost included in cost Soil 10,000 1,250 625 250,000 125,000 6,687,500 5,275,000 6,937,500 5,400,000 16,510,000 16,510,000 23,447,500 21,910,000 ft container can carry 16 tonnes. provided by provided by Pricing does not include return of facility facility containers. Assumed price for treating soil up to concentration 500 ppm is 1651 USD/tonne Valorec, Basel, Switzerland Shipping pricing provided by facility. Ground transportation costs provided by Panalpina. Assumption was that 20 Assumed Assumed ft container can carry 10 tonnes, and 40 included in cost included in cost Soil 10,000 1,000 500 200,000 100,000 4,399,000 3,631,250 4,599,000 3,731,250 4,980,000 4,980,000 9,579,000 8,711,250 ft container can carry 20 tonnes. provided by provided by Assumed price for treating soil up to facility facility concentration 500 ppm is 498 USD/tonne. Notification costs and VAT are not included in pricing. 5 Salt Mine Disposal Total Total Total Cost of Total Cost of Transportation Cost of Transportation Cost Transport (20 foot Transport (40 foot Waste Type Weight/tonne Cost (assuming 40 Disposal Exclusions/Comments (assuming 20 foot containers) and containers) and foot containers) (USD) containers) (USD) Treatment (USD) Treatment (USD) (USD) Shipping costs assumed to be Soil 10,000 2,448,571 3,120,833 3,540,000 5,988,571 6,660,833 the same as to Biebesheim. 6 Local Treatment-Holcim Cost of Treatment Total Cost of Total Cost of Est. Number Est. Number Total Transportation Total Transportation Total Cost Soil Quantity/ Transport (20 Transport (40 Facility/Waste Type of 20ft of 40ft Cost (assuming 20 Cost (assuming 40 of Exclusions/ Comments tonnes foot containers) foot containers) containers containers foot containers) foot containers) 50 ppm < Soil < 500 Treatment and Treatment and Treatment ppm Holcim Ground transportation costs provided in Panalpina. Assumed price of treating soil Soil 10,000 571 417 114,286 83,333 5,500,000 5,500,000 5,614,286 5,583,333 up to concentration 500 ppm is 800 USD/tonne Cost of treatment estimated by Paul Hayes of Holcim in e-mail communication of August 6, 2007. Costs provided ranged between $380 to $550 USD per ton. For this cost estimate, high point selected ($550 USD per ton). 7 Relocatable Local Treat-all Case Study: Soil (tonnes) 10,000 Assumptions: Soil is of concentration greater than 50 ppm and less than 500 ppm. Unless otherwise specified by the facility, it will be assumed that a 20ft container can carry 17.5 tonnes of material and a 40ft container can carry 24 tonnes of material Cost of Transportation Total Cost of Facility/Waste Soil Quantity/ Operating Costs (20 foot Set-Up Cost Transportation Exclusions/ Comments Type tonnes Cost container) plus Treatment 50 ppm < Soil < 500 ppm ESI Group, Australia Assumed price of treating soil up to concentration 500 ppm is $700 USD/tonne. Set up and provided in treatment Soil 10,000 114,286 not provided. 7,000,000 7,114,286 demobilization prices included in cost of treatment. estimate. Total cost of transportation plus treatment does not include operating costs. Dolomatrix International, Australia Assumed price of treating soil up to concentration 500 ppm is $3862.49 USD/tonne. Total cost of Soil 10,000 114,286 not provided. not provided. 19,312,450 19,426,736 transportation plus treatment does not include set up costs or operating costs. Hallet, Canada Assuming the plant is owned and operated by the Govt. of Vietnam (assuming $1M royalties and 10% processing fee): 4,000,000 (accounts for two Assumed price of treating soil up to concentration locations at $1M each, plus 500 ppm is $460 USD/tonne. Cost includes labour, included in Soil 10,000 114,286 site preparation and supply 4,600,000 4,714,286 utilities, maintenance, and capital depreciation. treatment cost. of utilities equipment, also Total cost of transportation plus treatment does $1M each location. not include set up costs, royalties or fees. Assuming the plant is owned and operated by Hallet (20% fee): 4,000,000 (accounts for two Assumed price of treating soil up to concentration locations at $1M each, plus 500 ppm is $500 USD/tonne. Cost includes labour, included in Soil 10,000 114,286 site preparation and supply 5,000,000 5,114,286 utilities, maintenance, and capital depreciation. treatment cost. of utilities equipment, also Total cost of transportation plus treatment does $1M each location. not include set up costs or fees. 8 In Situ or On-Site Treatment Cost of Treatment Soil Quantity/ Unit Cost of Total Cost of Technology Type Capital Cost Exclusions/ Comments tonnes Treatment Note Treatment 50 ppm < Soil < 500 ppm In Situ Vitrification In situ technology, no transport 10,000 4,000,000 750 1 7,500,000 11,500,000 (AMEC Geomelt) required. On site technology needing only conventional construction equipment. Anaerobic/Aerobic 10,000 n/a 32 2 320,000 320,000 Treatment limited to low concentration Composting PCBs and treatment times are in months to years. In Situ technology limited to low In Situ Enhanced 10,000 n/a 32 3 320,000 320,000 concentration PCBs and treatment Bioremediation times are in months to years. In Situ technology limited to low Thermally enhanced concentration PCBs and treatment Soil Vapour Extraction 10,000 n/a 59 4 590,000 590,000 times are in months to years, although (SVE) better than systems without thermal enhancement (above). Notes General All technologies on this spreadsheet are either in situ or on-site treatment technologies and do not require transport. 1. Costs provided ranged between $300 to $750 USD per ton. For this cost estimate, high point selected ($750 USD per ton). 2. $30 to $70 per cubic metre. For this estimate, the high point was selected. 3. $30 to $70 per cubic metre. For this estimate, the high point was selected. 4. $30 to $130 per cubic metre. For this estimate, the high point was selected. 9 Shipping Dangerous Total Other shipping Total Shipping Goods Fee Comments Cost/tonne quotes Cost/tonne Australia (Mitchell) Maximum mass for a 20' container is 21600 kg. 20 ft container 4107 385 Can carry 40 drums 561.50 (assume 200 kg/drum) = 8000 kg = 8 tonnes Maximum mass for a 40' container is 26500 kg. 40 ft container 6024 770 Can carry 80 drums 424.63 (assume 200 kg/drum) = 16000 kg = 16 tonnes France (Lagnieu) 20 ft container 3272 385 457.13 40 ft container 6143 770 432.06 Finland (Riihimaki) 20 ft container 3505 385 486.25 40 ft container 5978 770 421.75 Germany (Biebesheim) 20 ft container 3700 385 510.63 40 ft container 6520 770 455.63 Germany (Brunsbuttel) 20 ft container 3355 385 467.50 3780 40 ft container 5828 770 412.38 6480 Switzerland (Dottikon) 20 ft container 5015 385 675.00 5350 40 ft container 7823 770 537.06 8440 Switzerland (Basel) 20 ft container 4740 385 640.63 40 ft container 7763 770 533.31