HCB in Botany
We need your Help to Stop the Export of Australia's stockpile of hexachlorobenzene (HCB) waste to Europe for incineration!
Orica Australia Pty Ltd (formerly ICI Australia) is proposing to export 11,000 tonnes of highly toxic hexachlorobenzene waste to Europe for incineration. Help us stop this unnecessary export and ensure that the stockpile is destroyed by non incineration methods in Australia.
In 1996 the Australian National Advisory Body (NAB) on Scheduled Waste released the national Management Plan for Hexachlorobenzene (HCB) to oversee the destruction of the HCB waste stockpile. The plan recommended that the waste should be destroyed as "close to the source as possible" in the light of the significant risk in transporting such a large stockpile of persistent organic pollutant (POPs) waste and Australia's proven ability to destroy hazardous waste in an environmentally sound manner.
After many years of failing to address its hazardous waste responsibilities, the company rejected the well tried, community supported technology, ECOLOGIC Gas Phase Chemical Reduction (GPCR) Process. Its choice instead of an untried, semi incineration vitrification process led to local community concern and the rejection of its Environmental Impact Statement. The company has now been directed by the NSW Commission of Inquiry to find an alternative site in the state of New South Wales.
Orica's current proposal to export the 11,000 tonnes of HCB waste to an incinerator overseas is in breach of both the intention and spirit of the HCB Management Plan and contravenes the principles of environmentally sound management of hazardous waste as developed by the UN Secretariat of the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes & their Disposal (1989).
These include :
f) the self-sufficiency principle - management and disposal of waste in the country where it was created
g) the proximity principle - the disposal of hazardous waste as close as possible to their point of generation
h) the least transboundary movement principle - transboundary movements of hazardous waste reduced to a minimum
We are asking the Australian Minister for the Environment to accept the principle that Australia takes responsibility for the environmentally-sound destruction of its own HCB waste, as it has done for all previously generated POPs waste.
If you agree that Australia should be responsible for its own waste and not export this stockpile to Europe for
incineration, please download the letter of protest (Adobe Acrobat file 18KB) and email to the Australian Minister for the Environment and Heritage, Senator the Hon. Ian Campbell. senator.ian.campbell@aph.gov.au
Background to the HCB Stockpile
For over two
decades, the chemical company, Orica Australia Pty Ltd (formerly ICI
Australia) produced a large quantity of hexachlorobenzene (HCB)
waste. This industrial waste was an unwanted byproduct from the
manufacture of chemical solvents and was never used by Orica for
commercial purposes. Approximately 10,500 tonnes of HCB waste is now
stored at Orica site in the Botany Industrial Park in Sydney NSW
awaiting destruction. The site is surrounded by residential suburbs.
Unfortunately, HCB is difficult to destroy.
HCB waste is
considered a 'schedule waste' because it is organic in nature,
(i.e., its based on carbon molecules); resistant to degradation
(breakdown) by chemical, physical or biological means; toxic to
humans, vegetation or aquatic life, and bioaccumulates in humans,
flora and fauna. The destruction of the HCB is the focus of the
National HCB Scheduled Waste Management Plan.
Studies in animals have shown that eating HCB for a long time can
damage the liver, thyroid, nervous system, bones, kidneys, blood,
and immune and endocrine systems. The immune systems of rats that
breathed HCB for a few weeks were harmed and the U.S. Department of
Health and Human Services (DHHS) has determined that HCB may
reasonably be expected to be a carcinogen. HCB is found throughout
the environment and is regularly detected in the blood, breast milk
and fats of humans and wildlife. While much of the HCB contamination
has come from diverse sources such as HCB based agricultural
chemicals and industrial emissions, the stored HCB waste presents an
ongoing risk that needs to be addressed.
HCB does not dissolve in water very well, so most of it remains in
particles on the bottom of lakes and rivers allowing high levels to
build up in fish, marine mammals and birds. It also adheres strongly
to soil and can accumulate in wheat, grasses, some vegetables and
plants.
Most people are exposed to HCB through eating low levels in
contaminated food such as contaminated fish, milk or dairy products
or meat from cattle grazing on contaminated pastures. People can
also be exposed through drinking contaminated water or by breathing
low levels in contaminated air, eating or touching contaminated soil
or working at a factory that uses or produces HCB unintentionally.
Drinking contaminated breast milk from exposed mothers is a
significant source of HCB for babies.
As HCB breaks down very slowly, remaining in the environment for a
long time and is dispersed across the globe by both air and water,
the international community has included HCB on their target list of
persistent organic pollutants or POPs. Through the United Nations
Environment Program, the countries of United Nations have
cooperatively developed a global treaty to phase out and eliminate
persistent organic pollutants. The POPs Convention came into force
in May 2004.
There are two main
types of HCB wastes stored at Botany, they are the principal HCB
waste stored in drums and tanks and the encapsulated 'car park'
waste, consisting of approximately 45, 000 cubic meters of
contaminated sand and coal ash.
The treatment of these different types of waste requires different
approaches. Orica has reviewed a range of destruction technologies
for the drummed waste.
Orica carried out preliminary design work and cost estimates for a
destruction facility plant for the stockpiled drummed HCB waste,
stored at the Botany Industrial Park.
This work focused on the two technologies selected for trials :
GEOMELT
Vitrification Process
ECOLOGIC Gas
Phase Chemical Reduction (GPCR) Process.
Both technologies could be used either on site or off site. Orica
made its final selection of GeoMelt in November 2000.
NGOs and
community groups have opposed both the technology choice and the
destruction on site. While the Minister for the Environment gave
approval to the choice of technology, he has directed Orica to find
a more suitable site for the destruction of the largest HCB
stockpile in the world.
Contaminated Groundwater Plume
In late
August 2003, the New South Wales Environment Protection Authority (NSWEPA)
decided to issue Orica (Botany) Pty Ltd with a Clean Up Notice under
the Protection of the Environment Operations Act (POEO). It requires
Orica (formerly ICI Australia) to clean up the contaminated ground
water plume originally emanating from their industrial site at
Botany and now covering approximately two square kilometres.
Earlier in 2004,
Orica had submitted their report to the NSW EPA under the Voluntary
Investigation and Remediation agreement. The report noted that there
were high levels of EDC or 1,2 -Dichloroethane in the deep aquifer
beneath Orica’s ‘Southlands’. The center of the EDC plume where
levels are greater than 5,000 milligrams per litre is moving as a
‘slug’ with its axis shifting further east than previously modelled.
In the report
Orica also noted that levels of other contaminants
tetrachloroethylene (PCE) and trichloroethylene (TCE) were
increasing at the monitoring point at the Penrhyn Estuary, which
empties into Botany Bay. Other monitoring points for the northern
plume also showed increases in the levels of carbon tetrachloride (CTC).
This group of
chlorinated hydrocarbon chemicals nearly all have the potential to
cause cancer and affect reproductive and developmental health. EDC
is suspected of being capable of causing heritable genetic and
chromosomal mutations.
Despite Orica’s
voluntary investigations into remediation of the plumes, the NSW EPA
has now ordered Orica to ‘treat and pump’; ie, to extract the
contaminated ground water and treat it with an appropriate
technology, according to best international practice and in line
with national guidelines.
The NSW EPA
stated that the move to issue orders came after tests confirmed that
the contamination levels in groundwater from Orica’ s site were
spreading at a faster pace than was previously known.ICI Australia
has produced chlorine and the intermediaries for poly vinyl chloride
(PVC) on the Botany site since the 1940s and for the 30 years from
the 1960s to 1990 carbon tetrachloride was also manufactured. In
1989 ICI was directed by the then State Pollution Control Commission
(now the NSW EPA) to investigate contamination of groundwater in
their area. They carried out the Botany Groundwater Survey Stage 1
which was released in May, 1990.
The
investigations reported that the both shallow and deep groundwater
was contaminated with chlorinated hydrocarbons like
tetrachloroethylene (PCE), trichloroethane (TCA) and
trichloroethylene (TCE) as well as the persistent organic pollutant,
hexachlorobenzene (HCB). EDC was detected at around 150 mg/l in both
shallow and deep groundwater.
Mercury and chromium were also discovered in the sediments of
Springvale Drain running through the site, while both mercury and
HCB were detected in biological samples from the Penrhyn Estuary,
exceeding national guidelines.
Importantly, the 1990 report found that the deep plume could be
moving through the sand layers at approximately 60 to 210 metres per
year.
A Stage 2 survey, instigated to more clearly define the nature and
extent of groundwater contamination and to develop and evaluate
remediation options was released six years later in 1996. It
confirmed that groundwater contaminants linked to past industrial
activities were in both shallow and deep groundwater.
It confirmed six major source areas of contamination:
The former solvent plant;
EDC Storage tanks;
Former CTC Storage tank (polythene);
Filled areas adjacent to the railway line;
Old 'heavy ends' drum storage area; and
Old surface drain.
The Stage 2 survey provided 1994 sampling data showing levels of EDC
in deep groundwater of 6,800 mg/l and 6,300 mg/l in shallow
groundwater in the area of the old EDC storage tanks. It was
estimated that the plumes were moving in a south to south westerly
direction at around 70 to 80 metres per year in the upper layers and
3 to 4 metres per year at deeper levels. Assessments of health risks
carried out by Orica concluded that the contamination had not
created any unacceptable risk to human health.
The Stage 2 survey identified the possible remediation options
including the Reactive Barrier Technology, which Orica is currently
investigating and trialing. It is permeable trench filled with iron
filings installed below-ground to intercept and passively destroy
contaminants in shallow groundwater as they pass through the
barrier. Results collected in June 1999 from a Reactive Barrier
prototype to treat shallow groundwater indicate up to 89%
destruction of total chlorinated hydrocarbons. Other options include
in situ bioremediation and the range of pump and treat technologies.
However, all remediation options are listed as having a “very large”
timescale, which is measured in decades. The report notes that a
‘pump and treat’ exercise on the Orica plumes could take up to a
century. At the recent public meeting held in Botany (10/9/2003),
the NSW EPA claim that cleanup to drinking water standards is
possible within 15 years.
In 2004,
residents in the affected area were contacted by the NSW EPA and the
Department of Infrastructure Planning and Natural Resources (DIPNR)
advising them not to use bore water.
Of concern to
many is the ongoing commitment of Orica Australia to the Botany
site. The company is responsible for a stockpile of 10,500 tonnes of
HCB drummed waste, stored at the Botany site. The stockpile awaits
destruction at an estimated cost of over $80 million. The company on
the face of it seems over the years to have been winding back its
presence at Botany.The recent clean up order and publicity over the
groundwater plume emanating from the Botany Industrial Park
exemplifies serious questions about future financial liability.
Consideration of
the company’s potential liability for groundwater contamination may
make the estimated $80 million cost for HCB destruction look quite
small. For these reasons, it would be very appropriate for the NSW
Government to immediately secure a bond from Orica to cover the cost
of HCB destruction and other remediation in the very near future.
Failure to ensure this could potentially see the citizens of NSW
left not only with the legacy of appalling pollution but also with
substantial cost burdens of future remediation.
In late 2004, an
Environmental Impact Statement was completed for the Groundwater
Treatment Plant. The proposed treatment is by incineration and has
been opposed by NGOs and the local community.
(See NTN submission to the EIS) Word 109k
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