1

Hexachlorobenzene (HCB) waste at the Botany Industrial Park, Sydney

A concise history of management and disposal efforts
Prepared by Dr Rosalie Chapple on the request of CPRC Chair, Dr Paul Brown
December 2012
1. Overview
2. Background
- The HCB waste and its origin
- Status of HCB as a scheduled waste and its legislative framework
- Storage of HCB
3. History of treatment and disposal efforts
4. Summary
1. OVERVIEW
This paper provides a succinct history of the hexachlorobenzene (HCB) waste stored at the Botany Industrial
Park (BIP) in Sydney, and outlines the various attempts to destroy the waste across the last three decades.
There are currently no facilities to treat the HCB waste in Australia. After unsuccessful efforts to establish a
treatment plant in Australia, Orica Australia Pty Ltd (the company that owns the waste and manages legacy
issues at the BIP) sought other options including shipment to Europe for destruction in high temperature
incinerators, which have also been unsuccessful. Orica continues to investigate further destruction options.
Local residents remain concerned to see the waste removed from Botany as soon as possible.
Managing Oricas HCB waste is one of several projects to resolve legacy issues at the BIP
1
, with other
projects including groundwater treatment, containment of mercury contamination and other site remediation.
Recently completed is the Car Park Waste Encapsulation (CPWE) remediation project involving low level
HCB and related materials.
2. BACKGROUND
The HCB waste and its origin
Hexachlorobenzene is an organochlorine that was produced as a waste by-product primarily in the former
solvent and plastic manufacturing plants at the Botany Industrial Park between 1963 and 1991. HCB is a
white crystalline chemical, essentially insoluble in water. Approximately 15,000 tonnes of concentrated HCB
(mixed and in various forms) and low level (packaging etc) waste is now stored in containers at BIP, and is
managed by Orica Australia Pty Ltd
2
(previously ICI Australia Operations Pty Ltd). HCB can bio-accumulate
in the food chain (i.e., it tends to accumulate in an organism especially with prolonged or frequent exposure),
and is possibly carcinogenic to humans.
3
It is not flammable or volatile and is very resistant to degradation in
the environment.

Status of HCB as a scheduled waste and its legislative framework
Internationally, HCB is listed as a priority Persistent Organic Pollutant (POP) under the Stockholm
Convention on Persistent Organic Pollutants.
4
As a signatory to the Convention, Australia has obligations to
clean up and safely dispose of waste stockpiles that may contain POPs. The Stockholm Convention
operates alongside the Basel Convention on the Transboundary Movement of Hazardous Wastes and their
Disposal,
5
which is implemented through Australias Hazardous Waste (Regulation of Exports and Imports)
Act 1989. A third relevant international convention is the Rotterdam Convention on the Prior Informed
Consent Procedure for Certain Hazardous Chemicals and Pesticides in International Trade. Australia, as a

1
http://www.oricabotanytransformation.com
2
www.orica.com
3
HCB is classified by the International Agency for Research on Cancer (IARC) as a Group 2B substance possibly
carcinogenic to humans.
4
http://chm.pops.int/Convention/ThePOPs/The12InitialPOPs/tabid/296/Default.aspx
5
http://archive.basel.int/pub/techguid/pesticides/tg-pesticides-e.pdf


2
signatory to each of these conventions, is required to respond with localised regulatory frameworks, policy
decisions at every level of government, education and promotion, and to exercise corporate responsibility.

Oricas HCB is managed under its NSW Environmentally Hazardous Chemicals Act 1985 licence (EHC Act
Licence No. 26, issued by the NSW EPA) and in accordance with the Australian and New Zealand
Environment and Conservation Council's (ANZECC) National HCB Waste Management Plan
6
under the
National Strategy for the Management of Scheduled Waste.
7
The Community Participation and Review
Committee (CPRC) exist under this Plan, focusing on repackaging and destruction of the HCB waste.
8

Storage of HCB

Oricas HCB waste is stored in secure packaging at the Botany site in accordance with EHC Act Licence No.
26. Over time the HCB waste has been stored in a series of buildings and periodically needs to be re-
packaged due to corrosion of the storage containers, and the process of re-packaging itself increases the
stockpile of contaminated material.

3. HISTORY OF TREATMENT AND DISPOSAL EFFORTS

HCB at the Botany Industrial Park a 50-year timeline from 1963 to 2012
Year Milestones Key activities including destruction attempts
1963-
1991
HCB waste
produced
Manufacture of chlorinated solvents
Creation of HCB stockpiles.
1970s
Inadequate storage Storage of drummed high-level waste in an unsealed and uncovered area.
Commissioning of a process to rework the Solvents Plant waste and
concentrate it as crystalline HCB.
Construction of a purpose-built store.
1980
Car Park Waste
Encapsulation
Licensed excavation and storage of contaminated soil from the former drum
storage area in a polymer-lined cell, with a protective layer and car park
constructed on top.
1980s
High temperature
incineration
considered
Australian Government establishes a task force to investigate scheduled
wastes and installation of a national high temperature incinerator (HTI).
Communities and some environment groups oppose the plan for HTI.
1990s
Rejection of high
temperature
incineration in
Australia
National HTI rejected by the Australian Government in 1992.
National HCB Management Plan created in 1996, with a 2006 target for
destroying the Botany HCB waste.
Under the Plan, a National Advisory Body on Scheduled Waste is
established, and the CPRC is formed.
ICI Australia commences a study of available technologies.
In 1997 ICI in the UK sells its share of the company to the public (Australian
shareholders now have full responsibility to pay the costs of resolving legacy
issues). In 1998 Orica is adopted as new company name.


6
http://www.environment.gov.au/settlements/publications/chemicals/scheduled-waste/hcbplan.html The Australian and
New Zealand Environment and Conservation Council was a Ministerial Council operating between 1991 and 2001 which
comprised state, territory and Commonwealth governments of Australia and the Government of New Zealand. ANZECC
provided a forum for member governments to develop coordinated policies about national and international environment
and conservation issues. The HCB Plan was endorsed by all participating governments.
7
http://www.environment.gov.au/settlements/chemicals/scheduled-waste/index.html
8
The CPRC includes Orica (at the time it was known as ICI Australia) and, other industry representatives, Botany Bay
and Randwick City Councils, local residents, and observers from academia, the government and peak environment
groups. For current Terms of Reference: http://www.oricabotanytransformation.com/index.asp?page=71&project=83


3
2000
On-site treatment
considered -
Geomelt proposed
Following an intensive period of research into options, Orica proposes
treatment at its Botany site using Geomelt,
9
a batch melting process.
An environmental impact statement is produced by consultants URS.
Residents and local government oppose the Geomelt proposal.
2002
Geomelt has
conditional
approval
National Advisory Body is dissolved.
NSW Government establishes an Independent Commission of Inquiry into
Oricas proposal to use Geomelt.
10

The Commissions report recommends conditional approval of on-site
destruction of the HCB and its waste packaging.
2003
Geomelt and
alternatives further
considered
An Independent Review Panel (IRP) of experts is commissioned by the NSW
Government
11
to investigate the capability of Geomelt technology to be
predictable and reliable, and to consider other alternatives, namely:
Treatment at an existing facility in Australia;
Treatment at a reputable overseas facility;
Continued long-term storage at Botany;
Treatment at the Botany site using an alternative to GeoMelt;
Treatment at a remote site in NSW.
2004
On-site treatment
rejected at Botany
IRP concludes: forms of externally detectable operating upsets or
incidents are entirely possible during the life of the project, as is to be
expected with new technology, untried for a particular duty. Such events are
unlikely to result in any serious environmental damage or health impacts, but
have high propensity to elevate the level of public concern. a single
mishap, for example causing odour or noise impacts, may compromise the
project resulting in delays and continuing HCB storage.
12

IRP advises the Minister against proceeding with treatment of HCB Stored
Waste at Oricas Botany site. Orica withdraws Geomelt application and the
IRP recommends that Orica look for a remote site in NSW to treat the HCB.
2005
Alternative sites for
disposal explored
New planning phase commences with Orica evaluating HCB Stored Waste
treatment sites in (remote) New South Wales, while exploring overseas
export as an alternative.
2006
Failure to find
alternative site in
Australia;
Exploration of
international
options; Application
to export Stored
Waste for
destruction in
Germany
Treatment options for Car Park Waste Encapsulation (CPWE) under
consideration.
Second report
13
from the IRP notes the unlikely success of a search for a
NSW site for HCB Stored Waste treatment (Orica unable to find a site with
suitable infrastructure and community endorsement e.g. local agriculturalists
concerned about potential of contamination) and the IRP recommends
pursuing offshore destruction.
Orica lodges a formal application (which is then supported by the Australian
Governments Hazardous Waste Technical Group
14
) for export of the HCB
Stored Waste for destruction in Germany HTI facilities.
2007
Commence re-
packaging of waste
for planned export;
The German
application is
rejected
Automated waste re-packaging plant opens (previous packaging was
manual).
German state governments
15
reject the application because it was believed
that Australia had the capability to build its own waste treatment plant but
would not do so due to public opposition, which the German authorities felt
was insufficient reason and breaches the Basel Convention which states that
if alternatives for disposing of the waste exist within the country or if such
alternatives could be created, then the waste should not be transported.

9
The GeoMelt process works by passing electrical current through soil-bound waste materials to melt them in a
crucible at high temperature. When the current stops, the molten mass cools and solidifies into a highly stable solid
glassy substance, the organic contaminants having been vaporised (air emissions require further treatment).
http://www.geomelt.com
10
http://www.coi.nsw.gov.au/inquiry/40/6.pdf
11
Minister for Infrastructure Planning and Natural Resources
12
http://www.planning.nsw.gov.au/planningsystem/pdf/hcb_panel_report.pdf (p.37)
13
http://www.planning.nsw.gov.au/planningsystem/pdf/orica_hcb_panel_report.pdf
14
http://www.environment.gov.au/settlements/chemicals/hazardous-waste/tg/index.html
15
2007 letter to Orica from the Authority for Nature and the Environment of the Federal Land of Schleswig-Holstein.


4
2008
New application for
export of HCB
Stored Waste to
Denmark
Orica lodges a formal application with the Danish EPA for export of the HCB
Stored Waste for destruction in a Danish HTI.
2009
A new independent
expert assessment
concludes lack of
Australian capacity
to treat the waste
Australian Government commissions a new Independent Assessment
Report
16
that concludes there are no suitable technologies or facilities
available in Australia for the destruction of the Orica HCB Botany Stockpile.
CPWE Remediation Project approved, using Directly-heated Thermal
Desorption (DTD) technology.
2010
Denmark withdraws
from agreement
Export application approved by both Australian and Danish authorities.
The Danish Government then requests the Australian government to
withdraw its application, although the application meets all safety and
environmental requirements. Reasons include political situation and debate
within Denmark and community opposition in Denmark, with some
environmental groups arguing that Australia should deal with the waste at
home, and that shipping the chemicals posed an unacceptable risk.
17

An Independent Expert Panel
18
(IEP) is established to provide advice to the
community for the CPWE Remediation Project.
2011
HCB waste
repackaged
Orica completes automated waste repackaging into new packaging with
liners.
2012
Car park waste
remediation
completed;
New options for
HCB waste
destruction being
explored
CPWE Remediation Project completed,
19
with a site audit pending.
Groundwater monitoring to be maintained for a number of years.
Orica gains approval from NSW Government to relocate the Stored Waste
(within the BIP) from shipping containers to an on-site storage shed to
facilitate safe inspection.
Orica identifies broad options for treatment of the waste (all have long
approvals and lead time): These are:
A new treatment plant in Australia.
Export to an existing treatment plant (no active investigations
underway).
Bioremediation - Orica funds research collaboration between the
University of NSW and the Helmholtz Centre for Environmental
Research in Germany.


4. SUMMARY

Management of the HCB waste at Botany exists within a complex and variable local, national and
international context. Orica has been managing the storage and planning for disposal of toxic waste in
consultation with government, technical experts, environmentalists and the local community, while being
subject to the requirements and limitations of government decision-making, legislation and expert opinion.

Treatment alternatives have been investigated and proposed for over three decades. Each of the main
proposals has passed through several years of deliberation, involving research and development of
technologies, provision of independent expert advice and public participation. Some proposed solutions have
received initial support from experts and from government, and have met legislative and regulatory
requirements. Dealing with the HCB legacy is now one of the longest-running environmental management
challenges in Australia. The search continues for an agreed solution that will see the destruction of the waste
in the interests of the community and the environment.

16
Report by Sustainable Infrastructure Australia PL www.ing.dk/modules/fsArticle/download.php?fileid=555
17
http://www.heraldsun.com.au/ipad/danish-waste-ban-political-burke/story-fn6bfmgc-1225976011500
18
Remediation of the CPWE is a separate project from the stored HCB waste, but involved the CPRC:
http://www.oricabotanytransformation.com/files/pdf/Reports/CPWE/IEP/CPWE_IEP_ToR_final_Feb2010.pdf
19
http://www.oricabotanytransformation.com/index.asp?page=127&project=74