Code of good housekeeping
[Source: Annex III of the report of the Fifteenth Meeting of the Parties]
To provide additional guidance to facility operators, in May 1992 the Technical Advisory Committee prepared a “Code of Good Housekeeping” as a brief outline of measures that should be considered to ensure that environmental releases of ozone-depleting substances (ODS) through all media are minimized. This Code, updated by the Task Force on Destruction Technologies and amended by the Parties at their Fifteenth Meeting, in 2003, is also intended to provide a framework of practices and measures that should normally be adopted at facilities undertaking the destruction of ODS.
Not all measures will be appropriate to all situations and circumstances and, as with any code, nothing specified should be regarded as a barrier to the adoption of better or more effective measures if these can be identified. .
This refers to measures that may be appropriate prior to any delivery of ODS to a facility.
The facility operator should generate written guidelines on ODS packaging and containment criteria, together with labelling and transportation requirements. These guidelines should be provided to all suppliers and senders of ODS prior to agreement to accept such substances.
The facility operator should seek to visit and inspect the proposed sender’s stocks and arrangements prior to movement of the first consignment. This is to ensure awareness on the part of the sender of proper practices and compliance with standards.
Arrival at the facility
This refers to measures that should be taken at the time ODS are received at the facility gate.
These include an immediate check of documentation prior to admittance to the facility site, coupled with a preliminary inspection of the general condition of the consignment.
Where necessary, special or “fast-track” processing and repackaging facilities may be needed to mitigate risk of leakage or loss of ODS. Arrangements should exist to measure the gross weight of the consignment at the time of delivery.
Unloading from delivery vehicle
This refers to measures to be taken at the facility in connection with the unloading of ODS.
It is generally assumed that ODS will normally be delivered in some form of container, drum or other vessel that is removed from the delivery vehicle in total. Such containers may be returnable.
All unloading activities should be carried out in properly designated areas, to which restricted access of personnel applies.
Areas should be free of extraneous activities likely to lead to, or increase the risk of, collision, accidental dropping, spillage, etc.
Materials should be placed in designated quarantine areas for subsequent detailed checking and evaluation.
Testing and verification
This refers to the arrangements made for detailed checking of the ODS consignments prior to destruction.
Detailed checking of delivery documentation should be carried out, along with a complete inventory, to establish that delivery is as advised and appears to comply with expectations.
Detailed checks of containers should be made both in respect of accuracy of identification labels, etc, and of physical condition and integrity. Arrangements must be in place to permit repackaging or “fast-track” processing of any items identified as defective.
Sampling and analysis of representative quantities of ODS consignments should be carried out to verify material type and characteristics. All sampling and analysis should be conducted using approved procedures and techniques.
Storage and stock control
This refers to matters concerning the storage and stock control of ODS.
ODS materials should be stored in specially designated areas, subject to the regulations of the relevant local authorities. Arrangements should be put in place as soon as possible to minimize, to the extent practicable, stock emissions prior to destruction.
Locations of stock items should be identified through a system of control that should also provide a continuous update of quantities and locations as stock is destroyed and new stock delivered.
In regard to storage vessels for concentrated sources of ODS, these arrangements should include a system for regular monitoring and leak detection, as well as arrangements to permit repackaging of leaking stock as soon as possible.
Measuring quantities destroyed
It is important to be aware of the quantities of ODS processed through the destruction equipment. Where possible, flow meters or continuously recording weighing equipment for individual containers should be employed. As a minimum, containers should be weighed “full” and “empty” to establish quantities by difference.
Residual quantities of ODS in containers that can be sealed and are intended to be returned for further use, may be allowed. Otherwise, containers should be purged of residues or destroyed as part of the process.
This refers to basic features and requirements of plant, equipment and services deployed in the facility.
In general, any destruction facility should be properly designed and constructed in accordance with the best standards of engineering and technology and with particular regard to the need to minimize, if not eliminate, fugitive losses.
Particular care should be taken when designing plants to deal with dilute sources such as foams. These may be contained in refrigeration cabinets or may be part of more general demolition waste. The area in which foam is first separated from other substrates should be fully enclosed wherever possible and any significant emissions captured at that stage.
Pumps: Magnetic drive, sealers or double mechanical seal pumps should be installed to eliminate environmental releases resulting from seal leakage.
Valves: Valves with reduced leakage potential should be used. These include quarter-turn valves or valves with extended packing glands.
Tank vents (including loading vents): Filling and breathing discharges from tanks and vessels should be recovered or vented to a destruction process.
Piping joints: Screwed connections should not be used and the number of flanged joints should be kept to the minimum that is consistent with safety and the ability to dismantle for maintenance and repair.
Drainage systems: Areas of the facility where ODS are stored or handled should be provided with sloped concrete paving and a properly designed collection system. Water that is collected should, if contaminated, be treated prior to authorized discharge.
In general, all maintenance work should be performed according to properly planned programmes and should be executed within the framework of a permit system to ensure proper consideration of all aspects of the work.
ODS should be purged from all vessels, mechanical units and pipework prior to the opening of these items to the atmosphere. The contaminated purge should be routed to the destruction process or treated to recover the ODS.
All flanges, seals, gaskets and other sources of minor losses should be checked routinely to identify developing problems before containment is lost. Leaks should be repaired as soon as possible.
Consumable or short-life items, such as flexible hoses and couplings, must be monitored closely and replaced at a frequency that renders the risk of rupture negligible.
Quality control and quality assurance
All sampling and analytical work connected with ODS, the process and the monitoring of its overall performance should be subject to quality assessment and quality control measures in line with current recognized practices. This should include at least occasional independent verification and confirmation of data produced by the facility operators.
Consideration should also be given to the adoption of quality management systems and environment quality practices covering the entire facility.
All personnel concerned with the operation of the facility (with “operation” being interpreted in its widest sense) should have training appropriate to their task.
Of particular relevance to the ODS destruction objectives is training in the consequences of unnecessary losses and in the use, handling and maintenance of all equipment in the facility.
All training should be carried out by suitably qualified and experienced personnel and the details of such training should be maintained in written records. Refresher training should be conducted at appropriate intervals.
Code of transportation
In the interest of protecting the stratospheric ozone layer, it is essential that used ODS and products containing ODS are collected and moved efficiently to facilities practising approved destruction technologies. For transportation purposes, used ODS should receive the same hazard classification as the original substances or products. In practice, this may introduce restrictions on hazardous waste shipment under the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal and this should be consulted separately. In the absence of such specific restrictions, the following proposed code of transportation for ODS from customer to destruction facilities is provided as a guide to help minimize damage caused to the ozone layer as a result of ODS transfers. Additional guidance is contained in the United Nations Transport of Dangerous Goods Model Regulations.
It is important to supervise and control all shipments of used ODS and products containing ODS according to national and international requirements to protect the environment and human health. To ensure that ODS and products containing ODS do not constitute an unnecessary risk, they must be properly packaged and labelled. Instructions to be followed in the event of danger or accident must accompany each shipment to protect human beings and the environment from any danger that might arise during the operation.
Notification of the following information should be provided at any intermediate stage of the shipment from the place of dispatch until its final destination. When making notification, the notifier should supply the information requested on the consignment note, with particular regard to:
This code of transportation does not necessarily apply to the disposal of ODS-containing rigid insulation foams. The most appropriate way to dispose of such products may be by direct incineration in municipal waste incinerators or rotary kiln incinerators.
The objectives of monitoring should be to provide assurance that input materials are being destroyed with an acceptable efficiency generally consistent with the destruction and removal efficiency (DRE) recommendations listed in annex II to the present report and that the substances resulting from destruction yield environmentally acceptable emission levels consistent with, or better than, those required under national standards or other international protocols or treaties.
As there are as yet no International Organization for Standardization (ISO) standards applicable for the sampling and analysis of ODS or the majority of the other pollutants listed in annex IV to the present report, where national standards exist they should be employed. Further, where national standards exist they may be used in lieu of ISO standards provided that they have been the subject of a verification or validation process addressing their accuracy and representativeness.
As ISO develops international standards for pollutants listed in annex IV to the present report, the technical bodies charged with developing such standards should take note of the existing national standards including those identified in appendix F to the report of the Technology and Economic Assessment Panel (TEAP) of April 2002 (volume 3, report of the Task Force on Destruction Technologies) and strive to ensure consistency between any new ISO standards and the existing standard test methods, provided that there is no finding that those existing methods are inaccurate or unrepresentative.
Where national standards do not exist, the Technical Advisory Committee recommends adoption of the following guidelines for monitoring of destruction processes operating using an approved technology.
Recognizing that the Unites States of America Environmental Protection Agency (EPA) methods have been the subject of verification procedures to ensure that they are reasonably accurate and representative, that they cover all of the pollutants of interest (although not all ODS compounds have been the specific subject of verification activities), that they provide a comprehensive level of detail that should lead to replicability of the methods by trained personnel in other jurisdictions and that they are readily available for reference and downloading from the Internet without the payment of a fee, applicable EPA methods as described in appendix F to the 2002 report of TEAP may be employed.
In the interest of ensuring a common international basis of comparison for those pollutants or parameters where ISO standards exist (currently particulates, carbon monoxide, carbon dioxide and oxygen), use of those standards is encouraged and jurisdictions are encouraged to adopt them as national standards or acceptable alternatives to existing national standards.
The use of EPA or other national standards described in appendix F is also considered acceptable, however. The precedence given to the EPA methods in the present code is based on the relative comprehensiveness of the methods available (both in scope and content), and the relative ease of access to those methods.
Measurement of ODS
Operators of destruction facilities should take all necessary precautions concerning the storage and inventory control of ODS-containing material received for destruction. Prior to feeding the ODS to the approved destruction process, the following procedures are recommended:
Operators should ensure that destruction processes are operated efficiently to ensure complete destruction of ODS to the extent that it is technically feasible for the approved process. This will normally include the use of appropriate measurement devices and sampling techniques to monitor the operating parameters, burn conditions and mass concentrations of the pollutants that are generated by the process.
Gaseous emissions from the process need to be monitored and analysed using appropriate instrumentation. This should be supplemented by regular spot checks using manual stack-sampling methods. Other environmental releases, such as liquid effluents and solid residues, require laboratory analysis on a regular basis.
The continuous monitoring recommended for ongoing process control, including off-gas cleaning systems, is as follows:
Any additional continuous monitoring requirements are subject to the national regulatory authority that has jurisdiction. The performance of online monitors and instrumentation systems must be periodically checked and validated. When measuring detection limits, error values at the 95 per cent confidence level should not exceed 20 per cent.
Approved processes must be equipped with automatic cut-off control systems on the ODS feed system, or be able to go into standby mode whenever:
The approval of technologies recommended by TEAP is based on the destruction capability of the technology in question. It is recognized that the parameters may fluctuate during day-to-day operation from this generic capability. In practice, however, it is not possible to measure against performance criteria on a daily basis. This is particularly the case for situations where ODS only represents a small fraction of the substances being destroyed, thereby requiring specialist equipment to achieve detection of the very low concentrations present in the stack gas. It is therefore not uncommon for validation processes to take place annually at a given facility.
With this in mind, TEAP is aware that the measured performance of a facility may not always meet the criteria established for the technology. Nonetheless, TEAP sees no justification for reducing the minimum recommendations for a given technology. Regulators, however, may need to take these practical variations into account when setting minimum standards.
The ODS destruction and removal efficiency1 for a facility operating an approved technology should be validated at least once every three years. The validation process should also include an assessment of other relevant stack gas concentrations identified in annex II to decision XV/[…] and a comparison with maximum levels stipulated in relevant national standards or international protocols/treaties.
Determination of the ODS destruction and removal efficiency and other relevant substances identified in annex IV to the present report should also be followed when commissioning a new or rebuilt facility or when any other significant change is made to the destruction procedures in a facility to ensure that all facility characteristics are completely documented and assessed against the approved technology criteria.
Tests shall be done with known feed rates of a given ODS compound or with well-known ODS mixtures. In cases where a destruction process incinerates halogen-containing wastes together with ODS, the total halogen load should be calculated and controlled. The number and duration of test runs should be carefully selected to reflect the characteristics of the technology.
In summary, the destruction and removal efficiency recommended for concentrated sources means that less than 0.1 gram of total ODS should normally enter the environment from stack-gas emissions when 1,000 grams of ODS are fed into the process. A detailed analysis of stack test results should be made available to verify emissions of halogen acids and polychlorinated dibenzodioxin and dibenzofuran (PCDD/PCDF). In addition, a site-specific test protocol should be prepared and made available for inspection by the appropriate regulatory authorities. The sampling protocol shall report the following data from each test:
1 Destruction and removal efficiency has traditionally been determined by subtracting from the mass of a chemical fed into a destruction system during a specific period of time the mass of that chemical alone that is released in stack gases and expressing that difference as a percentage of the mass of that chemical fed into the system.
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