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the toxic truth - Greenpeace

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210 Amnesty internAtionAl And greenpeAce ne<strong>the</strong>rlAnds<br />

ANNEX I<br />

The mystery of chlorine:<br />

chlorine in very high<br />

levels present or not in<br />

<strong>the</strong> waste dumped?<br />

In its email to WAIBS on 18 August 2006,<br />

before <strong>the</strong> arrival of <strong>the</strong> Probo Koala<br />

in Abidjan, Trafigura gave <strong>the</strong> following<br />

information concerning <strong>the</strong> chemical content<br />

of <strong>the</strong> waste:<br />

ToTal organic chlorine (Tocl)<br />

It would be surprising if <strong>the</strong>re had been<br />

such high levels of organic bound chlorine<br />

in <strong>the</strong> waste, which was essentially<br />

residues from <strong>the</strong> treatment of sulphurous<br />

oil residues with caustic soda.<br />

Also, various analyses of <strong>the</strong> waste at<br />

different locations and times available<br />

to us do not support <strong>the</strong> presence of<br />

this high level of TOCl.<br />

If such high levels existed, <strong>the</strong>n it<br />

would imply that <strong>the</strong>re was significant<br />

contamination of <strong>the</strong> material (at some<br />

stage, whe<strong>the</strong>r before or after caustic<br />

treatment, whe<strong>the</strong>r before or after <strong>the</strong><br />

Probo Koala sailed from Amsterdam to<br />

Africa) with chlorinated materials, ei<strong>the</strong>r<br />

organic or inorganic reactive chlorine<br />

species. TOCl is generally determined<br />

by AOX analysis, and this analysis does<br />

not distinguish between different types<br />

of organic chlorine chemicals but simply<br />

gives a total amount of organic bound<br />

chlorine. In addition, it is unusual to<br />

report a result in this way (>5pct) - it<br />

implies that <strong>the</strong> value was too high<br />

to measure and this should lead to<br />

reanalysis of a diluted sample to determine<br />

<strong>the</strong> percentage.<br />

The text given by Trafigura in its email<br />

to WAIBS along with <strong>the</strong> measurements<br />

is very generic, making reference<br />

to sources of TOCl compounds<br />

which are clearly not related to <strong>the</strong><br />

waste in question or its processing.<br />

The description refers to pulp bleaching.<br />

Spent caustic is sometimes used<br />

in <strong>the</strong> paper industry for bleaching, but<br />

this has little relevance in <strong>the</strong> context<br />

of <strong>the</strong> Probo Koala. 24<br />

In <strong>the</strong> NFI report, reference is made<br />

to 2ppm of EOX in <strong>the</strong> oily fraction<br />

(based on analysis of a mixed sample<br />

of three samples of liquid collected<br />

from <strong>the</strong> starboard slop tanks of <strong>the</strong><br />

Probo Koala), <strong>the</strong> same value as that<br />

accepted by Trafigura with reference to<br />

<strong>the</strong> NFI analyses (although in that case<br />

with reference to <strong>the</strong> Main VII). 25 It is<br />

not clear whe<strong>the</strong>r <strong>the</strong> methods applied<br />

were <strong>the</strong> same as those used in determining<br />

<strong>the</strong> far higher value reported by<br />

Trafigura (>5% or >50,000ppm). What<br />

is clear, however, is that <strong>the</strong> description<br />

of <strong>the</strong> waste given by Trafigura to WAIBS<br />

differed very substantially from <strong>the</strong><br />

description of <strong>the</strong> waste reported by NFI<br />

in this respect, and that a very different<br />

value again was reported by <strong>the</strong> Ivorian<br />

authority agency CIAPOL for waste<br />

collected from one of <strong>the</strong> dumpsites<br />

two days after <strong>the</strong> dumping (250ppm<br />

for “organic chloride”). 26 If high values<br />

of TOCl were indeed measured for certain<br />

samples of <strong>the</strong> waste (for example,<br />

recorded in information which has yet to<br />

be disclosed), <strong>the</strong>n <strong>the</strong> next question is<br />

where <strong>the</strong> specific contamination might<br />

have come from. This is a difficult question<br />

to answer. As stated above, TOCl<br />

is a very generic type of analysis which<br />

simply converts all chlorinated organic<br />

compounds present into inorganic<br />

chloride before determining concentrations.<br />

It is not possible, <strong>the</strong>refore, to<br />

“ Please note details of <strong>the</strong> composition<br />

of <strong>the</strong> slops for your guidance:<br />

cod (chemical oxygen demand) - measured<br />

approx 21,000mg/l - The amount of oxygen<br />

consumed in complete chemical oxidation of<br />

matter present in wastewater; indicates <strong>the</strong><br />

content of slowly degradable organic matter<br />

present<br />

Total organic chlorine (Tocl) - measured >5<br />

pct - The total organic chlorine in <strong>the</strong> waste<br />

water. Typically measured using AoX analyses.<br />

The reaction of chlorine chemicals with lignins<br />

work back from such an analysis to<br />

determine what sorts of compounds<br />

contributed to <strong>the</strong> total.<br />

One possible explanation for <strong>the</strong><br />

apparent discrepancy between NFI’s<br />

report of 2ppm EOX in <strong>the</strong> oily fraction<br />

and Trafigura’s reference to >5% TOCl<br />

in <strong>the</strong> slops as a whole could be <strong>the</strong><br />

partitioning of chlorinated residues to<br />

oily sediments which were not sampled<br />

by NFI when <strong>the</strong> Probo Koala was in<br />

Amsterdam. There is, however, no information<br />

available on <strong>the</strong> origin of <strong>the</strong><br />

>5% figure for any conclusions to be<br />

drawn on this matter, and in any case,<br />

any judgement on level of hazard would<br />

require more detailed chemical-specific<br />

analysis of <strong>the</strong> material to determine<br />

what types of compounds were present<br />

and contributing to TOCl overall. All it<br />

is possible to say is that chlorinated<br />

organics, as a broad grouping of chemicals,<br />

includes a wide range of chemical<br />

families which are <strong>toxic</strong>, persistent and<br />

bioaccumulative. Percentage levels of<br />

composition would <strong>the</strong>refore clearly be<br />

of very high concern.<br />

We can conclude that ei<strong>the</strong>r <strong>the</strong> TOCl<br />

level of over 5 per cent was incorrect,<br />

such that Trafigura effectively<br />

misinformed <strong>the</strong> Ivorians on this aspect<br />

of <strong>the</strong> character of <strong>the</strong> waste, or<br />

it is a true finding but one based on<br />

information that has not so far been<br />

made public. At this stage, it is still impossible<br />

to say which is <strong>the</strong> more likely.

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