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DEMONSTRATING AND PROMOTING BEST TECHNIQUES AND PRACTICES FOR MANAGING HEALTHCARE WASTE AND PCBS PROJECT

GEF GRANT N0-FF056587

EXECUTIVE SUMMARY

September 24, 2010

GEREP-Environment17 Mustapha Abdessalem Street ; El Menzah V, 2037 - TUNISIATel: (+216) 71752976/71236248 Fax: (+216) 71234825www.gerep-environnement.com

Environmental and Social Impact Assessment Framework for the Tunisia PCBs Management

and Disposal and healthcare waste management improvement Project

THE REPUBLIC OF TUNISIA

MINISTRY OF ENVIRONMENT AND SUSTAINBLE DEVELOPPEMENT

AGENCE NATIONALE de GESTION DES DECHETS

E2321V2

ESIA –Tunisia PCBs management and disposal and HCW management improvement ProjectExecutive Summary ANGed - June 2010 revised

TABLE OF CONTENT

1. INTRODUCTION................................................................................................................3

2. PROJECT OBJECTIVES AND COMPONENTS...............................................................3

2.1 Objective.........................................................................................................................32.2 Project Components........................................................................................................4

3. Summary of regulatory and institutional requirements for project concept and implementation...........................................................................................................................4

3.1 Institutional and Regulatory Arrangements for Project Implementation........................5

3.2 World Bank Safeguard Policies......................................................................................7

4. HCW SUB-PROJECT..........................................................................................................8

4.1 Project Description..........................................................................................................8

4.2 Technical, economic, and environmental alternatives comparison................................9

4.3 Project Environmental and Social Assessment.............................................................11

4.4 Mitigation framework...................................................................................................12

4.5 Environmental and Social Management Framework Plan and Cost Estimates............14

4.6 Environmental and Social Monitoring Framework..................................................1716

4.7 Capacity building and training......................................................................................19

4.8 Implementation timetable for the HCW components and sub-components activities (2011-2014)..........................................................................................................................21

5. PCB SUB-COMPONENT..................................................................................................22

5.1 Project description....................................................................................................2322

5.2 Diagnosis of current PCB management practices in Tunisia.....Error! Bookmark not defined.24

5.3 Project Environmental and Social Impact Assessment Framework.............................26

5.3.1 Potential impacts of the current PCB management................................................265.4 Mitigation Framework..................................................................................................28

5.5 Environmental and Social Management Framework and Cost Estimates....................29

5.6 Environmental and Social Monitoring Framework..................................................3332

5.7 Capacity-Building and Training...............................................................................3534

5.7.1 Implementation of oversight and performance procedures, training and technical assistance.....................................................................................................................35345.7.2 Management Structure for PCB Project Activities.............................................3534

6. PUBLIC CONSULTATIONS........................................................................................3938

Public Consultation Findings............................................................................................3938

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1. INTRODUCTION

This report is the Executive Summary of the Environmental and Social Impact Assessment Framework (ESIAF) of the Tunisia Management and disposal of Hazardous Healthcare Waste (HCW) and PCBs Project.

This study is a framework assessment which aims at establishing a set of environmental and social procedures which will represent the basis for project implementation. This assessment is an exhaustive analysis and a comprehensive study on socio-economic and environmental impacts for improving healthcare waste and PCBs in Tunisia, in the context of a project co-financed by the Global Environmental Facility and the Tunisian Government.

This Framework assessment will be followed by specific ESMPs and environmental audits for PCBs storage areas and PCB contaminated sites, and storage areas of health care waste which will be identified prior to t implementation.

The ESIAF report was prepared according to the World Bank safeguard policies (specifically OP 4.01 on environmental assessment) and the Tunisian environmental conditions and regulations regarding the Environmental Impact Assessments (EIAs), particularly Decree no. 2005-1991 of July 11, 2005, related to the environmental impact study which define those unit categories for whch a EIA shoulbe conducted and unit catagories for which environmental specifications should be inincludedIn addition, the ESIAF is primarily based on feasibility studies already prepared under the proposed project: (i) the diagnostic study on HCW management in pilot areas, the development of an HCW management strategy for Tunisia and the feasibility study, and (ii) the feasibility study for the PCBs management plan in Tunisia.

This study was carried out by an independent consulting firm: GEREP-Environment. Key technical staff includes a team of environmentalists and an environmental economist with extensive experience in hazardous waste management and the technical support staff includes two environmental engineers. (See Annex)

2. PROJECT OBJECTIVES AND COMPONENTS

2.1 Objective

The Project Development Objective (PDO) is to improve handling of PCBs and management of health care waste through establishing sound and sustainable management programs and improving modalities of public private partnerships for waste management.

The Global Environment Objective (GEO) is to reduce POPs releases, specifically those of dioxins, furans and PCBs in Tunisia by strengthening the country’s regulatory and institutional frameworks to improving the HCW management system and phasing out the existing PCB equipment.

This project will allow Tunisia to fulfill its obligations under the Stockholm Convention and strengthen its national waste management capacities.

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2.2 Project Components

The project includes two sub-projects:

Sub-project 1: Improving Healthcare Waste Management (HCW): In the context of this project, an appropriate waste management system will be implemented, in accordance with the provisions of the Tunisian Decree no. 2745 of July 28, 2008, regarding management arrangements for healthcare waste activities (particularly those related to sorting, collection, storage, transport, and treatment).

An annual quantity of 3184 tons of healthcare waste, generated by public health facilities and hospitals in the following parts of the country: North (1555 T/year in the Governorates of: Tunis, Ariana, Manouba, Ben Arous), Center (937 T/year in the Governorates of: Sousse, Monastir, Mahdia and Kairouan) and South (692 T/year in the Governorates of: Safax, Gabès, Tataouine and Medenine).

Also included in this project, are the private healthcare facilities especially in the "Awareness-raising, training and capacity building" component. These facilities generate: 845 t/year in Greater Tunis, 163 T/year in the central area, and 253 T/year, in the south.

The implementation period of this sub-project will be 4 years. Its total cost excluding physical contingencies is US$9.5.5 million to be financed through a GEF contribution of US$2.14 million and co-financing from the Tunisian Government and the private sector of US$7.37 million.

Sub-project 2: Management and disposal of waste and PCB contaminated equipment in Tunisia: An environmentally and economically rational policy will be identified under this project, in addition to best practices and technical procedures for waste and PCB contaminated equipment management in Tunisia, in accordance with existing conventions and legislation in force.

The quantity of PCB and oil contaminated equipment to be treated is a project priority and amounts to 1,100 tons. It covers equipment (some operational but in poor condition) and waste oil.

The phase first of this sub-project will be implemented in 4 years. The total cost of this sub-project excluding physical contingencies is US$5.88 million financed by a GEF contribution of US$2.96 million and co-financing from the Tunisian Government and the private sector of US$2.92 million.

3. Summary of regulatory and institutional requirements for project concept and implementation

Regarding PCBS, it is worth mentioning that a circular from the Ministry of National Economy dated 1986, banned PCB containing equipment imports.

The regulatory requirements for project design and implementation are:

EIA and the ESMP for project concept and monitoring (HCW and PCB)

Law no. 96-41 of June 1996 on control, management and disposal of waste as well as application decrees (HCW and PCB)

Ministry of Environment and Sustainable Development approval of hazardous waste collection, transport and disposal activities (HCW and PCB)

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Law No. 97-37 of July 2, 1997 on hazardous waste road transport as well as application decrees (HCW and PCB)

Decree no. 2008-2745 of July 28, 2008 setting conditions and procedures for healthcare waste management (HCW)

Decree no. 2002-2010 of September 2002 setting up technical procedures for equipment and vehicles to be used for hazardous substances road transport (HCW and PCB)

Ministry of Transport Order of January 19, 2000 establishing hazardous labeling and distinctive symbols for hazardous substance road transportation (HCW and PCB)

The transport component specific to this project will be subject to the regulation governing the transport of dangerous goods in EU territory:

o The ADR, or “the European Agreement concerning the International Transport of Dangerous Goods by Road”

o The ADN, or “the European Agreement concerning the International Transport of Dangerous Goods by Inland Waterways”

o The RID, or “the European Agreement concerning the International Transport of Dangerous Goods by Rail”

The Basel Convention on transboundary transport of oils and wastes contaminated with PCBs for their treatment and disposal (PCB)

The Tunisian Standards (TS 106-02 and TS 106-04) concerning effluent discharge resulting from ground decontamination, handling of PCB equipment and healthcare waste storage and treatment (HCW and PCB).

In addition to these regulatory provisions, management procedure manuals for healthcare waste and PCB contaminated equipment will be prepared. These manuals will define:

- Waste management approaches

- Handling at all stages of management

- Handling during soil decontamination (for PCBs)

- Safety measures to be taken

- The equipment and the means used

3.1 Institutional and Regulatory Arrangements for Project Implementation

The project will be implemented by the National Agency for Waste Management (Agence Nationale de la Gestion des Déchets) ANGed in collaboration with the Ministry of Health for healthcare waste and the Ministry of Energy for PCBs. During project implementation, the entities responsible for the oversight, regulation and monitoring are:

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Regulatory requirements Control Entity Monitoring entity

HCW

EIA and ESMP ANPE ANPE, ANGed

Law of no. 96-41 of July 10, 1996 ANPE, DHMPE ANPE, DHMPE, ANGed

Hazardous waste collection, transport and disposal permits (HCW and PCB)

MEDD, ANPE MEDD, ANPE, ANGed

Law of no. 97-37 of July 2, 1997 Ministry of Interior and Local Development,

ANPE

Ministry of Transport, ANGed

Decree no. 2008-2745 of July 28, 2008 ANPE, DHMPE ANPE, DHMPE, ANGed

Decree no. 2002-2010 of September 2002 setting the technical procedures for equipment and vehicles for hazardous substances road transport

Ministry of Interior and Local Development,

ANPE


Ministerial order (Ministry of Transport) of January 19, 2000 establishing hazardous labeling and distinctive hazardous symbols for road transportation

Ministry of Interior and Local Development,

ANPE


Tunisian Standards (TS 106-02 and TS 106-04) ANPE ANPE, ANGed

PCB

EIS and ESMP ANPE ANPE, ANGed

Law no. 96-41 of July 10, 1996 ANPE ANPE, ANGed

Hazardous waste collection, transport and disposal permits (HW and PCB)

MEDD, ANPE MEDD, ANPE, ANGed

Law no. 97-37 of July 2, 1997 Ministry of Interior and Local

Development, ANPE


Decree no. 2002-2010 of September 2002 stipulating technical regulation for the equipment and vehicles to transport hazardous substances by road.

Ministry of Interior and Local

Development, ANPE


Ministerial order (Ministry of Transport) of January 19, 2000 regulating hazardous labeling and symbols for hazardous substances road transport

Ministry of Interior and Local

Development, ANPE


Stockholm, Basel and Bamako conventions ANPE MEDD, ANPE, ANGed

Tunisian Standards (TS 106-02 and TS 106-04) ANPE ANPE, ANGed

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3.2 World Bank Safeguard Policies

This ESIAF is also subject to the World Bank safeguard policies integrating natural resources management and social considerations. The 10 World Bank safeguard policies are:

1. Environmental Assessment OP. 4.01

2. Natural Habitats OP 4.04

3. Pest Management OP 4.09

4. Physical Cultural Resources OP 4.11

5. Involuntary Resettlement OP 4.12

6. Indigenous Peoples OP 4.10

7. Forests OP 4.36

8. Safety of Dams OP 4.37

9. Projects on International Waterways OP 7.50

10. Projects in Disputed Areas OP 7.60

The only policy triggered under this project is OP 4.01 on environmental assessment. According to this policy, the project has been classified as Category A, which requires the preparation of an environmental impact assessment which will be submitted to public consultation and disclosed on ANPE's and ANGed's websites, and on the World Bank’s Infoshop's website. Since the detailed technical design and location of storage areas and disposal and treatment sites were not fully identified prior to appraisal and will be completed during the Project implementation, the preparation of the Environment and Social Impact Assessment will take place in two stages :

Stage 1: An Environmental and Social Impact Assessment Framework (ESIAF) was prepared prior to appraisal, and mitigation, monitoring and institutional measures were outlined in an Environmental and Social Management Framework (ESMF) . Stage 2: The second stage will be the preparation during project implementation of site or group of sites- specific environment and social management plans for HCW storage and treatment sites ; and in case visual audit results on PCB contaminated sites show potential negative impacts, a specific environmental and social management plan of the site or group of sites, will be prepared, in accordance with the Environmental and Social Impact assessment Framework (ESIAF) and included in PCBs disposal bidding document. All EMPs will be disclosed on the ANGed website and in the InfoShop according to the Bank's Policy on Disclosure of Information.

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4. HCW SUB-PROJECT

4.1 Project Description

The HCW management project objective is to resolve considerable social, environmental, and economic problems resulting from current HCW management practices by identifying the most sustainable operational methodology for technical, institutional and financial management issues. Thus, the implementation of a national waste management strategy would include the following activities:

1. STRENGTHENING OF THE REGULATORy, INSTITUTIONAL AND TECHNICAL CAPACITY FRAMEWORK: (cost: US$1,239000) 1.1 Strengthening of the institutional and regulatory Framework: (cost: US$318,000)

- Organization of HCW management from an institutional and regulatory standpoint

- Strengthening of regulations, establishment of standards and technical guidelines and ensuring the oversight at the structural, as well as public and private health facility level, including private waste treatment operators

- Allocation of responsibilities for waste management

1.2 Awareness-raising and extension for the HCW management (cost: US$250,000)

- Development of awareness-raising campaign for staff on sharp objects handling and other infectious diseases risks

- Organization of regular workshops and information and monitoring seminars with sector participants

- HCW minimization program: Technical guidelines, brochures, support groups, billboards, movies, etc).

1.3 Training: (cost: US$671,000)

- Training for all HCW management participants

- Training of care providers on sorting, packaging, storage, transport, and waste handling: Training for trainers and workshops

- Strengthening of the oversight and monitoring teams within the agencies under the supervision of the MPH and the MEDD (ANPE, DHMPE, ANGed, etc)

- Training and technical assistance of monitoring staff in HCW management

- Participation in the different events

- Seminars, workshops, and courses

- Development of a training plan

2. HCW INVESTMENT IN THE THREE PROJECT AREAS, NORD, CENTRAL AND SOUTHERN TUNISIA: (Cost: US$9,155,00) of which US$916,000 for physical contingencies)

2.1 First Lot: Setting up of intermediate refrigerated storage facilities and centralized refrigerated facilities in public healthcare facilities of the Greater Tunis and the Governorates of Sousse, Kairouan, Monastir, Sfax, Gabès, Médenine and Tataouine: (cost: US$918,000)

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2.2 Second lot: Acquisition of transport and storage equipment, intra-mural (Dumpsters, LBC, rolling containers, and protection equipment): (cost: US$630,000)

2.3 Investment in HCW collective treatment equipment and HCW management production costs over four years: (cost: US$6,692,000)

3. PROJECT MONITORING, EVALUATION AND MANAGEMENT : (Cost: US$266,000) of which US$30,000 for physical contingencies)

3.1 PMU- Project implementation, coordination, technical and financial management

A central autoclaving system will be installed in each of the following pilot cities: Greater Tunis, Sousse-Kairouan, Monastir-Mehdia, and Sfax. However, centralized and refrigerated storage facilities will be constructed in the hospitals in Mednine, Tataouine and Gabès located in Southern Tunisia to allow for weekly waste transport produced by these facilities and consequently to optimize transport costs for such small HCW quantities.

The expected HCW project results are as follows:

Strengthening of the legal and institutional framework Strengthening of management capacity at all levels Strengthening of operational and financial capacities of all pilot cities Increase of private sector participation for HCW collection and disposal 100% of emissions will be eliminated from inappropriately installed incinerators since these

incinerators are already all closed, following IMC decisions, as revealed by the results of the project studies

4.2 Technical, economic, and environmental alternatives comparison

The following table summarizes the various alternatives proposed for HCW management together with the benefits and the disadvantages (or feasibility constraints) for each alternative, including unit cost.

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(The costs are those identified by the HCW management improvement study in Tunisia – ANGed – May 2008).

Alternatives Technical and environmental benefits

Technical and environmental

disadvantages (feasibility constraint)

Cost Estimates*

1 Without the project none Major impact on public health and the environment 0

2

Off-site Central Treatment Facility (CTF) (centralized)/ANGed's investment

Oversight and monitoring easier for ANGed's agencies

Treatment Unit outside healthcare facilities

Human and material resources important for

ANGedTD 770/ton

3 In situ CTF (for potential producers)

No transport

Immediate HCW treatment, without intermediate storage

Easier monitoring and oversight

Non local pollution risk

Human and material resources important for each

health care facility

Lack of space in healthcare facilities

TD 370/ton

4Off-site CTF/investment and private operation

Private sector involvement

Competition among contractors resulting in an improvement of the quality of service and cost

Treatment Unit outside healthcare institutions

Implementation of a national strategy for HCW management

Problems associated with lack of traceability 800 TD/ton

Alternative 4 has been selected: (Off-site CTF/private investment and production) has been selected although the cost per ton is higher. This scenario takes into account environmental advantages and the active private sector participation.

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HCW quantities generated by State facilities in the areas targeted by the study are listed in the following table:

Zones Area of Intervention HCW RI Quantity EPS in T/per year Total Number

of CTFsGreater Tunis Greater Tunis 1,555 1,555 3

CenterSousse & Kairouan 522

937 1Monastir & Mahdia 415 1

South-East

Sfax 457

692

1Gabès 107 -Tataouine 31 -Medenine 97

TOTAL 3,184 6The training and awareness-raising component will target private and national facilities located in the perimeter Governorates of the Study.

4.3 Project Environmental and Social Assessment

4.3.1 Potential impacts of the current HCW management

The absence of a proper treatment and disposal management plan for Tunisia engenders negative and widespread impacts on the environment and public health. Indeed, in general dangerous HCW has a direct impact on health care staff, patients, visitors, waste collection and transportation operators, the external public, landfill workers, etc. In addition, HCW arbitrary incineration produces unhealthy air quality through the emissions of dioxins and furan.

According to the various pathologies found in healthcare facilities in Tunisia, HCW is likely to contain several pathogenic germs for human, including staphylococcus sp, HIV, hepatitis viruses B and C in blood, salmonella and Shigella sp in feces and vomit, streptococcus sp in pus.A survey conducted in Sfax (Tunisia) over a two-year period (since 2003) by the Environmental Protection Agency of Sfax revealed the presence of Hepatitis B in 60% of municipal laborers working in waste collection.

The potential risks are illnesses or lesions due to this waste, namely: Infectious agents, sharp or cutting objects, genotoxic substances, and chemical or pharmaceutical substances (toxic and hazardous), etc.

HCW treatment and disposal aim to eradicate indirect health danger or risks associated with the waste residues in the environment:

- Healthcare waste disposal uncontrolled areas can have direct negative environmental impacts through soil and groundwater contamination.

- HCW disposal can potentially contaminate water resources. Some HCW storage facility operations can also pose health risks.

- Inadequate incineration (without effective emission treatment) or incineration of inappropriate substances can produce atmospheric pollution. Incineration of chlorine substances can emit dioxin and furan which are potentially carcinogenic for humans and can produce a whole host of other negative effects. Incineration of metal or metallic substances (in particular mercury, lead and cadmium) can release heavy metals into the environment. Dioxin, furan and metals are persistent and accumulate in the ecosystem.

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The matrix below gives an impact summary for the different measures under the project, including an assessment of their importance and likelihood, as well as their impact ratings as either, high, moderate, or low.

Matrices on importance of and likelihood of impacts (for the chosen alternative)

Phase

Importance of impact on:

Public health

Surface water Groundwater Air Soil Fauna and

Flora

Sorting moderate low low low low low

Packaging high low low moderate moderate low

Waste Collection at the health facility high low low low low low

Interim storage moderate low low low low low

Central storage or refrigerated area high moderate moderate moderate moderate moderate

Initial transport high moderate moderate moderate moderate moderate

Treatment (shredding + steam sterilization) moderate moderate moderate moderate moderate moderate

Secondary transport low low low low low low

PhaseLikelihood of impact on:

Public health

Surface water Groundwater Air Soil Fauna and

Flora

Sorting certain Unlikely Unlikely Unlikely Unlikely Unlikely

Packaging certain Unlikely Unlikely Unlikely Unlikely Unlikely

Collection at the health facility certain Unlikely Unlikely Unlikely Unlikely Unlikely

Interim storage certain Unlikely Unlikely Unlikely Likely Likely

Central storing or refrigerated area certain Likely Likely Likely Likely Likely

Initial transport certain Likely Likely Likely Likely Likely

Treatment (shredding + steam sterilization) certain Likely Likely Likely Likely Likely

Secondary transport Likely Unlikely Unlikely Unlikely Unlikely Unlikely

4.4 Mitigation framework

The proposed mitigation framework for each phase is as follows:

Project activities Proposed mitigation measures

Sorting Staff training on sorting arrangementsCompliance with waste sorting guidelines, as defined by the good management procedures manual

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Packaging

Application of good management techniques, as identified by the good management procedures manualAppropriate use of bags and containersEnsure permanent closure of infected waste bags and boxes

Interim storage

Appropriate and specific interim storage facility structure space, according to service and phase Application of good management techniques, as defined by the good management procedures manual

Collection at the health facility

Application of good management techniques, as defined by the good management procedures manualDetermine selection of collection times Collection carts cleaning and disinfecting Ensure cleanliness of elevators and stairwells after useTrained and qualified collection staff to perform this task

Intramural transport

Application of good management techniques as defined by the good management procedures manualUse of appropriate HCW dumpster and carts for HCW transportAppropriate selection of collection times Optimization of itinerary selection for transportCarts cleaning and disinfecting Intramural transport must be handled by trained and qualified collection staff

Central storage or refrigerated area

Appropriate refrigerated areas (closure, water-tightness, space, ventilation, light and adequate for healthcare activities) for cold remote areas without daily waste collection service and ventilated for areas with daily waste collection serviceEnsure regular maintenance of equipment and ventilation units Restrict access to facilities, except for waste collection and treatment facility staffWaste storage facility must be disinfected after each stored wastes collection

Collection and extramural transport

Application of good management techniques, as defined by the good management procedures manualWaste collection must be handled by trained and qualified personnel Bar codes and traceability to ensure remote monitoring (through a GPS or a computer network)Compliance with hazardous substances transport regulations Optimizing transport itinerary, by avoiding peak traffic and main national roads as much as possible

Treatment (shredding + steam sterilization)

Safe waste handlingRegular equipment maintenanceProper room ventilationTreatment obligation in the event of equipment malfunctions (sub-contracting with authorized companies, per guidelines on waste management from the Ministry of Environment and Sustainable Development

Disposal in landfillsOptimizing transport itinerary: avoidance of peak traffic and main national roads as much as possible

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4.5 Environmental and Social Management Framework (ESMF) Plan and Cost Estimates

The ESMFP has been prepared in accordance with both OP 4.01 (Environmental Assessment) and the Tunisian EIA Decree No. 2005-1991 of July 11, 2005. This ESMFP includes detailed mitigating, monitoring and institutional measures to be applied during the implementation of selected HCW alternative. The Project will finance HCW waste collection and intramural storage and extramural treatment, in Tunisia, and will recruit national specialized firms in waste treatment already pre-approved by the MEDD. Extramural operations will be financed by Government's contribution to the project according to the Tunisian trade code. Intramural collection and storage activities will include the preparation of an environmental and social management plan (ESMP) for each site, in accordance with the ESMFP, which will be published on ANGed’s website. For HCW treatment, the ANGed will ensure that with the 1998 Decree No. 2745 on treatment specifications for hazardous waste treatment, and Decree No. 1064 of 2009 on permits issued for the treatment of hazardous waste are being applied The latter decree requires the preparation of an environmental impact assessment for intramural collection, transport and waste treatment and the pre-approval of the ANPE. Twenty-one companies have already received authorization following submission of their EIAs, although only three (SEIT, ECOMED and SADIP) are currently operational.

This ESMFP takes into account both the monitoring of environmental parameters and the impact of mitigation measures. It also includes the following basic elements:

o Measures to mitigate or repair, and/or compensate for adverse impacts on the environment and cost estimates

o Environmental oversight and monitoring and costs estimates

o Institutional measures including the preparation of a hazardous HCW framework management manual, as wells as the preparation of specific manuals for each public health facility targeted by the project.

The incremental cost for the preparation of environment management plans for sites- specific or group of sites- specific the HCW storage facilities is: US$ 100,000. This is over and above the cost of institutional strengthening and investments related to HCW treatment estimated at US$ US$ 1.13 million and US$ 8.14 million respectively

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ESIA –Tunisia PCBs management and disposal and HCW management improvement ProjectExecutive Summary ANGed - June 2010

Project activities Potential environmental and health impacts

Proposed mitigation measures Institutional responsibilities Cost Estimates* Comments

Site specific EMPs To mitigate imapcts of the interim , and central storage facilities

To be determined SNGed 100,000

Sorting Risk of infection, contamination and injury to all persons exposed

Daily training for staff on sorting methodsCompliance with sorting required methods according to the good management procedures manual

Ministry of Public HealthHealth care facility

To be part of the operational budget of the jealth carse facility

Training of all heath care facility staff

Packaging and collection

Risk of contamination (injury and infection) in the exposed populationRisk of hazardous waste seepageRisk of contamination from biological and infectious wastesVisual and olfactory gene

Application of good management techniques, as defined by the good management procedures manualUse of appropriate containers and bagsEnsure complete sealing of waste infectious bags and boxesAcquisition of standardized consumable materials


To be part of the collection and transport contract

Standardized specifications and colors common in all health care facilities

Interim refrigerated storage

Poor space occupationPsycho-motor traumas Visual and olfactory problemsSite identification

Appropriate specific interim storage areas for each floor and serviceApplication of good management techniques, as defined by the good management procedures manualPreparation of an environmental and social management plan

Ministry of Public HealthHealth care facilityANGed

818,000

Central refrigerated storage facilities

Concentration of contaminated waste in one areaPotential risk of bacterial and viral propagationVisual and olfactory problemsRisk of passengers and staff contaminationRisk of contamination in natural

Appropriate areas planning (sealed, water-tight, spacious, ventilated, appropriate lighting at distance from health activities), refrigeratedAcquisition and regular maintenance of equipment restricting, restricted access of the facility, except for staff from the management and treatment companyCleaning and disinfection of storage areas after

Ministry of Public HealthHealth care facilityANGedANPE

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ESIA –Tunisia PCBs management and disposal and HCW management improvement of ProjectExecutive Summary ANGed - June 2010

environment (soil, air, water, fauna and flora)Site identification

stored waste removal

Intramural transport

Risk of infection, contamination or injury to all exposed personsContamination from collection cartsContamination of collection carts Contamination of elevators and stairwells

Use of appropriate techniques, as defined by the good management procedures manualUse of appropriate intramural transport equipmentAppropriate selection of transport times Carts cleaning and disinfecting Ensure cleanliness of elevators and/or stairwells after useTransport personnel must be trained and qualified to perform this task


630,000 Preference for IBC carts use

Collection and extramural transport

Traffic congestion around the facilityTraffic congestion on local roads and risk of accidents i.e., contaminated waste spills

Application of good management techniques, as defined by the good management procedures manualCollection ensured by trained and qualified staff Bar codes and traceability, including remote monitoring (by GPS or a computer network)Compliance with hazardous substances transport regulations Optimization, as much of possible, of the transport itinerary, during off- peak hours and away from national roadways

Private companies authorized by MEDD

Cost borne by a private waste treatment company

Approved company for HCW collection, transport and treatment

Treatment (shredding + steam sterilization) and disposal in landfills

Risk of injury and infections for all exposed staffNot appropriate for types of wastes Prior treatment required (burying)Risk of water and treated contaminated waste of spillage in case equipment malfunction

Waste handling precautions Maintenance of equipment Proper area ventilationWaste treatment obligation in case of equipment malfunction (sub-contracting with companies approved by the Ministry of Environment and Sustainable Development for waste management)

Private company authorized by MEDDANGedHealthcare facility

6, 692,000 cost borne by Countepart funding

Approved companies for HCW collection, transport and treatment

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4.6 Environmental and Social Monitoring Framework

Proposed mitigation measures Parameter Checklist Sites Data and/or

measures Frequency of measurement Required norms and standards Responsibilities Cost ($)

Sorting Quantities of HCW generated Healthcare facilitiesWeight scalesVisual oversight

One daily, during waste removal

Decree no. 2008-274 of July 28, 2008Good management procedures manual

Healthcare staffDHPME (oversight)ANPE (oversight)

Part of the operationaal budget of health care facilities

PackagingCondition of filled bags and containersLabeling

Every healthcare facility visual Twice a day

Decree no. 2008-2745 of July 28, 2008Good management manual of procedures

Healthcare facility personnelDHMPE (oversight))

idem

Interim storage Site cleanliness Every team and every floor visual Twice a day

Decree no. 2008-2745 of July 28, 2008 Good management manual of procedures

Healthcare facility personnelDHMPE (oversight)ANPE (oversight)

idem

Collection at healthcare facilities

Condition of carts and cleanliness of sites after collection

Hallways, stairwells and elevators used by IBC carts

visual Twice a day

Decree no. 2008-275 of 28 July 2008Good management manual of procedures


idem

Central refrigerated storage

Cleanliness of area, temperature control Storage area Visual,

thermometer Once a day

Decree no. 2008-2745 of July 28, 2008Good management procedures manual


idem

Extramural collection Condition of transport vehicle Itinerary visual During each Law on transport of hazardous Healthcare facility Part of the

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and transport Conditions of containers Roadmaps, dockets, registries

facility visitmaterialGood management procedures manual

staffANPE (oversight)Private companies

operaional contract of the operator

Treatment (shredding + steam sterilization)

Machinery conditionQuality of treated wasteQuality of wastewater in ONAS networkAtmospheric waste from vertical autoclave with shredder

Vertical autoclave with shredder Treatment unit

visualTreated waste analysis through germicidal and disinfection tubesBacteriological waste analysisAir quality analysis

Every semester

Decree no. 2008-2745 of July 28, 2008Tunisian Norm 106-02Tunisian Norm 106-04

Private companiesANPE (oversight)

US$500/treatment unit/semester, part of the operationala contract of the operator

Disposal in landfills Quantity of treated HCW Landfills Weighbridge at landfills Every day Initialed register

Private companiesHealthcare facilities

Part of the operationala contract of the operator

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4.7 Capacity building and training

This component includes capacity building and required training within ANGed, healthcare facilities and other concerned entities involved in HCW management applications.

4.7.1 Implementation of oversight and performance measures training, and technical assistance

This component includes:

The establishment of the coordination committee of the project chaired by the Minister of Environment and Sustainable Development ) comprising the major units and institutional partners (MSP, ANCSEP, ANPE, ANGed, MEDD). This structure will have a role on review the design , as well as the responsibility for monitoring and evaluating the application of the national HCW management policy.

The strengthening of awareness-raising and training (development of an awareness-raising

plan and training plans) Technical assistance

4.7.2 Management structure of HCW project activities

The establishment of a Project Management Unit (PMU:

) Implement the project, ensure coordination, technical and financial management, monitoring and oversight of the application of the environmental and social management framework.

This team will be composed of the project manager in HCW , four technicains in the HCW management, a secretariat for project management, office equipment and purchase of one vehicle, The team must have the required competencies and the means to ensure compliance with the environmental and social framework, following targeted and specialized training. The first project subcomponent component is the institutional measures of the ESMFP

Institutional strengthening

activityPositions Timetable Responsibilities

Mitigation

PMU (within ANGed)

During project Implementation, monitoring, evaluation and organization of workshops during project implementation

Preparation of specific hazardous HCW management manuals and technical guides

Three months following GEF Grant signing

PMU and ANGed, consulting firms

Strengthening the capacity of HCW management staff within healthcare structures and facilities

During projectSupervision of HCW management at healthcare facilities

Monitoring PMU (within ANGed) During project compliance with required mitigation measures

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Strengthening of ANPE through the hiring of an environmental engineer with experience in healthcare

During projectCompliance with required mitigation measures

Cost of the institutional strengthening US$239,000

Training activity Participants Type of training Content

EMP

ANGedANPEDHMPEHealthcare facilitiesHCW management approved companies

Training on HCW separation, packaging and storage

Regulatory requirements and practices as defined in the good management procedures manual

Environmental Process, methods and equipment

ANGedANPEMEDDMinistry of Public healthConsulting firmsNGOs

Training in equipment handling, operation and maintenance of interim and central storage facilities, and intramural and extramural transport

Information seminars

Information on available technology and HCW management good practices

Environmental policies and program

Regional healthcare section chiefs,Heads of HCW management units, doctors, nurses, and others,Laborers, Healthcare waste treatment service providersCleaning,HCW managementetc. Healthcare waste management supervisorsAll other person involved in HCW management activities.

Development of a training plan

Training programs in waste sorting, storage, transport and handling of various types of HCW

Strategies and objectives of the environmental policy in Tunisia and programs

Total training cost US$522,000

Awareness-raising activities Participants Type of training Content

Organization of large-scale workshops

ANGedANPEDHMPEHealthcare facilitiesHCW management approved companies

Preparation of an awareness-raising plan

HCW minimization program

Technical guides, brochures, didactic, billboards, etc.

Regulatory requirements and good management procedures manual practices

Total cost of awareness-raising US$252,000

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4.8 Implementation timetable for the HCW components and sub-components activities (2011-2014)

Activity 2011 2012 2013 2014

Site specific EMPs 2011

Specific dangerous HCW

management manuals

2011 2012

Training 2011 2012 2013 2014

Awareness-raising 2011 2012 2013 2014

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5. PCB SUB-COMPONENT

5.1 Diagnosis of current PCB management practices in Tunisia

PCB oil containing equipment is either is use or removed. Some owners, such as the STEG and the GIC, store their disposed equipment in an interim storage site, prior to its decontamination or export. Because of the absence of regulation or clear instructions on how to manage the contaminated equipment, other companies store the disposed of contaminated equipment in a scattered manner, usually close to the area where it will be used. Fifty sites where PCB containing equipment is stored have been identified (potentially contaminated with PCBs) the most important are:

- STEG Naâssan storage area, a suburb of the capital. The dense urban area surrounding this site makes it a particular site.

- The SNCPA site at Kasserine

- SOTULUB Workshops at Menzel Bourguiba

- SACEM workshops at Menzel Bourguiba

- CPG site at Metlaoui

Some have sold contaminated carcasses containing PCB oil.

Sites at risk are obviously all obsolete transformers storage sites of all owners as well as sites where transformers are in use and undergoing maintenance (filling) and repair.

The PCB governorates storage sites for potentially contaminated wastes are those of Tunis, Bizerte, Gafsa, Gabes, Sfax, followed, to a lesser extent, by Kébili, Sousse and Monastir, and Kasserine. (See map in Annex).

These storage sites will undergo environmental audits, provided prior and during the implementation of project activities, and will adhere to specific mitigation and PCB contaminated soil remediation plans.

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The Chosen Alternative

Three alternatives have been proposed for PCBs management:

Option 1: Export of all PCB contaminated equipment and waste to Europe for treatment and recycling, including metal recovery;

Option 2: Decontamination of PCB transformers in Tunisia, then export of decontaminated carcasses with condensers, PCB oil and waste to Europe for treatment and recycling includinig metal recovery;

Option 3: Decontamination of PCB transformers in Tunisia, including the recycling of decontaminated carcasses in El Fouledh and export of condensers and PCB oil to Europe for treatment.

Among the available options, option 1 was selection, which proposes the export of all equipment and PCB oil contaminated wastes to a European treatment and disposal facility, including the retrofilling of operational transformers containing a PCB concentration, between 50 and 2000 ppm by weight. This choice was determined by environmental advantages and disadvantages, technical feasibility and cost estimates.

The equipment will be removed and packaged where it will be found.

The choice of this option, which turned out to be the most favorable option, was determined by technical, environmental and safety considerations.This option seems to be the most appropriate for Tunisia, as it allows the final disposal of PCBs outside the Tunisian territory.

The first phase proposes priority actions: i) collection and disposal of obsolete PCB contaminated equipment ii) collection and disposal of PCB equipment intended for use in sensitive areas (schools, healthcare facilities, urban areas, water treatment and distribution facilities, malls, hotels, environmentally sensitive areas, ....), and leaking and in poor condition equipment, and iii) remediation of PCB contaminated sites.

It will involve the treatment of around 1,100 tons of PCB contaminated equipment and oil.

5.2 Project descriptionThe Tunisia PCBs management and disposal Project includes the following components:

Strengthening of the regulatory and institutional framework (Cost ): US$318,000)

- Establishment of the project management unit within ANGed;

- Improving the PCBs regulatory framework;

- Developing a good practice and technical PCBs management guide which will be made available to all PCBs contaminated equipment holders in Tunisia;

- Preparation of a cooperation agreement with STEG, if necessary (expertise, historic, analysis...);

- Preparation of a convention with competent laboratories to encourage them to acquire non-fixed and mobile measuring devices;

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- Preparation of a convention with the concerned waster holder ministries;

- Preparation of a separate convention with waste generators entities through the preparation of management program contracts, as defined by the PCBS good practices manual and PCB management techniques;

- Implementation of an oversight and monitoring PCBs management system and the carrying out of an inventory of national PCBs contaminated equipment;

- Ensuring private sector’s commitment to set up specialized business, approved by the Ministry of the environment, for repair and their reuse after decontamination (retrofilling or dehalogenation), removal, packaging, and sea and road transport.

Awareness-raising and training: (Cost: US$250,000)

- Develop an information and awareness-raising system for all those involved in the use and management of contaminated waste and equipment and/or containing PCBs

- Organize regular information and monitoring workshops and seminars, including sector participants

- Develop a training and awareness-raising program for the main stakeholders, such as: entities owning the equipment, the concerned administration, repair and maintenance companies, laboratories, NGOs,... etc

- Training activities and technical assistance for the PMU staff (training overseas, expertise, etc.)

Investments of PCB Management : (Cost: US$54.534 ,000)

The technical and economic feasibility study revealed that it would be more cost-effective to treat waste in a treatment facility abroad, particularly in Western Europe, given the current level of waste deposits and PCB-contaminated equipment in stock and in service (inventory updated in 2007).The retrofilling operation or dehalogenation process for the treatment of some processors (for reuse), including PCB contamination, does not exceed 2000 ppmThe objective of this component is to eliminate PCB-contaminated equipment and PCB wastes held by ten state companies1 associated with six ministries This component will include (a) the preparation of an environment assessment ; a geothechnical study and a study on the rehabilitation of the contaminated sites; (b) a decontamination of six-nine sites financed by counterpart funding; (c) the establishment a temporary storage facility in a separate location, for the storage of these oils if needed and required; (d) in country collection and transport and elimination of the PCB contaminated waste and equipment treatment facility outside Tunisia

. This process which is considered for the treatment of some processors is part of the previously mentioned deposit.The implementation of a storage area for the disposal of public entities PCB-contaminated operational equipment will be envisaged in hazardous treatment, storage, reception and transfer facilities (TSRTF).

1 STEG, Compagnie de Phosphate de Gafsa, El Fouledh, Societe Tunisienne d’Industrie du Raffinage, Societe Nationale C Papier Alpha, Group Chimique Tunisien, Industrie Chimique du Fluor, Societe de Transport en Pipe Line and Magasin General.

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One of the priorities of this project is the disposal of waste and equipment, equipment in use and in poor condition, in addition to all amenities in good condition in sensitive areas (schools, hospitals, urban areas, hotels, environmentally sensitive sectors).

The following steps will be carefully followed once waste and equipment disposal is scheduled (the same applies to waste from decontaminated sites):

On-site equipment dismantling and collection: This task is only performed by specialized companies approved by the Ministry of the Environment;

Disposal of operational or scrap PCB-contaminated oil transformers: This task is only performed by specialized companies by the Ministry of the Environment;

Equipment and oil wrapping and packaging: Oils will be collected in sealed barrels and placed in appropriate containers;

Site cleaning and decontamination: Only specialized companies approved by the Ministry of the Environment will be responsible for the cleaning and decontamination of PCB-contaminated sites. Contaminated waste will be collected, packaged, and transferred to the interim storage site;

PCBs interim storage: All waste (PCB-contaminated oil and equipment) collected will be stored in the TSDFs. It is an interim storage of no more than seven months (according to European directives) to facilitate waste management.

Transport in four different phases and according to regulations in force:

o PCBs land transport from the site to the interim storage Facility (TSDF);o PCBs land transport from the storage facility (TSDF) to the port of Tunis;o Shipping from the port of Tunis to the port of Marseilles or Genoa;o PCBs rail or land transport from Marseille and Genoa to the treatment facility;

PCB-contaminated waste and equipment treatment in a European facility: At treatment facility, wastes will be:

o received and verified (oversight of waste and material);

o Dismantled and broken down into several components (body, heart and winding, ceramics, paper and wood ...) with regard to transformers;

o Autoclaved: Once disassembled, all transformer parts will be decontaminated by autoclaving. solvents will be regenerated;

o Incinerated: (ceramics are discarded in landfills, wood and paper are incinerated, and metals are recovered);

o Condensers and PCB waste are incinerated.

These activities will be strengthened through the preparation of a PCB-contaminated waste and equipment good management procedures manual. The manual describes the various management phases by providing handling and various procedures to ensure a sound and rational management, in compliance with the Tunisian regulations and International recommendations.

Monitoring, evaluation, oversight, performance procedures implementation and technical assistance: (cost: US$120,000)

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- The establishment of a PMU to ensure project activities follow-up and monitoring through the allocation of responsibilities and the adoption of a participatory approach by all potential PCBs management participants.

The implementation of the first phase (the priority) will last four years. The implementation of the second phase (will last 12 years): operational PCB-contaminated and in good condition equipment, will include the following:

On-site retrofilling of transformers filled with PCB oil between 50 and 2000 ppm by weight, according to a proposed schedule, followed by the export of all PCB-contaminated oil to Europe for treatment;

Replacement of PCB-containing capacitors by non-PCB capacitors, according to a schedule covering a period lasting till 2025, followed by the export all PCB-containing capacitors, taken out of service, to Europe for treatment;

Replacement of PCB oil transformer stations (concentrations> 2000 ppm) by new non-PCB transformers, according to a schedule covering a period lasting till 2025, followed by the export of all PCB contaminated oil transformers, taken out of service, to Europe for treatment.

These activities will be included in a contract program entered into with the main entities owning PCB equipment, according to a schedule still to be defined and the overall project plan.

PCB sub-project expected results are:

Development of PCBs institutional and legal capacity Strengthening of management capacities at all levels Phasing out of stored PCB-containing transformers Development and implementation of a management plan for the gradual disposal of PCBs Ensuring private sector active participation

5.3 Project Environmental and Social Impact Assessment Framework

5.3.1 Potential impacts of the current PCB management

PCBs have adverse effects on the environment and health. These molecules are very poorly biodegradable, their release into the environment results in bioaccumulation with potential effects worrisome to both wildlife and human health. Therefore, they are among the persistent organic pollutants (POPs) banned by the Stockholm Convention.

The following matrix provides a summary of all potential impacts for the different project activities, including an assessment of their importance, their likelihood, as well as their rating as high, moderate, or low.

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Impacts significance and likelihood matrix (for the selected alternative)

PhaseImpact significance on:

Public health Surface water Groundwater Air Soil Fauna and

flora

PCB

Dismantling and collection moderate high moderate low high high

Retrofilling high high high moderate high high

Decontamination of the site where the article was found

moderate high moderate low high high

Transport to the interim storage zone moderate moderate minor moderate moderate moderate

Drainage and liquid collection moderate high moderate low high high

Packaging moderate moderate low low moderate low

Interim storage moderate high moderate high high high

Secondary transport (land and sea) low low low low low low

PhaseImpact likelihood

Public health Surface water Groundwater Air Soil Fauna and

flora

PCB

Dismantling and collection likely certain likely unlikely certain likely

Retrofiling certain certain likely likely certain likely


likely definite likely unlikely definite likely

Transport to the interim storage zone likely likely likely unlikely definite likely

Drainage and liquid collection likely certain likely unlikely certain likely

Packaging likely likely unlikely unlikely likely likely

Interim storage unlikely likely unlikely unlikely likely likely

Secondary transport (land and sea) unlikely unlikely unlikely unlikely unlikely unlikely

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5.4 Mitigation FrameworkThe mitigation measures for each management phase are as follows:

Project Activity Proposed Mitigation measuresSince this is an impact study framework, specific impact studies and environmental audits for interim storage sites will be conducted. The budget is allocated as port of the 2 subcomponent t to the project.

Dismantling and collection

Use of retention basin Operation must be performed by qualified agents from a specialized companyArticle must be collected in a metal drum or appropriate containerPrecautions must be taken to ensure laborers and passengers safetyCompliance with the good management procedure at every stage of handling


Environmental and geotechnical assessment to define the contaminated areaPrecautions must be taken to ensure the laborers and passengers safetyCollection and packaging of contaminated soils (considered PCB waste) in a sealed metallic, leak-proof, covered containerThe transport of this debris is considered hazardous material transport. Therefore, the hazardous materials transportation law must be complied withSoils must be treated along with the other waste and contaminated equipmentCompliance with the good management procedures manual

Transport to the interim storage zone

Compliance with the hazardous materials transportation regulationUse of appropriate leak-proof containers, with a liquid collection systemCompulsory labeling for contaminated equipmentThe area should be closed and protected from intrusion by persons or animalsDoors must have proper danger labeling and restricted access signageThe grounds must be separated into individual blocks, including paths wide enough for container movement and inspection. Remedial measures must be in place in case of leakage and accidentsRecommendations must be in place on maximum stockpiling for containersEach facility must have the required on-site emergency equipment

Drainage and liquid collection

Precautions must be taken to ensure the laborers and passengers safetyThe operation must be performed by a specialized company with experience in hazardous material handlingOperations must be conducted using leak-proof retention basin of appropriate dimensions for the equipment usedSufficient time must be allocated for complete drainage, i.e., until the last drop of oil has fallen from the equipment.Compliance with the good management procedures manual

Packaging

The operation must take place at the drainage site, without removing the retention basin. Compliance with the good management procedures manualCompulsory labelingIf transformers have been rinsed with solvent, exposure to these solvents should be taken into account, including appropriate cleansing measures

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Secondary transport (land and sea)

Optimization, as much of possible, of transport itinerary during peak-hours and away from national roadwaysCompliance with the hazardous material transportation regulation

5.5 Environmental and Social Management Framework and Cost Estimates

As previously mentioned, the selected alternative for PCB management consists of drainage and packaging of contaminated equipment on site and availability of an interim storage facility prior to transport to the coast for export.

Regarding PCBs, the project would include collection, packaging and transport for export and treatment overseas. ANGed wil ensure that during the collection, packaging and transport within Tunisia, visual environmental audits would be conducted by independent consultants for all PCB sites. If audit results show potential negative impacts, a specific environmental and social environment assessment will be prepared, in accordance with the Environmental and Social Impact assessment Framework (ESIAF) and included in PCBs disposal bidding documents. The ESMPs for PCB sites will identify the need for a rehabilitation and decontamination site plan which will be published on ANGed’s website. Regarding PCB treatment overseas, the operator will comply with the recipient country’s regulations and directives for hazardous waste treatment. The bidding documents will require that proposals provide detailed procedures, conditions and guidelines to be followed during the treatment of PCBs overseas. Non-compliance with these procedures will result in the proposal being rejected.

Specific impact studies or environmental audits will be prepared for pre-identified sites and those still to be confirmed (locations of contaminated or scrap equipment), including pollution characteristics.

This audit will include:

- Investigations on site pollution through soil analyses and underground probes to detect the presence and the extent of PCB contamination

- A study on pollution eradication measures of PCB contaminated soils will be prepared- A specific EMP for each site

The ESMP framework has been prepared in accordance with OP 4.01 (Environmental Assessment) and with Decree No. 2005-1991 of July 11, 2005.

o This plan includes mitigating , monitoring and institutionla measures to be applied during the implementation of selected PCB option. The EMP includes Specific environmental impact studies or detailed environmental audits will be prepared for sites for which a visual inspection audit showed potential negative impacts

o Measures to mitigate or repair, and/or compensate for adverse impacts on the environment and their cost estimates

o Environmental monitoring measures and their costs estimates

o Institutional measures including the preparation of an operational manual

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The incremental costs of the preparation of the site specific-or group specific environment management plans or environmental audits were estimated at US$ 154,000. Decontamination of the sites was estimated at US$ 515,000. This is over and above the cost of institutional strengthening and investments related to PCB treatment of US$ 829,000 and 4.26 million respectively

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ESIA –Tunisia PCBs management and disposal and HCW management improvement ProjectExecutive Summary ANGed – June 2010

Project Activity Potential Impacts on the Environment and Health Proposed Mitigation Measures Institutional

Responsibilities Cost Estimates Comments

Dismantling and Collection

Pollution of soil, surface and groundwater by accidental oil spills. Risk of injury/accidents for staff and laborers. Risk of contamination of fauna and flora.

Use of leak-proof retention tanks. Operations should be conducted qualified agents of specialized company.The collected substance should be stored in a metal tank or appropriate container.Precautions must be taken to ensure laborer and passenger safety.Good management procedures manual must be complied with for each operation.

Holding entity.Private company

3,865,000(Priority treatment phase)

Licensed company in handling of equipment containing PCB oils

Transport to interim storage areas

Traffic congestion.Risk of PCB oil seepage which can pollute the natural environment and public health along the transport route.

Compliance with hazardous material transport regulations.Use of appropriate sealed containers to avoid seepage, equipped with leak-free collection system.Compulsory labeling for contaminated equipment.

Private company

Licensed companies specialized transport of hazardous material

Storage Area

Risk of contaminated debris spills which can pollute the natural environment (groundwater, surface water runoff, fauna and flora) and negatively affect public health The area must be closed off and well protected against human and animal intrusions.

The area must be closed off and well protected against human and animal intrusions.Access doors must have locks , danger and restricted access signageThe grounds must be divided into blocks separated by paths wide enough for container access and be inspected against leakage Each storage facility must be equipped with appropriate emergency equipment

ANGed and/or a private company

Preparation of ESIA required for future interim storage facility


Risk of oil seepage. Laborers and agents can come into direct contact with contaminated oils during handling phases.Contamination of soil, surface water, fauna and flora.

Precautions must be taken to ensure the safety of laborers and passengersThe operation must be conducted by a specialized company qualified in this type of hazardous material handlingOperations must be conducted using a leak- proof retention basin adapted to the equipment dimensionsAllow sufficient time to complete drainage, i.e., until the last drop of

Private company Licensed company specialized in handling containing PCB oils equipment

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oil has fallen on the equipmentCompliance with the good management procedures manual

400,000(Technical Assistance)

Packaging

Laborers and agents can come into direct contact with contaminated oilsRinse water can contaminate soils or infiltrate groundwater in ONAS network. This contaminated water poses a risk to local fauna and flora

The operation must be conducted at the drainage site without removing the retention basinCompliance with the good management procedures manualCompulsory labelingIf transformers are rinsed with a solvent, potential exposure to these solvents must be acknowledged and appropriate remedial measures must be taken.

Private company

Licensed company specialized in handling equipment containing PCB oils

Secondary transport (land and sea)

Traffic congestion Optimization of transport itinerary, avoiding peak hours and national roadways as much as possible Compliance with hazardous material transport regulations

Private company

Licensed company specialized in hazardous material transport

Export and treatment of PCB equipment and waste to Europe

Treatment will take place in a licensed and specialized facility MEDD

ANGedHolding company

Technical assistance required

Site decontamination

Risk of spreading pollution to other areasRisk of laborers contaminatingDust formation Risk of accident or spillage of contaminated debris during transport human health along transport routes which can pollute the natural environment and negatively affect human health along transport routes

Environmental and geotechnical assessment of the contaminated area.Precautions must be taken to ensure laborers and passengers safetyCollection and treatment of contaminated soil (considered PCB waste) in leak-proof and covered metal container Transport of this debris is considered hazardous material transport and must be in compliance with hazardous material transport regulationsTreatment of this soil, debris and contaminated equipmentTreatment of this soil, debris and contaminated equipmentCompliance with the good management procedures manual

Holding companyPrivate companyANGedAuthorities

154,,000(environmental audits and site

characterization

515,000(decontaminatio

n activities)

Licensed and specialized company in decontamination of polluted soilRequirement to carry out ESIAs and EMPs for individual or group sites

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5.6 Environmental and Social Monitoring Framework

Proposed Mitigation Measures Parameter Checklist Sites Data and/or

measures Frequency of

Measures

Norms and Requirements to

be enforcedResponsibilities Cost (US$)

Dismantling and collection

Confirmation of PCB presenceLeaks and oils

Original siteOil analysisVisual

One measure per treatment facility

Presence of 50 ppm of PCBs in oil

Holding entity ANGedPrivate companies

US$ 200/position

Site decontamination Contamination specificationsContaminated surfacePCB concentration

Original site

VisualOlfactoryControl and validation of contamination specification and environmental auditFinal analyses following decontamination

Based on study and surveyFollowing decontamination works

PCB presence

ANPEANGedPrivate companiesHolding entities

US$500/site

Transport to interim storage site

Transport vehicleCondition of substance container

Visual Every transport operation

Hazardous material transport law

Authorities Private companies -


Condition of retention basinEquipment to be usedOperator safety requirements

Original storage site Visual Every drainage

operation

ANPEANGedPrivate companies

-

Packaging Equipment to be usedOperator safety requirements

Interim storage site

visual Every packaging operation ANPE

ANGedPrivate

-

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companies

Subsequent transport (land and sea) Containers, vehicles visual Every transport

operation

hazardous materials transportation law

MEDDANGED private companies

-

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5.7 Capacity-Building and Training

This component includes capacity-strengthening and requires training measures for ANGed, STEG and other entities involved in the application of the PCB management plan.

5.7.1 Implementation of oversight and performance procedures, training and technical assistance

This component includes: The establishment of a Project Management Unit (PMU) within ANGed, responsible for the

implementation, coordination and financial management of the PCB management project Organization of public awareness and training campaign Technical assistance, including the preparation of a procedures and good management

manual and environmental audits.

5.7.2 Management Structure for PCB Project Activities

A project management structure is planned. This structure will focus on the monitoring and oversight of the implementation of activities under the program during a four-year period. This unit will also be responsible for:

a) Preparation of a good PCB management procedures manual by a team of experts;

b) Sub-contracting of national consultants or consulting firms for the preparation of environmental audits of PCB storage sites, including a remediation plan for soil contamination;

c) Monitoring of and adherence to the application of the environmental and social management framework, and compliance with specific environmental and social management plans for storage sites.

The Project Management Unit (PMU) will have the following structure:

Project team leader in charge of the PMU: an engineer specialized in hazardous materials management with experience in PCBS contaminated equipment management;

Three assistant level technicians specialized in electrical work (trained in PCB-related operations): one for the Grand Tunis and the northern region, one for the central region and the Sahel, and one for the southern region;

PMU Secretariat; Internal expertise and assistance;


Office equipment; One vehicle.

The PMU will be located within ANGed and will have the authority to monitor and oversee all program operations and the competency and the means to ensure compliance with the environmental and social management plan following specialized and targeted training programs. The budget below is the the first subcomponent of the project on insititutional strengthening

Institutional strengthening

activitiesPositions Timetable responsibilities

Preparation of a good management manual

PMUThree months after loan signing

PMU and ANGed

Environmental audits PMU

During project and prior to implementation

PMU, ANGed and consulting firms

Mitigation PMU (within ANGed)

From project launch until completion

Implementation, monitoring, evaluation and organization of workshops during project implementation

Monitoring PMUFrom Project until completion

Compliance with timetable and monitoring of compliance with mitigation measures

Cost of Institutional Strengthening and awarenss US$558,000

Training Activities Participants Type of Training Content Timetable

EMP

ANGedANPEMEDDContaminated waste holding partiesPrivate companies

Seminars

General project data, including plan and an environmental monitoring planPCB Contaminated waste handlingInternational law and agreement on PCB management and exports of hazardous waste

First year of PCB management project plan

Environmental process, methodology and equipment

ANGedANPEMEDDConsulting firmsPrivate companies

Seminars and public information day

Information on PCB available management technologies and international management practices

Periodically, during the first two years of project planning

Environmental policy and program

ANGedANPEMEDDHolding entitiesConsulting firms

Seminars and workshops

Strategies and objectives of the environmental policy for PCB managementIn Tunisia

Periodically, during the third year of project planning

Training Cost and Technical Assistance US$271,000

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Timetable for Management plan implementation [2011-2025]

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6. PUBLIC CONSULTATIONS

In order to ensure consultations and coordination with government entities as well as NGOs and the civil population concerned, a presentation on the project and its management plan was held. This consultative process has helped to strengthen public trust in the project concept and its implementation.

The presentation was held on February 11, 2009, at ANGed, and participants included public and private health facility representatives, contractors, storage owners and equipment sites with equipment containing PCB oils, and those affected by the HCW management project.

The Project leader gave an overview of project objectives. An overview of the related technical assistance efforts was also presented.

The two sub-project leaders described the current HCW management and PCB handling situation in Tunisia and described the management actions envisaged under the project.

Finally, the consulting firm presented the impacts, mitigation measures, ESMP and capacity-building measures related to PCB and HCW management.

Public Consultation Findings

The public consultations on the HCW and PCB management project in Tunisia have achieved their objectives. The debate even bolstered the impact assessment and its components through recommendations and comments provided by the audience.

The participants thus confirmed the importance of the project and their endorsement of its upcoming implementation. They also expressed their concurrence with the planned mitigation measures during implementation of the envisaged HCW and PCB management actions.Some participants requested that the companies and industries that will benefit from the project should have qualified staff for the monitoring and follow up on environmental measures .Also awareness campaigns should be increased specifically on health impacts related to HCW and PCB and NGOs should be more involved. All these recommendations were included in the project component on institutional strengthening. Other participants requested that the treatment of HCW should be left open as there could be new technologies that can be more adapted in Tunisia and that existing equipment containing PCBs should be also replaced, The response form the project team is that the choice of the autoclaving technology was found to be the most advantageous from the technical, financial and environmental point of view and used worldwide. If new HCW treatment technologies would be commercially available they could be subsequently considered. With regards to the replacement of PCB oils equipment, the project will fund only the disposal of off-line PCB equipment and does not have funds for replacing on line equipment containing PCBs

Details on the consultation are included in the ESIAF Report.

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Acronyms

ANCSEP: Agence Nationale de Contrôle et de Surveillance Environmentale des produits - National Agency of Sanitary and Environmental Control (under the MSP)

ANPE: Agence National de protection de l’Environnement,National Environment Protection Agency, under the Ministry of Environment and Sustainable Development (www.anpe.nat.tn)

ANGed: Agence Nationale de Gestion des déchets, under the Ministry of Interior and Sustainable Development (www.anged.nat.tn) Tunisian Waste Management Agency

CTF: Common Treatment Facility (for HCW)

PCC: Project Coordination Committee

CPG: Compagnie des Phosphate de Gafsa – Tunisian Phosphate Industry

DHMPE: Direction de l’Hygiène du Milieu et de la Protection de l’EnvironnementDepartment of Environmental Hygiene and Environment protection, under the Ministry of Public Health

GCT: Groupe Chimique tunisisenTunisian Chemical Group

HW : Household Waste

HCW : Healthcare Waste

ICF: Industrie chimique du Fluor – Chemical Fluorine Industry

IHCW: Infectious Healthcare Waste

IMC: Inter-ministerial Council (Conseil Interministériel)

INS: Institut National des StatistiquesNational Statistical Institute

Magasin Géneral:

Tunisan retail store chain

MARH: Ministère de l’Agriculture et des Ressources HydrauliquesMinistry of Agriculture and Water Resources

MEDD: Ministère de l’Environnement et du Développement Durable Ministry of Environmental and Sustainable Development(www.environnement.nat.tn)

MEHAT: Ministère de l’Enquipement, de l’Habitat et de l’Aménagement du Territoire Ministry of Equipment, Habitat and Land Management

MOR: Moderate Occupancy Rate

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http://www.anpe.nat.tn/


MSP: Ministère de la Santé Publique Ministry of Public Health

ONAS: Office National d’Assainissement – National Office of Sanitation

PCB: Polychlorinated Bipheny

PCT: Polychloro Terphenyls

POP: Persistent and Organic Pollutants

Ppm: Part per million or milligram per kilogram- 50 ppm ≈ 50 mg/kg ≈ 0.005%- 1 mg PCB/kg ≈ 1 ppm PCB- 1 % PCB ≈ 10,000 ppm PCB- 100 % ≈ 1,000,000 ppm

RSTF: Hazardous Waste Reception, storage, and Transfer Facility

SACEM: Société Anonyme de Constructions Electro-MécaniquesA leading electrical distribution manufacturer located in Menzel (Bourguiba (Tunisia), specialized, since its creation in 1996, in the production and the sale of various electrical distribution transformers

SNCPA: Société Nationale de Cellulose et de Papier Alfa, located in Kasserine Public Company specialized in manufacturing esperato pulp

Sté El Fouledh:

A Steel mill

STEG: Société Tunisienne de l’Electricité et du GazThe Tunisian Company of Electricty and Gas The company, has a monopoly on the production, transmission and distribution of electricity in Tunisia

STIR: Sté Tunisienne de l’Industrie de RaffinageTunisian Company for Refining Industries

SOTRAPIL:

Société de transport des hydrocarbures par pipelinesTunisian oil and gas pipeline operator

SOTULUB: Société Tunisienne de Lubrifiants, located inBizerte (Tunisia), is a Tunisian company of lubricating oil, specialized in the treatment of waste oils

PMU Project Management Unit

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CONSULTING FIRM PROFILE

The study was carried out by the Consulting Firm GEREP-ENVIRONNEMENT

Address: 17 Rue Mustapha Abdessalem, El Menzah 5, 2037, TUNISIATel: +216 71 752976 fax: +216 71234825e-mail: [email protected]

The project team includes:

Key Technical Personnel:

Mr. Kamel Ben Mahmoud, Environmentalist, Senior Environmental Engineer

Mr. Mohamed Salah Matoussi, Specialist and environmental Economist, PhD in Economics

Support Technical Personnel:

Mr. Slim Ferchichi, Environmental Engineer

Mr. Fadhel Lahyani, Environmental Engineer

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http://www.gerep-environnement.com/

mailto:[email protected]

Documents

Sommaire exécutive de l’EIES relative à la gestion des …documents.worldbank.org/.../E23210v20P10041SIAF10S… · Web viewAGENCE NATIONALE de GESTION DES ... and on the World