INTEGRATED SAFEGUARDS DATA SHEET APPRAISAL STAGE Report No.: ISDSA260 Public Disclosure Copy Date ISDS Prepared/Updated: 17-Mar-2014 Date ISDS Approved/Disclosed: 20-Mar-2014 I. BASIC INFORMATION 1. Basic Project Data Country: Egypt, Arab Republic of Project ID: P116230 Project Name: Egypt: Sustainable POPs Management Project (P116230) Task Team Alaa Ahmed Sarhan Leader: Estimated 10-Mar-2014 Estimated 25-Apr-2014 Appraisal Date: Board Date: Managing Unit: MNSEE Lending Specific Investment Loan Instrument: GEF Focal Persistent Organic Pollutants Area: Sector(s): Central government administration (50%), Sub-national government administration (50%) Theme(s): Pollution management and environmental health (67%), Environmental policies and institutions (33%) Public Disclosure Copy Is this project processed under OP 8.50 (Emergency Recovery) or OP No 8.00 (Rapid Response to Crises and Emergencies)? Financing (In USD Million) Total Project Cost: 23.60 Total Bank Financing: 0.00 Financing Gap: 0.00 Financing Source Amount Borrower 15.50 Global Environment Facility (GEF) 8.10 Total 23.60 Environmental A - Full Assessment Category: Is this a No Repeater project? 2. Global Environmental Objective(s) Page 1 of 9 The project development objective is to demonstrate the improved management and disposal of targeted POPs stockpiles and PCBs in an environmentally sound and cost-effective manner. 3. Project Description Public Disclosure Copy Component 1: Destruction of High Risk Stocks of Obsolete Pesticide (US$ 3.83 million) Activities under this Component are focused on the environmentally sound disposal of high risk stocks known and inventoried at time of project appraisal. These activities directly support the PDO in the safe packaging, removal, transportation and destruction of high-risk stocks of pesticides, in state-of-the-art facilities overseas, and will provide hands-on experience and expertise for sustainable management of POPs wastes. MALR will have the lead in executing this component. Of the total 2,250 to 4,600 tons of obsolete pesticides that are stockpiled, it is estimated that 10 to 30% could be POPs pesticides. This component will support the disposal of at least 1000 tons of identified stocks of POPs and other high-risk obsolete pesticides, following a risk-based prioritization approach. It was determined during project preparation that disposal of the stockpiles at Al-Adabeya port and El-Saff would be financed as priority under this component. The former is adjacent to international waters; the latter is in the middle of a densely populated neighborhood. The component will finance re-packaging and export to an international disposal facility and site clean-up. Details of these two sites are provided below: a. The Al-Adabeya port storage facility was built in 1975 and dedicated for the storage of dry bulk. It is estimated that about 220 tons of Lindane, a POPs pesticide, has been stored at the port since 1998. The Lindane is packed in 25 kg plastic bags supported by a heavy paper outer wrapping and stored in 10 standard containers. The activity for disposal of the stockpiles at Al-Adabeya Port will commence immediately upon Board approval of the project. b. The El Saff storage facility has about 444 tons of pesticides, which comprises of 6.5 tons of POPs (including 3.9 tons of DDT (Dichlorodiphenyltrichloroethane), 1.9 tons of Lindane). The site Public Disclosure Copy has been in use for many years and shows clear signs of spillage of chemicals and leakage, from corroded or otherwise damaged and/or overturned containers. Over the years, the neighborhood has become more populated and the site is surrounded by dense residential areas at a distance less than 100 m. Additionally, the storage site also contains a granary of food stocks next to the these obsolete stockpiles. c. In addition, the project will support the identification of all high risk stockpiles, and dispose of another approx. 350 tonnes of high risk stocks currently scattered across a number of sites. The MALR’s Central Agricultural Pesticides Laboratory will have an important role under the project, mainly to identify unlabeled products uncovered, as necessary, and to analyze pesticide samples. The laboratory is reasonably well equipped as it does routine testing for the registration of agricultural chemicals; however the component will finance minor technical upgrading, as needed. The MSEA / EEAA will enhance its environmental management system to promote the identification, packaging, removal, transportation and destruction of high risk stocks of obsolete pesticides, consistent with Egypt’s international obligations under the Stockholm and Basel Conventions. It will do so through a learning-by-doing approach to immediately address the high risk stockpiles of obsolete chemicals which require immediate attention. Staff in EEAA and the cooperating ministries will be trained to track and monitor obsolete stockpiles and ensure the ultimate destruction of high risk stockpiles. This component will also support Project Monitoring and Evaluation and will support EEAA in enhancing the existing system of tracking obsolete pesticides to ensure sustainable project outcomes and monitoring of project performance indicators Page 2 of 9 (including needs for field monitoring and data processing). Dissemination of results, including awareness of the general population will also be supported. Public Disclosure Copy Component 2: Decontamination of PCB-containing transformer oils (US$ 4.27 million) Activities under this Component will focus on the procurement of equipment for dechlorination and purification of PCB contaminated oils, which will produ ce an oil suitable for reuse in transformers. These activities directly support the PDO in the management of PCBs and PCB related equipment, and will provide hands-on experience and expertise of EEAA and MOEE/EEHC staff to address the decommissioning of PCB transformers. MOEE/EEHC will have the lead in executing this component. It is estimated that the total number of transformers in Egypt is over 100,000, of which 10 to 40% can be expected, based on the situation in similar countries, to be contaminated by PCBs at a level above 50 parts per million (ppm). This is the threshold above which is the Stockholm Convention mandates environmentally sound management, based on the potential for harmful effects on human health and the environment. Egypt has received funds under a parallel UNEP managed GEF project, MEDPOL, which will target and dispose of high-concentration PCBs which are expected to be present in relatively small amount in the country. The focus of this component is therefore on decontaminating/dechlorination of low to medium-concentration stocks of PCB-contaminated transformer oils, which when decontaminated, can be reused. In view of the importance for PCB management and size of the sector, the project is moreover focused on PCBs in the public electricity generation and distribution sector. Dechlorination of PCB contaminated oil for re-use as a fuel or for insulation is often a cost-effective local solution where there is sufficient volume of medium-level PCB contaminated oil, as is the case in Egypt. The project will support the procurement of appropriate technology that is cost-effective for EEHC - which will include a dechlorination unit and a Fuller’s Earth facility of suitable size to purify the oil for re-use. During the course of the project, EEHC would operate its decontamination equipment to process as many of the PCB transformers as possible, and to recycle oils and other materials for further reuse. During the course of the project, 1,000 tons of PCB-contaminated oil will Public Disclosure Copy be targeted at a minimum. Remaining decontamination needs after project closing would be continued with GOE funding and the staff trained under the project. Instruments for sampling to measure the level of PCBs, chemicals, and electronic equipment will be financed from this component. Laboratory support might be needed to confirm levels of PCB contamination in the transformers. Small allowance has been made under the project for any upgrading needs for this project. For such cases, the EEAA’s laboratory, which has gas chromatography capacity, could handle such analyses, or another laboratory with existing capacity for testing trace contaminants could be upgraded as appropriate. The MSEA/EEAA will enhance its environmental management system to promote the identification and decontamination consistent with Egypt’s international obligations under the Stockholm. This component will also support Project Monitoring and Evaluation and will support EEAA in enhancing the existing system of tracking PCBs to a comprehensive one based on international best practice examples. Attention will be given to making available the necessary monitoring and data processing equipment, software, staffing and training and also addressing the needs for sustaining the system after project closure. The PMU will develop a system for monitoring project performance indicators (including needs for field monitoring and data processing). Staff in EEAA and the Cooperating Ministries will be trained to produce data needed for quarterly project reporting. Dissemination of results, including awareness of the general population will also be supported. Page 3 of 9 4. Project location and salient physical characteristics relevant to the safeguard analysis (if known) The National Implementation Plan (NIP) for Egypt included a national inventory of POPs which is Public Disclosure Copy being used to design theproject. The inventory identified the location, quantity, and in some cases, the composition obsolete pesticides throughout Egypt. 5. Environmental and Social Safeguards Specialists Sherif Kamel F. Arif (MNSSU) Chaogang Wang (MNSSU) Africa Eshogba Olojoba (MNSEE) 6. Safeguard Policies Triggered? Explanation (Optional) Environmental Assessment OP/ Yes In lieu of preparing an environmental and social BP 4.01 impact assessment (ESIA) report for the project as a whole, in accordance with OP 4.01, the Bank and the GOE have assessed the Use of Country Systems (UCS), as set forth in OP 4.00. In fact, the Bank has accepted the UCS in Egypt for the Egypt-Pollution Abatement Project II (EPAP II) and gaps between the World Bank OP 4.01 policies and the Egyptian EIA system were mostly removed, Bank staff have extended the EPAP II Safeguards Diagnostic Review (SDR) to include hazardous waste and emissions, and has assessed the equivalence of the new EIA legislation of 2009 with the Bank policies for EA, and the application of the new Egyptian Public Disclosure Copy legislation on hazardous wastes and emissions. Gaps and measures to remove these gaps were identified in the SDR and agreed upon. Natural Habitats OP/BP 4.04 No Forests OP/BP 4.36 No Pest Management OP 4.09 Yes Given that the existence of POPs stockpiles is partly the result of past mismanagement of pesticides, the UCS work was also extended to assess the capacity of the country’s regulatory framework and institutions to promote and support safe, effective, and environmentally sound pest management. Gaps and measures to remove these gaps were identified in the SDR and agreed upon. Physical Cultural Resources OP/ No BP 4.11 Page 4 of 9 Indigenous Peoples OP/BP 4.10 No Public Disclosure Copy Involuntary Resettlement OP/BP No Storage facilities to be used are already existing 4.12 on public lands. No new construction that might entail land acquisition or resettlement is included in the project. Safety of Dams OP/BP 4.37 No Projects on International No Waterways OP/BP 7.50 Projects in Disputed Areas OP/BP No 7.60 II. Key Safeguard Policy Issues and Their Management A. Summary of Key Safeguard Issues 1. Describe any safeguard issues and impacts associated with the proposed project. Identify and describe any potential large scale, significant and/or irreversible impacts: The project is essentially a POPs and PCB management project which will bring substantial environmental health benefits, both locally and globally.The project will safely dispose of obsolete pesticide stocks, establish preventive measures to avoid future accumulation, remove and dispose of PCB-contaminated equipment and prepare plans for remediation of contaminated sites. The project components include the mitigation, monitoring and institutional measures to reduce/ eliminate the adverse project impacts. The proposed project will not have significant adverse environmental impacts on human populations or environmentally important areas (e.g. natural habitats) that are sensitive, diverse, or Public Disclosure Copy unprecedented, and may take place in areas broader than individual sites or facilities subject to physical works. The project’s potentially adverse socio-environmental and health impacts are anticipated to be negligible to medium in magnitude and potential significance. All impacts are primarily site specific, can be contained within the existing POPs pesticides and PCBs site boundaries, and none of them is irreversible. The main potential adverse direct, cumulative and indirect socio-environmental impacts are related to: possible POPs pesticides and PCBs leakages and contamination at and nearest area around storages and burial sites during repackaging of old POPs sites and centralization in the selected temporary storage facilities due to the presence of workers; possible air pollution, soil and water contamination during POPs burial openings, accidents during national and international transportation, temporary storage prior to export shipment. 2. Describe any potential indirect and/or long term impacts due to anticipated future activities in the project area: No potential negative indirect impacts of the proposed project activities can be discerned at this stage. However, improved public awareness of the dangers of hazardous chemicals and the stringent measures needed for their safe handling may well put pressure on the authorities to exercise greater diligence in the handling of other hazardous substance – a positive indirect impact. Page 5 of 9 Long-Term Impacts: The international concern about POPs and the rationale for the Stockholm Convention and the present project owes much to the persistence of these particular toxic Public Disclosure Copy chemicals; they do not break down in the environment and accumulate in the food chain and human tissue over time. Thus the project is aimed directly at mitigating these long-term potential impacts. 3. Describe any project alternatives (if relevant) considered to help avoid or minimize adverse impacts. Two possible alternatives for the elimination of PCB equipment and obsolete pesticides exist: (1) export or (2) treatment within the country and export of carcasses in case of PCB equipment. The latter is not possible in practice (except in low concentrations) due to the lack of skills, equipment and disposal site necessary for treatment within the country; thus the Government is more favorable of the export alternative, as the most viable one. GEF would finance only part of the cost associated with the elimination of the PCB equipment and obsolete pesticides. 4. Describe measures taken by the borrower to address safeguard policy issues. Provide an assessment of borrower capacity to plan and implement the measures described. In accordance with OP 4.00, the World Bank conducted a Safeguard Diagnostic Review (SDR) to determine the equivalence and adequacy of the national system for environmental impact assessment and pest management and subsequently identify any existing gaps. The results of the equivalence assessment showed that the World Bank's Operational Policies and the Egyptian safeguards systems on Environmental Assessment, as amended in 2009, are nearly fully equivalent. The SPMP sets out to improve pesticide and pest management issues including prevention, and cleanup as well as measures directed towards the strengthening of pesticide management and promotion of Integrated Pest Management (IPM). The SDR concluded that the national pest management system meets all the Pest Management Plan requirements. The major gaps are related to weak coordination among EEAA departments involved in POPs, insufficient compliance with the requirements of the Stockholm Convention, lack of procedures Public Disclosure Copy guidelines of POP projects, insufficient knowledge on PCBs and POPs contract management, weak enforcement for PCBs and lack of assessment of the quality of the ESIAreports. Remedial measures which were identified these gaps with a proposed schedule, include the preparation of an operational manual which delineate functions and responsibilities during the ESIA process, completion of legal and regulatory framework pertaining to the Stockholm Convention, development of ESIA procedural guidelines for POPs, provision of training to EEAA staff and sector ministries and NGO development of an environmental register of POPs sites, and assessment of quality of the ESIA reports every two years. During project preparation, a preliminary hazardous waste and risk assessment was conducted for two potential Intermediate Collection Centers (ICCs) -Nassriya Hazardous Waste Center and El Saff Storage Site. A feasibility study, preliminary site and risk assessment was also undertaken for the Al-Adabeya port. In accordance with the national EIA system all subprojects will be reviewed and approved by the EEAA/ EIA department (which is independent from the PMU) including consultation and disclosure at the EEAA website (www.eeaa.gov.eg) before construction starts. Also grievance redressal mechanisms and consultations prior to sub-project specific ESIAs/ESMPs and physical interventions will be undertaken, documented, monitored and included in project activity reports. Up to 15comprehensive ESIAs/ESMPs, including in-depth risk assessments, will be conducted for Page 6 of 9 all sites which have been identified to be supported under the project for either disposal and clean- up or creation of safe storage sites. Comprehensive safeguard standards and mitigation measures to be incorporated in all contracts under the project involving hazardous materials or sites, based Public Disclosure Copy on best international practice for POPs chemicals. The yearly project implementation schedule to be prepared by the PMU will reflect the time line and number of ESIA/ESMP to be prepared by independent consultants and formally approved by EEAA/ EIA department which is totally independent from the PMU.The Bank will also responsible to review during the first 18 months, all the subprojects- specific ESIA and ESMPs. The expansion/reorganization of the EEAA Departments is one of the indications that the Ministry of State of the Environment is committed to the improvement of the environment. The Central Inspection Department has been reorganized into a Sector Department with specific functions and responsibilities whereas it consists of two General Directorates. The EEAA has also established a new Sector Department for the Protection and Improvement of Industrial Environmental and Energy to support the industry in improving their environmental performance on a voluntary basis. These two departments were understaffed. Now they are functional and working. Furthermore, there has been a constructive coordination between the three sector departments namely environment management, industrial environment and environmental inspection and environmental compliance on agreeing of projects that would be eligible for EPAP II or PPSI financing. Such coordination is expected to be replicated in the POPs projects as the three departments will be involved in project implementation. There are also still some weaknesses in the EIA system and in EEAA’s monitoring and enforcement. These are: a) Lack of knowledge related to POPs and PCBs and technologies for their management and disposal, Component 1 of the project will include a program to raise awareness and strengthen its position in political decision making in Egypt in order to convince stakeholders that there is an urgent need to solve POPs problems and implement the Stockholm Convention. b) Limited staff resources in the department of hazardous waste management. A Public Disclosure Copy comprehensive training program both technical and managerial in is included in Component 1 of the Project. It includes sound management of PCB and pesticides, secure storage of pesticides, best environment practice and best available technology for treatment and disposal of POPs and PCBs. c) Limited inter-ministerial cooperation on hazardous waste management. In order to strengthen such collaboration, the overall project coordination would be the responsibility of the POPs Project Steering Committee (PPSC), which would be formed. It would be chaired by the CEO of EEAA and would have senior representatives of the Cooperating Ministries, the Project Director and Project Manager. The PPSC would meet monthly to oversee project implementation matters and, approve the selection of the sub-projects and oversee the implementation of the different project components d) Insufficient public communication and awareness raising on hazardous waste and in particular with POPs The Project will also finance a dedicated sub-component 1,2, on Public Awareness and Participation with the objective to develop and maintain a system for informing stakeholders of the nature and dangers of POPs (and other hazardous substances), and for inviting public participation in decision-making related to such substances; and e) Shortcomings of monitoring and enforcement for obsolete pesticides and PCBs.project. The POPs Project will replicate the system of coordination successfully implemented in EPAP II whereby the PMU of EPAP II meet regularly with the cooperation between GDEIEC, the EIA Department to plan ahead the preparation and review of the EIA as well as the inspection and Page 7 of 9 compliance activities. Furthermore, the hazardous waste management strategy that will be developed during the project will include specific actions for reinforcing the application of the law regarding hazardous waste and in particular the OPs and PCBs. Public Disclosure Copy 5. Identify the key stakeholders and describe the mechanisms for consultation and disclosure on safeguard policies, with an emphasis on potentially affected people. A public consultation meeting was held on June 13, 2012 and attended by 64 representatives from ministries (Environment, Electricity and Energy, Industry, Planning and International Cooperation), research institutes and universities, 3 media representatives as well 16 NGOs. The workshop was conducted in Arabic. The meeting was chaired by the acting Chief Executive Officer of the Egyptian Environment Affairs Agency (EEAA); a list of the issues raised and comments made by the attendees and reviewers, and remarks/responses to these comments in included as in Section XI to the SDR report. B. Disclosure Requirements Environmental Assessment/Audit/Management Plan/Other Date of receipt by the Bank 10-Nov-2011 Date of submission to InfoShop 13-May-2013 For category A projects, date of distributing the Executive 13-Nov-2011 Summary of the EA to the Executive Directors "In country" Disclosure Egypt, Arab Republic of 13-Jun-2012 Comments: Pest Management Plan Was the document disclosed prior to appraisal? Yes Date of receipt by the Bank NA Date of submission to InfoShop NA Public Disclosure Copy "In country" Disclosure Egypt, Arab Republic of // Comments: If the project triggers the Pest Management and/or Physical Cultural Resources policies, the respective issues are to be addressed and disclosed as part of the Environmental Assessment/ Audit/or EMP. If in-country disclosure of any of the above documents is not expected, please explain why: C. Compliance Monitoring Indicators at the Corporate Level OP/BP/GP 4.01 - Environment Assessment Does the project require a stand-alone EA (including EMP) Yes [ ] No [ ] NA [ ] report? OP 4.09 - Pest Management Does the EA adequately address the pest management issues? Yes [ ] No [ ] NA [ ] Is a separate PMP required? Yes [ ] No [ ] NA [ ] Page 8 of 9 If yes, has the PMP been reviewed and approved by a Yes [ ] No [ ] NA [ ] safeguards specialist or SM? Are PMP requirements included Public Disclosure Copy in project design?If yes, does the project team include a Pest Management Specialist? The World Bank Policy on Disclosure of Information Have relevant safeguard policies documents been sent to the Yes [ ] No [ ] NA [ ] World Bank's Infoshop? Have relevant documents been disclosed in-country in a public Yes [ ] No [ ] NA [ ] place in a form and language that are understandable and accessible to project-affected groups and local NGOs? All Safeguard Policies Have satisfactory calendar, budget and clear institutional Yes [ ] No [ ] NA [ ] responsibilities been prepared for the implementation of measures related to safeguard policies? Have costs related to safeguard policy measures been included Yes [ ] No [ ] NA [ ] in the project cost? Does the Monitoring and Evaluation system of the project Yes [ ] No [ ] NA [ ] include the monitoring of safeguard impacts and measures related to safeguard policies? Have satisfactory implementation arrangements been agreed Yes [ ] No [ ] NA [ ] with the borrower and the same been adequately reflected in the project legal documents? III. APPROVALS Task Team Leader: Name: Alaa Ahmed Sarhan Public Disclosure Copy Approved By Regional Safeguards Name: Maged Mahmoud Hamed (RSA) Date: 18-Mar-2014 Advisor: Sector Manager: Name: Charles Joseph Cormier (SM) Date: 20-Mar-2014 Page 9 of 9