THE REPUBLIC OF TUNISIA
MINISTRY OF ENVIRONMENT AND SUSTAINBLE DEVELOPPEMENT
AGENCE NATIONALE de GESTION DES DECHETS
E2321
V2
DEMONSTRATING AND PROMOTING BEST TECHNIQUES AND PRACTICES FOR MANAGING
HEALTHCARE WASTE AND PCBS PROJECT
GEF GRANT N0-FF056587
Environmental and Social Impact
Assessment Framework for the Tunisia
PCBs Management and Disposal and
healthcare waste management improvement
Project
EXECUTIVE SUMMARY
September 24, 2010
GEREP-Environment
17 Mustapha Abdessalem Street ; El Menzah V, 2037 - TUNISIA
Tel: (+216) 71752976/71236248 Fax: (+216) 71234825
www.gerep-environnement.com
ESIA –Tunisia PCBs management and disposal and HCW management improvement Project
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TABLE OF CONTENT
1. INTRODUCTION ................................................................................................................ 3
2. PROJECT OBJECTIVES AND COMPONENTS ............................................................... 3
2.1 Objective......................................................................................................................... 3
2.2 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 ...................................................... 17
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 ........................................................................................................ 23
5.2 Diagnosis of current PCB management practices in Tunisia ...... Error! Bookmark not
defined.
5.3 Project Environmental and Social Impact Assessment Framework ............................. 26
5.3.1 Potential impacts of the current PCB management ................................................ 26
5.4 Mitigation Framework .................................................................................................. 28
5.5 Environmental and Social Management Framework and Cost Estimates .................... 29
5.6 Environmental and Social Monitoring Framework ...................................................... 33
5.7 Capacity-Building and Training ................................................................................... 35
5.7.1 Implementation of oversight and performance procedures, training and technical
assistance ......................................................................................................................... 35
5.7.2 Management Structure for PCB Project Activities................................................. 35
6. PUBLIC CONSULTATIONS ............................................................................................ 39
Public Consultation Findings ............................................................................................... 39
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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 inincluded
In 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 "Awarenessraising, 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 subproject 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:
3.1
-
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
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
Ministry of Interior and
Local Development,
ANPE
Ministry of
Transport, ANGed
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
Ministry of
Transport, ANGed
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
Ministry of
Transport, ANGed
ANPE
ANPE, ANGed
Law of no. 97-37 of July 2, 1997
Decree no. 2008-2745 of July 28, 2008
Tunisian Standards (TS 106-02 and TS 106-04)
PCB
EIS and ESMP
ANPE
ANPE, ANGed
Law no. 96-41 of July 10, 1996
ANPE
ANPE, ANGed
MEDD, ANPE
MEDD, ANPE, ANGed
Law no. 97-37 of July 2, 1997
Ministry of Interior
and Local
Development, ANPE
Ministry of
Transport, ANGed
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
Ministry of
Transport, ANGed
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
Ministry of
Transport, ANGed
Stockholm, Basel and Bamako conventions
ANPE
MEDD, ANPE, ANGed
Tunisian Standards (TS 106-02 and TS 106-04)
ANPE
ANPE, ANGed
Hazardous waste collection, transport and disposal
permits (HW and PCB)
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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:





4.2
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
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
1
Without the project
2
Off-site Central
Treatment Facility
(CTF)
(centralized)/ANGed's
investment
Technical and
environmental benefits
none
Oversight and
monitoring easier for
ANGed's agencies
Treatment Unit outside
healthcare facilities
No transport
3
In situ CTF (for
potential producers)
Technical and
environmental
disadvantages (feasibility
constraint)
Cost
Estimates*
Major impact on public
health and the environment
0
Human and material
resources important for
ANGed
TD 770/ton
Non local pollution risk
Immediate HCW
treatment, without
intermediate storage
Human and material
resources important for each
health care facility
Easier monitoring and
oversight
Lack of space in healthcare
facilities
TD 370/ton
Private sector
involvement
4
Off-site
CTF/investment and
private operation
Competition among
contractors resulting in
an improvement of the
quality of service and
cost
Problems associated with
lack of traceability
800 TD/ton
Treatment Unit outside
healthcare institutions
Implementation of a
national strategy for
HCW management
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
Greater Tunis
Center
South-East
Area of Intervention
Greater Tunis
Sousse & Kairouan
Monastir & Mahdia
Sfax
Gabès
Tataouine
Medenine
TOTAL
HCW RI Quantity EPS
in T/per year
1,555
522
415
457
107
31
97
Total
1,555
937
692
3,184
Number
of CTFs
3
1
1
1
6
The 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)
Importance of impact on:
Phase
Public
health
Surface
water
Groundwater
Air
Fauna and
Flora
Soil
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
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
moderate
moderate
moderate
moderate
moderate
moderate
low
low
low
low
low
low
Sorting
Interim storage
Treatment (shredding + steam
sterilization)
Secondary transport
Likelihood of impact on:
Phase
Public
health
Surface
water
Groundwater
Air
Soil
Fauna
Flora
and
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
Sorting
Proposed mitigation measures
Staff training on sorting arrangements
Compliance 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 manual
Appropriate use of bags and containers
Ensure 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 manual
Determine selection of collection times
Collection carts cleaning and disinfecting
Ensure cleanliness of elevators and stairwells after use
Trained and qualified collection staff to perform this task
Intramural transport
Application of good management techniques as defined by the good
management procedures manual
Use of appropriate HCW dumpster and carts for HCW transport
Appropriate selection of collection times
Optimization of itinerary selection for transport
Carts 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 service
Ensure regular maintenance of equipment and ventilation units
Restrict access to facilities, except for waste collection and treatment facility staff
Waste storage facility must be disinfected after each stored wastes collection
Application of good management techniques, as defined by the good
management procedures manual
Waste collection must be handled by trained and qualified personnel
Bar codes and traceability to ensure remote monitoring (through a GPS or a
Collection and
extramural transport 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 handling
Regular equipment maintenance
Proper room ventilation
Treatment 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 landfills
Optimizing 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 preapproved 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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Executive Summary
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Project activities
Potential environmental and health
impacts
Proposed mitigation measures
Institutional
responsibilities
Cost Estimates*
Site specific EMPs
To mitigate imapcts of the interim ,
and central storage facilities
To be determined
SNGed
100,000
Daily training for staff on sorting methods
Sorting
Packaging and
collection
Risk of infection, contamination and
injury to all persons exposed
Compliance with sorting required methods
according to the good management procedures
manual
Risk of contamination (injury and
infection) in the exposed population
Application of good management techniques, as
defined by the good management procedures
manual
Risk of hazardous waste seepage
Risk of contamination from biological
and infectious wastes
Visual and olfactory gene
Poor space occupation
Interim
refrigerated
storage
Central
refrigerated
storage facilities
Psycho-motor traumas
Visual and olfactory problems
Use of appropriate containers and bags
Ensure complete sealing of waste infectious bags
and boxes
Ministry of Public
Health
Health care
facility
Ministry of Public
Health
Health care
facility
Appropriate specific interim storage areas for
each floor and service
Training of all heath
care facility staff
To be part of the
collection and
transport contract
Standardized
specifications and
colors common in all
health care facilities
Application of good management techniques, as
defined by the good management procedures
manual
Ministry of Public
Health
Health care
facility
Preparation of an environmental and social
management plan
ANGed
Concentration of contaminated
waste in one area
Appropriate areas planning (sealed, water-tight,
spacious, ventilated, appropriate lighting at
distance from health activities), refrigerated
Ministry of Public
Health
ANGed
Risk of passengers and staff
contamination
Acquisition and regular maintenance of
equipment restricting, restricted access of the
facility, except for staff from the management and
treatment company
Risk of contamination in natural
Cleaning and disinfection of storage areas after
Visual and olfactory problems
To be part of the
operational budget of
the jealth carse facility
Acquisition of standardized consumable materials
Site identification
Potential risk of bacterial and viral
propagation
Comments
818,000
Health care
facility
ANPE
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Executive Summary
environment (soil, air, water, fauna
and flora)
ANGed - June 2010
stored waste removal
Site identification
Use of appropriate techniques, as defined by the
good management procedures manual
Risk of infection, contamination or
injury to all exposed persons
Intramural
transport
Contamination from collection carts
Contamination of collection carts
Contamination of elevators and
stairwells
Use of appropriate intramural transport
equipment
Appropriate selection of transport times
Carts cleaning and disinfecting
Ensure cleanliness of elevators and/or stairwells
after use
Ministry of Public
Health
Health care
facility
630,000
Preference for IBC
carts use
Cost borne by a private
waste treatment
company
Approved company
for HCW collection,
transport and
treatment
6, 692,000 cost borne
by Countepart funding
Approved
companies for HCW
collection, transport
and treatment
Transport personnel must be trained and qualified
to perform this task
Application of good management techniques, as
defined by the good management procedures
manual
Collection and
extramural
transport
Traffic congestion around the facility
Traffic congestion on local roads and
risk of accidents i.e., contaminated
waste spills
Collection 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
Private
companies
authorized by
MEDD
Optimization, as much of possible, of the
transport itinerary, during off- peak hours and
away from national roadways
Treatment
(shredding +
steam
sterilization) and
disposal in landfills
Risk of injury and infections for all
exposed staff
Waste handling precautions
Not appropriate for types of wastes
Proper area ventilation
Prior treatment required (burying)
Waste treatment obligation in case of equipment
malfunction (sub-contracting with companies
approved by the Ministry of Environment and
Sustainable Development for waste management)
Risk of water and treated
contaminated waste of spillage in
case equipment malfunction
Maintenance of equipment
Private company
authorized by
MEDD
ANGed
Healthcare
facility
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Executive Summary
4.6
ANGed - June 2010
Environmental and Social Monitoring Framework
Proposed mitigation
measures
Parameter Checklist
Sites
Data and/or
measures
Weight scales
Sorting
Packaging
Quantities of HCW generated
Condition of filled bags and
containers
Labeling
Interim storage
Collection at healthcare
facilities
Central refrigerated
storage
Site cleanliness
Condition of carts and
cleanliness of sites after
collection
Cleanliness of area,
temperature control
Healthcare facilities
Every healthcare
facility
Every team and every
floor
Hallways, stairwells
and elevators used
by IBC carts
Storage area
Visual
oversight
visual
visual
visual
Visual,
thermometer
Frequency of
measurement
One daily,
during waste
removal
Twice a day
Twice a day
Twice a day
Once a day
Required norms and standards
Decree no. 2008-274 of July
28, 2008
Good management procedures
manual
Decree no. 2008-2745 of July
28, 2008
Good management manual of
procedures
Decree no. 2008-2745 of July
28, 2008
Good management manual of
procedures
Decree no. 2008-275 of 28 July
2008
Good management manual of
procedures
Decree no. 2008-2745 of July
28, 2008
Good management procedures
manual
Responsibilities
Healthcare staff
DHPME
(oversight)
ANPE (oversight)
Healthcare facility
personnel
DHMPE
(oversight)
)
Healthcare facility
personnel
DHMPE
(oversight)
Cost ($)
Part of the
operationa
al budget
of health
care
facilities
idem
idem
ANPE (oversight)
Healthcare facility
personnel
DHMPE
(oversight)
ANPE (oversight)
idem
Healthcare facility
personnel
DHMPE
(oversight)
idem
ANPE (oversight)
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Extramural collection
and transport
Condition of transport vehicle
Conditions of containers
Itinerary
visual
Roadmaps, dockets, registries
ANGed - June 2010
During each
facility visit
Law on transport of hazardous
material
Good management procedures
manual
Healthcare facility
staff
ANPE (oversight)
Private
companies
Part of the
operaional
contract of
the
operator
visual
Machinery condition
Quality of treated waste
Treatment (shredding +
steam sterilization)
Quality of wastewater in
ONAS network
Vertical autoclave
with shredder
Atmospheric waste from
vertical autoclave with
shredder
Treatment unit
Treated waste
analysis
through
germicidal and
disinfection
tubes
Every
semester
Decree no. 2008-2745 of July
28, 2008
Tunisian Norm 106-02
Tunisian Norm 106-04
Bacteriological
waste analysis
Private
companies
ANPE (oversight)
Air quality
analysis
Disposal in landfills
Quantity of treated HCW
Landfills
Weighbridge
at landfills
Every day
Initialed register
US$500/tr
eatment
unit/semes
ter, part of
the
operationa
la contract
of the
operator
Part of the
operationa
la contract
of the
operator
Private
companies
Healthcare
facilities
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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:




4.7.2

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
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
activity
Positions
Timetable
During project
PMU (within ANGed)
Mitigation
Monitoring
Preparation of specific hazardous
HCW management manuals and
technical guides
Three months
following GEF Grant
signing
Strengthening the capacity of
HCW management staff within
healthcare structures and
facilities
During project
PMU (within ANGed)
During project
Responsibilities
Implementation, monitoring,
evaluation and organization of
workshops during project
implementation
PMU and ANGed, consulting firms
Supervision of HCW management at
healthcare facilities
compliance with required mitigation
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measures
Strengthening of ANPE through
the hiring of an environmental
engineer with experience in
healthcare
During project
Compliance with required mitigation
measures
Cost of the institutional strengthening
Training activity
EMP
Environmental
Process, methods
and equipment
Participants
ANGed
ANPE
DHMPE
Healthcare facilities
HCW management approved
companies
ANGed
ANPE
MEDD
Ministry of Public health
Consulting firms
NGOs
US$239,000
Type of training
Training on HCW
separation, packaging
and storage
Training in equipment
handling, operation
and maintenance of
interim and central
storage facilities, and
intramural and
extramural transport
Content
Regulatory requirements and
practices as defined in the good
management procedures manual
Information on available technology
and HCW management good
practices
Information seminars
Environmental
policies and
program
Regional healthcare section
chiefs,
Heads of HCW management
units, doctors, nurses, and
others,
Laborers,
Healthcare waste treatment
service providers
Cleaning,
HCW management
etc.
Healthcare waste management
supervisors
All 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
Total training cost
Awarenessraising activities
Organization of
large-scale
workshops
Strategies and objectives of the
environmental policy in Tunisia and
programs
US$522,000
Participants
ANGed
ANPE
DHMPE
Healthcare facilities
HCW management approved
companies
Total cost of awareness-raising
Type of training
Content
Preparation of an
awareness-raising plan
HCW minimization
program
Technical guides,
brochures, didactic,
billboards, etc.
Regulatory requirements and good
management procedures manual
practices
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 description
The 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 ppm
The 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 PCBcontaminated 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
o
o
o

PCBs land transport from the site to the interim storage Facility (TSDF);
PCBs land transport from the storage facility (TSDF) to the port of Tunis;
Shipping from the port of Tunis to the port of Marseilles or Genoa;
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)
Impact significance on:
Phase
Public
health
Surface water
Groundwater
Air
Soil
Fauna
flora
and
PCB
Dismantling and collection
moderate
high
moderate
low
high
high
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
low
low
low
Retrofilling
Secondary transport (land
and sea)
high
low
high
high
low
low
Impact likelihood
Phase
Public
health
Surface water
Groundwater
Air
Soil
Fauna
flora
and
PCB
Dismantling and collection
likely
certain
likely
unlikely
certain
likely
certain
certain
likely
likely
certain
likely
Decontamination of the
site where the article was
found
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
Retrofiling
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5.4
Mitigation Framework
The mitigation measures for each management phase are as follows:
Project Activity
Proposed Mitigation measures
Since 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 company
Article must be collected in a metal drum or appropriate container
Precautions must be taken to ensure laborers and passengers safety
Compliance with the good management procedure at every stage of handling
Decontamination of
the site where the
article was found
Environmental and geotechnical assessment to define the contaminated area
Precautions must be taken to ensure the laborers and passengers safety
Collection and packaging of contaminated soils (considered PCB waste) in a sealed
metallic, leak-proof, covered container
The transport of this debris is considered hazardous material transport.
Therefore, the hazardous materials transportation law must be complied with
Soils must be treated along with the other waste and contaminated equipment
Compliance with the good management procedures manual
Transport to the
interim storage zone
Compliance with the hazardous materials transportation regulation
Use of appropriate leak-proof containers, with a liquid collection system
Compulsory labeling for contaminated equipment
The area should be closed and protected from intrusion by persons or animals
Doors must have proper danger labeling and restricted access signage
The 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 accidents
Recommendations must be in place on maximum stockpiling for containers
Each facility must have the required on-site emergency equipment
Drainage and liquid
collection
Precautions must be taken to ensure the laborers and passengers safety
The operation must be performed by a specialized company with experience in
hazardous material handling
Operations must be conducted using leak-proof retention basin of appropriate
dimensions for the equipment used
Sufficient 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 manual
Compulsory labeling
If 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)
5.5
Optimization, as much of possible, of transport itinerary during peak-hours and
away from national roadways
Compliance with the hazardous material transportation regulation
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
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
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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 Project
Executive Summary
Project Activity
Potential Impacts on the Environment
and Health
Proposed Mitigation Measures
ANGed – June 2010
Institutional
Responsibilities
Cost Estimates
Comments
Use of leak-proof retention tanks.
Dismantling
and Collection
Transport to
interim storage
areas
Storage Area
Pollution of soil, surface and
groundwater by accidental oil spills.
Operations should be conducted qualified agents of specialized
company.
Risk of injury/accidents for staff and
laborers.
The collected substance should be stored in a metal tank or
appropriate container.
Risk of contamination of fauna and
flora.
Precautions must be taken to ensure laborer and passenger safety.
Compliance with hazardous material transport regulations.
Risk of PCB oil seepage which can
pollute the natural environment and
public health along the transport
route.
Use of appropriate sealed containers to avoid seepage, equipped
with leak-free collection system.
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.
Risk of oil seepage.
Drainage and
liquid collection
Laborers and agents can come into
direct contact with contaminated oils
during handling phases.
Contamination of soil, surface water,
fauna and flora.
Holding entity.
Private company
Good management procedures manual must be complied with for
each operation.
Traffic congestion.
3,865,000
(Priority
treatment phase)
Private company
Licensed
companies
specialized
transport of
hazardous
material
ANGed and/or a
private company
Preparation
of ESIA
required for
future
interim
storage
facility
Private company
Licensed
company
specialized in
handling
containing
PCB oils
equipment
Compulsory labeling for contaminated equipment.
The area must be closed off and well protected against human and
animal intrusions.
Access doors must have locks , danger and restricted access signage
The 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
Precautions must be taken to ensure the safety of laborers and
passengers
The operation must be conducted by a specialized company
qualified in this type of hazardous material handling
Operations must be conducted using a leak- proof retention basin
adapted to the equipment dimensions
Licensed
company in
handling of
equipment
containing
PCB oils
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Allow sufficient time to complete drainage, i.e., until the last drop of
oil has fallen on the equipment
Compliance with the good management procedures manual
Laborers and agents can come into
direct contact with contaminated oils
Packaging
Secondary
transport (land
and sea)
Export and
treatment of
PCB equipment
and waste to
Europe
Site
decontaminatio
n
Rinse water can contaminate soils or
infiltrate groundwater in ONAS
network. This contaminated water
poses a risk to local fauna and flora
Traffic congestion
The operation must be conducted at the drainage site without
removing the retention basin
Compliance with the good management procedures manual
Compulsory labeling
Licensed
company
specialized in
handling
equipment
containing
PCB oils
400,000
Private company
(Technical
Assistance)
If transformers are rinsed with a solvent, potential exposure to
these solvents must be acknowledged and appropriate remedial
measures must be taken.
Optimization of transport itinerary, avoiding peak hours and
national roadways as much as possible
Licensed
company
specialized in
hazardous
material
transport
Private company
Compliance with hazardous material transport regulations
Treatment will take place in a licensed
and specialized facility
MEDD
Technical
assistance
required
ANGed
Holding company
Risk of spreading pollution to other
areas
Environmental and geotechnical assessment of the contaminated
area.
Risk of laborers contaminating
Precautions must be taken to ensure laborers and passengers safety
Dust formation
Collection and treatment of contaminated soil (considered PCB
waste) in leak-proof and covered metal container
Holding company
Transport of this debris is considered hazardous material transport
and must be in compliance with hazardous material transport
regulations
ANGed
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
Treatment of this soil, debris and contaminated equipment
Treatment of this soil, debris and contaminated equipment
Compliance with the good management procedures manual
154,,000
Private company
Authorities
(environmental
audits and site
characterization
515,000
(decontaminatio
n activities)
Licensed and
specialized
company in
decontamina
tion of
polluted soil
Requirement
to carry out
ESIAs and
EMPs for
individual or
group sites
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5.6
ANGed – June 2010
Environmental and Social Monitoring Framework
Proposed Mitigation
Measures
Parameter Checklist
Sites
Data and/or
measures
Frequency of
Measures
Norms and
Requirements to
be enforced
One measure per
treatment facility
Presence of 50
ppm of PCBs in oil
Responsibilities
Cost (US$)
Holding entity
Dismantling and
collection
Confirmation of PCB presence
Leaks and oils
Original site
Oil analysis
Visual
ANGed
US$
200/position
Private
companies
Visual
Olfactory
Contamination specifications
Site decontamination
Contaminated surface
Original site
PCB concentration
Control and
validation of
contamination
specification and
environmental
audit
ANPE
Based on study and
survey
Following
decontamination
works
ANGed
PCB presence
US$500/site
Private
companies
Holding entities
Final analyses
following
decontamination
Transport to interim
storage site
Drainage and liquid
collection
Packaging
Transport vehicle
Visual
Every
transport
operation
Original storage
site
Visual
Every
drainage
operation
Interim storage
site
visual
Every
packaging
operation
Condition of substance container
Condition of retention basin
Equipment to be used
Operator safety requirements
Equipment to be used
Operator safety requirements
Hazardous
material transport
law
Authorities
Private
companies
-
ANPE
ANGed
-
Private
companies
-
ANPE
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ANGed
Private
companies
Subsequent transport
(land and sea)
Containers, vehicles
visual
Every
transport
operation
hazardous
materials
transportation law
MEDD
ANGED 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;
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

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
activities
Positions
Timetable
responsibilities
Preparation of a
good management
manual
PMU
Three months
after loan
signing
PMU and ANGed
Environmental
audits
PMU
During project
and prior to
implementation
PMU, ANGed and consulting firms
From project
launch until
completion
From Project
Monitoring
PMU
until
completion
Cost of Institutional Strengthening and awarenss
Mitigation
Training Activities
PMU (within
ANGed)
Participants
ANGed
ANPE
MEDD
Contaminated
EMP
waste holding
parties
Private
companies
ANGed
Environmental
ANPE
process,
MEDD
methodology and Consulting firms
equipment
Private
companies
ANGed
Environmental
ANPE
policy and
MEDD
program
Holding entities
Consulting firms
Training Cost and Technical Assistance
Implementation, monitoring, evaluation and
organization of workshops during project
implementation
Compliance with timetable and monitoring of
compliance with mitigation measures
US$558,000
Type of
Training
Content
Timetable
Seminars
General project data, including plan
and an environmental monitoring
plan
PCB Contaminated waste handling
International law and agreement on
PCB management and exports of
hazardous waste
First year of
PCB
management
project plan
Seminars and
public
information day
Information on PCB available
management technologies and
international management practices
Seminars and
workshops
Strategies and objectives of the
environmental policy for PCB
management
In Tunisia
Periodically,
during the
first two
years of
project
planning
Periodically,
during the
third year of
project
planning
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’Environnement
Department of Environmental Hygiene and Environment protection, under the Ministry of
Public Health
GCT:
Groupe Chimique tunisisen
Tunisian 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 Statistiques
National Statistical Institute
Magasin
Géneral:
Tunisan retail store chain
MARH:
Ministère de l’Agriculture et des Ressources Hydrauliques
Ministry 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
Moderate Occupancy Rate
MOR:
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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-Mécaniques
A 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 Gaz
The 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 Raffinage
Tunisian Company for Refining Industries
SOTRAPIL: Société de transport des hydrocarbures par pipelines
Tunisian 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, TUNISIA
Tel: +216 71 752976 fax: +216 71234825
e-mail: gerep@gnet.tn
www.gerep-environnement.com
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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