Document of
The World Bank
Report No:33862-MD
PROJECT DOCUMENT
ON A
GLOBAL ENVIRONMENT FACILITY GRANT
IN THE AMOUNT OF US$6.35 MILLION
TO THE
REPUBLIC OF MOLDOVA
FOR A
PERSISTENT ORGANIC POLLUTANTS (POPS) STOCKPILES
MANAGEMENT AND DESTRUCTION PROJECT
October 28, 2005
Environmentally & Socially Sustainable Development Sector Unit
Ukraine/Belarus/Moldova Country Unit
Europe and Central Asia Region
CURRENCY EQUIVALENTS
(Exchange Rate Effective June 1, 2005
Currency Unit =
12.60 =
Lei
US$1
FISCAL YEAR
January 1 –
December 31
ABBREVIATIONS AND ACRONYMS
Basel
BAT
BEP
CIS/NIS
CLRTAP
(POPs)
CPM
DES
DDE
DDT
DOC
EBRD
EIA
ESSD
EU
FAO
FDI
FM
FMR
FSU
GDP
GEF
GRM
HCB
HIPC
HMS
IBC
IBRD
IDA
IMF
LRTAP
MAC
MAFI
MDL
ME
Convention on the Control of Transboundary Movements of Hazardous Wastes and their
Disposal
Best Available Techniques
Best Environmental Practice
Commonwealth of Independent States/Newly Independent States
Convention on Long-Range Transboundary Air Pollution, Protocol on Persistent
Organic Pollutants
Center for Preventive Medicine
Department of Emergency Situations
Dichloro-diphenyl-dichloroethylene
Dichloro-diphenyl-trichloroethane
Department of Customs
European Bank for Reconstruction and Development
Environmental Impact Assessment
Environmentally and Socially Sustainable Development
European Union
Food and Agriculture Organization
Foreign Direct Investment
Financial Management
Financial Monitoring Report
Former Soviet Union\
Gross Domestic Product
Global Environment Facility
Government of the Republic of Moldova
Hexachlorobenzene
World Bank-IMF Heavily Indebted Poor Countries Initiative
Hydrometeorological Service
Intermediate Bulk Containers
International Bank for Reconstruction and Development
International Development Association
International Monetary Fund
Convention on Long-range Transboundary Air Pollution
Maximum Allowable Concentration
Ministry of Agriculture and Food Industry
Moldovan Lei (national currency)
Ministry of Energy
MECTD
MENR
MFA
MIA
MOD
MOE
MOH
MOI
MOJ
MOTC
NEAP
NEHAP
NGO
NIP
NIS
OECD
PCBs
PCDDs
PCDFs
PMT
POPs
ppb
ppm
REC
Rotterdam
SDES
SEI
SEE
TONS
TACIS
TBD
UNECE
WHO
Ministry of Ecology, Construction and Territorial Development
Ministry of Ecology and Natural Resources
Ministry of Foreign Affairs
Ministry of Internal Affairs
Ministry of Defense
Ministry of Economy
Ministry of Health
Ministry of Industry and Infrastructure
Ministry of Justice
Ministry of Transport and Communications
National Environmental Action Plan
National Environmental Health Action Plan
Non-governmental Organization
National Implementation Plan
Newly Independent States
Organization for Economic Co-operation and Development
Polychlorinated biphenyls
Polychlorinated dibenzo-p-dioxins
Polychlorinated dibenzofurans
Project Management Team
Persistent Organic Pollutants
parts per billion
parts per million
Regional Environmental Center
Convention on the Prior Informed Consent Procedure for Certain Hazardous Chemicals
and Pesticides in International Trade
State Department for Emergency Situations
State Ecological Inspectorate
State Ecological Expertise
Metric tons
Technical Assistance for the Commonwealth of Independent States (EU Programme)
To-be-Determined
United Nations Economic Commission for Europe
World Health Organization
Vice President:
Country Director:
Sector Manager:
Task Team Leader:
Shigeo Katsu
Paul Bermingham
Benoit Blarel
Rita Klees
MOLDOVA
Persistent Organic Pollutants (POPs) Stockpiles Management and Destruction Project
CONTENTS
Page
A.
STRATEGIC CONTEXT AND RATIONALE ................................................................. 9
1.
Country and sector issues.................................................................................................... 9
2.
Higher level objectives to which the project contributes .................................................. 11
B.
PROJECT DESCRIPTION ............................................................................................... 11
1.
Lending instrument ........................................................................................................... 11
2.
Project development objective and key indicators............................................................ 11
3.
Project components ........................................................................................................... 12
4.
Lessons learned and reflected in the project design .......................................................... 15
5.
Alternatives considered and reasons for rejection ............................................................ 16
C.
IMPLEMENTATION ........................................................................................................ 17
1.
Partnership arrangements .................................................................................................. 17
2.
Institutional and implementation arrangements ................................................................ 18
3. Monitoring and evaluation of outcomes/results .................................................................... 20
3.
Sustainability and Replicability ........................................................................................ 20
4.
Critical risks and possible controversial aspects ............................................................... 21
5.
Loan/credit conditions and covenants ............................................................................... 22
D.
APPRAISAL SUMMARY ................................................................................................. 22
1.
Economic and financial analyses ...................................................................................... 22
2.
Technical ........................................................................................................................... 22
3.
Fiduciary ........................................................................................................................... 23
4.
Social................................................................................................................................. 23
5.
Environment ...................................................................................................................... 24
6.
Safeguard policies ............................................................................................................. 25
7.
Policy Exceptions and Readiness...................................................................................... 25
Annex 1: Country and Sector or Program Background ......................................................... 27
Annex 2: Major Related Projects Financed by the Bank and/or other Agencies ................. 40
Annex 3: Results Framework and Monitoring ........................................................................ 46
Annex 4: Detailed Project Description ...................................................................................... 51
Annex 5: Project Costs Base (no contingencies included) ....................................................... 74
Annex 6: Implementation Arrangements ................................................................................. 76
Annex 7: Financial Management and Disbursement Arrangements ..................................... 91
Annex 8: Procurement Arrangements ...................................................................................... 95
Annex 9: Economic and Financial Analysis ........................................................................... 102
Annex 10: Safeguard Policy Issues .......................................................................................... 103
Annex 11: Project Preparation and Supervision ................................................................... 117
Annex 12: Documents in the Project File ............................................................................... 119
Annex 14: Country at a Glance ............................................................................................... 123
Annex 15: Incremental Cost Analysis ..................................................................................... 125
Annex 16: STAP Roster Review .............................................................................................. 134
MOLDOVA
PERSISTENT ORGANIC POLLUTANTS STOCKPILES
MANAGEMENT AND DESTRUCTION
PROJECT APPRAISAL DOCUMENT
EUROPE AND CENTRAL ASIA
ECSSD
Date: October 28, 2005
Country Director: Paul G. Bermingham
Sector Manager/Director: Benoit Paul Blarel
Project ID: P090037
Focal Area: Persistent Organic Pollutants
Lending Instrument: Specific Investment Loan
Team Leader: Rita Klees
Sectors: Health (50%); Solid waste management
(50%)
Themes: Pollution management and environmental
health (P); Environmental policies and institutions
(S); Other environment and natural resources
management (S)
Environmental screening category: Partial
Assessment
Safeguard screening category: Limited impact
Project Financing Data
[ ] Loan
[ ] Credit
[X] Grant
[ ] Guarantee
[ ] Other:
For Loans/Credits/Others:
Total Bank financing (US$m.): 0.00
Proposed terms:
Financing Plan (US$m)
Source
Local
Foreign
Total
BORROWER/RECIPIENT
3.72
0.00
3.72
GLOBAL ENVIRONMENT FACILITY
0.00
6.35
NATO
0.00
6.35
1.60
DUTCH Milieukontakt Oost-Europe (NGO)
0.00
0.93
0.93
Total:
3.72
Borrower:
Republic of Moldova
Moldova
Responsible Agency:
Ministry of Ecology & Natural Resources
Moldova
6
8.88
1.60
12.60
Estimated disbursements (Bank FY/US$m)
FY
2006
2007
2008
2009
2010
Annual
1.10
2.00
2.30
0.95
0.00
Cumulative
1.10
3.10
5.40
6.35
6.35
Project implementation period: Start March 15, 2006
End: November 30, 2009
Expected effectiveness date: March 15, 2006
Expected closing date: May 31, 2010
Does the project depart from the CAS in content or other significant
[ ]Yes [X] No
respects? Ref. PAD A.3
Does the project require any exceptions from Bank policies?
[ ]Yes [X] No
Ref. PAD D.7
Have these been approved by Bank management?
[ ]Yes [ ] No
Is approval for any policy exception sought from the Board?
[ ]Yes [X] No
Does the project include any critical risks rated “substantial” or “high”?
[ ]Yes [X] No
Ref. PAD C.5
Does the project meet the Regional criteria for readiness for
[X]Yes [ ] No
implementation? Ref. PAD D.7
Project development objective Ref. PAD B.2, Technical Annex 3
The main development objective of the project would be to protect the environment and human health by
safely managing and disposing of stockpiles of POPs contaminated pesticides and Polychlorinated
biphenyls (PCBs).
Global Environment objective Ref. PAD B.2, Technical Annex 3
The global project objective of the project is sustainable POPs stockpiles management and strengthening
of the regulatory and intuitional arrangements for long term control of POPs and other toxic substances in
line with the requirements of the Stockholm Convention and other related conventions and protocols
ratified by Moldova.
Project description [one-sentence summary of each component] Ref. PAD B.3.a, Technical Annex 4
The project has three components. The first component consists of two sub-components. Subcomponent
1 will finance the repackaging and final destruction by incineration of approximately 1150 tons of POPs
containing and contaminated obsolete pesticides. Sub-component 2 consists of three activities: (i)
establishing an inventory of PCB containing or contaminated equipment; (ii) destruction of a stockpile of
obsolete capacitors that would include the following: (a) dismantling of 17,300 obsolete capacitors from
thirteen substations and packing in closed containers (approximately 900 tons); (b) excavation of 2,000
capacitors buried in two pits in the Vulcanesti substation and packing in closed containers (approximately
111 tons); (c) destruction of 19,300 capacitors and up to 50 tons highly polluted soil (approximately
1,060 tons) through incineration; and (iii) a feasibility study of site clean-up at Vulcanesti Substation.
Component 2 includes actions for modernization of current legislation specifically related to the
Stockholm Convention and incorporation of provisions for establishing a broader chemical safety
approach in the country based on EU legislation. The third component will support two type of activities:
(i) Institution Strengthening; and (ii) Project Management
Which safeguard policies are triggered, if any? Ref. PAD D.6, Technical Annex 10
Safeguard Policies Triggered by the Project:
Environmental Assessment (OP/BP/GP 4.01): Yes
Natural Habitats (OP/BP 4.04): No
Pest Management (OP 4.09): No
Cultural Property (OPN 11.03, being revised as OP 4.11): No
Involuntary Resettlement (OP/BP 4.12): No
Indigenous Peoples (OD 4.20, being revised as OP 4.10): No
Forests (OP/BP 4.36): No
Safety of Dams (OP/BP 4.37): No
7
Projects in Disputed Areas (OP/BP/GP 7.60): No
Projects on International Waterways (OP/BP/GP 7.50): No
Significant, non-standard conditions, if any, for:
Ref. PAD C.7
Board presentation:
December 15, 2005
Loan/credit effectiveness:
Loan/credit conditions and covenants
1. Covenant on counterpart funds
2. Financial Management Conditions: Satisfactory financial management arrangements in place before
Board presentation date.
3. Financial Management Covenants: The recipient will maintain a financial management system
acceptable to the Bank. The project’s financial statements, withdrawal applications and Special Account
will be audited by independent auditors acceptable to the Bank and on terms of reference acceptable to
the Bank. The annual audited statements and audit report will be provided to the Bank within six months
of the end of each fiscal year.
Covenants applicable to project implementation:
8
A. STRATEGIC CONTEXT AND RATIONALE
1. Country and sector issues
Background. Mounting evidence of health and environmental damage has focused the attention of the
international community on a category of substances referred to as Persistent Organic Pollutants (POPs).
Some of these are used as pesticides, while others are industrial chemicals. POPs are also generated
unintentionally as byproducts of combustion and industrial processes. POPs possess toxic characteristics
which: are persistent, accumulate in the fatty tissues of most living organisms, are prone to long-range
transboundary transport, and are likely to cause significant adverse human health or environmental effects
near to and distant from their sources.
Due to POPs’ persistence and propensity to cross-border movement, countries have sought multinational
cooperation to address the challenge. The Stockholm Convention for POPs seeks to eliminate a group of
12 POPs. Under the Convention, which entered into force on May 17, 2004 and was ratified by Moldova
on February 19, 2004, parties are required to develop implementation plans to indicate how they will meet
their obligations under the Convention. In 2001, Moldova requested from the Global Environment
Facility (GEF) financial assistance in fulfilling its Stockholm Convention obligations and it received a
$410,000 GEF POPs Enabling Activity (EA) grant. The Moldova POPs NIP was one of the main outputs
of the project and was submitted October 20, 2004. The NIP identified the POPs chemicals of concern in
Moldova as being stockpiles of obsolete pesticides and Polychlorinated Biphenyls (PCBs) contained in
electrical equipment, primarily capacitors.
POPs Obsolete Pesticides: Moldova has used extremely high amounts of pesticides in the past.
Stockpiling of now banned and useless pesticides collectively referred to as “obsolete” pesticides is a
significant POPs issue. The stockpiles of POPs obsolete pesticides pose a continuous threat to the
environment and public health. In the absence of an obsolete pesticides management strategy, over the
years, significant amounts of obsolete pesticides have been stockpiled in warehouses on an ad hoc basis.
Often the warehouses are dilapidated; usually the passage of time and exposure has resulted in
deterioration of the packaging material. Both increase possibilities for leakage of the toxic materials to
the environment – the main pathway for contamination. When obsolete pesticides were placed in storage
they were generally indiscriminately mixed with each other in bags and drums. This resulted in a mixture
of POPs pesticides with non-POPs pesticides and there is no economically viable way of determining the
compositions of all the resultant mixtures in the repackaged plastic and steel drums. Representative
sampling analysis indicates that the average amount of POP pesticides out of the total stock of obsolete
pesticides is about 20 - 30%. There are approximately 3,000 tons of obsolete pesticides stored in
warehouses in Moldova. Studies have shown conclusively that these materials have contaminated the
sites and surrounding soils and nearby surface waters.
In November 2003, the Ministry of Defense (MOD) and the State Department of Emergency Situations
(SDES) initiated the repackaging and transportation of the obsolete pesticide stocks from some 344
warehouses scattered across the country, to 37 centralized district storage facilities, one in each of the
administrative districts. These warehouses were selected based on a number of criteria to ensure safety
and security. The warehouses were each examined during the Environmental Assessment of the project
to evaluate their integrity (see Annex 10). While this system of centralizing the storage is an
improvement it is not a long term solution. Centralizing the materials allows for improved security and
monitoring and will facilitate ultimate disposal. The repackaging, transport and storage activity has been,
and will continue to be until completion, co-financed by NATO. All of the obsolete pesticides will be
relocated to the 37 warehouses by the time the project is effective.
PCBs and PCB-containing electrical equipment. Moldova has an unusually high amount of PCBs
requiring disposal because in former Soviet Union times it was the energy hub transmitting electricity to
Bulgaria. Most of the PCBs in Moldova are concentrated in electrical power installations where the
dielectric oils in capacitors and transformers contain PCBs. Most of this equipment is out of use but still
9
in place. PCBs technical value derives from their chemical inertness, resistance to heat, nonflammability, low vapor pressure and high dielectric constant. The main pathways of environmental
pollution are PCB containing oil spills and leaks from electrical equipment no longer in use. The
capacitors at power installations are situated outdoors and PCBs leak from corroded capacitors to the soil
below the capacitor batteries. Twenty thousand PCB-containing capacitors, now unused and referred to
as “discarded,” are located in 20 electrical substations throughout the country but most (12,000) are at the
Vulcanesti Power station where there are also two dumps with approximately 1,000 broken capacitors.
The total PCB content in oils within the 20,000 capacitors (excluding the pits at Vulcanesti) is estimated
at 380 tons while the total weight of the capacitors is approximately 1,060 tons. Since PCBs are mobile
in the soil the contamination can spread. The PCB-containing capacitors in the electrical substations are
in a condition where leakages, due to corrosion, are occurring and leakages are expected to increase in the
coming years. Analysis has determined very high levels of PCB contamination at the capacitor sites
primarily at Vulcanesti where the 10,000 m2 of soil underneath this assemblage, to a depth of 60 cm, has
been found to be contaminated with PCBs.
An inventory of capacitors held by users of electricity has not been undertaken as yet, but based on expert
judgments the total PCB-content of those capacitors is roughly estimated at approximately 20-50 tons. A
detailed inventory of PCBs in transformers, switches and other electrical equipment has not been finalized
(but will be financed by this project) but according to a preliminary inventory about 30,000 tons of
dielectric oils are used in electrical power installations.
From a regulatory and institutional perspective Moldova does not have any specific requirements for the
management and control of POPs, but to a certain extent some of the requirements of the Stockholm
Convention are covered in a general sense under existing legislation and institutional arrangements. The
Ministry of Ecology and Natural Resources (MENR) is the central national environmental authority
which has been designated the Stockholm Convention competent authority and as such is responsible for
coordinating the POPs related activities of the following government bodies involved in chemicals
management issues: Ministry of Health, Ministry of Agriculture and food Industry, Ministry of Industry,
Ministry of Energy, Ministry of Economy, Ministry of Internal Affairs, Ministry of Defense, Department
of Customs, Department of Standardization and Metrology, and the Department for Emergency
Situations. Local authorities have responsibilities for environmental protection and management in the
limits of their territory. A National Coordination Committee (NCC) for implementation of the Stockholm
Convention, with MENR, as the lead agency has been established to provide overall guidance and
coordination for POPs NIP development. The NCC will act as the steering committee for the Project.
The roles and responsibilities are outlined in Annex 6 for each of the agencies.
The MENR is responsible for developing the POPs National Implementation Plan (NIP) and for
compliance and enforcement of national legal requirements and international obligations related to
management of toxic and hazardous products and substances. Capacity for enforcement of provisions of
the Articles covered under the Convention is currently non existent in Moldova. The NIP has identified
the need for a gap analysis of existing legislative requirements for POPs to bring them in line with that of
the Convention and comparable to those in EU countries for POPs and other toxic chemicals and wastes.
Rationale for Bank involvement
As a GEF Implementing Agency the Bank has a responsibility to help its client countries achieve the
global environmental objectives that are supported by the GEF. The GEF is the interim financial
mechanism of the Stockholm Convention and this Project will contribute significantly to achieving the
objectives of the corresponding GEF Operational Program for Reducing and Eliminating Releases of
Persistent Organic Pollutants (OP14). The Bank has been very active in supporting Moldova in
improving its environmental management capabilities and in incorporating environmental and social
concerns into its sector operations. The proposed project is consistent with the Bank’s Environment
Strategy and 2005 Country Assistance Strategy (CAS) for Moldova. The key pillars of the strategy –
improving people’s quality of life, quality of economic growth, and quality of regional and global
10
commons – are all reflected in the project’s objectives and approach. The Bank’s technical knowledge on
POPs management and its experience in the design and implementation of GEF investment projects give
it a comparative advantage among the GEF Implementing Agencies in providing this assistance.
2. Higher level objectives to which the project contributes
The project will contribute to both national and global objectives. On the national level, it will support
implementation of the country’s Economic Growth and Poverty Reduction Strategy Paper, which has
several references to POPs, and its action plan proposes interventions in the area of obsolete pesticides
and PCBs, along with the recognition of the need to strengthen institutional capacity in this area. The
implementation of proposed activities would provide many local benefits by reducing the impact of POPs
on public health and environment. The project would address land degradation by preventing further soil
pollution by various POPs.
The project will serve as a triggering mechanism for modernization of the current national chemicals
management system steering it towards environmentally sound management of toxic, persistent, harmful
and bio-accumulative substances in all spheres of human society. Minimization and final elimination of
POPs related pressures and impacts to the natural and human environment is an integral part of national
environmental policy. It is considered that environmentally sound management of chemicals, if being
adequately set up and functioning, is an important element which contributes to a well-being of the
country, society sustainable development and poverty alleviation. Resolution of POPs pesticides
problems, as well as sound management of other prohibited and unused agricultural chemicals, is
considered to be helpful for promotion of Moldovan ecologically clean agricultural products world wide.
The project will also provide the following global benefits: (i) reduced threats on biological diversity the elimination of POPs stockpiles and their sound management would decrease both the global pollutant
burden and possible impacts on wildlife, domestic animals and humans; and (ii) improved transboundary
water quality - by ensuring sustainable POPs management, the project will contribute to the prevention of
future contamination and threats to the quality of the global hydrological regime. It will also contribute to
the objectives of two other international environmental agreements – the Basel Convention on the Control
of Trans-boundary Movements of Hazardous Wastes and Their Disposal and the Rotterdam Convention
on the Prior Informed Consent Procedures for Certain Hazardous Chemicals.
B. PROJECT DESCRIPTION
1. Lending instrument
The lending instrument is a GEF grant. The grant will be complemented by counterpart funding from
Moldova as well as multilateral and bilateral funding.
2. Project development objective and key indicators
The main development objective of the project would be to protect the environment and human health by
safely managing and disposing of stockpiles of POPs contaminated pesticides and PCBs.
The global project objective of the project is sustainable POPs stockpiles management and strengthening
of the regulatory and intuitional arrangements for long term control of POPs and other toxic substances in
line with the requirements of the Stockholm Convention and other related conventions and protocols
ratified by Moldova. To track the progress toward achieving this development objective, the project will
use four key results indicators as summarized below, and explained in more detail in Annex 3:
(i)
(ii)
Reduced risks of POPs environmental pollution to human health by safely storing and disposing
of stockpiles of POPs contaminated pesticides and PCBs
Destruction of 1,060 tons of PCBs from capacitors and 1,150 tons of POPs containing and
contaminated obsolete pesticides
11
(iii)
(iv)
Modern regulatory system established within Moldova for the management and control of POPs
and other toxic and harmful chemicals and wastes
Institutional and human capacities for enforcement of the POPs regulatory framework and for
sustainable POPs stockpiles management strengthened
3. Project components
The project consists of three components: (1) Management and Destruction of POPs; (2) Development of
a Regulatory Framework for PCB Management and Control; and (3) Institution Strengthening and Project
Management. The project will be financed with a grant from the GEF (US$6.35 m), counterpart
contributions (US$3.72 m), and other donors (US$2.53 m). Project components and their cost estimates
are listed in Table 1.
Table 1. Summary of Proposed Project Components Costs (including 5% contingencies)
Component
1. Management and Destruction
of POPs
2. Development of a Regulatory
Framework for POPs
Management and Control
3. Institutional Strengtheing and
Project Management
Total
Cost
(US$ m)
% of
Total
Cost
GEF
Grant
(US$ m)
Counterpart
Funds
(US$ m)
Other
Donors
(US$ m)
8.23
65
3.79
2.78
1.66
2.31
18
1.27
0.50
0.54
2.06
16
1.29
0.44
0.33
12.60
100
6.35
3.72
2.53
Component 1. Management and Destruction of POPs (US$ 8.23 m, of which GEF US$ 3.79 m)
This component consists of two sub-components: (i) Destruction of Stockpiles of POPs Containing and
Contaminated Obsolete Pesticides; (ii) Management of PCBs and Destruction of Obsolete Capacitor
Stockpiles.
Sub-component 1.1. Destruction of Stockpiles of POPs Containing and Contaminated Obsolete
Pesticides. (US$ 5.37 m, of which GEF US$ 1.21 m)
This sub component will finance the destruction by incineration of approximately 1,150 tons of stockpiled
obsolete pesticides (out of the total 3,000 tons). NATO is co-financing this sub-component and is
seeking additional financing to dispose of the remaining obsolete pesticides (about 1950 tons).
The
stockpile warehouses were prioritized in terms of the risk they would pose to the environment and
humans if there were leakages. The project will finance disposal of obsolete pesticides stockpiles at 10
sites ranked as having the highest risk for threats to environment and human health. As additional funds
become available, the risk ranking will continue to be used to prioritize stockpiles for disposal (see Annex
4).
Local public authorities are responsible for supervising the warehouses containing obsolete
pesticide stockpiles. The project will ensure that this responsibility is fulfilled.
Sub-component 1.2. Management of PCBs and Destruction of Obsolete Capacitor Stockpiles. (US$
2.86 m, of which GEF US$ 2.58 m)
This sub-component consists of three activities: (1) establishing an inventory of PCB containing or
contaminated equipment; (2) destruction of a stockpile of obsolete capacitors; and (3) feasibility study of
site clean-up at Vulcanesti Substation.
12
Activity 1. Establishing an Inventory of PCB Containing or Contaminated Equipment. (US$ 0.48
m, of which GEF US$ 0.28 m) This will finance a detailed inventory of PCB-containing or
contaminated equipment, and include appropriate labeling and identification of premises where the
equipment is located. The following tasks are planned: (i) Preparation of inventory forms and guidelines
to holders of PCB contaminated equipment on how to carry out an inventory, notification and reporting
requirements.; (ii) identification of potential holders of equipment; (iii) purchase of simple test kits for use
by holders to screen transformer oils for potential contamination; (iv) purchase of analytical kits for 3
laboratories to enable them to carry out accurate analyses of oils that test positive for contamination and
training of laboratory technicians in the use of such kits; (v) develop labeling system and provide labels
for use by holders; (vi) training of MENR’s State Ecological Inspectorate (SEI) Inspectors on
identification and notification of PCB contaminated equipment; (vii) presentation of seminars for
potential holders of equipment on identification and test screening for contamination; (viii) sending
information and forms to potential holders and follow up by SEI Inspectors; (ix) establishing a database
for storing information from the inventory and for future management of PCB contaminated equipment
(Component 3); and (x) development of future management options for final disposal of PCBs and
decontamination of equipment.
Activity 2. Destruction of a Stockpile of Obsolete Capacitors. (US$ 2.09 m, of which GEF US$ 2.07
m) This will finance: (i) dismantling of 17,300 obsolete capacitors from thirteen substations and
packing in closed containers (approximately 899 tons); (ii) excavation of 2,000 capacitors buried in
two pits in the Vulcanesti substation and packing in closed containers (approximately 111 tons); (iii)
destruction of 19,300 capacitors and up to 50 tons highly polluted soil (approximately 1,060 tons) by
incineration.
Activity 3. Feasibility Study of Site Clean-up at Vulcanesti Substation. (US$ 0.29 m, of which GEF
US$ 0.24 m) This activity will finance a study to assess the technical, financial and environmental
feasibility of different remediation approaches and recommend a least cost solultion.
Component 2. Strengthening the Regulatory Framework and Capacity Building for POPs
Management. (US$ 2.32 m, of which GEF US$ 1.27 m) This component includes actions for
modernization of current legislation specifically related to the Stockholm Convention and incorporation
of provisions for establishing a broader chemical safety approach in the country based on EU directives.
Full transposition of all relevant EU legal acts shall be achieved.
Sub-component 2.1: Modification of the Regulatory Framework for POPs Management.
(US$ 0.74 m, of which GEF US$ 0.61 m)
This sub-component will provide a legal basis for POPs chemical management under Stockholm
Convention requirements and set-up an overall chemical safety system in Moldova according to the EU
regulation and legislation related to handling of dangerous chemical substances and hazardous waste. It
will develop an integrated system of POPs management. Three Activities will be funded under this subcomponent: (i) Assessment of Existing Legislation Regarding Compliance with EU Regulations; (ii)
Assistance in Drafting of Relevant Regulations and Instructions; and (iii) Development of Regulatory
Mechanisms:
Activity 1. Assessment of Existing Legislation Regarding Compliance with EU Regulations. (US$
0.25 m, of which GEF US$ 0.21 m) This activity will finance a gap analysis comparing EU legislation
and Conventions’ requirements with existing legislation in Moldova and the preparation of Table of
Concordance in relation to international obligations for POPs, hazardous wastes and dangerous
substances.
Activity 2. Assistance in Drafting of Relevant Regulations and Instructions. (US$ 0.25 m, of which
GEF US$ 0.21 m) This activity will finance preparation of national legislation to: strengthen the
chemical safety management system in Moldova; clearly define responsibilities; specifically prohibit
13
production and use of POPs chemicals and regulate their export/import; and provide a legal basis for
reduction/elimination of unintentional releases from production processes. The legal provisions will
cover: (i) POPs contaminated site management issues; (ii) responsibility for POPs contaminated sites; (iii)
incorporation of POPs monitoring and reporting; (iv) assessment of new chemicals meeting POPs
criteria; (v) BAT and BEP for new and existing sources; and (vi) requirements for modified materials,
products and processes.
Activity 3. Development of Regulatory Mechanisms. (US$ 0.23 m, of which GEF 0.19 m) This will
finance development of specific implementing regulations (by laws) and instructions. The regulations and
instructions will be prepared based on the EU legislation.
Sub-component 2.2: Capacity Building (US$ 1.58 m, of which GEF US$ 0.66 m)
This sub-component consists of two activities: (i) Strengthening of Inspectorates for Enforcement of
POPs Regulations; and (ii) Upgrading and Strengthening of Existing Laboratories for POPs Analysis.
Activity 1. Strengthening of Inspectorates for Enforcement of POPs Regulations and Prevention of
Further Accumulation of POPs stockpiles (US$ 0.25 m, of which GEF US$ 0.19 m) The goal of this
activity is to increase the skills of key inspectors in government agencies who will be dealing with the
enforcement of regulations developed under sub-component 2.1.
Activity 2. Upgrading and Strengthening of Existing Laboratories for POPs Analysis.
(US$ 1.23 m, of which GEF US$ 0.47 m). This will finance upgrading of the laboratories of the State
Environmental Inspectorate (SEI), Ministry of Health (MOH) and the Hydrometeorological Service for
POPs detection in different media; and support the regulatory requirements for reporting, management
and control of POPs at national and international levels. This activity will be co-financed by NATO’s
“NATO Science for Peace: Development of Modern Analytical Approaches for POPs Investigation
Project.”
Activity 3. Prevention of Accumulation of new Stockpiles of Obsolete Pesticides (US$ 0.11 m, of
which GEF US$ 0.00). Besides developing new regulations to eliminate or minimize risks to health and
the environment that are stipulated within Component 2, the project will provide support in promoting
best practices in Pest Management in crop production, including Integrated Pest Management (IPM) that
is based on careful integration of a number of available pest control techniques. The project will benefit
from two projects which support integrated pest management. The World Bank Rural Investment and
Services Project (RISP) II finances extension services which disseminate good agricultural practices to
farmers and farmers associations including integrated pest management. The Milieukontakt Oost-Europa
(Dutch Environmental NGO) Project : Elimination of acute risks of obsolete pesticides in Moldova,
Georgia, Armenia, finances training and extension services related to pesticide management. Activities
related to best practices in agriculture financed under the RISP I Project and the Agricultural Pollution
Control project will benefit the project.
Component 3. Institutional Strengthening and Project Management Support (US$2.06 m of which
GEF US$1.29m)
This component of the project consists of two sub-components: Institution Strengthening and Project
Management Support
Sub-component 3.1. Institutional Strengthening (US$ 1.43 of which GEF US$0.74)
This sub component will strengthen the MENR’s capacity for POPs management and includes the
following activities. (i) POPs Information Management and Reporting System for POPs (ii) POPs
Monitoring Network; (iii) Identification of POPs residuals and Mapping of Polluted Areas; and (iv) POPs
Awareness and Educational Activities.
Activity 1.POPs Information Management and Reporting System. (US$ 0.40 m, of which GEF US$
0.25 m). This activity will finance: (i) the design of a central management information system, including
14
data base and GIS applications; (ii) installation of required hardware and software and training of staff
for operation; and (iii) testing of the information system performance.
Activity.2. POPs Monitoring Network. (US$0.17 m, of which GEF US$ 0.11) This activity will
finance an interlinked monitoring network for POPs within national laboratories in SEI, MOH, and the
Hydrometeorological Service.
Activity 3. Identification of POPs Residuals and Mapping of Polluted Areas. (US$ 0.23m, of which
GEF US$0.19m) This activity will support a research effort by local institutes to identify, characterize
and perform a risk assessment of these sites for decisions on future management options.
Activity 4. POPs Awareness and Educational Activities (US$ 0.62 m, of which GEF US$0.19 m). As
part of the social assessment (SA) conducted during preparation, a survey of public perceptions in respect
to POPs in several rural localities and in the city of Chisinau was done and revealed a lack of
understanding of problems related to POPs and other dangerous chemicals. The survey has also revealed
very limited knowledge regarding POPs sources and effects within groups with a high risk of POPs
exposure, such as: farmers, industry employees, staff of the power and heat generating and distributing
companies, and units responsible for collection and disposal of waste. The goal of this activity is to
create a communications framework for POPs and other chemicals and to improve awareness of the
Moldovan public regarding POPs sources and effects through awareness building activities, as well as
training and education of target groups with higher exposure to risks.
Sub-component 3.2. Project Management Support. (US$ 0.64m, of which GEF US$ 0.55 m)
A project management team (PMT) within the MENR will carry out the usual project management
functions of financial management, procurement, auditing, managing, monitoring and evaluating project
implementation, and dissemination of project results. The PMT is already operational having been
established during the GEF supported NIP preparation and has been further supported by a GEF PDF B
Grant for the preparation of this project. The Unit has established its financial management system,
which has been audited by the Bank’s FM Specialist as noted in Annex 7. The deficiencies noted in this
audit have since been rectified by the PMT. The PMT will include a Project Manager, an assistant, a
procurement specialist and a part-time financial management/disbursement specialist. The PMT staff
will remain the same under implementation.
4. Lessons learned and reflected in the project design
The project design draws upon the Bank’s considerable experience in working with Moldova on
environmental issues, including those related to agricultural chemicals. The Bank has been working
closely with Moldova on the implementation of other GEF projects and lessons learned in these programs
have been taken into account in designing this project. Finally, the Bank has drawn on the experience of
POPs projects in China and Africa and on experience generally in implementing similar projects in ECA
and other regions. Specific lessons include:
Keep the design of the project simple: The design of all of the components of this project have been
kept as simple as possible and draw on extensive experience gained on similar projects worldwide. For
instance Component 1 utilizes highly experienced hazardous waste plant operators to destruct the stocks
of PCBs and obsolete pesticides and contracts will be designed as a “cradle to grave” approach with the
contractor taking responsibility for dismantling capacitors and packaging them in International Bulk
Container (IBC) containers, repackaging drums of pesticides in IBC containers, transporting the IBC
containers to the hazardous waste disposal facility and final destruction. Packaging as one large contract
will attract the most bidders and will likely lead to a number of cost savings over separate contracts for
the two sub-components. Components 2 and 3 draw upon extensive experience in Europe for the
management and control of POPs and other dangerous substances and the EU directives that have been
promulgated to control these substances will be adapted to Moldova’s regulatory needs and provide early
harmonization with the EU system. An early proposal to carry out three pilot projects to remediate POPs
pesticide contaminated storage sites was rejected because of costs and complexity.
Setting up of the Project Management Arrangements:
15
The project will benefit from the early
establishment of a Project Management Team (PMT) for the management of the initial NIP preparation
under the GEF EA grant funding and a subsequent PDF B Grant from the GEF for the preparation of this
project. The staff of the PMT have proven their competence and have been exposed to many of the
requirements of the World Bank for the effective management of such projects. They already have set up
accounting systems and have developed certain skills in procurement that will prove highly beneficial for
the early start to project implementation. Deficiencies noted in the Financial Management Audit and
Procurement Audit during this project’s preparation also have been rectified.
Early start on regulatory reform process: Experience on other projects in the Region and elsewhere in
the Bank, which have required regulatory reforms have encountered long delays. With this experience in
mind, MENR has agreed to start the development of the regulatory instruments required for the
implementation of Component 2 by June 2005 and to include the estimate of counterpart funds to carry
forward this activity as well as the other activities under the project in the budgeting process occurring at
that time. Only the highest priority needs of the project have been identified for this initial activity under
Component 2.
Involvement of Local Stakeholders: The process of developing the NIP and the carrying out the
Environmental and Social Assessment for this project involved a wide group of local stakeholders in
government as well as NGO’s and local communities that have been affected by POPs pollution. The
consensus that was arrived at during this consultation process has resulted in an agreed National Action
Plan, to which this project contributes in a very substantial way. There is strong evidence of broad support
within government and local communities for the implementation of this project.
5. Alternatives considered and reasons for rejection
For Component 1, five additional alternatives were considered, but rejected in favour of the proposed
project design:
-
No action Consideration has been given to leaving the PCBs in the sites undisturbed and to leaving
the obsolete pesticides in the 37 centralized storage sites. This was rejected because of the potential
threat to human health and the environment - both in Moldova and globally - posed by leaking
capacitors or leakages or accidents at the centralized storage sites, particularly the sites which were
assessed to pose potential extremely high or high risk.
-
Medium to long-term storage of POP containing and contaminated pesticides. Storage can be
implemented in the current configuration (37 centralized facilities), in one facility or in a number of
facilities. The idea of storing the pesticides in one single (existing) place was tested by the
Government but never accepted by the populace. The option of a new storage construction is
expensive. Besides, Moldova is a densely populated country, with predominantly rural population
and intensive agriculture land-use. Therefore, selecting a site responding to all health and
environmental criteria and resolving associated tenure problems would be hard to accomplish. This
option requires regular inspection of stores, immediate containment of leakages and spillage's and
proper stacking of available stock. It requires significant operating and maintenance costs while not
providing a final solution to the problem.
-
Collect PCB contaminated capacitors and store for future disposal. Consideration was given to
just collecting the PCB containing equipment from the site and moving it into safe storage. This was
rejected because of the potential harm that could be caused by leaving the PCB equipment in a
storage facility vulnerable to renewed release by natural disaster, accidents, fires or other human
failures. In any case the equipment has to be finally destructed and there is no reason for anticipating
that cheaper disposal would be available in the future. Overall the costs would be higher than the
16
selected alternative if a temporary storage facility is established and the capacitors were stored prior
to disposal.
-
Collect and destruct POPs in a permanent destruction facility in Moldova. At the current time
there is no consideration as to establishing a permanent facility for destruction of hazardous waste in
Moldova due to the small amount of waste that is generated in the country. Discussions have been
held with the private sector operator of a cement plant but considering the very high cost of
retrofitting this plant to process hazardous wastes and to meet EU emission limits on dioxins and
furans it is not feasible to undertake these investments just to treat the stocks of pesticides and
capacitors that will require disposal under this project. The costs per tonne would likely be double
that of the proposed project.
-
Collect and destruct POPs in a mobile facility. Consideration has been given to destruction of the
capacitors and stocks of obsolete pesticides in a mobile incinerator set up at one fixed location. A
mobile incinerator of acceptable standard costs at least about US$ 5-7 million. Using a mobile
incinerator for capacitor destruction would also imply installation of a unit for shredding the
capacitors before treatment at a price of approximately US$ 1 million. Infrastructure costs for setting
up the incinerator would add an additional US$ 1 million to the capital costs, which would likely be
in the range US$ 7 – 9 million. Operation and maintenance costs to dispose of the 4,000 tons of
PCBs and pesticides would add at least an additional US$ 2 million. Thus the total cost would be in
the range US$ 9 – 11 million, compared with US$ 8 million for the proposed project design. There
also could be long delays and public opposition to the setting up of such a facility which would add
to risks of POPs releases and add to the costs. For these reasons this alternative was rejected.
-
Collect and Store POPs until a possible future Regional Hazardous Waste Facility is built.
UNEP is promoting such a facility under its Strategic Approach to International Chemicals
Management (SAICM). Firstly, there are grave doubts that this facility will ever be built in this
region considering the excess current private sector capacity for hazardous waste treatment in
Europe. Moreover, there is no guarantee that such a facility could treat Moldova’s POPs’ stockpiles
at a lower cost than the private sector. In addition Moldova would be forced to store its POPs
stockpiles until such a facility is built (if ever) greatly adding to its costs and, as argued above, would
represent a higher cost alternative than the proposed project design. For these reasons it was rejected.
For Components 2 and 3, the only other alternative considered was to do nothing to improve the
regulatory and institutional arrangements for management and control of POPs. This was rejected on the
basis that Moldova needed to meet its obligations under the Stockholm Convention. During the
preparation of the NIP an analysis of the current arrangements showed there were many shortfalls in the
current system compared with these obligations.
C.
IMPLEMENTATION
1. Partnership arrangements
Financial partnerships: The Global Environment Facility (GEF), as the interim financial mechanism for
the Stockholm Convention, will provide most of the funding for this project. In addition, NATO, and
Bilateral NGOs will be the co-financiers of the project, as will the Government of Moldova.
Coordination among international donors: POPs issues have captured the attention of a number of
donors in Moldova including France, the Netherlands, the USEPA, NATO, UNIDO, Bilateral NGOs, and
some academic institutions with linkages to Moldova, e.g. North Carolina State University, United State
of America. The entry point varies amongst the donors, as it has for the World Bank, depending on the
sector with whom they have shared interests. The PMT will coordinate the activities of the donors in this
17
sector to achieve maximum synergies and efficient use of donor resources. The following are proposals
for assistance in the phase out of POPs in Moldova:
NATO project on upgrading MAFI analytical laboratory capacity to identify the POPs content of
obsolete pesticides. Based on the request of Moldovan Government, NATO will provide to the Ministry
of Agriculture laboratory equipment ( at the level of Euro 0.125 million) for identifying the content of
repackaged obsolete pesticides as well as its operating costs for the next 2 years (with a financing of about
Euro 200,000) - the total NATO financing is US $ 363.000.
NATO project on Destruction of Pesticides and Dangerous Chemicals in Moldova In
coordination with the proposed GEF project will assist in the financing of repackaging, storage, and
disposal of obsolete pesticides – US$1.04 million.
Milieukontakt Oost-Europa (Dutch Environmental NGO) Project: Elimination of acute risks of
obsolete pesticides in Moldova, Georgia , Armenia. The overall objective of the project is to eliminate
the risks of further contamination of obsolete pesticides and to contribute to the betterment of the
environment regarding the risks of pesticides residues. The (short term) project goal is to eliminate the
acute risks of further contamination from obsolete pesticides through proper storage and destruction of
chemicals, and to set an example for the international community more specifically in Eastern Europe.
The project started in January 2005 and is supporting demonstration activities for obsolete pesticide
stockpiles repackaging and centralized safe storage. It also supports a broad information dissemination
and public awareness campaign, including POPs pollution prevention and promotion of Integrated Pest
Management. The Moldovan component will be financed at US $ 930,000.
Support for the Project from Other World Bank Credits to Moldova: Other World Bank operations
in Moldova will support this project in various ways. For example:
IDA funded Energy II project. The project component on Feasibility Study for Rehabilitation of
System Metering, Dispatch, Communications and Transmission will support several activities regarding
PCBs in the energy sector. In particular the project will finance the upgrading of analytical laboratory
equipment for identifying PCBs, as well as for undertaking a PCBs inventory in the sector. The level of
financing is US$ 200,000.
IDA funded Rural Investment and Services Project (RISP)II. The project is under preparation
and it is proposed to support rural advisory services, including consultancy in the area of pesticides usage
in agriculture. These activities will be implemented by the existing national rural extension network
(Agriculture Consultancy and Scholarship Agency, - ACSA), that includes 460 networks, of which 100
are regional and 350 local. This network provides advisory services for more than 700,000 clients. The
level of financing of these activities is expected to be US $100,000.
The RISP I and Agricultural
Pollution Control project also finance activities related to best practices in agriculture which will benefit
the project.
2. Institutional and implementation arrangements
MENR has been designated as the national lead implementing agency for all POPs activities and
implementation of the POPs Convention. It will be the implementing agency for the project. Other
national and local government agencies that will be involved in the project are described in Annex 4. and
include: the National Coordination Committee (NCC) for implementation of the Stockholm Convention;
the POPs Convention Focal Point (CFP); the Ministry of Industry and Infrastructure (MOI);
Moldelectrica; the Ministry of Agriculture and Food Industry (MAFI); and the Ministry of Defense
(MOD) and Department of Emergency Situations (DES). The reporting relationships are shown in
Figure 1:
18
Figure 1. Framework of the Institutional Arrangements for Implementation of Proposed POPs
Project
The National Coordination
Committee for POPs
Ministry of Environment and
Natural Resources
Ministry of Agriculture
and Food
Ministry
of Defense
Ministry of Industry and
Infrastructure
Department of
Emergency Situations
Moldelectica
Other Ministries, Departments and
Agencies dealing with POPs
19
3. Monitoring and evaluation of outcomes/results
The monitoring indicators describe in section B2 reflect the project’s focus on: (i) the environmentally
sound management and disposal of the majority of POPs stockpiles in the country; (ii) on reducing risks
from PCBs in the remaining electrical equipment still in use; (iii) strengthening the regulatory system for
POPs management and control; and (iv) providing better oversight and coordination of POPs related
activities, including information management and dissemination. The data for determining the values of
the proposed indicators will come from two main sources. First, an important monitoring and control
arrangement will be set up for the POPs stockpile destruction contract with the hiring of an experienced
consulting firm to assist Moldelectrica and MOFI to monitor and supervise the destruction contract. Not
only will the firm ensure that the contractor meets all its technical, environmental, health and safety
obligations under the contract but it also will closely review and validate all of the contractors requests for
payments on completion of agreed stages of the contract. Confirmation of these data will provide the
information on how much of the POPs stockpile has been packaged in IBC containers, transported and
finally destructed, as well as compliance with other conditions of the contract. The second source of data
for monitoring and evaluation of results will be the MIS that will be set up and operated by the PMT.
The PMT will assign an IT specialist to the development and operation of the MIS with support from MIS
consultants in the setting up of the system. This system will store all of the data gathered in the inventory
from holders of PCB contaminated equipment and will continue to track these data for the life of the
equipment through to final destruction of the PCBs. The MIS will also track the development of the new
POPs regulatory system and results from the improved and expanded monitoring of POPs contamination
and identification of areas requiring additional security measures to prevent access of animals and people.
It also will track progress on all aspects of project implementation and highlight where delays are being
experienced as an early warning indication for corrective action. These will be highlighted in quarterly
reports on progress in meeting results indicators and implementation progress in general, which will be
prepared by the PMT.
The World Bank is responsible for supervising the implementation of the project to ensure that financing
is used only for the purposes intended, with due regard to efficiency and economy. Bank missions will
visit Moldova at least twice a year for this purpose. An annual meeting will be held to review project
implementation with representatives from all project stakeholders. Progress reports will be distributed
beforehand for review at the meeting.
3. Sustainability and Replicability
As a Party to the Stockholm Convention, Moldova is obligated to identify, manage, and dispose of POPs
in an environmentally sound manner. With the destruction of about 30% of the stocks of POPs
contaminated obsolete and banned pesticides and approximately 80% destruction of the PCB’s in the
country, Moldova will have taken a large step in meeting its POPs convention commitments. Financing
for the destruction of the remainder of the obsolete pesticides is being determined. For the remaining
20% of the PCBs in electrical equipment which is scattered through out the country the project will
support the introduction of a comprehensive legal and institutional framework for POPs and dangerous
substances consistent with the EU Directives for these substances. This will lead to the establishment of a
national inventory of holders of PCB containing and contaminated equipment and a management plan for
the ultimate disposal of this stock of PCB’s according to the program set out in the Convention.
The sustainable management of this residual stock of PCB’s will be assured with the support of the
capacity building activities of the project, which will provide training of Inspectors in all aspects of PCB
enforcement, management and control and in establishing Inspector networks across the country along the
lines of the EU’s IMPEL-TFS . In addition the strengthening of the analytical capabilities of key
20
laboratories in PCB and POPs measurements will allow Inspectors and other regulators to track POPs in
equipment, in process, in emissions and in the environment. A comprehensive system of POPs regulation,
testing, enforcement, management, data storage and information exchange will be put in place to assure
the Convention Parties of Moldova’s commitment to the complete elimination of POPs in the country and
the protection of its people and the environment.
This project will build upon other related and ongoing POPs projects. These include: (a) development of
a National Implementation Plan for the Stockholm Convention, which has been completed with GEF
funding; (b) the ongoing NATO projects to set up a dedicated laboratory for POPs analysis and
repackage, transport and destroy obsolete pesticides ; and (c) repackaging of obsolete pesticides under the
direction of MOFI. These activities have already provided useful information which has been used in the
development of this project.
This project does not seek to introduce a new approach to POPs management and control, but uses well
established models from the experience of other countries. Since the project targets the whole country,
internal replicability does not apply as it would in a much larger country where one province or state was
initially targeted for POPs phase out. However, as a country model the approach adopted would be
replicable in other relatively countries with strong central government systems.
4. Critical risks and possible controversial aspects
Risk
Rating
To Project Development Objective
Barriers and delays in development
of POPs regulations and their timely
implementation
S
Risk Mitigation Measure
MENR starting the gap analysis of
legislation prior to project start up
Training and Capacity building for
drafting legislation across ministries
involved in POPs
Use of applicable EU Directives as the
legislative model and commitment of
Moldova to harmonize its laws with
these Directives.
To Component Results
Uncertainty in the estimate of total
quantity of POP containing and
contaminated obsolete pesticides for
destruction
S
Contract for a guaranteed minimum
quantity of pesticides for destruction and
a cost per tonne for any amount over the
guaranteed amount. MAFI has added a
contingency amount of 500 tons over
their 2002 estimate of 2,500 tons, making
a total of 3,000 tons, which is the amount
used for cost estimates in this PAD.
Agree a yearly financing plan for
counterpart funds for the project with
MOF early in the budget process and
make realistic estimates of Moldova’s
capacity for such payments in the
original financial plan for the project
Incorporation of EMP in contract
conditions, independent supervision by
consultant of contractor’s compliance
with environmental and health and safety
conditions in the contract, and prequalification of contractors
Lack of provision of counterpart S
funds
Accidental release of POPs during
packaging, transport and disposal
N
21
Problems in setting up MIS
impacting on effectiveness of PCB M
inventory
Overall Risk Rating
Extensive stakeholder consultation on
end user requirements of MIS,
development in linked modules, and
utilization of highly qualified experts to
design and set up the system
M
5. Loan/credit conditions and covenants
1. Covenant on counterpart funds
2. Financial Management Conditions: Satisfactory financial management arrangements in place before
Board presentation date.
3. Financial Management Covenants: The recipient will maintain a financial management system
acceptable to the Bank. The project’s financial statements, withdrawal applications and Special Account
will be audited by independent auditors acceptable to the Bank and on terms of reference acceptable to
the Bank. The annual audited statements and audit report will be provided to the Bank within six months
of the end of each fiscal year.
D.
APPRAISAL SUMMARY
1. Economic and financial analyses
The is contributing to local and global public good by reducing the risk of contamination to the
environment through releases of POPs contaminated pesticides and PCBs. Typical economic or financial
analysis is difficult in this situation. While it may be theoretically possible to apply cost-benefit analysis
to the process, the lack of reliable base data on health and the controversial aspects related to the
valuation of human life make such an analysis impractical. It is nonetheless clear that the benefits from
reducing damage to the environment and to human health from releases of POPs will substantially exceed
the costs associated with implementing this project.
Health impacts associated with POPs exposure
include suppressed immune systems, respiratory damage, reproductive health problems, cancer and
neurological and behavioral problems. It is difficult to establish the direct link between exposure and
health conditions under the best of conditions and in Moldova there is scarce documentation of any types
of environmental health conditions. However, the health problems caused by POPs are clearly evidenced
in the Moldovan health profile; the contamination of water, soils, and other media, e.g.mother’s milk, by
POPs is documented; and the exposure risks are demonstrable. The project will seek maximum costeffectiveness in all of its interventions, and it has used maximum risk reduction as the criterion to
prioritize among the POPs issues being addressed.
2. Technical
According to the Stockholm Convention each party shall take appropriate measures so that POPs wastes
are "Disposed of in such a way that the persistent organic pollutant content is destroyed or irreversibly
transformed so that they do not exhibit the characteristics of persistent organic pollutants or otherwise
disposed of in an environmentally sound manner when destruction or irreversible transformation does not
represent the environmentally preferable option or the persistent organic pollutant content is low, taking
into account international rules, standards, and guidelines, including those that may be developed
pursuant to paragraph 2, and relevant global and regional regimes governing the management of
hazardous wastes;” (SC, Article 6).
The technical option of incineration to be used in the project was determined based on review of a number
of reports by national and international agencies concerned with POPs and PCBs; consultation with POPs
technical specialists; and a thorough analylsis of options. These are described in detail in Annex 1.Based
on the available information, it is concluded that incineration is the best disposal option provided that the
incinerator meets the requirements of internationally accepted environmental standards, for example, as
stipulated in the European Union Waste Directive with a dioxin/furan atmospheric emission limit of less
22
than 0.1 ng I-TEQ/Nm3. Incineration meeting this limit value is currently the least cost acceptable
technology for destruction of PCB-containing capacitors and POPs contaminated pesticides in Europe
where there is currently available capacity for destruction of Moldova's stockpiles of these hazardous
wastes.
3. Fiduciary
The Bank’s Financial Management Specialist visited Moldova during the week of May 16, 2005 to carry
out a FM audit of the PMT. The financial management arrangements of the project were found to be
generally sound. A number of actions to further strengthen the project financial management
arrangements were agreed upon and implemented prior to the Bank’s pre-appraisal mission, July, 2005.
Annex 7 presents the details. The Borrower is in compliance with its audit covenants of the Bankfinanced projects. Formats of the FMRs and financial reports and of the audit terms of reference will be
developed, agreed upon and will be attached to the minutes of negotiations.
The 2003 Country Financial Management Accountability Assessment (CFAA) in Moldova concludes that
the financial accountability framework in Moldova is weak and requires substantial strengthening. The
key weaknesses identified include (a) budget framework process is fragmented, (b) inefficient cash
management, (c) weak internal control and internal audit, and (d) inadequate external audits. It would be
inappropriate for the Bank to place a blanket reliance on that framework for the purposes of satisfying the
Bank’s fiduciary financial management requirements. Specific procedures have been developed by the
project to secure proper financial accountability of this project.
4. Social
A social assessment (SA) was conducted under project preparation. The SA has identified and dealt with
potential social issues and concerns of local population and primary stakeholders in the project’s areas of
influence. It has been integrated with two public consultations regarding the EA preparation and the
institutional assessment. Because the costs and benefits of changes associated with the project’s
implementation are anticipated to be felt most acutely on the local level, the focus of the SA has been
affected communities around POPs storage fcilitiy sites. The broad categories of primary stakeholders
have included: local communities and NGOs, local authorities and experts. The project is expected to
have measurable and significant social benefits by reducing public health risks associated with past,
current and potential future releases of POPs pesticides and PCBs. The benefits of the project are
primarily related to the removal and destruction of selected POPs pesticides and PCBs stockpiles and
avoidance of future costs from accumulating.
The number of Moldovan people likely to directly benefit from the project is estimated to be over 150,000
people living in the vicinity of POPs sites (it should be also noted that the number of people
professionally and directly exposed to pesticides at work has been estimated to drop from 34,700 in 1993
to 8,800 in 2002.). The project will reduce opportunity costs that are lost when resources are diverted to
management and replacement of POPs as well as it will lower economic losses associated with: land
contamination (lost productivity;) health impacts (healthcare costs, lost labor;) impacts on livestock
(death or illness) and crops (crop losses or contamination;) degradation of natural resources (water and
soil contamination,) and wildlife impacts (poisoning of natural pest predators.)
Local, regional, regional and global benefits of the project include: reduced pollution of water supplies;
reduced pesticides and PCBs entering regional and global food chain through soil contamination; reduced
impact on poor; reduced impacts on land, biodiversity, transboundary watercourses and international
waters; compliance with international conventions.
The project’s benefits accrue principally through the elimination or avoidance of contamination and its
consequences, caused by the existence of the stockpiles of POPs pesticides and PCBs. It will therefore be
23
of significant benefit to both local and regional levels, and the health and well being of local and regional
communities that these banned chemicals are safely and completely destroyed as quickly as possible. The
agricultural potential of exporting clean products will be improved as well as aesthetic attractiveness of
Moldovan nature and tourism potential will be enhanced.
During the SA, 600 households and 120 experts from the selected 19 settlements (14 villages and 5 towns
with the total population of 77,523 people) were interviewed, 48 people participated in 6 focus group
discussions and over 200 people took part in 3 regional workshops. The majority of those interviewed
consider a project aimed at POPs threat reduction and wastes elimination as a great benefit in general but
primarily to those living around POPs pesticides and PCB sites. The SA suggests that creation of a
transparent and timely environmental/POPs communication and education program to be an important
project component, and community participation should be enhanced. The SA findings also suggest a
number of actions that should be incorporated to ensure project sustainability and success:
 Create a permanent local service to provide POPs-related information and advice on
environmentally safe and sound chemicals management, or utilizing the existing network of
private agro-chemicals stores.
 Creation of designated centers for collecting obsolete pesticides and prohibited chemicals from
private citizens and judicial persons for further safe disposal and destruction.
 Ensure timely and transparent public consultations regarding selection of temporary centralized
POPs pesticides storages.
 Create a local waste management service, and consider introducing waste management fees.
 Implement consistent and continuous POPs nation-wide awareness campaign, and ensure
transparent government’s POPs-related communication process.
 Establish rigorous and effective POPs monitoring, compliance enforcement and prosecution of
environmental violations.
 Current burning and unauthorized land-filling of domestic garbage and other wastes, including
POPs, shall be prohibited.
5. Environment
For Environmental Assessment (EA) purposes the project is categorized as an “A” due to the risks
associated with handling of POPs contaminated pesticides and capacitors. However, as about 30% of the
POPs containing and contaminated pesticides held in warehouses around the country and approximately
80% of the PCB contaminated electrical equipment in the country will be destructed under the project,
there will be considerable local and also global environmental and human health benefits, although in the
global context the quantities of POPs are small. As required under World Bank Safeguard Policies and
Procedures, a comprehensive EA was carried out by independent experts. The draft TOR for the EA was
presented to a stakeholders’ workshop on February 8, 2005; modified to reflect the comments of the
participants; and approved by the ECA Safeguards Unit. The EA was carried out over a period of three
months and the draft final EA was presented at a stakeholders’ workshop on May 19, 2005 and was
endorsed by the participants with minor improvements. The EA was been submitted to the ECA
Safeguards Unit (May 30, 2005) and found to be satisfactory. It was disclosed in the Info Shop July 5,
2005, and publicly disclosed.
Due to the nature of the project, the EA was national in scope, but focused on the sites where POPs
containing and contaminated pesticides were stored and electrical substations where obsolete capacitors
containing PCBs are concentrated. The EA concluded that the greatest risks to the environment and
human health were the 37 centralized warehouses where the obsolete pesticides are being stored and the
Vulcanesti substation. The EA carried out a risk assessment at each of the centralized pesticide storage
sites and ranked them according to overall risk, which included: condition of storage buildings; proximity
to populated areas, agricultural lands, watercourses, forest and pasture; vulnerability to floods; depth to
groundwater; amount of pesticides stored; availability of space for storage. The participants at the EA
workshop confirmed that the GEF project must place the highest priority on the earliest removal of
24
pesticides from the warehouses posing the highest risks and transport them overseas for final destruction.
As the capacitors at Vulcanesti and primarily in one grouping, there was no need to prioritize here. The
EA conducted soil and water analyses at Vulcanesti Power Plant and confirmed the extent of the
contamination. It should be noted, no radioactive materials, munitions, or other explosives/weapons are
present at any of the sites at which treatment or disposal of POPs and PCB is to be undertaken during the
course of Project implementation.
An Environmental Management Plan (EMP) was developed as part of the EA preparation which specifies
detailed mitigation measures for all of the operations proposed under Component 1 of the project,
including operations involved in the removal, repackaging, transport and final disposal of the POPs
contaminated pesticides and obsolete capacitors. This EMP will be attached to the Contract Conditions
for the international contractor which will carry out all of these operations. The Contractor will be
required to develop an internal EMP for the project taking into account the all of the requirements of the
project EMP, and will be required to have in place an Environmental Management System (EMS) that
can effectively implement the necessary mitigating measures. The EMS will also have to be linked to an
internal Health and Safety Management System to ensure that all workers on the project will be
adequately protected against chemical hazards and that they use safe working practices. In order to ensure
that the Contractor implements these measures the Supervising Consultant’s scope of work will include
independent verification that the Contractor is meeting all its obligations to protect the environment and
health and safety of employees working on the project. The regular reporting requirements of the
Consultant will include an assessment of these issues.
6. Safeguard policies
Safeguard Policies Triggered by the Project
Yes
No
Environmental Assessment (OP/BP/GP 4.01)
[X]
[]
Natural Habitats (OP/BP 4.04)
[]
[X]
Pest Management (OP 4.09)
[]
[X]
Cultural Property (OPN 11.03, being revised as OP 4.11)
[]
[X]
Involuntary Resettlement (OP/BP 4.12)
[]
[X]
Indigenous Peoples (OD 4.20, being revised as OP 4.10)
[]
[X]
Forests (OP/BP 4.36)
[]
[X]
[]
[X]
[]
[X]
[]
[X]
Safety of Dams (OP/BP 4.37)
Projects in Disputed Areas (OP/BP/GP 7.60)
*
Projects on International Waterways (OP/BP/GP 7.50)
7. Policy Exceptions and Readiness
The Persistent Organic Pollutants Management and Destruction Project does not require any policy
exceptions and is ready for implementation.
*
By supporting the proposed project, the Bank does not intend to prejudice the final determination of the parties' claims on the
disputed areas
25
26
Annex 1: Country and Sector or Program Background
MOLDOVA: Persistent Organic Pollutants Management and Destruction Project
COUNTRY CONTEXT
The Republic of Moldova is a small, landlocked and densely populated country located in the SouthEastern part of Europe, bordering Romania and Ukraine. The country has a population of 4.3 million
people of which 0.7 million live in Transnistria, Moldova's most industrialized region. Transnistria, is de
facto (politically and institutionally) separated from the rest of the country. Out of the total population,
54% are rural inhabitants, most of them involved in agriculture activities. The prevalence of rural
population has important social, economic, political and environmental consequences.
The country is relatively low-lying and hilly, with semi-arid steppe plains in the south covering one third
of the territory and fluvial terraces in the west and the east. Moldova is endowed with fertile black soils,
covering about 70% of the territory. The climate is temperate and continental. Precipitation is low (400500 mm a year) and droughts are frequent.
GLOBAL CONVENTIONS TO CONTROL TOXIC SUBSTANCES
Over the last 40 years the awareness has been growing globally about the threats posed to human health
and the environment by the ever-increasing emissions and discharges into the natural environment of
various toxic and hazardous substances. Mounting evidence of health and environmental damage has
focused the attention of the international community on a category of substances referred to as Persistent
Organic Pollutants (POPs.) Some of these are used as pesticides, while others are industrial chemicals.
They are also generated unintentionally as byproducts of combustion and industrial processes. POPs
possess toxic characteristics, are persistent, accumulate in the fatty tissues of most living organisms, are
prone to long-range transboundary transport and are likely to cause significant adverse human health or
environmental effects near to and distant from their sources. The realization of POPs’ health and
environmental threats led a number of countries to introduce policies and legislation to manage an
increasing number of these chemicals. Due to POPs’ persistence and propensity to cross-border
movement, states are also seeking multinational cooperation to address the challenge.. The Convention on
Persistent Organic Pollutants (The Stockholm or POPs Convention) was adopted and opened for signature
at the Conference of Plenipotentiaries in Stockholm on May 22, 2001. The Convention become legally
binding on May 19, 2004. The overall objective of the Stockholm Convention is to protect human health
and the environment from POPs1.
The Convention also foresees identification and safe management of stockpiles containing or consisting
of POPs. Waste containing, consisting of or contaminated with POPs should be disposed of in such a way
that the POP content is destroyed or irreversibly transformed so that it does not exhibit POPs
characteristics. Where this does not represent the environmentally preferable option or where the POPs
content is low, waste shall be otherwise disposed of in an environmentally sound manner. Disposal
operations that may lead to recovery or re-use of POPs are explicitly prohibited. With regard to shipment
of wastes, relevant international rules, standards and guidelines, such as stipulated in the Basel
Convention, are to be taken into account.
The POPs Convention requires the Parties to develop implementation plans to indicate how they will
meet their obligations under the Convention. The implementation plans are to be transmitted to the
Conference of the Parties within two years of the Convention entering into force. In addition, the
1
The 12 chemicals listed in the Convention are: aldrin, chlordane, dieldrin, endrin, heptachlor, mirex, toxaphene,
DDT, hexachlorobenzene, PCBs, chlorinated dioxins and chlorinated furans.
27
Convention sets forth a number of obligations that the Parties shall or which they are encouraged to
undertake, including designating a national focal point, fostering information exchange, providing
technical assistance, promoting and facilitating public awareness and participation, consultation and
education, stimulating research and monitoring, and reporting “at periodic intervals.” The Republic of
Moldova signed the Stockholm Convention on May 23, 2001 and ratified it on February 19, 2004.
PREPARATION OF A NATIONAL IMPLEMENTATION PLAN TO CONTROL POPS IN MOLDOVA
Moldova has severe public health and environmental problems linked to the intensive pesticides use in the
past. The stockpiles of obsolete (including POPs containing and contaminated ) pesticides are a
continuous threat to the health of thousands of people. The country has also accumulated large amounts of
PCB oils and PCB-contaminated equipment in the energy sector presenting high risks to the environment
and public health. At the same time, Moldova lacks credible evidence about the current releases, the
degree of environmental contamination and health impacts due to unintentionally produced POPs and
PCBs. The Government of Moldova acknowledges that elimination of POPs will serve the long-term
interests of public health, the environment, and economic development of the country.
In 2001, the Government of Moldova requested from the Global Environment Facility (GEF) financial
assistance for strengthening its capacity to fulfill the obligations arising from the POPs Convention,
including the development of a planning framework to identify priority activities. This assistance has
been provided in the framework of a $410,000 GEF POPs grant - “Enabling activities related to the
implementation of the Stockholm Convention on POPs in the Republic of Moldova”. The National
Implementation Plan (NIP) was one of the main outputs of this project. The goal of the NIP is to provide
a framework and management options and measures in order to meet the obligations taken by Moldova by
joining the Stockholm Convention and to reach the national objectives and priorities regarding the POPs.
The Ministry of Ecology and Natural Resources (MENR) assumed the main responsibility for developing
the NIP as the state authority responsible for compliance and enforcement of national legal requirements
and international obligations related to management of toxic and hazardous products and substances. It
must be stressed that the NIP was developed as an interagency and cross-sectoral document. The NIP was
prepared by a multi-disciplinary group of national experts. From the very beginning, the NIP development
was approached as a process with active participation of all stakeholders and based on the shared
responsibility of the governmental bodies, local communities, consumer groups, the business sector,
scientific community, NGOs, etc.
EXISTING POPS-RELATED LEGAL AND REGULATORY FRAMEWORK IN MOLDOVA
There are over twenty five legal and regulatory acts in Moldova deal in general terms with the full lifecycle of managing toxic and hazardous substances and wastes, which, though not naming specifically,
cover POPs regulated by the Stockholm Convention. The most important are:
The Law on Environmental Protection, adopted on June 16, 1993, established basic principles of
environmental protection, including the priority of environmental goals, mandatory environmental
compliance, environmental liability, prohibition of implementation of any programs and projects without
a positive conclusion of the state ecological expertise and concurrence by the population in the area of
impacts, payments for use of natural resources and non-compliance, and use of collected funds for
environmental mitigation and rehabilitation.
The Law on Sanitary-Epidemiological Well-being of Population, adopted on June 16, 1993, seeks to
ensure favorable environmental conditions to support healthy life of citizens, including variety of
chemical safety measures.
The Law on Ecological Expertise and Environmental Impact Assessment, adopted on July 26, 1996, seeks
to prevent or minimize potential direct, indirect or cumulative impacts of various activities on the
28
environment and to ensure environmental and social sustainability of planning, design and decisionmaking processes. The state ecological expertise and EIA have mandatory obligations to deal with some
chemical related issues.
The Law on Wastes from Industrial Production and Consumption, adopted on October 9, 1997, aims at
fostering efficient management of wastes in order to reduce their amount and increase recycling, reuse
and prevent environmental pollution and degradation.
Current Moldovan legislation includes general prohibitions and restrictions on production, use, storage,
marketing and disposal of a broad variety of toxic, hazardous, flammable and volatile substances and
waste, including POPs listed in the Convention. The main deficiency in the present legal framework is
that legislation does not specifically mention POPs and only covers use of substances as plant protection
products, not, for example, biocidal or industrial uses, and it does not regulate unintentional and byproduct POPs. As the Convention has both mandatory and aspiration stipulations, and is very broad in
scope, in the sense that the control measures cover the whole cycle of POPs from production to disposal,
Moldovan legislation does not yet fully cover all these measures.
Numerous Moldovan laws mandate that individuals and judicial entities develop, introduce and use
advanced environmentally clean technologies that: (i) provide for energy and resources conservation and
savings; (ii) ensure low- and no-wastes production; (iii) prevent emissions and discharges, and reduce
impacts on the environment and public health; and (iv)implement highly efficient and effective processes.
Though the scope and application of these requirements are similar in their spirit to the Best Available
Techniques (BAT) and Best Available Practices (BEP) described in Annex C to the Convention,
Moldovan legislation does not mention BAT or BEP by name and is less specific.
An analysis of existing POPs-related legal and regulatory framework has identified the following
problems:

Moldovan legislation does not specifically mention POPs and only covers use of substances as
plant protection products, not, for example, for biocidal or industrial uses;

does not regulate unintentional and by-product POPs and does not mention BAT or BEP;

does not define public and private sector management responsibilities for POPs during their lifecycle, from production to disposal, as well as contaminated sites;

no framework for prohibition of production and use of specific POPs chemicals to be added to the
Convention in the future;

not all of the 12 POPs regulated by the Stockholm Convention have environmental standards; and

no provision has been made for sound chemical management in general.
The state control institutions, involved in enforcement and compliance on POPs issues in the Republic of
Moldova are organized in accordance with the administrative territorial division and sectoral institutional
structure:
 The State Ecological Inspectorate, a subdivision of the Ministry of Ecology and Natural
Resources, is responsible for monitoring the implementation of environmental regulations at the
local level, as well as compliance control and laboratory investigations. Its functions are
performed through its territorial subdivisions: Ecological Agencies Center, Fishery Inspection
and other specialized control services.
 The State Inspectorate for Plant Protection, in the Ministry of Agriculture and Food Industry, is
responsible for the controlling the application of pesticides and fertilizers in agriculture. It has a
certified laboratory and representatives in each raion.
 The National Centre for Preventive Medicine, in the Ministry of Health, is responsible for
monitoring and ensuring compliance with public health requirements at the national and local
level, including monitoring and laboratory analysis. It has subdivisions in each raion, as well as
central and local territorial laboratories.
29
Formal Environmental Impact Assessment (EIA) procedures were introduced in Moldova in 1996.
Current legislation treats EIA’s as a project level process, applicable at the planning phase of complex
and potentially harmful (to the environment) projects, which could have significant impacts. Strategic,
regional or sectoral environmental assessments are not incorporated into this legislation.
Current State and capacity Assessment of POPs Monitoring in the Republic of Moldova: In
Moldova there are several laboratories, centers, institutions and departments which are involved in
monitoring activities regarding pesticides (including POPs).
The State Ecological Inspectorate (SEI) is in charge of compliance monitoring and pollution
control. The main focus of the SEI is the analysis of pollutants in waste discharges and in the environment
in the vicinity of pollution sources. SEI is equipped with a modern gas chromatograph with FID and ECD
detectors which was recently supplied to the central laboratory in Chisinau, increasing its capability for
high-precision measurements of POPs pesticides and PCBs.
The State Hydrometeorological Service (HMS) monitors background air, water and soil quality to
assist in the formulation of pollution control measures. It has certified laboratories for water and soil
analyses, which regularly participate in international quality assurance and quality control schemes. The
HMS is running programs of pesticide monitoring in soil and water. The most comprehensive program
involved the investigation of DDT and DDE residues in soil starting from 1979. The HMS has a
comprehensive network of sampling stations covering all major water courses and water bodies and
monitors a range of some 35 parameters including DDT and other pesticides.
The Ministry of Health is responsible for monitoring in relation to human health. The MOH has
an extensive network of regional laboratories in the Centers for Preventive Medicine (CPMs) carrying out
a significant number of analyses of foodstuffs, agriculture soils, air, drinking water and surface waters for
pesticides residues. It is also responsible for occupational health issues related to pesticides use. Several
other CPM laboratories in the country are also quite well equipped and staffed.
Center for Agrochemical Service of the Ministry of Agriculture and Food Industry, and the
Institute of Geophysics and Geography of the Academy of Sciences. These do not carry out regular
analyses for POPs and depend upon demand from interested clients. The industries and the energy sector
currently do not have the obligation of self-monitoring in respect of specific pollutants like PCBs or
PCDD/PCDF, since those are usually not listed in environmental permit requirements. No national
environmental quality standards have been established either.
An assessment of existing POPs monitoring programs revealed the following problems:





From the POPs list of the Stockholm Convention only DDT and its metabolites are regularly
monitored at the national scale. Data on other POPs are fragmentary and scattered among
different institutions.
Coordination and exchange of information among the monitoring agencies is sporadic. Currently
there are no operational channels of information exchange between the parties.
The general laboratory capacity is insufficient especially for PCBs and unintended POPs.
Quality assurance/quality control issues are of concern since the equipment in many laboratories
is obsolete, training of staff is episodic and inter-laboratory comparison exercises are not
undertaken.
Data handling and analysis procedures are deficient preventing the possibility to use gathered
monitoring information for decision-making.
30
CURRENT POPS MANAGEMENT, MONITORING AND CONTROL
PCBs: The content of PCBs in electrical equipment in Moldova can be determined based on where the
equipment was manufactured. Until 1991 Moldova was part of the former Soviet Union and all PCBcontaining equipment present in the country today originates from the Soviet period. Information on
PCB-containing equipment has been very scarce and fragmented until recently. A multilateral project
carried out in the Russian Federation in the framework of Arctic Council Action Plan to Eliminate
Pollution of the Arctic (ACAP) in 1998-2002 has for the first time shed light on the use of PCBs in the
Soviet Union.
According to information from “Moldelectrica”, approximately 10% of the used transformers in Moldova
were produced in other Eastern European countries: The Czech Republic; Poland; the former Yugoslavia;
and the former GDR. Surveys in other former Soviet Union republics (Latvia and Estonia) have similarly
demonstrated that 10-15% of the transformers originated from other Eastern European countries. Initial
surveys of electric equipment in Estonia and Lithuania have further demonstrated the presence of PCBcontaining capacitors used in industry. PCBs have been produced in significant amounts in both Slovakia
(22,000 tons) and Poland (800 tons) from where they were exported to other countries in the region. At
the moment only scarce information on PCB-containing equipment from these countries is available.
PCB-containing Equipment in Moldova. PCBs and PCB-containing equipment have never been
produced in Moldova. Large power capacitors are used by the power transmission companies and large
consumers of electricity. According to a survey undertaken as part of the NIP preparation, almost 20,000
PCB-containing capacitors are located in 20 electrical substations throughout the country. The substations
with capacitors are all owned by the two transmission companies "Moldelectrica" and "Dnesterenergo"
(in the Transnistria region). According to survey undertaken as part of the project preparation about
17,300 capacitors are located in Moldova, excluding the Transnistria region, in 12 substations all owned
by Moldelectrica. Of these, 12,000 capacitors are kept in one assembly consisting of 18 capacitor
batteries at the Vulcanesti substation. About 300 discarded capacitors are kept in closed containers at the
station. In addition, two dumps with approximately 1000 broken capacitors each are located at this
substation giving a total of 14000 spent capacitors in Vulcanesti.
The capacitors at the Vulcanesti substation were commissioned in 1972 as part of a network for export of
electricity from the Soviet Union to Bulgaria, which explains the presence of this large substation and the
exceptionally large amount of PCB-containing capacitors in Moldova. In the Vulcanesti substation and
most of the other substations the capacitors have not been in operation since the collapse of the Soviet
Union, however, some of the batteries have been used periodically during winter time. The total PCB
content in the 19,200 capacitors (including the pits at Vulcanesti) is estimated at 355 tons while the total
weight of the capacitors is approximately 1,011 tons.
The amount of PCBs is planned to be disposed of and destructed as part of this project. The 355 tons
account for almost 1% of the PCBs used for capacitor production in the former Soviet Union. Considering
the size of Moldova (approximately 1.8 % of the population of the former Soviet Union) the destruction
of the 355 tons must be considered a significant contribution to reducing the total global PCBs problem.
Besides their use in the energy sector, capacitors are widely used by large consumers of electricity. An
inventory of capacitors held by users of electricity has not been undertaken as yet, but based on expert
judgments the total PCB-content of those capacitors is roughly estimated at approximately 20-50 tons,
about 10% of the amount in the substations removed and destructed within this project. PCB-containing
capacitors may potentially be held by a large number of consumers of electricity within many sectors
including:
► Industries: foundries and steel plants; production of bricks and cement; feedstuff producers;
slaughterhouses, diaries and other larger food processing factories; larger machine-producing
factories; electro-technical factories, saw mills and wood processing factories; plastic moulders;
31
paint factories; textile and carpet factories; and paper and packaging factories
► Gas and oil-processing facilities;
► Large laundries; print houses; central data-processing facilities; hospitals;
► Large greenhouses and farms;
► Water and sewage water treatment plants.
Explosion of Capacitors. Due to voltage surges at the Vulcanesti substation in two incidents in 1974 and
1978 approximately 1,000 capacitors exploded in each incident and the contents were partly dissipated on
the ground below the batteries. The remaining parts of the capacitors from each incident were buried in a
pit of reportedly 6-10 meters in depth. The pits were without any lining. The location of the two pits on
the territory of the substation is known. Each pit may contain 15-20 tons of PCBs. On the top of one of
the pits PCB-containing capacitor parts are visible on the ground.
A survey of the capacitor batteries of all substations (except in the Transnistria region) revealed that an
accident with an explosion had taken place in a capacitor battery in the substation at Donduseni. The
exact number of exploded capacitors and the time of the accident are unknown, but two storage containers
at the station contain 41 broken capacitors and different capacitor parts. The ground below the capacitor
battery and near the storage containers is probably highly contaminated. The survey did not reveal any
other waste dumps apart from the disposal pits in Vulcanesti. In one substation, Straseni, 52 discarded
capacitors are stored outdoors. The ground below the storage also may be highly contaminated.
Releases of PCBs from Capacitors. The large power capacitors are situated outdoors and PCBs can leak
from corroded capacitors to the soil below the capacitor batteries. A visual survey did not reveal any
significant leakages from the installed capacitors, but considering the physical state of the capacitors, with
evidence of visible rust on many capacitors, it must be assumed that some capacitors may have leaked
PCBs to the ground below the batteries. As most capacitor batteries are not in use, leakages may continue
for long time before they are discovered. Compared to the incidences of explosion, the leakages from
installed capacitors are presumably small, and substations with exploded capacitors should be assigned
the highest priority for decontamination.
Soil Contamination with PCBs from Capacitors. By the explosions of capacitors in the 1970'ies and
releases from corroded capacitors during the last 33 years the ground below the capacitor assembly in
Vulcanesti has been highly contaminated. The capacitor assembly covers an area of about 10 000 m2; of
this about 2700 m2 just below the 18 capacitor batteries. Further the soil and groundwater around the two
pits with about 1000 broken exploded capacitors each may be highly contaminated.
Table 1. Results of Pre-feasibility Analysis Program Spring 2005 in Vulcanesti Substation
Sample No
Sample location
57, 58
Between batteries underneath the assembly
construction
Underneath capacitor battery
Underneath capacitor battery
Underneath capacitor battery
Between batteries underneath the assembly
construction
Underneath capacitor battery
Underneath capacitor battery
Beside the assembly
Uphill the assembly
By waste storage
By storage pit
59, 60
61, 62
63, 64
65, 66
67, 68
69,70
71
54
55
53
32
PCB content (mg/kg) *
0-10 cm
50-60 cm
1.3
0.1
331.7
95.1
638.2
7097.7
0.4
0.2
50.3
44.8
5300.4
5.1
0.7
0.5
33.4
0.03
177.2
3.3
71
By storage pit
0.02
74
Capacitor oil **
368141.8
* Total of the 12 PCB congeners: PCB 18, 28, 31, 52, 44, 110, 118, 138, 149, 153, 180 and 194
** The laboratory did not have analytical standards for analyzing the PCB content of the oils in
accordance with the European standard EN 61619, so the data represent the total of the same 12
congeners.
The measurements clearly demonstrate that the PCBs are mobile in the soil and there is an urgent need for
preventing further dissipation of PCBs to the surroundings. The PCB content in the upper 10 cm varied
from 1.3 to 7,098 mg/kg, with the highest concentration found in the soil beneath the assembly, but
between the batteries, indicating that the PCBs have been dissipated over the whole area under the
assembly. In 50-60 cm the concentration ranged from 0.1 to 177 mg/kg. A first rough estimate of the total
amount of PCB in the upper 60 cm of the soil under the assembly can be done by simply taking the
average of the 14 samples below the assembly and multiply with the weight of the soil. By this, the total
amount of PCB (12 congeners) is estimated at 10.6 tons, indicating that a significant amount of the 2000
capacitor's PCB content was released during the explosions. In spite of the high uncertainty on the
estimate it clearly demonstrates the gravity of the contamination of the site. Measurements taken from
other parts of the substation areas indicated that soil near the storage of waste capacitors were
contaminated as well (33 mg/kg)
At least one of the other substations in Moldova, Donduseni, is contaminated as well. A few
measurements in four of the smaller substations demonstrated PCB levels of up to 95 mg/kg in Donduseni
beneath the capacitor battery, whereas the highest value found in the other stations was 2.5 mg/kg.
The feasibility study and remediation of the Vulcanesti station will serve as demonstration project for
future remediation measures at other contaminated sites.
A detailed inventory of PCBs in transformers, switches and other electrical equipment is also still pending
in Moldova. According to an inventory of the electrical equipment currently in use, undertaken as part of
the NIP preparation, approximately 23,000 power transformers are in use in the country; of these about
2,500 belongs to large consumers of electricity. The total content of oil in the transformers is
approximately 18,000 tons and additionally about 5,400 tons oils are in use in switches, inductors and
other electrical equipment. Approximately 10% of the transformers in Moldova originate from other
Eastern European countries as former Yugoslavia and the GDR in which countries PCB-containing
transformers were also produced. Besides transformers originally filled with PCBs, an unknown number
of the transformers in use may be contaminated by PCBs by cross-contamination by maintenance of
transformers. A few selected analyses executed by Fichtner (Germany) in 1999, in transformers from the
transport division of the power system did not provide proof of any PCB presence. A preliminary survey
of 30 PCBs in transformers in the distribution company "Union Fenosa" showed PCB levels <5 ppm.
PCBs in Small Capacitors. A significant amount of PCBs has been used in small capacitors for
fluorescent tubes, washing machines, etc. Most of the capacitors have probably been disposed of today
together with discarded products. By the implementation of the future Moldovan PCB regulation, the
management of small capacitors should be considered. Identification of the small capacitors is not
included in the proposed inventory, which will follow the requirements stipulated by the EU PCB/PCT
Directive regarding equipment subject to inventory.
Releases of PCBs from Transformers. Transformers are regularly maintained and PCB may be released
both during the maintenance of transformers and by leakages while in operation. The amount of PCBs in
transformers is still unknown, but estimates on the amount of transformer oil losses annually from
transformers may give an indication of the potential extent of PCB releases.
Until now no management and systematic monitoring of PCB in Moldova has taken place.
Requirements of the Stockholm Convention. Concerning intentional uses of PCBs the Stockholm
33
Convention requires that all Parties must:
 cease the production of new PCBs immediately (at the date of entry into force);
 eliminate the use of PCBs in equipment (e.g. transformers, capacitors or other receptacles
containing liquid stocks) by 2025;
 make determined efforts to identify, label and remove from use, equipment containing greater
than 10% PCBs and volumes greater than 5 litres;
 make determined efforts to identify, label and remove from use, equipment containing greater
than 0.05% PCBs and volumes greater than 5 litres;
 endeavour to identify and remove from use equipment containing greater than 0.005% PCBs and
volumes greater than 0.05 litres of PCBs;
 prohibit export and import of PCBs and PCB-containing equipment (except for environmentally
sound management of wastes);
 not allow recovery of liquids with a PCB content above 0.005% for reuse in other equipment,
except for maintenance and servicing operations;
 achieve environmentally sound management of PCB wastes as soon as possible and not later than
2028;
 develop and implement strategies for identifying stockpiles, products and articles in use and
wastes containing PCBs;
 manage stockpiles in a safe, efficient and environmentally sound manner until they are deemed to
be wastes;
 take measures to handle, collect, transport and store PCB wastes in an environmentally sound
manner and dispose of the wastes in a way that destroys the PCB content, or otherwise in an
environmentally sound manner taking into account international rules, standards and guidelines;
 not allow recovery, recycling, reclamation, direct reuse or alternative uses of PCBs;
 not transport these materials across international boundaries taking into account international
rules (e.g. the Basel Convention);
 develop strategies for identifying contaminated sites and, if remediation is attempted, do it in an
environmentally sound manner.
Currently Available PCB Waste Disposal Technologies. According to the Stockholm Convention each
party shall take appropriate measures so that POPs wastes are "Disposed of in such a way that the
persistent organic pollutant content is destroyed or irreversibly transformed so that they do not exhibit
the characteristics of persistent organic pollutants or otherwise disposed of in an environmentally sound
manner when destruction or irreversible transformation does not represent the environmentally
preferable option or the persistent organic pollutant content is low, taking into account international
rules, standards, and guidelines, including those that may be developed pursuant to paragraph 2, and
relevant global and regional regimes governing the management of hazardous wastes;” (SC, Article 6).
For equipment with high PCB content like capacitors, for which environmentally acceptable destruction
technologies exist, the management should thus aim to destroy or irreversible transform the substance.
A number of national and international agencies concerned with POPs and PCBs have reviewed PCB
destruction technologies. The documents examined in order to gather information on PCBs destruction
technologies include:
► "Inventory of world-wide PCB destruction capacity" prepared by UNEP Chemicals. The most
recent issue of the inventory dates December 2004 and provides information on applied
technologies and references to 42 companies involved in PCBs destruction.
► "Review of emerging, innovative technologies for the destruction and decontamination of
POPs and the identification of promising technologies for use in developing countries" completed
January 2004 by The Scientific and Technical Advisory Panel of the GEF. The report review
approximately 50 technologies; among these 6 non-incineration technologies with
commercialised technologies with considerable experience. The purpose of the work was to
review all existing technologies that were non-combustion in character and identify those
34
technologies that are innovative and emerging and hold promise for the destruction of the POPs
stockpiles.
► "Destruction technologies for polychlorinated biphenyls (PCBs)"; ICS-UNIDO Proceedings of
Expert Group Meetings on POPs and Pesticides Contamination: Remediation Technologies (April
2000) and on Clean Technologies for the Reduction and Elimination of POPs (May 2000)
► "Detailed review of selected non-Incineration and incineration POPs elimination technologies
for the CEE region" published by the Danish EPA in 2005. The report reviews four commercially
available POPs destruction technologies: Container-based Incineration Systems, Cement Kiln
Incineration; Gas Phased Chemical Reduction and Base Catalysed Dechlorination. The
technologies were evaluated using technical, environmental (material consumption, emissions
and others e.g. residues) and economic criteria.
Commercially available technologies with considerable experience are as follows:
1. Incineration
1.1 Rotary kiln incineration;
1.2 Mobil incineration plant;
1.3 Incineration in cement kilns;
2. Dechlorination processes
2.1 Gas phase chemical reduction (GPCR);
2.2 Base catalysed dechlorination (BCD);
2.3 Sodium reduction;
2.4 Super-critical water oxidation;
2.5 Mobile/stationary hydrogenation plant (Eco Logic);
2.6 Plasma arc incineration;
2.7 Molten salt oxidation;
2.8 Pyrolysis/gasifiers.
Some of the technologies are not suitable for capacitor destruction, but mainly developed for
decontamination of transformer oils. In Western Europe high-temperature incineration is by far the most
applied technology for destruction of PCB-containing capacitors. Due to a large amount of incinerator
capacity, incineration is economically competitive and it has been difficult for non-incineration
technologies to enter the market. The main drawback of incineration is the formation of dioxins and
furans, but incineration technology and flue gas cleaning systems have been developed to eliminate these
toxic compounds to extremely low levels below the EU atmospheric emission limit.
Of the alternatives, a recent review by the Danish EPA on POPs elimination technologies for the CEE
(Central and East European) countries concluded that Container-based ("mobile") Incineration Systems
and the Gas Phased Chemical Reduction elimination technologies are applicable and equally appropriate.
The Base Catalysed Dechlorination technology is characterized as having a relatively low capacity, high
need of supply lines (in particular nitrogen supply) and is thus relatively less affordable, while the Cement
Kiln Incineration technology is characterized as ‘a way through’, but also has several disadvantages.
A number of POPs destruction technologies have been developed in the Russian Federation. A study by
the Nordic Environment Finance Corporation (NEFCO) in 2001 reviewed a number of processes
including Plasma Arc Destruction, Cyclone Reactor and Rocket Engine Process. PCB-destruction
facilities exist or are under construction in Russia, but it is considered that these technologies have not
reached maturity, neither environmentally nor commercially, to be considered for the present destruction
of capacitors from Moldova.
Based on the available information incineration is considered an acceptable destruction technology
provided that the incinerator meets the requirements of internationally accepted environmental standards,
for example, as stipulated in the European Union Waste Directive with a dioxin/furan atmospheric
emission limit of less than 0.1 ng I-TEQ/Nm3. Incineration meeting this limit value is currently the least
cost acceptable technology for destruction of PCB-containing capacitors in Europe where there is
currently available capacity for destruction of Moldova's stockpiles of PCB-containing capacitors.
35
Whereas incineration is considered an appropriate technology for destruction of PCB-containing
capacitors as well as other waste containing high concentrations of PCBs, non-incineration technologies
should be considered for eventual future decontamination of PCB containing transformers in Moldova; in
particular transformers contaminated with PCBs at relatively low level (50-1000 ppm). One option,
widely used in Europe, is the LTR (Low-Temperature Rinsing and Re-Use/Recovery) dechlorination
method, which has been applied for decontamination of more than 15,000 transformers. By this method
both the oil and the solid parts of the transformer are decontaminated for reuse or recycling.
POP’S AND OBSOLETE PESTICIDES IN MOLDOVA
The Republic of Moldova has never had and does not currently have pesticide producing enterprises or
factories; all agrochemicals for plant protection permitted for use in the country have been and are
imported from abroad. None of the POPs pesticides is presently included in the register of permitted
substances for use in agriculture, forestry and households.
The import/export of pesticides is a licensed activity in Moldova. It is regulated by a number of acts
developed by MECTD, MAFI, and MOH, and enforced by DOC. POPs pesticides have reportedly not
been subject to import/export during last decade. Also no data exist about possible illegal entries of POPs
pesticides but this is not anticipated to be a very large problem due to lack of specific demand from the
farmers.
In the 1950-1990s an estimated total amount of 560,000 tons of pesticides were used in Moldova
including 22,000 tons of persistent organochlorinated compounds (OCPs). Pesticides use registered a
peak in 1975-1985 but reduced dramatically over the last 10-12 years (from 38,300 tons in 1984 to some
2,800 tons in 2000, as active ingredient). The share of persistent OCPs also decreased, in favor of other
pesticide groups.
The absence in the past of controls on pesticides manufacture, imports, transportation, storage, and use
have resulted in the stockpiling of now banned and obsolete pesticides which constitute an acute
environmental problem/hazard. In order to find a solution for the ever-increasing amount of obsolete
pesticides accumulated in the country a pesticide dump was built in 1978 on the territory adjacent to
Cismichioi village, in the South of Moldova. Over a period of ten years (1978-1988) 3,940 tons of
pesticides were buried there, including 654.1 tons of DDT. Since the pesticides in the old storage
locations, during the repackaging process, were indiscriminately mixed, in bags and drums, there is no
way of determining the compositions of the resultant mixtures in the repackaged plastic and steel drums.
Therefore to estimate the percentage of POP pesticides in the total amount of pesticides, the statistical
data for the last 40 years was analyzed while the project document was developed. It is estimated that
about 560 thousands tons of pesticides were brought into the country during the last 40 years. However,
according to the data from the Ministry of Agriculture and Food Industry, State Enterprise
“Moldselhozhimia” and State Ecological Inspectorate there is no accurate information on their use and the
quantities and types of the chemicals used differ a lot. An approximate estimation of this data shows that
the average amount of POP pesticides out of the total stock of pesticides is about 20-30%. By the early
1990s, over 1,000 warehouses for pesticide storage have been built in the collective farms. During 19912003 about 60% of these were destroyed or dismantled with only 20% of the remaining ones maintained
in a satisfactory condition. Significant amounts of obsolete pesticides are stored in the open. The
deteriorated packaging enhances the risk of harmful effect on people’s health and environment, with some
warehouses being situated close to residential areas.
The pesticides should have been packaged and stored in these warehouses according to the following
instruction and rules that were developed by the Ministry of Agriculture of the Soviet Union in 1985:
“Rules on Pesticides Receiving, Keeping and Delivery at Agricol Chemistry Ltd’s Storages”; and
“Instruction on Collecting, Preparing and Transporting of Old and Banned Pesticides and Their
36
Packages”. These Rules required that the solids and liquids be kept in separate sections of the warehouse
as shown in Figure 1, and that the 5 categories of pesticides be separated as shown on this diagram.
Stacking of pesticide containers and sacks should have been on specially constructed metal racks not
package upon package. However the storage in the warehouses had deteriorated to the stage that there
was mixing of different categories of pesticides, both in the solids sections and liquids sections. There
was even mixing of solids and liquids in the same section. In many cases bags of pesticides had broken
and drums of liquids had corroded and were leaking. The segregation system envisioned in the 1985
Rules had completely broken down and the stored pesticides could no longer be categorization according
to this system. Hence in the repackaging the majority of the pesticide packages can only be categorized as
“Unknown” and can only be classified as “hazardous waste with the potential of POPs contamination”.
Figure 1. Stores Plan for Different Types of Pesticides According to the 1985 Rules
Solids
Entrance of
Liquids
I. Unknown
Warehouse
I. Unknown
II. Herbicides
II. Herbicides
III. Insecticides
III. Insecticides
IV. Fungicides
IV. Fungicides
V. Chemicals for Seeds Treatment
V. Chemicals for Seeds Treatment
37
The amount of obsolete pesticides stored in the warehouses showed a steady decrease over the years.
Since 1995, the total amount of recorded pesticides decreased by approximately 600 tons. It would be
very difficult to say whether these changes exist only on paper or they are real. It would not be totally
unreasonable, however, to assume that some amounts of stored pesticides are subject to illegal disposal,
they are stolen, washed out with the runoff or infiltrate into the groundwater, conducting to soil and water
contamination.
In November 2003, the MOD and SDES started repackaging and transportation of obsolete pesticides in a
few districts. At that time it was estimated that the total amount of obsolete pesticides in Moldova was
approximately 6,940 tons. This included about 3,940 tons buried at the pesticide dump in Cismichioi and
an estimated 3,0002 tons located in 344 poorly equipped or unfit storage facilities, which lacked proper
monitoring and security. There was an unknown amount of POPs pesticides mixed with the other obsolete
and banned pesticides in storage as the broad categorization system for the warehouses did not distinguish
the actual pesticide composition.
No comprehensive assessment of the risks associated with POPs stockpiles, contaminated sites and
wastes had been made in Moldova prior to the NIP and project preparation. No guidelines were developed
providing criteria and procedures for such inventories and for assessing the risks posed by such places,
and no decontamination measures have been elaborated at the national level.
During 1976-1990, the soil samples showed pesticide contamination levels exceeding the maximum
allowable concentration (MAC) from five times in the Southern zone to 50 times in the Central zone. A
research by the Institute for Experimental Meteorology of the State Committee for Meteorology of the
former Soviet Union showed that in 1979-1985 about 60% of soil samples were polluted with DDT
exceeding the MAC, in spite of the fact that DDT was prohibited in 1970.
Beginning in 1989, due to reduction in pesticide application, investigations showed an anticipated
decrease of pesticides-related pressure both in annual and perennial crops. During 1990-1995, the
regional Centers of Preventive Medicine of the MOH have analyzed the contents of 28 pesticides’
residuals in 10 agricultural crops and foodstuffs. Pesticide residuals were found in 56.4% of the tomato
samples and in 40 % of the grape samples, but they never exceeded the MAC. This downward trend has
continued in the last years. The percentage of samples investigated during 1995-2002 showing traces of
DDT and HCH has decreased every year and only episodically exceeded the MAC. Traces of heptachlor
showed up only once. From the foodstuffs, animal products were found to accumulate most: in 2002,
DDT residuals were found in 4.5% of samples and HCH in 1.8% of samples. The contamination level of
crops was insignificant.
A survey made by the State Ecological Inspectorate in 2002 in the Nistru River basin revealed a
significant level of soil contamination with organo-chlorinated pesticides (OCP), including DDT and
HCH, around most of the storage facilities that were monitored. The concentrations of OCPs in soil
regularly and significantly exceeded the maximum allowable concentration (MAC) even at 200 m from
these facilities. In several cases the contamination of surface waters nearby occurred.
The review of the findings of POPs pesticides assessment against the provisions of the Stockholm
Convention revealed the following problems:


2
Large amounts of obsolete (including POPs containing and contaminated) pesticides are stored in
poorly equipped or unfit storage facilities lacking proper monitoring and security.
There is no clear ownership and accountability of obsolete pesticides issue related to stockpile
and contaminated sites management.
From Ministry of Agriculture and Food
38






There is evidence of some amounts of POPs pesticides (especially DDT) stored in private
households and used by farmers in an uncontrolled way.
POPs pesticides are still identifiable in the environment (including soil, surface and ground water
and foodstuffs) despite the ban on their use imposed long time ago.
Large areas around former and existing storage facilities are contaminated with POPs pesticides.
Tracking, reporting and enforcement systems associated with imports and exports of POPs
pesticides have to be improved.
The Government is aware of and committed to solve the problem of obsolete pesticides but lacks
capacity for doing it.
No regulations, standards and/or guidelines have been developed covering contaminated sites
assessment procedures, remediation criteria, future site use restrictions and site monitoring.
COUNTRY STRATEGY FOR POPS MANAGEMENT
The “National Implementation Plan for the Stockholm Convention on Persistent Organic Pollutants” lays
out a strategy for Moldova to deal with existing and future threats from POPs and other toxic substances.
The national policy regarding POPs chemicals is driven by understanding that a national chemical safety
management system needs to be created for applying a precautionary, prevention and polluter pays
approach in identifying toxic chemicals’ pressures and impacts, in assessing remediation options and in
implementing cost-effective measures to prevent environmental degradation and negative societal,
particularly health, impacts.
The range of POPs chemicals concerns, highlighted by the Stockholm Convention, is considered as a
country priority for the time being and will serve as a triggering mechanism for modernization of current
national chemicals management system towards environmentally sound management of toxic, persistent,
harmful and bio-accumulative substances in all spheres of human society. Minimization and final
elimination of POPs related pressures and impacts to the natural and human environment is an integral
part of national environmental policy. It is considered that environmentally sound management of
chemicals, if being adequately set up and functioning, is an important element which contributes to a
well-being of the country, society sustainable development and poverty alleviation. Adequate solving of
POPs pesticides problems, as well as sound management of other prohibited and unused agricultural
chemicals, is considered to be helpful for promotion of Moldovan ecologically clean agricultural products
world wide.
As described in the NIP, the country strategy comprehensively addresses strengthening of the regulatory,
administrative, institutional, human resource and financial aspects of POPs and toxic chemical
management in Moldova and in addition specifically addresses the requirements under each Article of the
Stockholm Convention. Annex 4 of this PAD describes how this strategy has been translated and
incorporated into the proposed project taking into account economic, technical, social and environmental
factors to optimize the use of scarce available financial resources.
39
Annex 2: Major Related Projects Financed by the Bank and/or other Agencies
MOLDOVA: Persistent Organic Pollutants Management and Destruction Project
World Bank Operations
World Bank Projects
Other Related Operations
China:
“Canadian Grant for Evaluation
of Effects of Exposure to
Persistent Organic Pollutants
and Enhancement of Capacity
to Manage Such Pollutants”
Funded with CDN$823,800,
including a termite study with
CDN$343,300 through
Canada TF051540 – ongoing
China:
“Italian Grant for the
Development of a PCB
Inventory Methodology and a
draft Strategy on PCB
Reduction and Disposal in
China”
Funded with Euro 1,425,000
Italy TF051188 – ongoing
China:
“PCB
Management
and
Disposal
demonstration
Project” to be
funded with USD 18.34 from
the Global Environmental
Facility P082993 – in
preparation
Targeted Sector Issues
Collect information on the use of
mirex and chlordane for termite
control,
alternatives
to
said
substances and integrated pest
management; carry out workshops
to review the information collected,
raise public awareness of the same
and develop a workplan for studies
to be carried out in pilot sites;
implement trial application of
alternatives to mirex and chlordane
in pilot sites; and evaluate feasibility
of integrated pest management
practices for termite control.
Assist the Recipient in building its
capacity to take concrete measures
to reduce or eliminate the release of
Polychlorinated Biphenyl (PCBs)
into the environment; assist in the
implementation of their obligation
under the Stockhom Convention and
other agreements which pursue
similar objectives; and assist in
addressing critical domestic, health,
environment
and
sustainable
development issues related to PCBs
Assist the Recipient to identify,
recover and safely dispose of
Zhejiang
Province’s
PCB
capacitors, transformers, oils and
associated wastes (e.g., PCBcontaminated soils and water). The
project will also serve as a
demonstration of how to most costeffectively achieve recovery and
disposal of PCBs and clean up of
similar PCB contaminated sites
throughout China and in other
countries
that
face
similar
challenges.
40
Performance Ratings
Implementation Progress: S
Development Objective: S
Implementation Progress: S
Development Objective: S
World Bank Projects
Honduras:
“Urgent Tracking and Disposal
of Hazardous Materials”
Funded with $730,000 through
Dutch TF021813
April 1999 – August 2000
Closed
Mali:
“Agricultural Services and
Producer
Organizations
Project”
P035630 – ongoing
Africa (53 countries):
“Africa Stockpiles Program,
Strategic Partnership 1”
– under development
Belarus:
Enabling activities related to
the Implementation of the
Stockholm Convention on
Persistent Organic Pollutants
(POPs) in the Republic of
Belarus – ongoing
Colombia:
Initial Assistance to Colombia
to Meet its Obligations Under
the Stockholm Convention on
Persistent Organic Pollutants
(POPs) – ongoing
Mexico:
Enabling Activities to Help
Mexico Comply with the
Stockholm Convention on
Persistent Organic Pollutants
(POPs – ongoing
Targeted Sector Issues
Inventory and cleanup of 104 tons
of POPs, obsolete pesticides and
other toxic waste, following
Hurricane Mitch. Groundwater and
breast milk testing in contaminated
areas.
Also awareness raising,
capacity building and public
information campaigns
Building capacity for pesticide
management including obsolete
pesticide inventories and clean up
for $1million.
Find and dispose of stockpiles of
obsolete pesticides in all 53
countries
on
continent,
and
introduce measures to prevent future
such
stockpiles,
arting
with
Ethiopia, Mali, Morocco, Nigeria,
Tanzania, Tunisia, South Africa.
Develop a National Implementation
Plan (NIP) for POPs issues with the
assistance
of
international
organisations so that Belarus
effectively addresses the reduction
and elimination of persistent organic
pollutants consistent with the
protection of human health and the
environment from the effect thereof,
and meet its obligations under the
Stockholm Convention.
Prepare a National Implementation
Plan (NIP); build capacity support
for Enabling Activities; and help
develop indicators for incremental
costs through the application and
test of techniques for cleaning
POPs-contaminated
sites.
The
project will help develop and
implement priority policy and
regulatory reform, capacity building
and investment programs as
mandated by the Convention.
Develop a National Implementation
Plan (NIP) for Persistent Organic
Pollutants (POPs), such that Mexico
can meet its obligations to the
Stockholm Convention.
41
Performance Ratings
Not rated
Implementation Progress: S
Development Objective: S
Implementation Progress: S
Development Objective: S
Implementation Progress: S
Development Objective: S
Implementation Progress: S
Development Objective: S
World Bank Projects
Moldova:
Enabling activities related to
the implementation of the
Stockholm Convention on
Persistent Organic Pollutants
(POPs) in the Republic of
Moldova – completed
Moldova:
US $ 7.2 million IDA funded
Implementation on Team Trade
and Transport Facilitation in
South-east Europe.
Moldova:
US $ 35 IDA funded Energy II
project
Moldova:
US$39.5 million IDA funded
Rural Investment and Services
Project (RISP) WB Rural
Investment and Services project
(RISP)
Moldova:
US $ 5.0 million GEF
Agricultural Pollution Control
Project.
Targeted Sector Issues
Develop a National Implementation
Plan (NIP) and provide supporting
capacity strengthening such that the
Republic of Moldova can effectively
protect human health and the
environment from persistent organic
pollutants and can fully comply with
its obligations under the Stockholm
Convention
The project it is implemented by the
Customs Department of the
Republic of Moldova. Among
different activities within the
project, there will be provided TA
on: (a) Selectivity and Risk
Assessment
for
export/import
operations (including on PCBs and
pesticides); (b) Post Clearance Audit
and Control; and (c) Transport
control.
Within the project there is a
component on Feasibility Study for
Rehabilitation of System Metering,
Dispatch, Communications and
Transmission. The component will
support several activities regarding
PCBs in the energy sector. In
particular there will be financed
activities on upgrading analytical
laboratory equipment for identifying
PCBs, as well as for undertaking a
detailed PCBs inventory in the
sector.
The project outside the providing
credits for rural development
activities is supporting rural
advisory
services,
including
consultancy in the area of pesticides
usage in agriculture. For that
purpose, there was created a
national rural extension network
(Agriculture
Consultancy
and
Scholarship Agency, - ACSA), that
includes 460, of which 100 regional
and 350 local consultants network.
This network provides advisory
services for more than 700 000
clients.
The overall project development
objective is to increase significantly
the use of environmentally friendly
agricultural practices by farmers and
42
Performance Ratings
Not rated
Implementation Progress: S
Development Objective:S
Implementation Progress: S
Development Objective: S
Implementation Progress: S
Development Objective: S
Implementation Progress: S
Development Objective: S
World Bank Projects
Targeted Sector Issues
agro-industry and thereby reduce
nutrient discharge from agricultural
sources in Moldova to the Danube
River and Black Sea. In support of
this objective, the project will assist
the Government of Moldova to: (i)
promote the adoption of mitigating
measures by farmers and agroindustry for reducing the nutrient
loads entering the water bodies; (ii)
strengthen
national
policy,
regulatory
enforcement
and
institutional capacity for agricultural
nutrient pollution control and
organic farming; and (iii) promote a
public awareness campaign and
replication strategy.
Performance Ratings
Related Operations:
Related cleanup and prevention POPs projects implemented by agencies other than the World Bank.
AGENCY
CLEAN-UP
ACTIVITIES
OR
DISPOSAL PREVENTION
OR
BUILDING
AND
ACTIVITIES
POP Activities in Moldova
US$ 363,000 upgrading MAFI analytical
NATO
laboratory capacity to identify the content
of obsolete pesticides, including operating
costs for 2 years

841,000 EURO Destruction of Pesticides
and Dangerous Chemicals in Moldova

Milieukontakt US$ 0.77 million (Moldova component)
Oost-Europa Project:
(Dutch
Environment
al NGO)

NATO
Other Related Operations
UNIDO

43
CAPACITYAWARENESS
NATO will provide to MA
laboratory
equipment
for
identifying
the
content
of
repackaged obsolete pesticides as
well as its operating costs for the
next 2 years.
Repackaging,
transport
and
destruction of stockpiled pesticides
2005-2007
Elimination of acute risks of
obsolete pesticides in Moldova,
Georgia, Armenia. The (short term)
project goal is to eliminate the
acute risks of dissemination of
obsolete pesticides through proper
storage and export and destruction
of chemicals, and to set an example
for the international community
more specifically in Eastern
Europe.
Building the Capacity of the
People’s republic of China to
implement
the
Stockholm
Convention on POPs and Develop
a National Implementation Plan
UNDP

UNEP
Chemicals





Secretariat
Basel
Convention



UNIDO

Demonstration projects on noncombustion destruction technology
for PCBs and other POPs in Slovak
Republic, Philippines
Switzerland
Australia

FAO





(NIP)
Strategy and Program on Reduction
and Phase-out of POPs Pesticides
in China
Stockholm Convention Secretariat
(interim)
Technical and financial support to
33 countries on PCB inventories
PCB inventory and management
support to SADC (14 countries)
Awareness raising workshops;
guidance and awareness raising
publications on PCBs and other
POPs, and on alternatives to POPs
pesticides.
Technical
guidelines
on
environmentally
sound
management of PCBs and other
POPs (drafting stage)
Support for national inventories of
PCBs and for development of
national PCB management plans in
Costa Rica, Côte d’Ivoire, El
Salvador, Guatemala, Honduras,
Nicaragua, Panama.
Awareness raising, policy making
and training workshops.
Technical assistance for the
undertaking of the national
inventory of obsolete pesticides in
Mauritius, Venezuela.
Technical and financial support to
identify and dispose of PCBs and
other hazardous wastes in Pacific
Island Countries
Manage Ethiopia pesticide disposal
project
Initiate/coordinate
national
inventories of obsolete pesticide
stockpiles
Initiate/formulate disposal projects
for FAO member countries
Supervise/monitor/follow
up
disposal and prevention operations
in the field
Removal and disposal of obsolete
44

PCB Inventory, strategy, awareness
raising in Morocco

Awareness- raising workshops on
obsolete pesticides in affected
countries and regions.
Guidelines on prevention and
management of obsolete pesticides
Guidance
and
support
for
prevention programs and strategies
in FAO member countries
Global IPM Facility; International
Code of Conduct on the
Distribution and Use of Pesticides;
Pesticides
Management




GTZ

USAID/USEP
A

Arctic
Monitoring
and
Assessment
Program
(AMAP)
World
Wildlife Fund
/ WWF
for Nature
pesticides
from
Iran,
Iraq,
Seychelles,
Lebanon,
Yemen,
Zambia.
Engage donors in action to resolve
obsolete pesticide problems
Cleanup of over 850 tons of POPscontaining and other pesticides in
Madagascar,
Mozambique,
Mauritania, Niger, Zambia
Contributed to disposal POPscontaining and other pesticides in
Ethiopia, Niger, Senegal





Engagement with Governments and
NGOs on the implementation of the
Stockholm Convention on POPs;
Global Toxics Program
45


Programme; Joint Secretariat of the
Rotterdam Convention on Prior
Informed Consent; Advice and
support on pesticide regulation;
regional programs on pesticides
registration
(CILSS),
IOMC
member and co chair of IOMC
working group on obsolete
pesticides.
PCB inventories in Thailand, The
Gambia
Awareness raising
Training package for inventory
taking
Inventory of obsolete stocks of
pesticides in Russia
Awareness raising on issue of
toxics
Financial and technical assistance
Annex 3: Results Framework and Monitoring
MOLDOVA: Persistent Organic Pollutants Management and Destruction Project
Results Framework
PDO
The main development objective
of the project would be to protect
the environment and human
health by safely managing and
disposing of stockpiles of POPs
contaminated pesticides and
PCBs.
The global project objective of
the project is sustainable POPs
stockpiles management and
strengthening of the regulatory
and intuitional arrangements for
long term control of POPs and
other toxic substances in line
with the requirements of the
Stockholm Convention and other
related conventions and protocols
ratified by Moldova.
Outcome Indicators
Reduced POPs environmental
pollution and risks to human
health by safely storing and
disposing of stockpiles of POPs
contaminated pesticides and
PCBs.
Use of Outcome Information
1.
Demonstrate
to
the
international community that
Moldova meets its obligations
under the Stockholm and other
related conventions and protocols
2. Harmonize its policies and
regulatory management systems
Destruction of 1,060 tons of PCB for toxic chemicals and wastes
containing capacitors, and 1,150 with that of its neighbors in the
tons of POPs containing and EU.
contaminated obsolete pesticides
Modern
regulatory
system
established within GRM for the
management and control of POPs
and other toxic and harmful
chemicals and wastes for the
protection of the environment
and human health
Intermediate Results
One per Component
Component One:
1. Repackaging and safe disposal
of POPs contaminated pesticides.
Results Indicators for Each
Component
Component One:
1. Repackaging, transport and
final destruction of 1,150 tons of
POPs
containing
and
contaminated obsolete pesticides
held in 10 temporary storage sites
in
administrative
districts
2. Packaging and safe disposal of throughout Moldova
obsolete capacitors containing 2. Dismantling of 17,300
PCBs.
obsolete
capacitors
and
excavation of 2,000 capacitors
buried in two pits, packing in
closed containers, shipment and
destruction (approximately 1060
tons of capacitors – containing up
to 380 tons of PCB oils) as well
as up to 50 tons highly polluted
soil
from
the
Vulcanesti
substation.
3. Inventory registration system
and national database for
46
Use of Results Monitoring
Component One:
1. Demonstration of safe
packaging and labeling of toxic
chemicals
to
international
standards. Provide data on likely
range of chemicals that were held
in temporary storage for the
eventual clean up of these sites.
2. As demonstration for other
holders of obsolete capacitors
and transformers containing
PCBs and for their eventual safe
disposal. Raise awareness of
dangers of PCBs to human health
and the environment and pave the
way for the adoption of a modern
system of toxic chemical
management in the country.
Component Two:
Regulations requiring holders of
PCB contaminated equipment to
inventory their holdings and
register them with the relevant
regulatory body.
Component Three:
Institution Strengthening
electrical equipment containing
or contaminated with PCBs
above a concentration of 50 ppm.
Component Two
1. New, revised or supplemental
national policies, regulations and
guidelines issued on:
(i) POPs contaminated site
management
issues;
(ii)
responsibility
for
POPs
contaminated sites; (iii) POPs
monitoring and reporting; (iv)
assessment of new chemicals
meeting POPs criteria; (v)
promotion of BAT and BEP for
new and existing sources; and
(vi) requirements for modified
materials,
products
and
processes.
2.
Development
of
new
regulatory
mechanisms
on
various
aspects
of
POPs
management.
3. Training provided for (i)
inspectors in enforcement and
compliance with the POPs
convention requirements; (ii)
farmers on integrated pest
management; (iii) technicians
from Moldelectrica on PCBs
management and disposal of
obsolete PCBs
4. State Ecological Inspectorate,
Ministry
of
Health,
and
Hydrometeorological laboratories
upgraded and training provided
for technicians in conducting
POPs analyses.
5. Supply of PCBs screening kits
for detection of PCB levels in
transformer oil
Component Three:
1. Training completed for the
PMT
staff
in
project
management.
2. Information management and
reporting system in place
3. POPs Monitoring network
created
4. POPs polluted areas digital
map created
5. System in place for the
evaluation and monitoring of
project implementation
47
Component Two:
1. The information will be used
internationally for reporting
under the Stockholm Convention,
and nationally for tracking
hazardous wastes and developing
management systems for their
eventual safe disposal.
2.
Developed
Regulatory
Mechanisms will be used as legal
framework for implementation of
Stockholm Convention:
-Developed PCBs regulations
- Developed POPs provisions in
the management of POPs
stockpiles
3. Trained staff of
State
Ecological Inspectorate will
implement
accumulated
knowledge in order to improve
Moldovan capacity in a POPs
monitoring network
4. Annually: Review if pest
management is implemented by
the trained farmers
5. Upgraded Laboratory will
apply the international standards
and methods in the filed of POPs
detection and analyses.
6. Annually: Update the National
PCBs inventory. This database
will document progress in the
field of PCBs inventory
Component Three:
Consolidation of management of
dangerous substances under one
umbrella organization for more
effective management and less
duplication of effort and better
reporting of results to the
national
government
and
international organizations under
various
conventions
and
protocols.
Semi-annually and annually:
PMT will report to the World
6. Specific monitoring strategies
developed
7. Workshops at the national and
international level conducted
8. Public awareness activities
including seminars, workshops,
conference TV and radio
programs
conducted,
POPs
environmental information center
strengthened
48
Bank and MERN about project
progress and implementation of
the work plans
Quarterly or semi-annually:
Public awareness will be
assessed by special tests and
interviews in order to monitoring
the rise of public information in
the filed of POPs
Outcome Indicators
Destruction of 2,210 tons of POPs
containing and contaminated obsolete
pesticides & PCBs
Results
Indicators
for
Each
Component
Component One :
1. Repackaging, transport and final
destruction of 1,150 tons of POPs
containing and contaminated obsolete
pesticides held in 10 temporary
storage sites in administrative districts
throughout Moldova
2. Repacking, transport, and final
destruction of up to 1,060 tons of
PCBs from capacitors ( including up
to 50 tons highly polluted soil from
the Vulcanesti substation).
3. Inventory registration system and
national database for electrical
equipment containing or contaminated
with PCBs above a concentration of
50 ppm.
Component Two:
1. New, revised or supplemental
national policies, regulations and
guidelines issued on:
(i) POPs contaminated site
management issues; (ii) define
responsibility for POPs contaminated
sites; (iii) incorporate POPs
monitoring and reporting; (iv) regulate
assessment of new chemicals meeting
POPs criteria; (v) promote BAT and
BEP for new and existing sources; as
well as (vi) specify requirements for
modified materials, products and
processes.
Baseline
YR1
Target Values
YR2 YR3 YR4
YR5
Frequency
Reports
0
0
1105
0
Six monthly
1105
0
0
0
575
575
0
0
Six monthly
0
0
530
530
0
0
Six monthly
and
Data Collection and Reporting
Data Collection Instruments
Responsibility
Data Collection
Database on disposal (MIS)
PMT
Database on disposal of toxic
substances established under
the MIS
PMT
Database on the PCBs
stockpiles disposal under MIS
PMT
for
0
5%
50%
80%
100%
100%
Six monthly
Database on inventory of
equipment contaminated by
PCBs established under MIS
PMT with assistance
from Ministry of
Industry and
Infrastructure and
consultant firm
supervising the PCBs
stockpile destruction
contractor
0
0%
50%
80%
100%
100%
Six monthly
Database as part of MIS
PMT
Local and International
Consultants
49
2. New Regulatory Mechanisms on
various aspects of the POPs
management developed.
- number of laws amended/ number of
provisions on POPs included in the
existing legislation and number of
developed new regulations and
instructions deve
3. Number of inspectors trained in
enforcement and compliance with the
POPs convention requirements;
4. Number of farmers trained on
Integrated Pest Management.
6. Number of technicians from
Moldelectrica trained in PCBs
management and disposal of obsolete
PCBs stockpiles
7. Supply of PCBs screening kits for
detection of PCBs level in the
transformers oil from Energy sector
Component Three:
1. Training completed for the PMT
staff in project management.
2. Information Management and
Reporting system in place
3. POPs Monitoring network created
PMT
Local and International
Consultants
0
0
50%
80%
100%
100%
Six monthly
Database as part of MIS
0
0
140
80
60
0
Six monthly
Progress reports,
Progress review meetings
(annually)
PMT
0
0
25
35
50
0
Six monthly
Survey
PMT
Consultants: review
0
0
10
15
20
0
Six monthly
Survey
PMT
Consultants: review
0
20%
50%
80%
100%
100%
Six monthly
0
20%
50%
80%
100%
100%
Six monthly
0
0
50%
80%
100%
100%
Six monthly
Database as part of MIS
0
50%
80%
100%
100%
Six monthly
Database established under
MIS
Database on inventory of
equipment contaminated by
PCBs and POPs pesticides and
POPs contaminated sites
established under MIS
Progress reports,
Progress review meetings
(annually)
0
Database on inventory of
equipment contaminated by
PCBs established under MIS
Progress reports,
Progress review meetings
(annually)
PMT
Consultants: review
PMT, MERN
Consultants: review by
local and international
PMT, MERN
Consultants: review
PMT from the MIS
4. POPs polluted areas digital map
created
0
0
50%
80%
100%
100%
Six monthly
5. Evaluation and Monitoring of
Project Implementation in place
0
0
50%
80%
100%
100%
Quarterly
0
1
1
1
0
0
Six monthly
Database as part of MIS
0
0
50%
80%
100%
100%
NA
Survey
PMT
Consultants: review
Six monthly
Survey
PMT
Consultants: review
6. Specific monitoring strategies
developed
8. National and international
seminars, workshops and conferences,
TV and Radio programs conducted
PMT from the MIS
PMT, MERN
9. Books, brochures and leaflets
published
0
2
5
5
5
0
50
Annex 4: Detailed Project Description
MOLDOVA: Persistent Organic Pollutants (POPs) Management and Destruction Project
COMPONENT 1: MANAGEMENT AND DESTRUCTION OF POPS. (US$ 8.23, OF WHICH GEF US$ 3.79
M)
This component will support investments for the environmentally safe management and disposal of
obsolete POPs, including repackaging and centralized safe storage of obsolete pesticides in the
agricultural sector, and PCBs in the energy sector, as well as their final destruction. These activities are
priorities as specified in the POPs National Implementation Plan that was approved by Moldova
Government on October 20, 2004 (no. 1155).
SUB-COMPONENT 1.1: DESTRUCTION OF STOCKPILES OF POPS CONTAINING AND CONTAMINATED
OBSOLETE PESTICIDES (US$ 5.37 M, OF WHICH GEF US$ 1.21 M)
Following two previously failed Government decrees to have the stock of obsolete pesticides repackaged
and transported to a central storage facility, in 2002 the Government adopted Decision Nr 1543 “On
Additional Actions toward Centralized Disposal and Neutralization of Obsolete and Banned Pesticides”.
This Decision stated that on the basis of contracts with the Ministry of Agriculture, the Ministry of
Defense and Department of Emergency Situations would be responsible for repackaging, transport and
storing the country’s stock of obsolete and banned pesticides in a central facility located in a former army
depot for storing flammable and explosive substances. This site was considered the most suitable as it was
located well away from residential and sensitive natural areas and was securely protected by the army.
However, public opposition caused the Government to reconsider the selection of this site and in 2003 the
Government adopted a Decision Nr 1389 “On approval of modifications and agenda in the Governmental
Decision 1543 as of 29 November, 2002”. This decision delegated responsibility to the heads of raions,
majors of settlements and Executive Committee of Gaguzia to select one storehouse on their
administrated territories, as a central facility for storing repackaged pesticides. It was this Decision that
finally broke the deadlock on centralizing the storage of these pesticides
In this regard the State Ecological Inspectorate outlined a number of criteria to be used while selecting of
sites for centralized storage. In particular, the following criteria were suggested:
(i)
in case of location in the vicinity of water bodies the protective zone had to be not less
than 2000 meters;
(ii)
the width of the protective zone from any other water bodies used for non-fishery
purposes was to be established on the basis of the warehouses’ capacity, as follows: up to
20 t - 200 m; 20 - 50 t - 300 m; 50-100 t - 400 m; 100 – 300 t - 500 m; 300 – 500 t 700 m and more than 500 t – 1000 m;
(iii)
sanitary zone from houses, poultry and livestock farms, water sources, sites of livestock
and poultry concentration (e.g., grazing areas) had to be not less than 200 meters.
Other criteria for selecting the central facilities included; minimum costs for their rehabilitation; amount
of pesticides already stored in these facilities to avoid extra re-packaging and transportation of pesticides;
etc. Solid pesticides were to be repackaged firstly into polypropylene sacks, which were then to be placed
in plastic drums (2-3 sacks per drum). Liquid pesticides were to be pumped from their old containers into
metal drums. There was no requirement to clean the old metal drums, which either were left at the old
storage sites, or were transported to the new sites (there is no data at the current time on where they are
51
stored or the quantities of old drums). The plastic drums are 1203 liter capacity (0.8 m high and 0.5
diameter). The metal drums are either 200 liter (1.2 m high and 0.47 m diameter), 1004 liter (0.6 m high
and 0.47 m diameter), or 50 liter (0.4 m high and 0.47 diameter).
As noted in this table some 1,800 tons of pesticides had been fully or partially repackaged and stored by
this date (May 2005). MAFI estimate that MOD and DES have used 60,727polypropylene sacks, 14,463
plastic drums and 1,200 metal drums in the repackaging effort so far. They estimate that after the
repackaging is completed (March 2006) there will be 94,000 polypropylene sacks, 40,000 plastic drums,
3000 of the 100 liter metal drums, 100 of the 200 liter metal drums and 100 of the 50 liter drums. In total
there is expected to be 3000 tons of POPs contaminated pesticides and pesticides contaminated soil and
drums for final destruction. By the time repackaging is complete the total cost of repackaging,
transportation, and warehousing 3,000 tons of pesticides and pesticide contaminated soil and drums will
have reached 9. 4 million Lei, or approximately US$ 780,000 which is being provided by the government.
Inspections by the EA study teams of the repackaged pesticides and storage in the centralized warehouses
indicates the following deficiencies:
 drums with missing labels;
 drums not segregated by category as required by the rules;
 damaged plastic drums;
 the weight of each packaged drum was not taken and recorded, thus the total weight of pesticides
in each storage location is only and estimate from a 2002 survey;
 drums stacked one on top of the other without intermediate support as required by the rules,
including the more fragile plastic drums even to 3 to 4;
 drums packed too tightly together not allowing for access or inspection;
 storage sites not meeting the criteria laid down for sanitary protection zones;
 some storage facilities would present many difficulties for emergency response in case of fires
and explosions;
 Some of the storage buildings require maintenance of roofs to prevent leaks during rainfall;
 on many plastic barrels covers were missing;
 in some locations solid pesticides are only stored in bags as there were insufficient plastic barrels;
 in many cases the pesticides were repacked in not specially assigned bags (in fact, some of them
had inscription “sugar”);
 in many storehouses, e.g. in Floresti, Cimislia, Ratus and others liquid pesticides were not
repackaged, but stored in old metallic rusty barrels;
 in some centralized storehouses there were old used and new spoiled barrels;
 passage and even grazing of domestic animals (sheep, goats and others) noted on some sites; and
 security at most sites was lacking 24 hr vigilance and even during day light hours at some sites.
Of the 37 sites, disposal of stockpiles in 10 warehouses will be financed by the project (Telenesti,
Briceni, Hincesti, Cimislia, Floresti, Riscani, Straseni, Stefan-Voda, Nisporeni, and Soldanesti rayon
warehouses). These are the 10 warehouses posing the highest risk. They hold about 1150 tons of
material. As noted in Annex 1, it has to be assumed that there entire stockpile of obsolete and banned
pesticides contain or could potentially be contaminated with POPs. GEF can only finance the 20-30%
POPs destruction.
3
Ministry of Agriculture and Food estimate that 35 bags in 15 plastic containers contain 1 tonne of solid pesticides
Ministry of Agriculture and Food estimate that 10 of the 100 liter drums contain 1 tonne of pesticides, that 10 of
the 200 liter drums contain 2 tons of pesticide and 20 of the 50 liter drums contain 1 tonne of pesticides. All future
drums will be 100 liter. Currently there are 1000 of the 10 liter drums in store and 100 each of the 200 and 50 liter
drums.
4
52
Table 1. Obsolete pesticides stockpiles: 37 centralized warehouses
Nr.
District
Quantities
of Central Storage Location Repackaged by
Packaged
Pesticides (kg)
Districts in which Repackaging is Completed or Packaged in Sacks Awaiting Delivery of Drums
1
Anenii Noi
19 950
Mayoralty Bulboaca
MoD
2
Telenesti
305 532
Mayoralty Ratus
MoD
3
Floresti
128 235
Mayoralty Timiliuti
MoD
27 000
Mayoralty Ghindesti
4
Mun. Balti‫٭‬
13 700
Alexandreni
MoD
5
Criuleni ‫٭‬
44 195
Pascani
DES
6
Comrat TAUG 77 200
Fertilitatea SA / Comrat
DES
7
Ciadir Lunga
68 736
Mayoralty Gaidar
DES
8
Vulcanesti
49 000
Mayoralty Cismichioi
DES
9
Stefan Voda‫٭‬
201 547
Mayoralty Tudora
MoD
Mayoralty Olanesti
10
Singerei
86 240
Mayoralty Alexandreni
DES
11
Cimislia
149 117
Cimislia
MoD
12
Dubasari ‫٭‬
25 270
Porumbeni
MoD
13
Donduseni
65 130
Plant from Tirnova
MoD
14
Briceni
132 030
Mayoralty Grimancauti
MoD
15
Causeni ‫٭‬
141 714
Mayoralty Gradinita
MoD
16
Ocnita
21 280
Mayoralty Clocusna
MoD
17
Rezina ‫٭‬
34 120
Mayoralty Papauti
MoD
18
Nisporeni
54 125
Mayoralty Nisporeni
MoD
19
Soldanesti
35 400
Mayoralty Chipesca
MoD
20
Ungheni
77 915
Storage from military range MoD
21
Mun. Chisinau 55 000
Mayoralty
Pascani DES
(Porumbeni)
Total
1 807 036
Districts where Repackaging has not Started due to lack of Bags and Drums but Expected to be
Completed by the end of 2005
22
Cahul
54 228
Mayoralty Cahul/ ATP-5
DES
23
Cantemir
8 000
v.
Ciobalaccia
/SA MoD
Ciobalaccia
24
Calarasi
123 586
Mayoralty Onitcani
MoD
25
Edinet
2 682
Mayoralty
MoD
26
Hincesti
49 895
Mayoralty Carpineni
MoD
27
Orhei
35 100
Mayoralty Pelivan
MoD
28
Riscani
23 286
Mayoralty Recea
MoD
29
Straseni
32 872
Fertilitatea SA / Straseni
MoD
30
Soroca
25 750
v.Cosauti
/
Ltd MoD
“Agrovaslad”
31
Basarabeasca
10 420
v. Sdaclia/ Ltd “Sadic MoD
Agro”
32
Drochia
15 300
MoD
33
Ialoveni
75 240
DES
53
Glodeni
31 945
c. Singerei / “Vast Protect” DES
Falesti
61 141
Fertilitatea SA / Falesti
DES
Leova
25 310
c. Iargara
MoD
Taraclia
109 570
DES
Total
684 325
Total 2,491,361 kg (approx 2,500 tons)
Estimated Amount of Soil and Old Drums Containing High Concentrations of POPs
Contaminated Pesticides from Old Storage Sites = 500 tons
Total Estimated Amount of Pesticides and Wastes for Destruction = 3,000 tons
MoD - Ministry of Defense;
DES - Department of Emergency Situations
Extremenly High Risk
34
35
36
37
High Risk
The EA carried out a risk assessment at each of the above sites and ranked them according to overall risk,
which included: condition of storage buildings; proximity to populated areas, agricultural lands,
watercourses, forest and pasture; vulnerability to floods; depth to groundwater; amount of pesticides
stored; availability of space for storage. The following central sites are ranked as: Extremely High Risk:
2, 3, 11, 14, 26, 28, and 29. The following sites are ranked as High Risk: 6, 7, 9, 18, 19, 24, 27, 31, and
34. Thus 43% of the central storage facilities are ranked as either extremely high or high risk. It was
estimated that the first group of warehouses would contain about 850 tons of pesticides, while in the
second and third (low risk) ones, -610 and 1,460 tons, respectively.
If the Moldovan Government was required to analyze every package in the expected 40,000 plastic drums
storing solid pesticides and some 3,200 drums of liquids for POPs contamination, it would be necessary
to carry out some 97,200 analyses. Even at a low cost of US$ 100 per analysis for screening purposes,
this would cost the Government a total of US$ 9.72 million. Such a program is clearly out of the question
and would expose workers and the environment to additional unnecessary risks. The most obvious low
cost solution in order to reduce the risk of further releases of POPs pesticides to the environment and
human exposure is to destroy these stockpile as soon as possible. Since there are no hazardous waste
disposal facilities in Moldova which could handle such waste, the only option is to transport it to such a
facility in another country. It is proposed, therefore, to contract with a hazardous waste incinerator
operator selected under World Bank ICB procurement rules, to repackage the pesticides in IBC containers
and transport them to an EU or nationally approved hazardous waste incinerator for final destruction. The
contractor would be responsible for carrying out the entire operation according to international
conventions and EU standards for repackaging and transport of hazardous substances.
The project will finance disposal of about 1150 tons of obsolete pesticides. GEF financing will be used
for about 500 tons (or about 16% of the total – within the 20-30% total amount considered incremental
cost). The Government and NATO will finance the rest. NATO is currently seeking financing to fund
the disposal of the remainder of the stockpiles not covered by the project. The Government is committed
to the sound containment of the stockpiles until their ultimate disposal.
The cost estimates for these components are based on repackaging of 100 liter plastic drums containing
solid pesticides in 0.9m long wide by 0.5m high IBC containers, and 100 liter steel drums containing
liquid pesticides in separate IBC containers of the same size.
54
COMPONENT 1.2: MANAGEMENT OF PCBS AND DESTRUCTION OF OBSOLETE CAPACITOR
STOCKPILES. (US$ 2.86 M, OF WHICH GEF US$ 2.58 M)
This component consists of the following activities:
 Inventory of PCB containing or contaminated equipment
 Destruction of obsolete capacitor stockpiles
 Feasibility study of site clean-up at Vulcanesti substation
Activity 1: Inventory of PCB Containing or Contaminated Equipment. (US$ 0.48 m, of which GEF
US$ 0.28 m)
A detailed inventory of PCB-containing or contaminated equipment, with appropriate labeling and
identification of premises where the equipment is located, is a prerequisite for the future management and
disposal of PCBs. Companies within the energy sector in Moldova are aware of the PCB problem, but for
most consumers of electricity there is limited if any awareness of the problem.
Regulation of PCB Phase Out. A precondition for a detailed inventory of PCB-containing or
contaminated equipment is the implementation of regulations requiring the holders to identity and label
the equipment and notify the government regulator of its location. Since Moldova does not currently have
such regulations it is proposed to assist the Government to develop and implement them under this subcomponent.
The proposed regulation will meet the stipulations of the EU PCB/PCT directive (except for the phase-out
time schedule). The PCB/PCT Directive stipulates that Member States shall ensure that inventories are
compiled of equipment with PCB volumes of more than 5 dm³ (at concentrations > 50 mg/kg PCBs). In
order to undertake inventories the Directive requires that Member States take the necessary measures to
ensure that the holders of such equipment notify the competent authorities of the quantities which they
hold (in use and storage) and of any changes in this respect. In the case of electrical capacitors, the
threshold of 5 dm³ is understood as including all the separate elements of a combined set. In practice it
means all large electrical capacitors and transformers. Experience from other countries indicates that it is
expedient that holders of large capacitors and transformers on request have the obligation to notify, even
if they do not hold PCB-containing equipment of the size subject to inventory. Besides stipulating
requirements to compile inventories, the Directive also requires Member States to define laboratory
sampling and analysis methods for PCBs, as well as management of PCB-containing equipment and final
disposal of PCB-containing equipment.
Inventory Preparation. As the holders of the equipment in general do not know that they hold PCBcontaining equipment it is necessary to send guidelines for identification of the equipment and inquiries
(inventory forms) to all potential holders of such equipment. The guidelines that will be developed under
this sub-component will include information on PCBs, information on equipment that might contain
PCBs, lists of equipment known to contain PCBs by type number, guidelines for sampling of transformer
oils and guidelines for labeling of PCB-containing equipment.
The inventory form will follow the lines of the inventory form prepared by UNEP Chemicals. However, a
simpler form will be used for capacitors as the holders would not know the type of oil, PCBs
concentration and PCBs amount in each capacitor. For capacitors, information of type-numbers will be
adequate for compiling the inventory as they are all from known sources. A comprehensive list of the
major potential holders will be compiled by combining information from different information sources
including: enterprise registers; Chamber of Commerce and Industry of the Republic of Moldova;
electricity distribution companies; Yellow pages of Moldova; and regional environmental authorities.
Based on experience it is estimated that the list will comprise at the least 500-1000 potential holders of
capacitors.
55
The list of enterprises, companies, institutions and organizations, holding electrical transformers, is
available at the electricity supply companies and will be received from these on an official request from
the MENR.
A specific problem for PCB inventories in former Soviet Union republics has been the presence of closed
down production facilities, which cannot be identified from, for example, enterprise registers. The
problem will be specifically addressed by the project implementation. The PMT will be responsible for
clarification of the legal aspects concerning these facilities, generating a list of facilities in which PCBcontaining equipment may be present, identification of owners and identification and labeling of
equipment in the part of the facilities owned by the Moldovan state.
Undertaking the Inventory. The guidelines and inventory forms will be sent to all potential holders of
the equipment. The most time consuming part of the inventory is the actual identification of the
equipment by the holders and sampling of transformer oils. If it is assumed that sampling from each of
5000 transformers takes 0.5 hour and each of 1000 potential holders of capacitors and transformers use on
average 2.5 hours on identification and reporting, then the total time consumption is 6000 hours. The
costs of identification, sampling and reporting will be covered by the holders. Subsequent to the inventory
actual holders of equipment will use further time on labeling and preparation of management plans. Based
on experience many holders may have additional questions regarding the identification of the equipment,
sampling, etc. Further inspectors from the Environmental Inspectorate will be trained in order to be able
to assist the holders in fulfilling their obligations.
Compiling, Reporting and Updating of the Inventory. The results of the inventory will be entered into
a database and summarized for the consideration of the government in developing its PCB waste
management system. Further, the compiled data will be reported to the Conference of the Parties of the
Stockholm Convention since the Convention requires Parties to provide a report every five years on
progress in eliminating PCBs. The holders of equipment have the obligation to report when they dispose
of the PCB-containing equipment and the database is updated regularly with this information.
Analysis of Transformer Oils in the Commercial and Institutional Sectors. Determination of the
presence of PCBs in equipment still in use is the responsibility of the holders. The testing of PCBs in
transformer oil can be done by simple test kits (testing the presence of chlorine), or by laboratory
analysis; usually by gas chromatography. Testing for PCBs requires a level of expertise not usually
available in most commercial or institutional establishments using transformers. Therefore, it is proposed
that the project provides for testing of oils from all transformers held by the consumers of electricity,
independent of transformer manufacturer and type. According to the initial inventory, in total around
2,500 transformers are held by large consumers of electricity.
For the first screening identification of PCBs, the simple tests kits will be used. Kits are available for
detection of PCBs at different levels of 20, 50, 100 and 500 ppm (mg/kg). Considering the provisions of
the Stockholm Convention and the EU PCB/PCT directive, test kits for 50 ppm will be used. Several kits
meeting the Stockholm Convention requirements exist on the market. A sufficient sock g kits will be
procured under the project to meet the expected demand from holders of equipment. For cost estimate
purposes, the price of a widely used test-kit, Dexsil’s Clor-N-Oil PCB screening kit, has been used. It is
available at a cost of approximately US$20 per kit, including customs duty.
On request sampling kits (not to confuse with the test kit) and guidelines for their use will be sent to the
equipment holders. The sampling kits are similar to kits used regular sampling of transformer oils for test
of physical/technical parameters. Sampling is the responsibility of the holders which will send the
samples to the central laboratory of the Environmental Inspectorate which will be responsible for the
56
initial test using the PCB test kits. Samples testing positive >50 ppm will be send to the laboratory of the
Hydrometeorological Service for further analysis of the actual concentration of PCB using gas
chromatography following the European Standard EN 61619 (PCB analysis in insulating liquids). The
results of the analyses will be sent to the holders of the equipment which include the information in the
inventory form. The laboratory of the Hydrometeorological Service will be provided with equipment for
PCB analysis by gas chromatography and upgraded for analysis in accordance with the European
standards for PCB analysis. It is assumed that about 500 samples are analyzed by gas chromatography at a
price of 70 US$ per analysis.
Testing of Transformers in the Energy Sector. Approximately 20,300 transformers are in use in energy
sector. From past experience it can be assumed that contamination of the transformers within the energy
sector is not widespread and for this reason a three step approach is proposed. The energy companies hold
comprehensive files of all transformers by type-number. As a first step, the energy company will group
the transformers into three categories:
1. "TH" types containing PBCs;
2. other types produced in the Soviet Union and originally filled with mineral oil (i.a. TM, TД, TЦ,
TДЦ); and
3. transformers of non-Soviet Union origin or of unknown type.
All transformers of "TH" types, or of non-Soviet Union origin, will be tested using the same procedure as
proposed for the transformers held by consumers. It is estimated that it will be necessary to test
approximately 2500 transformers in this group. The result of these tests will indicate whether PCB cross
contamination has taken place. If so then MENR and MoE will decide whether further analyses of Group
2 and 3 transformers will be required. This testing will be the responsibility of the holders of the
equipment.
Testing of Capacitors. The presence of PCBs in capacitors produced in the Soviet Union can be
determined on the basis of the type-number and there is no need for analysis. Capacitors produced in
other European countries before 1990 must be considered PCB-containing until the opposite is proved by
analysis. Capacitors are closed containers and it is not possible to take samples of capacitors in operation.
Training Seminar. A one-day training seminar in sampling and inventory methodology will be held for
key staff from companies in the energy sector.
Labeling and Management Guidelines. PCB-containing equipment and the doors of premises where
such equipment is located will be labeled to indicate the presence of PCBs. Similarly, eventually
decontaminated transformers should be labeled (the decontamination of transformers is not part of this
project). Labeling is the responsibility of the holders, but it should be ensured that correct labels are
available for their use. Proper labeling is considered essential for ensuring correct disposal of the
equipment when discarded. Awareness about PCBs will be raised during the inventory process, but the
holders may be less aware some years later when they have to dispose of the equipment unless it is
properly labeled. Internationally recognized labels will be provided under the project to all holders of
such equipment.
One of the provisions of the proposed regulation will be a requirement that holders of PCB-containing
equipment will have to develop detailed management plans for preventing accidents and releases of PCBs
from the equipment. Guidelines for environmental sound management of PCB-containing equipment will
be prepared as part of this sub-component. Subsequent to the inventory the developed guidelines will be
submitted to holders who have declared the presence of PCB-containing equipment and a seminar will be
held for training of personnel of companies that hold such equipment.
57
Enforcement. The holders of the equipment have the obligation to notify the presence of PCB-containing
equipment. However, in order to enforce the regulation it will be necessary to make provisions for
independent inspections by the competent authority.
In order to provide inspectors with the necessary technical understanding a one-day workshop for selected
MENR inspectors will be provided. Further the inspectorate will be provided 500 testing kits to be used
for point inspection. In total 5,500 test kits at an approximate price of US$15 per kit will be purchased for
inventory and inspection.
Future Management of PCBs in Moldova. Based on the results of the inventory a plan for future
management of PCBs and PCB-containing equipment in Moldova will be developed as part of this subcomponent of the project. The results of the inventory and the management plan will be presented at a
seminar for relevant stakeholders. It is presumed that regulation meeting the stipulations of the PCB/PCT
Directive will be implemented. It is further proposed to develop a system for management of PCBcontaining waste and obsolete PCB-containing equipment as an integrated component of a general
hazardous waste management system being developed by the MENR. Payment for final destruction is the
responsibility of the holders and would be included in the payment for transfer of the PCB waste and
PCB-containing equipment to the temporary storage site.
The stipulations of the PCB/PCT Directive include the development of a license system for undertakings
involved in decontamination, dismantling and removal of PCB-containing transformers. Depending on
the PCB contamination level, the identified transformers may either be decontaminated for further use or
replaced. The selected management of the transformers depends among other things on the age of the
transformer, the location, the contamination level, price of decontamination, and the investment plans of
the holders. Management plans for each particular transformer is the responsibility of the holders and not
included in this subcomponent.
Activity 2: Destruction of Obsolete Capacitor Stockpiles (US$ 2.09 m, of which GEF US$ 2.07 m)
The subcomponent consists of three main activities:
 Dismantling of 17,300 obsolete capacitors and packing in closed containers (approximately 899
tons);

Excavation of 2,000 capacitors buried in two pits in the Vulcanesti substation and packing in
closed containers (approximately 111 tons);

Shipment and destruction of 19,300 capacitors and up to 50 tons highly polluted soil
(approximately 1,060 tons).
The PCB-containing capacitors in the electrical substations are in a condition where leakages due to
corrosion are occurring and leakages are expected to increase in the coming years. There is an urgent need
for preventing further releases to the surroundings by dismantling the capacitor batteries and packaging of
the capacitors in closed containers. The broken capacitors in the two pits at the Vulcanesti substation are a
significant risk for pollution of the groundwater and surface waters of the area and there is an urgent need
for excavating the pits and placing the capacitors in closed containers.
Capacitors to be Destructed. The electricity substations with disused capacitors requiring immediate
attention are all owned by the state-owned transmission company ‘Moldelectrica’. Some of the capacitor
batteries of ‘Moldelectrica’ have previously been used periodically during wintertime. ‘Moldelectrica’
plan to take all PCB-containing capacitors out of service for final disposal under this project. Table 2
provides a list of all capacitors requiring disposal in electricity substations throughout Moldova
58
(excluding Transnistria).
Table 2. List of Capacitors Requiring Final Disposal in Moldova (Excluding Transnistria)
Substation
No
of
Capacitors
for
Disposal
Total
Weight
(tons)
Number of
Exploded
Capacitors
Briceni
251
30 x 30 x 10
28
7.0
-
Ciadir-Lunga
66
60 x 30 x 10
56
3.7
-
Comrat
247
60 x 30 x 10
56
13.8
-
Donduseni
206
60 x 30 x 10
56
11.5
10-100
Drochia
528
30 x 30 x 10
28
14.8
-
Edinet
349
60 x 30 x 10
56
19.5
-
Hincesti
167
30 x 30 x 10
28
4.7
-
Lipcani
177
30 x 30 x 10
28
5.0
-
Orhei
371
60 x 30 x 10
56
20.8
-
Soroca
334
3-4
60 x 30 x 10
56
18.7
-
Straseni, bay 1
864
52
60 x 30 x 10
56
51.3
-
Straseni, bay 2
864
30 x 30 x 10
28
24.2
-
Ungheni
528
30 x 30 x 10
28
14.8
-
Total
substations
small 5,004
Of These in Dimensions Unit
Storage
of Capacitor Weight
Containers Box (cm)
(kg)
41
Approx 100
207
210
Vulcanesti
12,303
60 x 30 x 10
56
689
Vulcanesti, pits
2,000
60 x 30 x 10
56
112
Total Vulcanesti
14,303
207
801
Total Moldova
19,307
Approx 300
1,011
About
2000
The steel support structures on which the capacitors are attached will not be dismantled as part of this
activity, but planning for dismantling of the overhead support structures at Vulcanesti is included in the
third subcomponent.
Planning of the Disposal Operations. In order not to waste resources on establishment of temporary
storage facilities, it is planned that the capacitors will be dismantled and packed directly in the containers
used for shipping. As a shipping container is filled it will be immediately shipped for disposal, reducing
the number of containers needed for the operation. The facility used for the destruction of the capacitors
will be required to comply with the best international environmental and safety standards. World Bank
approved bidding documents for packaging, exaction, transport and final disposal of the capacitors will be
advertised internationally, but it is expected that hazardous waste incineration facilities in Europe meeting
59
EU standards will be the only ones which will have the capacity and the interest to offer bids. With
overcapacity in this sector it is expected that highly competitive bids will be received making it
imperative that this sub-component be ready for procurement immediately after project appraisal so the
procurement process can begin even before Board approval.
After selection of the facility for destruction of the disused capacitors, finalized schedules for dismantling,
packing and transport will be agreed with the facility. In fact a proposed schedule would be required in
the work plan to be included in the submission of bids.
Packing of Capacitors. The dimension of the 60 x 30 x 10 capacitors including the ceramic insulators is
799 mm high, 430 mm broad and 120 mm deep. Using an Intermediate Bulk Container (IBC) of 1m x
1m x 0.8m (800 l), each container would hold 18 capacitors independent of the size of the capacitors. The
capacitors should be packed with the ceramic insulators intact in order to prevent leakages. It is assumed
that the trucks for international transport can each carry 24 containers with a total of 420 capacitors. The
number of round trips would then be approximately 46 including the transport of the contaminated soil.
Assuming a price per round trip of 3,500 US$ the total costs of round trips will be US$ 160,000. The cost
of leasing of containers is assumed to be US$ 28,600 using a unit cost for leasing of one container for 20
days of US$ 26. The total transport costs including leasing of containers are thus US$ 190,000.
The gross weight of a container filled with 18 capacitors will be about 1,250 kg. For handling the filled
containers a forklift on big wheels that can carry this weight will be required. It is assumed that a fork lift
is purchased as part of the project at a price of US$ 22,000.
For the cost estimate it is anticipated that 800 l IBC containers will be leased by the disposal contractor.
The containers will be filled with absorbent materials in the bottom to contain any PCB leakages. If two
trucks with 24 containers each are shipped every week, then 864 capacitors/week will be removed, and
the entire disused stock of 19,300 capacitors would be disposed of in 5-7 months. The total weight of the
capacitors and contaminated soil is estimated at 1061 tons.
The capacitors will be continuously dismantled by about 9 trained workers (1 foreman and 4 teams of
two). It is anticipated that each team will be able to dismantle and pack about 5-6 capacitors per hour,
achieving the targeted 864 capacitors/week. It is proposed to use the same group of workers to dismantle
capacitors at all of the Moldelectrica substations. Capacitors will be lowered carefully to the ground and
the ceramic isolators on top of the capacitors will be protected from damage in order not to create a risk of
further PCB leakage. In case of corroded or damaged capacitors, the IBC container will be partially filled
with absorption material after placement of the capacitors. At the disposal facility the capacitors together
with the absorption material will be destructed.
Health and Safety of Workers. In order to ensure safe working conditions, all the capacitors in elevated
positions will be dismantled with the help of scaffolding. A lowering mechanism will be incorporated into
the scaffold structure to ensure the safe transport of the capacitors to ground level. Before the start up of
dismantling activities the work force will be trained in the safe methods of handling and packaging of
capacitors, as well as personnel health and safety protection measures, including use of suitable protective
clothing; prohibition of smoking, drinking and eating during work in contaminated areas, etc. The
workers will be trained in procedures to prevent leakages and releases of PCBs and in the treatment of
emergency situations should accidents occur. The training will takes place in a one-day training
workshop, as well as in supervised on-the-job training during the initial start up period. Safe dismantling,
handling and packaging procedures as well as health and safety measures will be presented in simple
illustrative form with constant evaluation of performance of the teams by the foreman in charge.
Establishment of Buffer Storage. Although the dismantled capacitors should be continuously shipped
60
with adequate container capacity provided at the site by the disposal contractor at all times, there may be
a need for buffer storage in Vulcanesti in order to make the dismantling more efficient. If so, then a
secure safe storage, consisting of an area of approximately 200 m2 will be paved and provided with a
bund wall and a sump. Considering the amount of capacitors in the small substations it is anticipated that
the containers can be placed for the short time concerned on existing paved ground.
Excavation of PCB Capacitors from Two Pits in Vulcanesti. Two pits each with 1,000 capacitors will
be excavated and the removed capacitors will be placed in IBC containers and shipped. The approximate
locations of the pits are known. In one of these sites capacitor parts are visible on top of the soil cover.
Anecdotal evidence indicates that the capacitors have been placed at a dept between 0-7 m and that the
area of each site is approximately 5m x 5m.
Before the start of the excavation, as part of the feasibility study described in Activity 3, information of
geography, topography, soil morphology, geo-hydrology (in particular, groundwater depth and flow
direction), groundwater use, etc. will be collected and assessed. Further samples will be taken to
determine whether PCDDs/PCDFs have been formed during the explosions. The eventual presence of
PCDDs/PCDFs influences the preventive measures to be taken during the excavation. Based on this
information a more detailed plan for the excavation will be developed. The following description of the
methodology has been developed for the cost assessment but will be reassessed as part of the feasibility
study.
Before excavation a lined area of 10m x 20 m with a 1.2 m high cofferdam will be prepared beside each
of the pits. The polluted top soil will be removed and stored temporarily in the cofferdam. The total
amount of polluted soil that will be removed during the excavation of the capacitors is estimated at 2 x
200 m3 = 400 m3. Once filled, the cofferdam will be covered by a waterproofed lining on the top of the
excavated soil. Procedures for taking care of leachate water also must be considered (e.g., treatment of the
polluted water through activated carbon filters before release). It is presumed that it will be necessary to
employ and excavator for about 250 hours at unit costs of US$ 150 per hour.
The capacitors and soil with visible capacitor parts will be excavated and placed in IBC containers for
shipment. Highly contaminated soil removed during the excavation will be sent for destruction together
with the spent capacitors. It is estimated that besides the estimated 110 tons of capacitors some 50 tons of
highly polluted soil will be excavated and sent for destruction.
It may be necessary to install protective steel balustrades in order to prevent soil collapse from the walls
of the excavations into the pits. Groundwater shall be pumped from the excavated area and stored for
analysis and possible future treatment. The further treatment of the two excavation sites and necessary
remediation measures will be assessed as part of the feasibility study.
Provision will be made for draining of water from saturated soil excavated from the pits by sloping the
base of the coffer dams and providing a sump for collection of the drained water. This water will be
pumped into storage tanks from which it will be treated by absorption in activated carbon filters before
release. The polluted filter material will be sent for destruction. The detailed procedures for excavation
and removal of capacitors and highly contaminated soil and storage of less contaminated soil will be
specified in the feasibility study.
Transport of the Capacitors for Disposal. A total amount of 1,060 tons capacitors and highly polluted
soil will be exported for destruction outside Moldova. Transport arrangements for this hazardous waste
will be in accordance with the stipulations of:
 Government Decision on Transportation of Hazardous/Dangerous goods within the Territory of
the Republic of Moldova (No. 672, dated May 28, 2002);
 International transport rules: The European Agreements on the International Carriage of
61


Dangerous Goods by Road (ADR) and Rail (RID) and the International Maritime Dangerous
Goods Code (IMDG);
The EU waste shipment rules set out in EU Waste Shipment Regulation (Council Regulation
(EEC) No 259/93).
The Basel Convention requirements relating to transboundary shipments of PCB containing waste
also will be followed.
The regulations that will apply to the transport of these wastes will be specified in the bidding documents.
Final Destruction of Capacitors. The disused capacitors and polluted soil will be destructed in
accordance with best international practices and environmental and safety standards. If incineration is
used for destruction the incinerator will be required to meet international accepted requirements such as
the EU Waste Directive. For the cost estimation purposes it is assumed that the capacitors will be shipped
to Germany and destroyed in a hazardous waste incinerator.
The major cost element is the destruction of the capacitors. Assuming a destruction cost of US$ 1,365 per
ton of waste, the destruction of 1,061 tons capacitors and contaminated soil amounts to US$ 1.45 million.
It is notable that the estimated costs of international transport of US$ 190,000 only increase the total costs
of the final disposal by about 8%.
The cost estimations for this activity take these requirements into account. It is assumed that the
contractor will lease 800 liter Intermediate Bulk Containers (IBC), which will hold 16 – 18 capacitors
each. The sealed containers will have absorbent material placed in the bottom to contain any leakages of
PCB. Dismantled capacitors will be loaded directly into the containers, which will be shipped
immediately to the disposal facility. It has been estimated that two trucks with 24 containers each could
perform one round trip per week to a European incinerator. At this rate all of the capacitors and the
additional 50 tons of highly contaminated soil could be dispatched for disposal in 5 – 7 months. The
weekly load of capacitors could be dismantled by approximately 9 trained workers in two teams of four
with one supervisor. The contractor would be responsible for selecting and training these workers and
would provide all the necessary protective and safety equipment as specified in the contract. It is
estimated that only 8% of the costs of this activity will be for the transport of the capacitors to the final
disposal facility. Hence the export option does not add significantly to the cost and allows bidding in a
highly competitive environment. It is expected that the cost of destruction including all costs from
dismantling of capacitors through to final disposal will be approximately US$ 1972 / ton of waste.
The contractor also will be responsible for excavating 1,000 capacitors from the two disposal pits at
Vulcanesti. Specifications have been drawn up and will be included in the bidding documents on how
this excavation is to be carried out by the contractor. Additional information will be provided to the
contractor by the contract supervising consultant who also will be carrying out the feasibility study under
Activity 3 and will be performing tests on the disposal pits prior to their excavation.
International Contractor for Packing, Transport and PCB Disposal. An international hazardous
waste treatment company will be selected for planning and implementation of the dismantling and
packing of the capacitors, excavation of capacitors, transportation to the destruction facility and final
destruction of the capacitors.
International Supervising Consultant Company. An international consulting company will be selected
to assist Moldelectrica in the supervision of the international destruction Contractor in the dismantling
and disposal of the obsolete capacitors in the substations. In order to build national capacity in this regard,
it is proposed the contractor with select a local company, which will be fully involved in these activities
and will get the relevant training. The Supervising Consultant will monitor and evaluate the performance
of the contractor to ensure that it complies with the conditions of the contract and will verify the accuracy
62
of the contractor’s tracking system and reporting on quantities handled and destructed. Further, the
company will be responsible for undertaking the feasibility study for the clean up of PCB contamination
at the Vulcanesti site in close cooperation with Moldelectrica, and provide advice as to the procedures for
excavating the capacitors from the pits.
Activity 3: Feasibility Study of Site Clean-up at Vulcanesti Substation. (US$ 0.29 m, of which GEF
US$ 0.24 m)
Due to the two incidents of capacitor explosions mentioned previously, and leakage by corrosion of the
33-years old capacitors in Vulcanesti substation, the elevated steel support structures holding the
capacitors and the ground below may be expected to be highly contaminated. Measurements taken in the
spring 2005 (see Table 2) clearly demonstrate that the PCBs are mobile in the soil and there is an urgent
need for preventing further dissipation of PCBs to the surroundings. The PCB content in the upper 10 cm
varied from 1.3 to 7,098 mg/kg, with the highest concentration found in the soil beneath the assembly, but
between the batteries, indicating that the PCBs have been dissipated over the whole area under the
assembly. In 50-60 cm the concentration ranged from 0.1 to 177 mg/kg.
.
The capacitor assembly covers an area of about 10,000 m2, of this about 2,700 m2 is located directly
below the 18 capacitor batteries. The measurements show that it is not only the ground just beneath the
batteries that is contaminated. The highest measured concentration was found in a sample taken under the
assembly, but between the batteries. In addition the soil and groundwater around the two pits with about
1000 broken exploded capacitors each and a temporary storage facility with 380 capacitors may be highly
contaminated with PCBs. At least one of the other substations in Moldova, Donduseni, is contaminated as
well due to a previous capacitor explosion incident. A few measurements in four of the smaller
substations demonstrated PCB levels of up to 95 mg/kg in Donduseni beneath the capacitor battery,
whereas the highest value found in the other stations was 2.5 mg/kg. The feasibility study and
remediation of the Vulcanesti station will serve as demonstration project for future remediation measures
at other contaminated sites.
Pre-excavation Analysis. The feasibility study is closely linked with sub-component 1.2.2. Before the
start of the excavation of the two pits, information on geography, topography, soil morphology, geohydrology (in particular, groundwater depth and flow direction), groundwater use, etc. will be collected
and assessed. In order to investigate whether PCDDs/PCDFs have been formed by the explosions samples
of capacitor parts from the pits are taken and analyzed for PCDDs/PCDFs. At three positions on the site,
boreholes will be drilled to at least 3 m below the water table. Two of these boreholes will be established
adjacent to, but not in, the waste pits described above. The third borehole will be established at some
distance from the first two. The exact position of the boreholes can only be determined on site, but
establishing three boreholes into the same groundwater aquifer will enable the groundwater flow direction
to be determined.
The boreholes will be constructed as 110 mm boreholes or similar and fitted with screens from 1.0 m
above the groundwater level to the base of the borehole. The borehole casing will be established to
approximately 0.5 m above the surface. The borehole casing will be protected from accidental damage
above the surface by a concrete ring or similar. The geographical position and height above sea level of
each of the wells will be determined. During drilling, soil samples will be collected for every 0.5 meters
and at every apparent change in soil type or characteristic will be noted. A lithological (about the soil
minerals) well log for each well will be established on the basis of the soil samples. Groundwater levels in
each of the wells will be measured and groundwater flow direction determined.
Delimiting the Area of Capacitor Deposition Sites. The position and approximate extent of two
63
deposition sites for waste capacitors is known. However, in order to determine the volume of material that
is expected to be excavated more detailed knowledge of the extent of the sites is needed. Similarly, it is
possible that further deposition sites exist, consequently surface mapping ‘of the site is recommended.
Surface mapping can be carried out using ‘geo-radar" or geo-electrical resistivity methods. The expected
depth of the deposition sites is approximately 7 m and the geo-electrical resistivity method can be used to
this and greater depths; consequently this method is recommended. Measurements will be taken at regular
intervals of e.g. 3, 5 and 10 meters along a traverse of the area. The results of the measurements give
information on the relative resistivity of the soil along the traverse. Areas where excavations have taken
place and areas where waste has been deposited will have a relative resistivity that is different from the
surrounding area. The waste deposits can then be mapped in areal extent and depth.
Based on this information a detailed plan for the excavation will be developed including the establishment
of the temporary storage for the polluted excavated soil.
Post-excavation Analyses. After the excavation of the capacitors, the opened pits will be analyzed for
further pollution and a remediation plan for the pits will be prepared. In the excavated pit at least one soil
sample will be collected from each of the four sides and at least one soil sample will be collected from the
base. As the sample is intended to represent the entire side or base of the excavation, the actual number of
samples that are collected will depend on the size of the excavation. It is expected that the size of the
excavation will be approximately 5 m x 5m x 7 m.
Mapping of PCBs Contamination of the Site. After dismantling of the capacitors and shipment of
stored capacitors a detailed mapping of the PCB contamination of the site will be undertaken. The
sampling program will include the soil under the capacitors assembly, soil around the two pits and soil
around the temporary storage of capacitors. The investigation carried out in the spring of 2005 will be
supplemented by further surface sampling. In the previous study the surface deposits beneath 5 of the 18
capacitor battery assemblies were investigated. Additional sampling and analyses will be carried out as
follows:
 The surface deposits beneath the remaining 13 assemblies will be investigated at depths of 0.1 m
and 0.5 m below the surface;
 At a further four sites in the area between the capacitor assemblies soil samples will be are
collected at depths of 0.1 m and 0.5 m below the surface;
 Soil samples are collected from four sites distributed around the perimeter of the temporary
storage site for the capacitors. The samples are collected at depths of 0.1 m and 0.5 m below the
surface;
 From each of the boreholes three soil samples will be selected for analysis;
 Two water samples will be collected from each of the new wells. The well screens in each of the
new wells will be positioned so that immiscible fluids that collect on the surface of the water
table also can flow into the well. The first water sample from each well will therefore be taken
from the upper surface layer of the water table using a water bailer. For collection of the second
sample, a pump will be lowered further into the water column and groundwater pumped until
sufficient water has been removed to ensure that the sample collected represents groundwater in
the aquifer;
 After samples have been collected at least one well test pumping will be carried-out to determine
aquifer characteristics; and
 Samples will be taken to determine to what extent the steel structures holding the capacitors are
polluted with PCBs. Four of the steel structures will be selected and at three different heights on
each of these an area of approximately 10 cm2 will be scraped into a sample container for
analysis.
In total it is assumed that about 300 soil samples, 28 water samples and 18 samples from the steel
64
construction will be analyzed for PCBs at a unit price of 100 US$ per sample. Further 3 samples will be
analyzed for PCDD/PCDFs by an international laboratory. The total costs of drilling and analysis is
estimated at US$ 70,000.
Site Environmental Characterization. Based on the results of these investigations, the area distribution
and depth of contamination of the soil will be determined and illustrated on plans of the area. Possible
groundwater contamination will be identified and contaminant flow directions and flux determined. The
results of the investigation will be compared with acceptable international standards for soil and
groundwater contamination with PCBs and possible risk for the environment and people in the area will
be assessed.
Site Remediation Approaches. Based on site environmental characterization and the risk assessment
different technologies for site remediation will be evaluated. The cleanup procedures may be different for
different PCBs contamination levels. The possible options should include (but not be limited to):
(a) Removal of surface soils below capacitor batteries. The surface soil below the 18 capacitor
batteries would be removed to a depth of 0.5 m and replaced by uncontaminated soil. The
removed soil would be transported in sealed containers to a destruction facility. The amount of
soil removed would be approximately 1,350 m3 or 2,700 tons;
(b) Removal of surface soils from capacitor battery area. The surface soil of the capacitor battery
area would be removed to a depth of 0.5 m and replaced by uncontaminated soil. The removed
soil is transported in sealed containers to a destruction facility. The amount of soil removed
would be approximately 5,000 m3 or 10,000 tons;
(c) Sealing of the area beneath the 18 capacitor batteries. Surface vegetation beneath the capacitor
batteries would be removed and an impermeable mat or membrane installed on the area. On this
membrane drains and a sand / gravel layer would be installed. A further impermeable membrane
is installed over the gravel layer and covered by a top soil layer;
(d) On-site decomposition of the PCBs using reductive dechlorination, aerobic biodegradation or
other in-situ decomposition methods; and
(e) Removal of isolated contaminant hot spots and sealing of the remaining area (as in Option (c).
The feasibility study will determine which option is the least cost approach to achieve the desired level of
environmental and human health protection. Under the contract to carry out the feasibility study the
consultants will be required to prepare specifications and estimate of costs for a follow up contract to
carry out the remedial measures.
Groundwater Monitoring. Monitoring of contaminant levels in groundwater under and adjacent to the
site are considered imperative for the long term control and possible containment of pollutant transport
from the site. Groundwater flow rates and flow direction will be determined using results from the three
wells established during the investigation of the site for the feasibility study. On the basis of these results
one well will be designated as the monitoring well upstream the site. Groundwater samples from this well
can be taken to represent background levels of contamination not associated with contamination from the
site. If one of the remaining two wells is directly downstream the site, this will then be designated the
downstream monitoring well, and groundwater samples from this well will provide an indication of
contaminant transport from the site. The position of the well downstream the site may, however, not be
ideally placed for monitoring purposes as it was initially established to determine flow directions. It may,
therefore, be necessary to establish a new well for downstream monitoring purposes. The position of this
well will be determined on the basis of the results of the three existing wells.
On the basis of the initial analyses of groundwater samples, a monitoring program will be established.
The program will recommend monitoring intervals, chemical analyses to be performed as well as
sampling procedures. The monitoring program will also describe a recommended action plan based on the
results of the analyses, and cut-off levels for further monitoring.
65
Institutional Arrangements. All the work under this sub-component will be supervised by Moldelectrica
in cooperation with the Ministry of Ecology and Natural Resources. All analytical and laboratory quality
control procedures will be in accordance with the relevant European standards. Laboratory equipment and
training of laboratory technicians for PCB analyses will be handled under Sub-component 1.2.1.
COMPONENT 2: STRENGTHENING THE REGULATORY FRAMEWORK AND CAPACITY BUILDING FOR
POPS MANAGEMENT. (US$ 2.32 M, OF WHICH GEF US$ 1.27 M )
This component includes actions for modernization of current legislation specifically related to the
Stockholm Convention and incorporation of provisions for establishing a broader chemical safety
approach in the country based on EU legislation. During project implementation full transposition of all
relevant EU legal acts is expected to be achieved. This will include drafting of specific regulatory acts and
supporting operational guidelines/handbooks for practical application. An important element will be the
creation of adequate institutional arrangements for co-ordination of POPs related activities country-wide
and dissemination of experience gained for overall chemical safety aspects. This component consists of
two sub-components: (i) Modification of the Legal and Regulatory Framework for POPs; and (ii)
Institutional Capacity Building for POPs Management.
Sub-component 2.1: Modification of the Regulatory Framework. (US$ 0.74 m, of which GEF US$
0.61 m)
The objective of this sub-component is to provide a legal basis for POPs chemical management under
Stockholm Convention requirements and set-up an overall chemical safety system in Moldova according
the EU regulation and legislation5 related to handling of dangerous chemical substances and hazardous
waste. This sub component will develop an integrated system of POPs management with the
transposition of modern regulations and international obligations under several international treaties
related to POPs and specifically the Stockholm Convention on Persistent Organic Pollutants, 2001
(ratified by Moldova on February 19, 2004), the Basel Convention on the Control of Transboundary
Movements of Hazardous Wastes and their Disposal, 1989, the Convention on the Long-range
Transboundary Air Pollution, Geneva, 1979, Aarhus Protocol on Persistent Organic Pollutants, 1998, the
Rotterdam Convention on the Prior Informed Consent Procedure for Certain hazardous Chemicals and
Pesticides in International Trade, ratified by Moldova in 2004.
5
COUNCIL DIRECTIVE of 12 December 1991 on hazardous waste (91/689/EEC, as amended by 94/31/EC); COUNCIL
DIRECTIVE of 16 September 1996 on the disposal of polychlorinated biphenyls and polychlorinated
terphenyls (PCB/PCT) (96/59/EC, as implemented by Commission Decision 2001/68/EC); COUNCIL DIRECTIVE
67/548/EEC of 27 June 1967 on the classification, packaging and labelling of dangerous substances (as amended for the 27th
time by Commission Directive 2000/33/EC); Council Regulation of 23 July 1992 concerning the export and import of certain
dangerous substances (EEC/2455/92, as amended by Regulations EC/3135/94, EC/1492/96, EC/1237/97 and EC/2247/98);
COUNCIL DIRECTIVE of 15 July 1975 on waste (75/442/EEC, as amended by Council Directive 91/156/EEC;
COUNCIL DIRECTIVE of 16 September 1996 on the disposal of polychlorinated biphenyls and polychlorinated
terphenyls (96/59/EC); COUNCIL DIRECTIVE of 16 June 1975 on the disposal of waste oils (75/439/EEC, as
amended by Council Directive 87/101/EEC and Council Directive 91/692/EEC); COUNCIL DIRECTIVE of 16
December 1994 on incineration of hazardous waste (94/67/EC); Directive 2000/76/EC of the European Parliament
and of the Council of 4 December 2000 on the incineration of waste;
66
Activity 1. Assessment of Existing Legislation Regarding Compliance with EU Regulations. (US$
0.25 m, of which GEF US$ 0.21 m) This activity is planned to begin during the project preparation
phase, prior to the start up of project implementation. In order to revise existing legal and institutional
arrangements it is necessary to start with a gap analysis comparing EU legislation and Conventions’
requirements with existing legislation in Moldova and preparation of Table of Concordance in relation to
international obligations for POPs, hazardous wastes and dangerous substances. This activity will allow
the establishment of priorities regarding the time schedule for legislation preparation, particularly those
related to the project time schedule needs.
Based on the gap analysis, timetable for legislation drafting will be set at the beginning of project. Taking
into account that activities relating to the PCBs inventory cannot start without basic legal
background/support, MENR has agreed that at least Council Directive of 16 September 1996 on the
Disposal of Polychlorinated Biphenyls and Polychlorinated Terphenyls (PCB/PCT) (96/59/EC, as
implemented by Commission Decision 2001/68/EC will be prepared during 2005 before project start up.
Activity 2. Assistance in Drafting of Relevant Regulations and Instructions. (US$ 0.25 m, of which
GEF US$ 0.21 m) Under this activity national legislation will be promulgated to: strengthen the chemical
safety management system in Moldova; to clearly define responsibilities; specifically prohibit production
and use of POPs chemicals and regulate their export/import; and provide a legal basis for
reduction/elimination of unintentional releases from production processes. The legal provisions will also
cover: POPs contaminated site management issues; define responsibility for POPs contaminated sites;
incorporate POPs monitoring and reporting; regulate assessment of new chemicals meeting POPs criteria;
promote BAT and BEP for new and existing sources; as well as specify requirements for modified
materials, products and processes.
The improved legal framework will provide the general context for POPs management in Moldova, and
specific regulations will establish relevant rules and procedures for implementing the requirements of the
framework legislation. To be efficient, the legal acts and regulations should be clearly understood by
involved parties and should be supported by relevant operational and methodological guidance.
Training for all stakeholders regarding the transposition of the legal acts will be organized. The training
will particularly emphasize preparation of regulatory “Cost – Benefit Analysis” and implementation
feasibility related to: (i) available human resources in the MENR and related ministries for
implementation (issuing of permits, monitoring, reporting, etc.); (ii) planned economic instruments (i.e.,
user taxes; waste disposal fees, packaging fee/taxes, etc.); (iii) required institutional arrangements (on
national and local level); (iv) required additional investments in public and private sector monitoring and
reporting; and (v) needed supporting guidelines, stakeholders awareness and information campaign to
stakeholders.
Technical Assistance will be provided under this activity to include: education in the EU legislative
system, elements of the law preparation, assistance in drafting of laws, regulatory “Cost-Benefit”
analysis, preparation of training materials and training facilitation.
Activity 3. Development of Regulatory Mechanisms. (US$ 0.23 m, of which GEF 0.19 m) The new
legal provisions for dangerous chemicals and hazardous wastes will be sustained by development of
specific implementing regulations (by laws) and instructions. The regulations and instructions will be
prepared based on the EU legislation. For the project needs, the following related issues under this
legislation will be covered: (1) management of district storage facilities for obsolete pesticides and
hazardous wastes*; (2) management of abandoned storehouses and contaminated sites*; (3) import/export
and transboundary transportation of obsolete pesticides and PCBs; (4) procedures for assessment of new
pesticides and pesticides currently in use against POPs criteria; (5) regulation on statistical reporting on
67
POPs pesticides and PCBs wastes, products, installations and PCB-contaminated sites; (6) instruction for
management of PCB-contaminated power equipment*; (6) instruction on storage and management of
PCBs wastes*; (7) recommendations for safe usage of PCBs materials; (8) instruction on field and
laboratory identification of PCBs content in dielectric oils and other materials*; (9) instruction on
performing PCBs inventories and identification of contaminated sites*; (10) instruction on transportation
of oils, equipment and other PCB-contaminated materials*; (11) instruction on disposal of PCBcontaminated oils and PCB-contaminated power equipment*; (12) instruction on refilling the power
equipment*; (13) instruction for labeling of PCB-containing equipment*; and (14) regulation on POPs
management control. As far as possible the above activities will take into consideration (and contribute
too) sound chemical management in general. The leading implementation agency for this sub-component
is MENR, in partnership with MOE, MAFI, DOC, MOH. The tasks that are marked with a * will be
developed together with activities under the PCB inventory of Component 1.
Technical Assistance that will be provided under this sub-component will include: preparation of
regulations and instructions, preparation of training materials, and training facilitation
Sub-component 2.2: Capacity Building for POPs Management. (US$ 1.58 m, of which GEF US$
0.66 m)
This sub-component includes priority actions related to training of Inspectors involved in applying the
new regulations relating to POPs to assist them in a clearer understanding of their professional and
technical roles in the regulation and management of POPs, developing inventories for POPs chemicals
and identification of contaminated sites, as well as strengthening the monitoring, reporting and control of
POPs. This sub-component consists of two activities: (i) Strengthening of Inspectorates for Enforcement
of POPs Regulations; and (ii) Upgrading and Strengthening of Existing Laboratories for POPs Analysis.
Activity 1. Strengthening of Inspectorates for Enforcement of POPs Regulations and Prevention of
POPs stockpiles Accumulation. (US$ 0.25 m, of which GEF US$ 0.19 m) The goal of this activity is to
increase the available human capacities (skills and education) of key Inspectors in Government Agencies
who will be dealing with the enforcement of regulations developed under sub-component 2.1. It will build
a network of Inspectors in different Government Agencies into a cooperative interlinked system along the
lines of the EU Inspectorate Network (IMPEL). This will result in an efficient and transparent
organizational framework for POPs enforcement and extend the knowledge base and introduce consistent
working practices to ensure that scarce resources are used for maximum benefit.
Field inspectors are the main liaison point between most stakeholders and the authorities. In order to
deliver their role effectively, they must gain the respect of the individuals or organisations with whom
they work. The field inspectors must be seen as knowledgeable and fair minded individuals, providing
assistance and advice to their clients during this time of major changes to policies and regulations, as well
as conducting their compliance control functions.
Technical Assistance will be provided under this sub-component to include: preparation of training
materials, preparation of guidelines and other supporting materials, and training on-the-job. Particular
care will be taken to improve coordination between different inspectorates.
Because enforcement of national legislation is the weak OECD set up the EECCA Environmental
Inspectorates Network to tackle this problem. As co-operation and communication between inspectors
from different countries are extremely important, a regional partnership - the NIS Environmental
Compliance and Enforcement Network (NISECEN) - was established to address this issue. The
Network’s long-term objective is to increase the effectiveness of enforcement agencies in the NIS and
promote compliance with environmental requirements. Experience gained in this network will be applied
68
under this project.
In addition IMPEL-TFS experience also will be utilized in the training of Inspectors. IMPEL-TFS is a
network of representatives from enforcement authorities of the Member States and some other European
countries dealing with matters on Transfrontier Shipments of Waste. The IMPEL-TFS network was set up
in 1992 in order to harmonise the enforcement of EU Regulation 259/93 (replacing EC Directive 84/631)
on Transfrontier Shipments of Waste with regard to the supervision and control of waste shipments into,
out of and through the European Union. The aim of the network is to: promote compliance with the EU
Regulation 259/93 through enforcement; carry out joint enforcement projects; and promote exchange of
knowledge and experience with the enforcement of the EU Regulation 259/93.
Activity 2. Upgrading and Strengthening of Existing Laboratories for POPs Analysis. (US$ 1.23 m,
of which GEF US$ 0.47 m) The laboratories of the State Environmental Inspectorate (SEI), Ministry of
Health (MOH) and the Hydrometeorological Service all need upgrading of their analytical capabilities for
POPs detection in different media and to support the regulatory requirements for reporting, management
and control of POPs at national and international levels. The Laboratory of SEI will be upgraded relating
to rapid assessment of PCBs, sampling and reporting. The MOH laboratory will be upgraded to be in the
position to estimate POPs residues in different media, including in food and human materials.
Hydrometeorological Service will be upgraded particularly for detection of PCBs and POPs in water and
soil. Technical Assistance will be provided under this sub-component to include: identification of
equipment needs; specification of instruments for sampling and analysis; specification of standard
methods of analysis; provision of standard samples and analytical supplies; setting up QA/QC procedures,
as well as training of staff.
This activity shall be developed together with the project planed to be financed by NATO, which will
update one of MAFI’s laboratories for identification of POPs pesticides.
Activity 3. Prevention of Accumulation of new Stockpiles of Obsolete Pesticides (US 0.11m, of
which GEF US$0.00). Besides developing new regulations to eliminate or minimize risks to health and
the environment that are stipulated within Component 2, the project will provide support in promoting
best practices in Pest Management in crop production, including Integrated Pest Management (IPM) that
is based on careful integration of a number of available pest control techniques. Furthermore, the project
will also support improvements of pesticides procurement and imports. Training will be provided for
farmers and farmers association, and organized information dissemination campaigns through media,
publishing relevant guides and other information materials. This activity will be implemented within the
forthcoming IDA RISP II project.
COMPONENT 3. INSTITUTIONAL STRENGTHENING AND PROJECT MANAGEMENT SUPPORT. (US$ 2.06,
OF WHICH GEF US$ 1.29 M)
This component of the project consists of two sub-components, namely: (1) Institution Strengthening;
and (2) Project Management Support
Sub-component 3.1. Institutional Strengthening (US$ 1.43 of which GEF US$0.74)
This sub component will strengthen the MENR’s capacity for POPs management. The PMT will serve as
the national focal point for the coordination and management of international obligations under the Basel
and Stockholm Conventions, LRTAP and the Aarhus protocol. The PMT will coordinate these activities
with other government agencies responsible for regulating, managing and controlling POPs and
dangerous substances. The PMT will manage and coordinate implementation of the NIP, improve data
management and reporting in the field of chemicals, support the POPs legal and regulatory framework by
developing operational guides, etc. This component will include the following sub-components which
69
strengthen the capacity of the PMT to manage POPs: (i) POPs Information Management and Reporting
System for POPs (ii) POPs Monitoring Network; (iii) Identification of POPs residuals and Mapping of
Polluted Areas; and (iv) POPs Awareness and Educational Activities.
Activity 1. POPs Information Management and Reporting System. (US$ 0.40 m, of which GEF US$
0.25 m). To be effective, the MENR will develop a unified information reporting and management system
for POPs and other dangerous chemicals and wastes. Under this activity it is proposed to: (i) design this
central management information system, including data base and GIS applications; (ii) install required
hardware and software and train the staff for operation; and (iii) test the information system performance.
Establishing a national reporting framework and procedures will first require the amendment of relevant
legislation. An Instruction for POPs Statistical and Informational Reports will be created to transfer the
legal provisions into a more practical document. A set of specific reporting sheets and formats also will be
prepared. The sources of information will be identified and delivery formats will be proposed. Raw
statistical data which will be processed and reported in agreed formats and schedules to concerned
national and international parties according to agreed reporting obligations. The GRM will ensure that
annual statistical data from relevant agencies (MAFI, DOC, etc), are furnished to the MENR on a regular
basis. The figure below shows how the MIS may operate in practice.
70
POPs and Toxic Substances Management Information System
Websites Interface
Users:
Regulatory
Interface
Line Ministries; Local Authorities,
Enterprises; Institutes; etc.
Applications:
Communication; data
exchange; enforcement; monitoring; etc.
Regulatory and
Management
Database
Users:
Toxic Substances
Inventory Database
MENR, MoH
Applications:
Inventory control;
enforcement; management control
options; health and safety; reporting;
research and development; etc.
International
Convention
Database
71
Activity.2. POPs Monitoring Network. (US$0.17 m, of which GEF US$ 0.11m) The specific
monitoring strategies will be tailored for different POPs groups (i.e., pesticides, PCBs, PCDD/PCDF), for
different purposes (e.g. source, ambient and impacts monitoring) and for various media and components
(water, soil, sediments, biota, agricultural and food production and humans). The objective of his subcomponent is to develop interlinked monitoring networks for POPs within national laboratories in SEI,
MOH, and the Hydrometeorological Service, as well as to create a platform for data management and
exchange. The proposed monitoring system will be tailored to the needs identified above for reporting at
national and international levels and will be tested in the pilot regions and scaled up to national level as
appropriate. An important aspect will be the analytical needs for developing and maintaining an inventory
of POPs sources.
Activity 3. Identification of POPs Residuals and Mapping of Polluted Areas. (US$ 0.23m, of which
GEF US$0.19m) In Moldova there are about one thousand areas which are polluted with POPs,
particularly around destroyed warehouses and depots for temporary storage of obsolete and banned
pesticides. This project will not be involved in the remediation of these polluted areas. However, it is
important from a public health and environmental management perspective that these sites be identified,
mapped and as necessary access restricted until they are remediated, or are shown to be safe for public
access or other beneficial uses. This activity will support a research effort by local institutes to identify,
characterize and perform a risk assessment of these sites for decisions on future management options.
Activity 4. POPs Awareness and Educational Activities (US$ 0.62 m, of which GEF US$0.19 m) In
compliance with Article 10 of the Stockholm Convention, the Republic of Moldova has a commitment to
build awareness regarding POPs problems with decision-makers, and to raise awareness in the general
population. A survey of public perception in respect to POPs in several rural localities and in the city of
Chisinau during project preparation revealed a lack of understanding of problems related to POPs and
other dangerous chemicals. The survey also revealed very limited knowledge regarding POPs sources and
effects within groups with a high risk of POPs exposure, such as: farmers, industry employees, staff of the
power and heat generating and distributing companies, and units responsible for collection and disposal of
waste. The goal of this activity is to create a communications framework for POPs and other chemicals
and to improve awareness of the Moldovan public regarding POPs sources and effects through awareness
building activities, as well as training and education of target groups with higher exposure to risks.
The following tasks are intended to support the activities proposed under Component 2: (i)
development/upgrade of the project's home page; (ii) development of brochures, books and leaflets; (iii)
organize videoconferences, TV and radio program; (iv) inception and national implementation workshops
(4 workshops, one per year); (v) international workshop for information dissemination; (vi) strengthening
of the environmental information centre for POPs information dissemination; (vii) promotion of research
and development on POPs issues; and (viii) increasing of awareness of Unintended POPs Release
Sources.
Sub-component 3.2. Project Management Support. (US$ 0.64m, of which GEF US$ 0.55 m)
A project management team (PMT) will carry out the usual project management functions of financial
management, procurement, auditing, managing, monitoring and evaluating project implementation, and
dissemination of project results. The PMT is already operational having been set up under the GEF
supported NIP preparation and has been further supported by a GEF PDF B Grant for the preparation of
this project. The Unit has established its financial management system, which has been audited by the
Bank’s FM Specialist as noted in Annex 7. The deficiencies noted in this audit have since been rectified
72
by the PMT. The PMT includes a Project Manager, an assistant, a procurement specialist and a part-time
financial management/ disbursement specialist.
The PMT staff will remain the same under
implementation.
73
Annex 5: Project Costs Base (no contingencies included)
MOLDOVA: Persistent Organic Pollutants (POPs) Management and Destruction Project
GEF
Local
Foreign
Total
Million
Million
Million
Million
(US $)
(US $)
(US $)
(US $)
Sub-Component 1.1: Destruction of Stockpiles 1.152
of POPs Containing and
Contaminated
Obsolete Pesticides
2.380
1.661
5.193
1. Repackaging obsolete pesticides and storing in
37 centralized warehouses
2. Repackage in leased IBC containers and 1.000
destruction in a disposal facility in another
country
0.780
0.601
1.381
1.600
1.060
3.660
Project Cost By Sub-Component and Activity
3. Supervising Consultancy
0.152
Sub-Component 1.2: Management of PCBs and
Destruction of Obsolete Capacitors Stockpiles
2.461
1. Development of a national PCB inventory
0.264
2. Dismantling and packaging obsolete capacitors 1.724
and contaminated soil in leased IBC containers
and destruction in disposal facility
0.152
0.262
2.723
0.192
0.456
0.020
1.744
3. International transport to disposal facility
0.161
0.161
4. Supervising Consultancy
5. Feasibility study for clean up of PCB
contamination at the Vulcanesti substation
Sub-Component 2.1: Modification of the
Regulatory Framework
1. Revision and gap analyses of the existing
legislation regarding the compliance with EU
regulation
2. Assistance in drafting relevant regulations and
instructions
3. Development of regulatory mechanisms
Sub-Component 2.2: Capacity Building for
POPs Management
0.084
0.084
1. Strengthening
of
Inspectorates
Enforcement of POPs Regulations
2. Upgrading
and
strengthening
laboratories for POPs analysis
0.228
0.050
0.278
0. 580
0.120
0.700
0.200
0.040
0.240
0.200
0.040
0.240
0.200
0.040
0.240
0.630
0.360
for 0.180
0.060
existing 0.450
0.200
3. Strengthening of Inspectorates for
0.1
74
0.5433
1.533
0.240
0.543
1.193
0.1
GEF
Local
Foreign
Total
Million
Million
Million
Million
(US $)
Enforcement of POPs Regulations and
Prevention of POPs stockpiles Accumulation
Sub-Component 3.1: Institution Strengthening 0.705
and project management support
(US $)
(US $)
(US $)
0.340
0.330
1.375
1. Management information and reporting system
2. Developing strategies and coordinating POPs
monitoring network
3. Identification of POPs residuals and mapping
of polluted areas
4. POPs awareness and educational activities
including free access to information
0.240
0.140
0.380
0.105
0.060
0.165
0.180
0.040
0.220
0.180
0.100
0.522
0.083
0.605
1. PMT staff
0.242
0.048
0.290
2. Incremental/Operating Costs
0.240
0.030
0.270
3. Audit, Monitoring and Evaluation
0.040
0.005
0.045
Total Baseline Cost
6.050
3.545
Project Cost By Sub-Component and Activity
Sub-Component 3.2:
Support
0.330
0,610
Project Management
3.534
12.129
Physical Contingencies
0.15
0.089
0.239
Price Contingencies
0.15
0.089
0.239
Total Project Costs1
6.350
3.722
Total GEF Financing Required
6.350

#
To be identified
1
No taxes or duties are included in the cost estimates
75
2.534
12.60
Annex 6: Implementation Arrangements
MOLDOVA:
SUSTAINABLE PERSISTENT ORGANIC POLLUTANTS STOCKPILES
MANAGEMENT
OVERALL PROJECT IMPLEMENTATION ARRANGEMENTS
MENR has been designated as the national lead implementing agency for all POPs activities and
implementation of the POPs Convention. All the major national and local government, scientific
institutions, and private sectors that are concerned with the elimination of POPs in Moldova will be
involved in project implementation, and many have already been involved in its initial preparation. The
responsibilities of each stakeholder are described as follows.
National Coordinating Committee (NCC) for Implementation of the Stockholm Convention. A
National Coordination Committee, with MENR as the lead agency, was established to provide overall
guidance and coordination for the POPs National Implementation Plan development. This Group has
become the NCC for implementation of the Stockholm Convention. The NCC will provide overall
guidance to: (i) review significant policies related to POPs; (ii) oversea implementation of the NIP; and
(iii) act as steering committee for implementation of this GEF project. The NCC consists of
representatives of the following agencies:









Ministry of Environment and Natural Resources (MENR);
Permanent Parliamentary Commission for Ecology and Territorial Development;
Ministry of Finance;
Ministry of Agriculture and Food Industry (MAFI);
Ministry of Industry and Infrastructure (MOII);
Ministry of Health (MOH);
Academy of Sciences (AS);
National Institute of Ecology
NGO “INQUA-Moldova” (INQUA Moldova represents civil society. It’s president is on the
NCC).
International Implementing Agency. The World Bank was invited as the international implementing
agency for the project. The World Bank will be responsible for supervising implementation of all project
activities specified in this project document along the lines of the following:
a. Supervising overall project progress;
b. Carrying out supervision missions;
c. Helping Moldova to set up an operating mechanism to allow effective and transparent
implementation of the project;
d. Ensuring that disbursements made to Moldova are based agreed disbursement procedures;
e. Vetting the financial management system of the project to ensure that it complies with
international standards of accounting;
f. Ensuring that procurement arrangements are carried out based on agreed procurement procedures;
g. Providing Moldova with the necessary policy, management and technical support; and
h. Reporting to GEF on the project progress.
National Implementing Agency. MENR will be the national implementing agency for the project. Its
responsibilities will include (1) assignment and supervision of project activities; (2) providing direction to
the local PMT; and (3) coordination with stakeholders, including GEF, donors, IAs, and relevant domestic
ministries and agencies.
76
Project Management Team (PMT). The PMT will carry out the usual project management functions of
financial management, procurement, auditing, managing, monitoring and evaluating project
implementation, and dissemination of project results. The PMT is already operational having been set up
under the GEF supported NIP preparation and has been further supported by a GEF PDF B Grant for the
preparation of this project.
Convention Focal Point (CFP). The CFP will be responsible for day-to-day compliance with the
Stockholm Convention. CFP’s responsibilities include (1) providing technical support to international
negotiations and policy studies on the Stockholm Convention, (2) providing support to the development
and implementation of corresponding policy and regulations, as well as coordinating with key
governmental stakeholders, (3) screening, preparing and implementing Convention activities, (4) raising
co-financing (bilateral and domestic) for international collaborative programs, (5) preparing and
submitting funding withdrawal applications to the Bank, and (6) collecting data and information,
preparing reports and organizing training, education, and information dissemination activities.
IMPLEMENTATION ARRANGEMENTS FOR DISPOSAL OF POPS CONTAMINATED OBSOLETE
PESTICIDES SUB-COMPONENT 1.1
Ministry of Agriculture and Food Industry. MAFI is responsible for the management and safe disposal
of the stocks of obsolete and banned pesticides. It has contracted with the MOD and DES to repackage,
transport and store the repackaged pesticides in 37 centralized warehouses. The process of consolidating
this stockpile and collecting the highly contaminated soil and waste from the original storage places has
greatly facilitated the next phase of the process of disposal of this stockpile which will be supported under
this GEF project. MAFI will be responsible for managing the implementation of this sub-component’s
activities, including overseeing the work of the PCB Destruction Contractor and the Supervising
Consultant Company which is monitoring and reporting on the work of the Contractor.
International Supervising Consultant Company. An international consulting company will be selected
to assist MAFI in the supervision of the international contractor that will be repackaging the obsolete
pesticides and waste in ICB containers and transporting them to a hazardous waste treatment facility in
another country for final destruction. The Supervising Consultant will monitor and evaluate the
performance of the contractor to ensure that it complies with the conditions of the contract and will verify
the accuracy of the contractor’s tracking system and reporting on quantities handled and destructed.
PMT. The PMT will be responsible for assisting MAFI in the selection of the obsolete pesticides
destruction Contractor and Supervising Consultant and in all matters relating to their contracts.
International Contractor for Packing, Transport and PCB Disposal. An international hazardous
waste treatment company will be selected for planning and implementation of the packing of the drums of
obsolete pesticides in IBC containers, transport to the destruction facility and final destruction of the
pesticide waste.
77
Figure 1. Implementation Arrangements for the Disposal of POPs Containing and Contaminated
Obsolete Pesticides Sub-Component 1.1.
National Coordinating
Committee for POPs
GEF/World Bank
Ministry of Ecology and
Natural Resources PMT
Ministry of Agriculture
and Food Industry
International
Supervising
Consultant
International Pesticides
Destruction Contractor
78
IMPLEMENTATION ARRANGEMENTS FOR CARRYING OUT THE PCB INVENTORY –
SUB-COMPONENT 1.2, ACTIVITY 1
PMT/MENR The PMT under the MENR has the overall responsibility for supervising the preparation of
appropriate regulations and guidelines and for the implementation of the PCBs inventory. The inventory
will be undertaken by sending questionnaires directly from the PMT to the potential holders of the
equipment, which reply directly to the PMT. Future reporting from the holders (e.g. on management plans
and changes in amount hold) will similarly go directly from the holders to the PMT. The PMT will
coordinate with the hazardous waste unit within the MENR in order to develop the future PCB
management system as an integrated part of the general hazardous waste management system of
Moldova.
State Ecological Inspectorate. The State Ecological Inspectorate will be responsible for the analysis of
transformer oils sampled by the holders of equipment in the industry using the test kits and advising the
holders of the equipment on sampling methods to the extent necessary. For the enforcement of the PCBs
regulation the inspectorate will, in cooperation with the PMT, prepare plans for PCBs inspection and
undertake control tests of transformer oils in approximately 10% of the transformers held by the industry.
In cooperation with the PMT, the State Ecological Inspectorate will arrange a training workshop for
selected inspectors.
Holders of equipment. The identification of the PCB-containing equipment, oil sampling, notification
and labeling is, in accordance with the proposed regulation, the responsibility of the holders of equipment.
Further, holders of PCB-containing equipment have the responsibility of preparing management plans and
to notify the relevant authorities of any changes in the amount of such equipment which they hold. The
holders will be informed about their duties and receive guidelines in PCB identification, notification,
labeling and management. The potential holders include power plants, power distribution companies,
industrial companies, waste waster treatment plants, army units, universities, etc.
Hazardous waste undertakings. Hazardous waste undertakings will also have the obligation to report on
the amount of PCBs and PCB-containing equipment they hold. The rationale of the PCB/PCTs Directive
it that is should be possible to track each piece of equipments until it is finally destructed. No hazardous
waste undertakings currently are licensed for management of PCB-containing waste in Moldova, but a
license system will be developed as part of the implementation of the PCBs regulation.
Ministry of Industry and Infrastructure. The training of personnel of Moldelectrica, the state owned
power transmission company, and the power distribution companies will be included in an inventory plan
prepared in cooperation between the PMT and the Ministry of Industry and Infrastructure.
State Hydrometeorological Service. The State Hydrometeorological Service will in cooperation with the
PMT be responsible for analysis of PCBs in transformer oils having concentrations >50 ppm as
determined by the use of test kits.
International Consulting Company. In order assist and build up the capacity of the PMT, the
Hydrometeorological service, energy companies, State Ecological Inspectorate and other stakeholders an
international environmental consulting company with relevant expertise will be selected under this
activity. The company will select and fully involve in its activity a local company in order to build
national capacity in this regard.
79
Figure 2. Proposed Implementation Arrangements for the PCBs Inventory.
National
Coordinating
Committee for
POPs
GEF /
MENR - PMT
World Bank
Ministry of
Industry and
Infrastructure
Moldelectrica
International
Consulting
Company
Power Plants and
Distribution
Companies
State
Hydrometeorological
Service
Unionfenosa
Consumers of
electricity:
Industry,
Institutions,
Water Treatment
State Ecological
Inspectorate
Plants, hospitals,
etc.
80
INSTITUTIONAL ARRANGEMENTS FOR DESTRUCTION OF OBSOLETE CAPACITOR STOCKPILES AND
FEASIBILITY STUDY FOR CLEAN UP OF THE VULKANESKI SITE - SUB-COMPONENT 1.2, ACTIVITIES 2
AND 3
Ministry of Industry and Infrastructure and "Moldelectrica". The PCB-containing capacitors and
substations concerned in Component 1.2 belong to Moldelectrica, a state-owned company under the
Ministry of Industry and Infrastructure. Moldelectrica will be responsible for managing the
implementation of this sub-component’s two activities, including overseeing the work of the PCB
Destruction Contractor and the Supervising Consultant Company, which is monitoring and reporting on
the work of the Contractor, and is carrying out the feasibility study.
International Supervising Consultant Company. An international consulting company will be selected
to assist Moldelectrica in the supervision of the international destruction Contractor in the dismantling
and disposal of the obsolete capacitors in the substations. The Supervising Consultant will monitor and
evaluate the performance of the contractor to ensure that it complies with the conditions of the contract
and will verify the accuracy of the contractor’s tracking system and reporting on quantities handled and
destructed. Further, the company will be responsible for undertaking the feasibility study for the clean up
of PCB contamination at the Vulcanesti site in close cooperation with Moldelectrica, and provide advice
as to the procedures for excavating the capacitors from the pits.
PMT. The PMT will be responsible for assisting Moldelectrica in the selection of the PCB destruction
Contractor and Supervising Consultant and in all matters relating to their contracts..
International Contractor for Packing, Transport and PCB Disposal. An international hazardous
waste treatment company will be selected for planning and implementation of the dismantling and
packing of the capacitors, excavation of capacitors, transportation to the destruction facility and final
destruction of the capacitors. The contractor will select and fully involve in its activity a local company in
order to build national capacity in this regard.
State Hydrometeorological Service. The State Hydrometeorological Service will be responsible for
sampling and analysis of PCBs in soil and groundwater. For groundwater monitoring the State
Hydrometeorological Service will make arrangements with the State Geological Association "AGeoM"
for drilling of wells. Samples for analysis of PCDD/PCDFs will be taken by The State
Hydrometeorological Service under supervision of international laboratory selected for the PCDD/PCDF
analysis. The State Hydrometeorological Service will further cooperate with the Supervision Consultant
on the feasibility study’s risk assessment of the site in order to build up capacity in risk assessments and
PCB clean-up and remediation techniques in Moldova.
81
Figure 3. Proposed Arrangements for Implementation of Subcomponent 1.2 – Destruction of
Obsolete Capacitor Stockpiles and Feasibility Study for PCB Clean-up of Vulcanseti Site
National Coordinating
Committee for POPs
MENR - PMT
GEF/
World Bank
Ministry of Industry and
Infrastructure
International
Supervising and
Feasibility Study
Consultant
Moldelectrica
State Geological
Association “AGeoM”
International PCB
Disposal Contractor
State
Hydrometeorological
Service
82
IMPLEMENTATION ARRANGEMENTS FOR THE REGULATORY AND INSTITUTIONAL STRENGTHENING
COMPONENT
Implementation of Sub-Component 2.1 - Modification of the Regulatory Framework for POPs – will be
managed and supervised by the PMT as it will involve different departments in MENR as well as MOH,
MAFI, MOII, etc. However the MENR will be the main ministry involved in preparing these legal
instruments and instructions. The PMT will also take the lead in implementing Sub-Component 2.2 Institutional Capacity Building for POPs Management. The other main organizations involved in
implementing this sub- component will be the inspectorates and laboratories in MENR, MoH and MAFI
and the Hydrometeorological Service Laboratory. The NATO project will provide POPs analytical
equipment and training to one of the MAFI laboratories. This GEF project will provide POPs laboratory
equipment and training to SEI’s National Laboratory, The Hydrometeorological Laboratory and the
National Center for Preventive Medicine in MOH. Inspectorates in SEI, MOH and MAFI will also be
strengthened for POPs management, monitoring and control.
The State Ecological Inspectorate (SEI), a subdivision of the Ministry of Ecology and Natural
Resources, is responsible for monitoring the implementation of environmental regulations at the local
level, as well as compliance control and laboratory investigations. Its functions are performed through its
territorial subdivisions: Ecological Agencies Center, Fishery Inspection and other specialized control
services.
The SEI is in charge of compliance monitoring and pollution control. The main focus of the SEI is
analysis of pollutants in discharges and in the environment in the vicinity of pollution sources. The
Inspectorate has six certified laboratories (one central and five regional) with skilled staff. However, an
evaluation of laboratory capabilities undertaken in 2002 in the framework of the World Bank
Environmental Compliance and Enforcement Capacity Building Project revealed that the analytical
instrumentation in all laboratories is extremely obsolete and none of them is equipped for adequate
analyses of organic micro-pollutants (which include the POPs) in water, air and soil samples. Since the
laboratories do not participate in the national/international inter-laboratory comparisons, the quality
assurance/quality control issues are of concern6. A modern gas chromatograph with FID and ECD
detectors was recently supplied to the central laboratory in Chisinau in the framework of the mentioned
project, increasing its capability for high-precision measurements of POPs pesticides and PCBs. In 20022003, the SEI undertook a survey of old pesticides storehouses and investigated the level of
contamination of adjacent areas with organochlorinated pesticides including DDT, in the Dniester River
basin.
The State Hydrometeorological Service (HMS) monitors background air, water and soil quality to assist
in the formulation of pollution control measures. It has certified laboratories for water and soil analyses
which regularly participate in international quality assurance and quality control schemes. The HMS is
running programs of pesticide monitoring in soil and water. The most comprehensive program involved
the investigation of DDT and DDE residues in soil starting from 1979. The results showed a clear
downward trend after the peak was reached in the 1980s. The same tendency has been recorded in the
surface waters. The HMS has a comprehensive network of sampling stations covering all major water
courses and water bodies and monitoring a range of some 35 parameters including DDT and other
6
Upgrading Compliance Monitoring Capabilities of the State Ecological Inspectorate. Final Report. June 2002.
Environmental Compliance and Enforcement Capacity Building Project, The World Bank.
83
pesticides. Water quality reports are sent regularly to national authorities and also to the Secretariat of the
Danube Protection Convention. In the same time, air monitoring is deficient due to a lack of equipment
for measuring POPs pesticides.
The National Centre for Preventive Medicine. The Ministry of Health is responsible for monitoring
and ensuring compliance with public health requirements at the national and local level, including
monitoring and laboratory analysis. It has subdivisions in each raion, as well as central and local
territorial laboratories. The MOH is responsible for monitoring in relation to human health. The MOH has
an extensive network of regional laboratories in the Centers for Preventive Medicine (CPMs) carrying out
a significant number of analyses of foodstuffs, agricultural soils, air, drinking water and surface waters for
pesticides residues. It is also responsible for occupational health issues related to pesticides use. The
National Center for Preventive Medicine in Chisinau has a fully equipped laboratory with trained staff,
capable of carrying out sophisticated analyses. The laboratory has national certification and its results are
mutually recognized by the health authorities of Russia and Ukraine. Several other CPM laboratories in
the country are also quite well equipped and staffed.
The State Inspectorate for Plant Protection, in the Ministry of Agriculture and Food Industry, is
responsible for the controlling the application of pesticides and fertilizers in agriculture. It has a certified
laboratory and representatives in each raion. The Center for Agrochemical Service of the MAFI has the
technical capacity for POPs pesticides analyses, but these substances are not analyzed on a regular basis
as the Service depends upon demand from interested clients.
PROJECT IMPLEMENTATION PLAN.
The project will be implemented over a period of four years beginning in the first quarter of 2006 through
to the end of the final quarter of 2009. However, since most of the activities will be concentrated in the
first three years only this part of the implementation plan is shown in the Implementation Table below.
The fourth year’s program will mainly consist of project wrap up activities including evaluating the
results of the project preparing implementation completion reports and lessons learned and finalizing
disbursements and project financial audits. The proposed implementation schedules for the three
components of the project are given in the following figures 4-6.
84
Figure 4. Implementation Schedule for Destruction of Stockpiles of POPs Contaminated Obsolete Pesticides - Sub-Component 1.1
2005
Project Sub-Component 1.1
2006
2007
1
Q
2
Q
3
Q
4
Q
1
Q
2
Q
3
Q
4
Q
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
1
Q
2008
2009
2
Q
3
Q
4
Q
1
Q
2
Q
3
Q
4
Q
1
Q
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
XX
Destruction of Stockpiles of POPs
Containing and Contaminated Obsolete
Pesticides
Repackaging of obsolete pesticides and
storing in centralized warehouses
Preparation of bidding documents for
international contractor for pesticide and
capacitor destruction
Prequalification of international
contractor
Tendering process for international
contractor
Selection of international contractor and
mobilization
Repackage of drums of pesticides in IBC
containers
International transport of IBC containers
to disposal facility for disposal
Destruction of pesticides at hazardous
waste facility
Preparation of RfP for International
Supervising Consultant contract
Tendering process for International
Supervising Consultant contract
Selection of Supervising Consultant and
mobilization
X
X
X
X
X
X
X
X
X
X
X
X
85
X
X
2010
2
Q
3
Q
4
Q
2
1Q Q
3
Q
4
Q
Figure 5. Implementation Schedule for Management of PCBs and Destruction of Obsolete Capacitor Stockpiles – Sub-Component 1.2
Project
Sub2005
Component 1.2
2006
2007
1Q 2Q 3Q 4Q 1Q 2Q 3Q 4Q
Management
of
PCBs
and
Destruction
of
Capacitor Stockpiles
Activity 1. Inventory
of PCB Containing
Equipment
Tendering
selection
and mobilization of
International
Consultant
Preparation
of
guidelines, forms and
list of holders
Undertaking
the
inventory, preparation
of MIS and database
Compiling
and
reporting
Preparation
of
guidelines
for
management of PCBs
Preparation of PCBs
management plan for
Moldova
Training workshops for
SEI Inspectors
Activity
2,
Destruction
of
Obsolete Capacitors
Tendering, selection
and mobilization of
International
Supervising
2008
2009
2010
1Q 2Q 3Q 4Q 1Q 2Q 3Q 4Q 1Q 2Q 3Q 4Q 1Q 2Q 3Q 4Q
XX XX XX
XX XX
XX
XX XX XX XX XX XX XX XX XX XX XX XX XX
XX XX XX XX XX XX XX XX XX XX XX XX
XX XX
XX XX XX
XX
XX XX XX XX
86
Consultant
Tendering
selection
and mobilization of
International
Contractor
Site preparation and
training
Dismantling, shipment
and final disposal of
capacitors
by
Contractor
Excavation
of
Vulcanesti pits
Activity 3, Feasibility
Study of PCB Clean
up
at
Vulcanesti
Sub-station
Project mobilization
Pre-excavation
analysis
and
assessment
Post-excavation
analysis
Mapping
of
PCB
contamination
Site
environmental
characterization and
risk assessment
Preparation of site
clean-up design
Detailed
work
schedule
for
site
clean-up
XX XX XX XX XX
XX
XX XX XX XX
XX XX XX
XX
XX
XX XX
XX XX
XX XX
XX XX
XX XX
87
Figure 6. Implementation Schedule for Component 2 - POPs Regulatory and Institutional Strengthening, and Component 3 -Institutional
Strengthening and Project Management.
Project Components
2005
2 and 3
2006
2007
2008
2009
2010
Component 2. POPs
Regulatory
Framework
and
1Q 2Q 3Q 4Q 1Q 2Q 3Q 4Q 1Q 2Q 3Q 4Q 1Q 2Q 3Q 4Q 1Q 2Q 3Q 4Q 1Q 2Q 3Q 4Q
Capacity Building
Sub-component 2.1:
Modification
of
Regulatory
Framework for POPs
Gap
analysis
and
revision of the existing
legislation
regarding
EU regulation
Development
of
regulatory
mechanisms
and
administrative
arrangements
for
POPs management
Practical
Guidelines
and Handbooks for
POPs Management
Unified
information
reporting
and
management system
Tendering
and
selection
of
an
international consultant
for Component 2
International
consultant's assistance
in
planning
and
carrying out the work
program and in training
XX XX XX XX XX XX
XX XX XX XX XX XX XX XX XX XX
XX XX XX XX XX XX XX XX XX XX XX
XX XX XX XX
XX XX
XX XX XX XX XX XX XX
88
Sub-component 2.2:
Capacity Building for
POPs Management
Strengthening
of
Inspectorates
Improvement of the
coordination between
different
level
of
authorities,
inspectorates
and
stakeholders
Tendering
of
equipment
and
supplies for upgrading
of existing laboratories
for POPs
Upgrading of existing
laboratories for POPs
Strengthening POPs
monitoring capacity of
Environmental
and
Health Agencies
Training for farmers
and
information
dissemination
regarding
best
practices
in
pest
management
and
prevention of POP
obsolete
pesticides
accumulation
Component
3.
Institutional
Strengthening
and
Project
Management support
Project Management
Tendering
and
mobilization of MIS
XX XX XX XX XX XX
XX XX XX XX XX XX
XX XX XX XX
XX XX XX
XX XX XX XX
X
X
X
X
X
XX XX XX XX XX XX XX XX XX XX XX XX XX XX XX XX XX
XX XX XX
89
consultant
POPs
and
Toxic
Substances
Management
Information
System
Development
XX XX XX XX
90
Annex 7: Financial Management and Disbursement Arrangements
MOLDOVA:
PERSISTENT ORGANIC POLLUTANTS (POPS) MANAGEMENT AND
DESTRUCTION PROJECT
Country Issues.
The 2003 Country Financial Management Accountability Assessment (CFAA) in Moldova
concludes that the financial accountability framework in Moldova is weak and requires
substantial strengthening. The key weaknesses identified include (a) budget framework process is
fragmented, (b) inefficient cash management, (c) weak internal control and internal audit, and (d)
inadequate external audits. Thus specific procedures are developed by the project to secure proper
financial accountability. Additional financial management arrangements in the project will
include the audit of project financial statements by independent auditor acceptable to the Bank, in
accordance with audit terms of reference acceptable to the Bank. The audited financial statements
and reports are to be provided to the Bank within six months of the end of each fiscal year and
also at the closing of the project. The project will also produce a full set of Financial Monitoring
Reports (FMRs) every quarter throughout the life of the project.
Strengths and Weaknesses.
The significant strengths that provide a basis of reliance on the project’s financial management
system include: (i) the simple funds’ flow and centralized financial management arrangements;
and (ii) the experience of the project’s accountant in implementing Bank-financed projects and
satisfying Bank financial management requirements.
There are no significant weaknesses of the project’s financial management system.
Implementing Entity.
The project implementation unit (PMT), which already has been established under the Ministry of
Ecology and Natural Resources (MENR) to implement the NIP and prepare this project under a
GEF PDF-B grant would be responsible for the financial management aspects of the Project.
The Grant Agreement for the project would be signed between the World Bank and Moldova,
represented by the Ministry of Finance (MoF). A subsidiary agreement would be signed between
MoF and MoENR.
Funds Flow.
Project funds will flow in respect of each of the sources of project financing as follows:
(i)
the GEF grant, by direct payments or via the Special Account (SA), which will be replenished on
transactional methods using Statements of Expenditure; and
(ii) Government counterpart contribution, via dedicated Treasury project accounts.
A Special Account will be opened at a commercial bank and on terms and conditions acceptable
to the Bank. Foreign currency amounts will be exchanged as needed in local currency (MDL), to
91
cover eligible expenditures payments in local currency to suppliers, from the Special Account
into a local currency transfer account that will be opened at a commercial bank and on terms and
conditions acceptable to the Bank. This arrangement is already in place for the Project
Preparation Grant (GEF PPG PDF B - TF 53700), on which disbursements started in February
2005 and for which the SA is opened at a commercial bank acceptable to the Bank. Subject to
satisfactory performance, the PMT intends to use the same commercial bank for keeping the SA
for the main GEF project.
Government counterpart contribution payments will be made from a separate Treasury project
account, which will be used specifically for the counterpart contributions to the project. These
contributions will be received monthly in accordance with normal budget procedures, as is
already the case for the GEF PPG.
Staffing.
The PMT includes a part time accountant. The accountant has good experience of implementing
Bank-financed projects and has demonstrated that he is fully capable of fulfilling the financial
management needs of the project, as shown during the previous years worked on another WBfinanced project. The accountant position may have to be converted to full time for the main
project, in view of the increased workload level.
Accounting Policies and Procedures.
The project’s accounting books and records will be maintained on a cash basis and denominated
in Moldovan Lei (MDL), with the exception of the books and records in respect of the Special
Account, which will be maintained in the US dollars.
The PMT will build upon the existing accounting procedures and internal controls to ensure that
all project procedures and controls are adequately documented, contract monitoring and invoice
payment procedures are in place. Accordingly, a project accounting procedures manual was
developed and found satisfactory to the Bank (July 2005).
2. Audit Arrangements
Internal Audit.
No reliance would be placed on the internal audit function for this project.
External Audit.
As of the date of this report, the Borrower is in compliance with its audit covenants of the Bankfinanced projects. The Project will be audited annually both by an audit firm and on audit terms
of reference acceptable to the Bank. The terms of reference for the audit have been prepared and
found satisfactory to the Bank. They will be attached to the minutes of negotiations. The audit
scope will include the project’s books and records as maintained by the implementing unit, all
withdrawal applications, and the Special Account. The audited project financial statements
together with the auditor’s opinion thereon will be provided to the Bank within six months of the
end of the reporting period, being the fiscal year.
In addition, the Moldovan Court of Accounts (CoA), the country’s supreme audit institution, will
continue to perform ad hoc external audits of the implementing entity, including of this project.
92
3. Disbursement Arrangements
Bank funds will be disbursed either as direct payments, or to the Special Account which will be
replenished under the transactional disbursement procedures. Withdrawal applications for the
replenishments of the SA will be sent to the Bank monthly, or when about equal to a third of the
initial deposit in the SA has been utilized, whichever comes first. All replenishments for
transactions above the prior-review threshold will be fully documented.
Supporting
documentation for all transactions, including completion reports, goods received noted and
acceptance certificates will be retained by the implementing entity and made available to the
Bank during project supervision. There is no plan to move to forecast-based periodic
disbursements.
4. Reporting and Monitoring
Project management-oriented Financial Monitoring Reports (FMRs) will be used for project
monitoring and supervision. The project management team will produce the project’s FMRs
every calendar quarter and the reports will be submitted to the Bank within 45 days after the
calendar quarter-end. The formats of the FMRs and financial reports were agreed upon June 30,
2005, and will be attached to the minutes of negotiations.
5. Information Systems
The PMT is currently using excel spreadsheets for the accounting and reporting under the GEF
PPG TF. The PMT considers purchasing an accounting software system for the main project. To
this end, the software provider will be requested to perform a limited customization of an ‘off the
shelf’ accounting system, so that project-specific accounting ledgers will be created to allow the
PMT to record accurately the project operations, by each source of funding, by disbursement
categories and by project components, sub-components and activities, using the statutory chart of
accounts customized. The PMT will start the selection of the accounting software provider by
November 30, 2005, to start using the accounting software for the main project in 2006.
6. Action Plan (Agreed with Borrower)
The following action plan was agreed upon with the PMT:
PMT to prepare for the GEF PPG the first quarterly reports for Q1, Q2, and Q3 of 2005 in the
simple format provided by the end of the last month of each quarter of 2005, and quarterly
thereafter within 45 days after each quarter’s end:
PMT to prepare the draft financial management and accounting procedures manual, based on the
summary provided of suggested contents of such a manual by June 15, 2005 (Done)
PMT to document the monthly reconciliation of project accounting records with WB client
connection disbursement records – on a continuing basis
PMT to agree with the Bank and the FMRs format for the main project by June 30, 2005 (Done)
PMT to agree with the Bank on the audit terms of reference by September 30, 2005 (Done)
93
WB FMS to revisit the project FM arrangements and confirm acceptance by July 15, 2005 (Done)
7. Supervision Plan
During project implementation, the Bank will supervise the project’s financial management
arrangements in two main ways: (i) review the project’s quarterly financial monitoring reports
(FMRs), as well as the project’s annual audited financial statements and auditor’s management
letter; and (ii) during the Bank’s supervision missions, review the project’s financial management
and disbursement arrangements (including a review of a sample of withdrawal applications and
movements on the Special Account) to ensure compliance with the Bank's financial management
requirements.
94
Annex 8: Procurement Arrangements
MOLDOVA: PERSISTANT ORGANIC POLLUTANTS (POPS) MANAGEMENT
AND DESTRUCTION PROJECT
General
Procurement for the proposed project would be carried out in accordance with the World
Bank’s "Guidelines: Procurement under IBRD Loans and IDA Credits" dated May 2004;
and "Guidelines: Selection and Employment of Consultants by World Bank Borrowers"
dated May 2004, and the provisions stipulated in the Legal Agreement. The various
items under different expenditure categories are described in general below. For each
contract to be financed by the Loan/Credit, the different procurement methods or
consultant selection methods, the need for pre-qualification, estimated costs, prior review
requirements, and time frame are agreed between the Borrower and the Bank in the
Procurement Plan. The Procurement Plan will be updated at least annually or as required
to reflect the actual project implementation needs and improvements in institutional
capacity.
Procurement of Technical Services: Technical Services procured under this project
would include one large ICB technical services contract for the destruction of POPs
contaminated obsolete pesticides stockpiles and obsolete stockpiles of PCB containing
capacitors. The technical services would be carried out by a contractor which operates or
has access to a hazardous waste treatment facility meeting international environmental
and health and safety standards. The contractor would be responsible for dismantling the
capacitor batteries at 20 Moldelectrica substations, packing them in IBC containers and
transporting them to its hazardous waste treatment facility for final destruction. Likewise,
the contractor would repackage the drums and sacks of obsolete pesticides stored in 37
centralized warehouses in Moldova into IBC containers and transport them to this waste
disposal facility for final destruction. The procurement will be done using the Bank’s
Sample Bidding Documents (SBD) for Works contract. Prequalification of the
prospective bidders will be carried out prior to invitations to bid are issued.
Procurement of Works: Works procured under the project would include an NCB
contract for the rehabilitation of Storage Warehouse for contaminated obsolete pesticides.
The procurement will be done using ECA region’s sample Bidding Document.
Procurement of Goods: Goods procured under this project would include; analytical
equipment and supplies of chemicals, standard gases and other supplies for analytical
laboratories; test kits for PCB detection in transformer oils; computers and office supplies
and one project vehicle. The procurement will be done using the Bank’s SBD for all ICB
goods.
Selection of Consultants: Consultants, will be hired to provide services for: (i)
supervision of the contractor for destruction of obsolete pesticide and capacitor stockpiles
and carrying out the feasibility study for the clean up of PCB contaminated soils at the
95
Vulcanesti substation; (ii) planning and design of the PCB inventory program; (iii) POPs
regulatory and institutional strengthening program; (iv) strengthening of POPs analytical
capabilities and monitoring program; (v) development of the MIS for POPs inventory and
regulatory database; (vi) POPs awareness program; and (vii) assistance to PMT in
strengthening of the PMT. Short lists of consultants for services estimated to cost less
than $ 100,000 equivalent per contract may be composed entirely of national consultants
in accordance with the provisions of paragraph 2.7 of the Consultant Guidelines.
Operating Costs: The operating costs of the PMT covering salaries, office rent, office
supplies, utilities, operating and maintenance expenditures of equipment and vehicles and
fuel among others during the four years of project implementation will be met from the
Credit.
The procurement procedures and SBDs to be used for each procurement method, as well
as model contracts for works and goods procured, will be presented in the Project
Implementation Manual.
B. Assessment of the agency’s capacity to implement procurement
A Project Management Team (PMT) established under the Ministry of Ecology and
Natural Resources (MENR) will have the overall responsibility for project
implementation and coordination including planning, procurement, financial
management, monitoring and evaluation etc. The PMT has gained experience in project
management and implementation, limited to having worked for the implementation of the
previous GEF Grant. The PMT is staffed by a manager, assistant manager, who also acts
as the procurement expert and a part time financial management specialist. In addition to
the existing assistant project manager / procurement specialist, the PMT will hire a part
time procurement consultant. The procurement activities will be under the responsibility
of PMT, which will be strengthened by hiring a part time procurement expert recruited on
competitive basis as individual consultant.
An assessment of the capacity of the Implementing Agency to implement procurement
actions for the project has been carried out by Ahmet Gokce, Sr. Procurement Specialist
in July 2005. The assessment reviewed the organizational structure of MENR for
implementing the project and possible implementation arrangements.
The key issues and risks concerning procurement for implementation of the project have
been identified and include the following:
- At the country level, a comprehensive analysis of the public procurement system in
Moldova was carried out during the Country Procurement Assessment review (CPAR) in
June 2003. The Public Procurement Law was adopted on April 9, 1997. The Public
Procurement Law is being re-written currently by a consultant hired by the Procurement
Agency under an IDF Grant. Moldova was ranked as a high risk country in respect of its
public procurement system in the last Country Procurement Assessment Review (CPAR)
dated June 2003.
96
- PMT has limited experience in implementation of Bank financed project (previous GEF
grant). PMT will hire an additional procurement expert as a part time consultant to
strengthen its procurement capacity. The overall project will be managed by the Project
Implementation Unit (PMT) established in MENR.
The corrective measures which have been agreed are as follows:
- PMT will hire a part time procurement expert to assist the in – house procurement
expert.
- The procurement file containing up to date procurement documents (guidelines,
manuals, templates of procurement notices, standard bidding documents for procurement
of goods and works, standard request for proposal documents for consultants’ services,
evaluation report formats, regional and simplified procurement documents etc.) will be
provided to PMT at the time of Project Launch Workshop. The PMT is recommended to
visit the Bank’s web-site frequently to ensure using the most updated procurement
documents.
- The Project Launch Workshop will have a specific session on Procurement Training for
the PMT staff.
- The procurement staff of the PMT are recommended to attend procurement trainings on
Bank’s procurement procedures given by ILO in Turin and/or by the Bank at the
beginning of the project and will attend additional courses to improve and update their
procurement knowledge.
- Bank procurement specialist will be a member of the project team throughout the
project cycle. During project implementation, the Bank procurement specialist shall be
part of the supervision missions.
The overall project risk for procurement is high risk
C. Procurement Plan
The Borrower, at appraisal, developed a procurement plan for project implementation
which provides the basis for the procurement methods. This plan has been agreed
between the Borrower and the Project Team on July 19, 2005 and is available at the
Project Implementation Unit 9, Cosmonautilor str., office 614a MD-2005, Chisinau, the
Republic of Moldova. It will also be available in the project’s database and in the Bank’s
external website. The Procurement Plan will be updated in agreement with the Project
Team annually or as required to reflect the actual project implementation needs and
improvements in institutional capacity.
D. Frequency of Procurement Supervision
97
In addition to the prior review supervision to be carried out from Bank offices, the
capacity assessment of the Implementing Agency has recommended every six months
supervision missions to visit the field to carry out post review of procurement actions.
98
E. Details of the Procurement Arrangements Involving International Competition
1. Goods, Works, and Non Consulting Services
(a) List of contract packages to be procured following ICB and direct contracting:
1
2
3
4
5
6
7
8
9
10
11
Contract
No.
Contract Description
Estimated
Cost
(million $)
Procurement
Method
Prequalification
(yes/no)
Domestic
Preference
(yes/no)
Review
by Bank
(Prior / Post
Invitation to
Bid/Proposal
Bid/Proposal
Opening
Contract
Award
Contract
Completion
ICB
yes
no
Prior
Apr-06;
(P/Q Jan06)
May-06
Jul-06
Jul-08
0.47
ICB
no
no
Prior
Jul-06
Aug-06
Sep-06
Nov-06
0.08
Shopping
no
no
Prior
Apr-06
May-06
Jul-06
Sep-06
0.01
Shopping
no
no
Post
May-06
May-06
Jun-06
Jul-06
0.04
Shopping
no
no
Post
May-06
May-06
Jun-06
Jul-06
0.05
Shopping
no
no
Post
Jul-06
Jul-06
Aug-06
Aug-06
1. Technical Services
Contract for disposal
TS-1
of obsolete pesticides
and capacitors
4.64
2. Goods
0.65
G-1
G-2
G-3
G-4
G-5
Laboratory equipment
and supplies
PCB Test Kits
Office equipment for
PMT
Project vehicle for
PMT
Office equipment for
chemicals inspectors
& software (39
workstations)
4.64
(b) All ICB goods, works and technical services contracts, first Shopping and all direct contracting will be subject to prior review by the Bank.
2. Consulting Services
(a) List of consulting assignments with short-list of international firms.
.
99
1
2
3
4
5
6
7
8
9
10
11
Contract
No.
Contract Description
Estimated
Cost
(million $)
Procurement
Method
Prequalification
(yes/no)
Domestic
Preference
(yes/no)
Review
by Bank
(Prior / Post)
Invitation to
Bid/Proposal
Bid/Proposal
Opening
Contract
Award
Contract
Completion
0.30
QCBS
no
n/a
Prior
Apr-06
May-06
Jul-06
Jul-09
0.22
QCBS
no
n/a
Prior
Jul-06
Aug-06
Sep-06
Dec-08
0.95
QCBS
no
n/a
Prior
Sep-06
Nov-06
Dec-06
Jul-07
0.24
QCBS
no
n/a
Prior
Oct-06
Dec-06
Jan-07
Jul-07
0.18
QCBS
no
n/a
Prior
Jul-07
Sep-07
Jan-08
Jul-09
0.04
LCS
no
n/a
Prior
Nov-06
Jan-07
Feb-07
May-10
0.19
CQ
no
n/a
Prior
Mar-06
Apr-06
Apr-06
Dec-09
3. Consultant Services
CS-1
CS-2
CS-3
CS-4
CS-5
CS-6
CS-7
Supervision of
disposal of pesticides
and capacitors and
preparation of
feasibility study for
clean up of PCB
contamination at
Vulcanesti substation
Design and technical
assistance for carrying
out the inventory of
PCB contaminated
electrical equipment
Assessment of
existing legislation
and drafting of
regulation,
Instructions for POPs
including relevant
trainings and
workshops
Development of the
MIS for the POPs
inventory and
regulatory database
Identification of POPs
residuals and mapping
of polluted areas
Project Financial
Audits
POPs awareness and
educational activities
including free access
to information
2.16
100
CS-8
CS-9
Technical assistance
to MAFI to
implement the
pesticides destruction
Sub-Component 1.1
(required for 4 years)
Technical assistance
to Moldelectrica to
implement the PCB
management and
stockpiles destruction
Sub-Component 1.2
(required for 4 years)
0.01
IC
no
n/a
Post
Apr-06
May-06
Jul-06
Jul-09
0.03
IC
no
n/a
Post
Apr-06
May-06
Jul-06
Jul-09
(b) Consultancy services estimated to cost above USD 100,000 per contract with firms and USD 50,000 per contract for individuals and single source
selection of consultants (firms) will be subject to prior review by the Bank.
(c) Short lists composed entirely of national consultants: Short lists of consultants for services estimated to cost less than USD 100,000 equivalent per
contract may be composed entirely of national consultants in accordance with the provisions of paragraph 2.7 of the Consultant Guidelines.
101
Annex 9: Economic and Financial Analysis
MOLDOVA:
PERSISTENT ORGANIC POLLUTANTS (POPS) MANAGEMENT AND
DESTRUCTION PROJECT
This GEF supported project is essentially contributing to local and global public good by reducing the
risk of contaminating the environment through releases of POPs. Typical economic or financial analysis
is thus difficult and problematic at best. While it may be theoretically possible to apply cost-benefit
analysis to the process, the lack of reliable base data and the controversial aspects related to the valuation
of human life make such an analysis impractical. It is nonetheless clear that the benefits from reducing
damage to the environment and to human health from releases of POPs will substantially exceed the costs
associated with implementing this project. In addition, the project seeks maximum cost-effectiveness in
all of its interventions, and has used maximum risk reduction as the criterion to prioritize among the POPs
activities being addressed.
Please refer to Annex 15 for Incremental Cost Analysis.
102
Annex 10: Safeguard Policy Issues
MOLDOVA:
PERSISTENT ORGANIC POLLUTANTS (POPS) MANAGEMENT AND
DESTRUCTION PROJECT
A.
Project Background
The use of pesticides and other chemicals, toxic to both human health and the environment, grew
dramatically during the last 40 years in Moldova. Due to poor management practices and the imposition
of bans in the use of particular chemicals, Moldova has accumulated over the years large amounts of
PCBs and obsolete pesticides, in particular POPs7. This poses a serious threat to human health, the local
and global environment. These substances possess toxic characteristics, are persistent, accumulate in the
tissues of most living organisms and are likely to cause adverse human health or environmental effects
near to and distant from their sources.
The total current amount of obsolete pesticides in Moldova is estimated at 6,940 tons, including about
3,940 tons buried at a pesticide dump in the South of the country and 3,000 tons stored in over 300 poorly
equipped or unfitted facilities which lack proper monitoring and security. On the other side, about 20,000
PCB-containing power capacitors are stockpiled at 20 electrical substations all over the country. The total
PCB content in these capacitors is estimated at 380 tons, while the total weight of the capacitors is
approximately 1,060 tons. The power capacitors are situated outdoors and PCBs leak from corroded
equipment to the soil below the capacitor batteries. The investigation of soil quality in the vicinity of
obsolete pesticides and PCBs stockpiles showed varying degrees of environmental contamination posing
problems of occupational health and endangering the public health at large.
Moldova has severe public health and environmental problems linked to the intensive use of pesticides in
the past. The existence of obsolete (including POPs) pesticides stockpiles and lack of remediation are a
continuous threat to the health of thousands of people. Poverty and ignorance push the local inhabitants
e.g. to dismantle the old pesticide stores for construction materials, to use the proximal (contaminated)
lands for crop production or grazing the cattle. Long-term exposure to POPs in such ways is likely to
produce insidious chronic effects and irremediably affect people’s health. Besides direct health effects,
this may have notable impacts on the economy of rural regions by undermining the opportunities for
organic agriculture and the export potential of food products, thus affecting the income of small farmers
and the rural poor.
The Government of Moldova acknowledges that elimination of POPs will serve the long-term interests of
public health, environment, and economic development of the country. In October 2004, the POPs
National Implementation Plan was approved8 aiming to provide a framework and management options
and measures in order to meet the obligations taken by Moldova by joining the Stockholm Convention on
Persistent Organic Pollutants and to reach the national objectives and priorities regarding the POPs. The
Government initiated repackaging of obsolete pesticides and their storage in a limited number of sites
under more controlled conditions. Repackaging all obsolete pesticides in the country is expected to be
finalized by the end of 2005. These activities provide an immediate short term solution to the current
situation where pesticides are widely dispersed and present a serious environmental and health hazard. At
the same time, the national authorities do not have capacity to handle the problem of PCBs in power
7
POP-pesticides as addressed under the Stockholm Convention are: aldrin, dieldrin, endrin, chlordane, heptachlor,
DDT, mirex, hexachlorobenzene and toxaphene.
8
Government Decision No. 1155 of 20.10.2004 on the approval of the National Strategy and the National
Implementation Plan for the Stockholm Convention on persistent organic pollutants.
103
equipment present at a number of sites. The Government of Moldova formulated a request to the GEF to
assist in providing a more sustainable solution to the POPs problem thus helping the country to comply
with its obligations under the Stockholm Convention. On the basis of this demand, the Moldova
Stockpiles Management Project is being prepared.
Since the proposed project involves the handling, dismantling, excavating, packaging, transporting and
disposal of hazardous chemicals and wastes, the project has been categorized as an ‘A’ for Environmental
Assessment (EA) purposes. The EA for this project focuses on Component 1 which deals with the
destruction of stockpiles of obsolete pesticides and capacitors containing PCBs. The other components of
the project involve institutional and regulatory strengthening for POPs management and control and do
not include physical activities which would have environmental and social impacts. A group of local
environmental and social experts carried out the EA and SA for the project and were assisted by an
international expert familiar with the Bank’s safeguard policy requirements. Their final EA report was
submitted to the Bank on DATE.
B. EA Legal Framework
The two laws governing the EA process in Moldova are the Law on Environmental Protection and the
Law on Ecological Expertise and Environmental Impact Assessment. The Law on the Environmental
Protection ( no. 1515 – XII adopted on June 16, 1993) established a legal foundation for developing
normative acts and regulations applicable to different environmental media in order inter alia to protect
land and subterranean resources, waters and air from “chemical, physical and biological pollution, and
from other impacts.” The law sets the basic principles of environmental protection, including the priority
of environmental goals, mandatory environmental compliance, environmental liability, prohibition of
implementation of any programs and projects without a positive conclusion of the state ecological
expertise (SEE) and concurrence by the population in the area of impacts, payments for use of natural
resources and non-compliance, and use of collected monies for environmental mitigation and
rehabilitation. The Law on Ecological Expertise and Environmental Impact Assessment (no. 851XIII 29.05.96 from 1996). determines goals, objectives and principles of Ecological Expertise and
Environmental Impact Assessment, as well as fundamentals of both procedures. SEE seeks to prevent or
minimize potential direct, indirect or cumulative impacts of various activities on the environment and to
ensure environmental and social sustainability of planning, design and decision-making processes. The
state ecological expertise and EIA have mandatory obligations to deal with some chemical related issues.
There are no specific requirements for POPs in this legislation.
As this is a GEF-financed project, requirements of the Stockholm Convention on Persistent Organic
Pollutants (POPs) have also been taken into consideration in the EA preparation. Among the ten World
Bank Safeguards Policies, two have been identified to be directly applicable to this project: (a)
Environmental Assessment (OP/BP/GP4.01); and (b) Information Disclosure (BP17.50).
C. Environmental Baseline Condition
Since the project sites are spread all over the country, the description of environment has been focused on
the key national environmental concerns and aspects relevant to POPs, as well as on social and economic
country features. The findings obtained during the screening and scoping stages guided and limited
baseline description. Relevant specific information has been collected at rayon level, including general,
weather, natural disaster risks, hydrology, soil, groundwater, flora, fauna, and protected areas information.
The EA team visited all 37 sites where centralisation of obsolete pesticides has already been or will be
implemented, as well as all identified PCBs stockpile sites (12 locations). For each visited site, a short
description and evaluation of possible environmental impacts, identification of sensitive areas and
104
simplified risk assessment has been conducted. The simplified scoring matrix developed allowed ranking
of central stores against anticipated risks. The number of old and evacuated pesticides warehouses has
been reviewed by field examination in order to develop “without project” alternative and identify residual
impacts. The study has also included a program of environmental sampling and analysis for POPs
pesticides and PCBs. The sampling program has been prepared by the EA team, clarified by the PMT and
implemented by the Hydrometeorological Service and the State Ecological Inspectorate.
Obsolete Pesticide Stockpile: According to the information available on April 21, 2005 repackaging had
been completed (solids completed in sacks but still awaiting drums) at 21 central storage sites. Storage
sites had been located at an additional 13 sites while 3 sites had not yet been identified. No work had
begun on repackaging at these 16 sites due to a lack of drums. As noted in this table some 1,800 tons of
pesticides had been fully or partially repackaged and stored by this date. MAFI estimate that MOD and
DES have used 60,727polypropylene sacks, 14,463 plastic drums and 1,200 metal drums in the
repackaging effort so far. They estimate that after the repackaging is completed there will be 94,000
polypropylene sacks of solid pesticides stored in 40,000 plastic drums, and liquid pesticides stored in
3000 of the 100 liter metal drums, 100 of the 200 liter metal drums and 100 of the 50 liter drums. In total
there is expected to be 3000 tons of POPs contaminated pesticides and pesticides contaminated soil and
drums for final destruction. If funds are made available in time, the work on repackaging and storing
should be competed by the end of 2005. However, there is likely to be further delays so that repackaging
may not be completed by the time this GEF project is ready for implementation.
Inspections by the EA study teams of the repackaged pesticides and storage in the centralized warehouses
indicates the following deficiencies:
 drums with missing labels;
 drums not segregated by category as required by the rules;
 damaged plastic drums;
 the weight of each packaged drum was not taken and recorded, thus the total weight of pesticides
in each storage location is only and estimate from a 2002 survey;
 drums stacked one on top of the other without intermediate support as required by the rules,
including the more fragile plastic drums even to 3 to 4;
 drums packed too tightly together not allowing for access or inspection;
 storage sites not meeting the criteria laid down for sanitary protection zones;
 some storage facilities would present many difficulties for emergency response in case of fires
and explosions;
 Some of the storage buildings require maintenance of roofs to prevent leaks during rainfall;
 on many plastic barrels covers were missing;
 in some locations solid pesticides are only stored in bags as there were insufficient plastic barrels;
 in many cases the pesticides were repacked in not specially assigned bags (in fact, some of them
had inscription “sugar”);
 in many storehouses, e.g. in Floresti, Cimislia, Ratus and others liquid pesticides were not
repackaged, but stored in old metallic rusty barrels;
 in some centralized storehouses there were old used and new spoiled barrels;
 passage and even grazing of domestic animals (sheep, goats and others) noted on some sites; and
 security at most sites was lacking 24 hr vigilance and even during day light hours at some sites.
The EA carried out a risk assessment at each of the above sites and ranked them according to overall risk,
which included: condition of storage buildings; proximity to populated areas, agricultural lands,
watercourses, forest and pasture; vulnerability to floods; depth to groundwater; amount of pesticides
stored; availability of space for storage. The following central sites are ranked as: Extremely High Risk:
2, 3, 11, 14, 26, 28, and 29. The following sites are ranked as High Risk: 6, 7, 9, 18, 19, 24, 27, 31, and
105
34. Thus 43% of the central storage facilities are ranked as either extremely high or high risk. These
contain 1460 tons of material. These should be considered as first priority in destruction of the material.
Obsolete Capacitor Stockpile: PCBs and PCB-containing equipment have never been produced in
Moldova. Large power capacitors are used by the power transmission companies and large consumers of
electricity. The substations with capacitors are all owned by the two transmission companies
"Moldelectrica" and "Dnesterenergo" (in the Transnistria region). According to survey undertaken as part
of the project preparation, about 17,300 capacitors are located in Moldova in 12 substations, all owned by
Moldelectrica. Of these, 12,000 capacitors are kept in one assembly consisting of 18 capacitor batteries at
the Vulcanesti substation. About 300 discarded capacitors are kept in closed containers at the station. In
addition, two dumps with approximately 1000 broken capacitors each are located at this substation giving
a total of 14000 spent capacitors in Vulcanesti.
The capacitors at the Vulcanesti substation were commissioned in 1972 as part of a network for export of
electricity from the Soviet Union to Bulgaria, which explains the presence of this large substation and the
exceptionally large amount of PCB-containing capacitors in Moldova. In the Vulcanesti substation and
most of the other substations the capacitors have not been in operation since the collapse of the Soviet
Union, however, some of the batteries have been used periodically during winter time.
Besides their use in the energy sector, capacitors are widely used by large consumers of electricity. An
inventory of capacitors held by users of electricity has not been undertaken as yet, but based on expert
judgments the total PCB-content of those capacitors is roughly estimated at approximately 20-50 tons,
about 10% of the amount in the substations removed and destructed within this project. PCB-containing
capacitors may potentially be held by a large number of consumers of electricity within many sectors
including:
► Industries: foundries and steel plants; production of bricks and cement; feedstuff producers;
slaughterhouses, diaries and other larger food processing factories; larger machine-producing
factories; electro-technical factories, saw mills and wood processing factories; plastic moulders;
paint factories; textile and carpet factories; and paper and packaging factories
► Gas and oil-processing facilities;
► Large laundries; print houses; central data-processing facilities; hospitals;
► Large greenhouses and farms;
► Water and sewage water treatment plants.
Existing data on the baseline levels of contamination with POPs pesticides and PCBs in the environment
are scarce. There is no systematic information on the level of contamination of lands adjacent to the
pesticide stores and/or on the pathways of POPs dissipation in the environment. This was one of the
major impediments to a comprehensive assessment of the risks associated with POPs stockpiles and
contaminated sites in Moldova. A few surveys undertaken by the State Ecological Inspectorate in 2002
and 2003 revealed a significant level of soil contamination with POPs pesticides (including DDT) around
most checked facilities9. These surveys, however, were limited in scope and extent and were rather
fragmentary in temporal and spatial terms.
The EA team, supported by the PMT, designed a sampling and analysis program to bring more light on
the issue of environmental pollution with POPs. Several components of this program were implemented
during the spring of 2005 and their results are briefly presented and discussed below.
9
National Implementation Plan for the Stockholm Convention on Persistent Organic Pollutants, 2004.
106
Pilot investigation of contamination with POPs pesticides (Orhei rayon). A pilot investigation of soil
contamination near 24 former as well as currently operating pesticide storage facilities in the Orhei rayon
was undertaken. The program was designed by the EA team and implemented by the SEI central
laboratory. One indicative sample was taken from each location, usually at 50 meters from the storage
facility, at a point where the movement of pesticides would be most likely. In selecting the sampling
point, consideration was given to the landscape features, adjacent land-use, and proximity to the
residential areas. The study revealed that at most sites the 50-cm surface/top soil layer is significantly
polluted with POPs. The national standard for (DDT+DDE+DDD) in soil is exceeded at some locations
as much as 10-20 times, even at 50 meters from the facility. Some of those facilities are situated close to
health and environmentally sensitive/vulnerable areas such as residential areas, water bodies, or water
courses. The results of this survey demonstrate (and confirm) the large extent of the problem of soil
contamination in areas close to former and currently operating pesticide stores. This represents a direct
threat to human and environmental health and urges for measures being taken to eliminate/limit this risk.
Investigation of environmental pathways of POPs pesticides (Pascani). A thorough integrated
investigation of environmental pathways of POPs was performed in the vicinity of an old pesticide store
in village Pascani, Hincesti rayon. The Pascani facility was used for pesticide storage for about 30 years
and presently contains several tons of obsolete pesticides including 1,300 kg of toxaphen10. The visual
investigation of the facility revealed significant potential health and environmental risks associated with
this store. The building, in poor condition, is situated in the river Lapusna floodplain, on the outskirts of
the residential area and close to agriculture lands and pastures. The groundwater table is close to the earth
surface and the area is exposed to flooding.
Soil, surface and ground water, vegetation and bottom sediments were investigated for POPs. The results
showed a high level of soil contamination with (DDT+DDE+DDD) in the area adjacent to the storage
facility (16.6 times the national standard). Areas situated at 200-500 m uphill and downhill of the store
were not significantly contaminated. Bottom sediments and vegetation also did not accumulate high
amounts of POPs pesticides, while concentrations in water samples were insignificant.
Investigation of soil contamination with PCBs. Data on environmental contamination with PCBs are
scarce. Most PCBs and PCB-contaminated equipment in Moldova are concentrated in the energy sector,
particularly in power capacitors. The capacitors represent a significant hazard to the environment and a
real threat for the health of people working at or living in the vicinity of the substations. Most of them
have been in operation for more than 30 years. The capacitors are situated outdoors and PCBs leak from
corroded capacitors to the soil below the capacitor batteries. Due to past incidents of capacitor explosions
and leakage by corrosion the ground below capacitor batteries could be highly contaminated. The analysis
of soil samples taken by the HMS in 2005 below the capacitors as well as on the territory of several
substations showed a worrying degree of environmental contamination with PCBs (12 congeners). This
was particularly high at the Vulcanesti (culminating with concentrations of 5300 ppm and 7100 ppm) and
Donduseni (95 ppm) substations. This correlates with the reported facts about explosions of capacitors
that occurred at these stations in the past. In the same time, even out of the direct reach of PCB leaks from
capacitors, their concentrations in the topsoil on the territory of the substations exceeded the national
standard (0.06 ppm) in almost every sample.
D. Description of the Project’s Physical Activities
The physical activities of the project are concentrated in Component 1, which involves the destruction of
10
Toxaphene is one of the 12 POPs referred to in the Stockholm Convention.
107
stockpiles of obsolete pesticides and capacitors containing POPs. The obsolete pesticides will be located
in 37 centralized warehouses scattered through out the country. After the repackaging is completed there
will be 94,000 polypropylene sacks of solid pesticides stored in 40,000 plastic drums, and liquid
pesticides stored in 3000 of the 100 liter metal drums, 100 of the 200 liter metal drums and 100 of the 50
liter drums. In total there is expected to be 3000 tons of POPs contaminated pesticides and pesticides
contaminated soil and drums for final destruction in a hazardous waste incinerator. This will eliminate
100% of the pesticide stockpile currently stored in warehouses in the country. The hazardous waste
treatment contractor selected for this operation will repackage the containers of pesticides in Intermediate
Bulk Containers (IBC) which will be leased for the duration of the contract and will transport the
containers to the treatment facility according to international standards as described below.
The destruction of the obsolete capacitor stockpile consists of three main tasks, which will eliminate some
80% of the likely PCB’s currently held in electrical equipment in Moldova:
 Dismantling of 17,300 obsolete capacitors from thirteen substations (the bulk of them are located
at one substation, Vulcanesti) and packing in closed containers (approximately 899 tons);

Excavation of 2,000 capacitors buried in two pits in the Vulcanesti substation and packing in
closed containers (approximately 111 tons);

Shipment of 19,300 capacitors and up to 50 tons highly polluted soil (approximately 1,060 tons)
to a hazardous waste incinerator for destruction, most likely located in Europe.
In order not to waste resources on establishment of temporary storage facilities, it is planned that the
capacitors will be dismantled and packed directly in the containers used for shipping. As a shipping
container is filled it will be immediately shipped for disposal, reducing the number of containers needed
for the operation.
The facility used for the destruction of the capacitors and pesticides will be required to comply with the
best international environmental and health and safety standards. World Bank approved bidding
documents for packaging, exaction, transport and final disposal of the capacitors and pesticides will be
advertised internationally, but it is expected that hazardous waste incineration facilities in Europe meeting
EU standards will be the only ones which will have the capacity and the interest to offer bids.
Transport arrangements for these hazardous wastes will be in accordance with the stipulations of:
 Government Decision on Transportation of Hazardous/Dangerous goods within the Territory of
the Republic of Moldova (No. 672, dated May 28, 2002);
 International transport rules: The European Agreements on the International Carriage of
Dangerous Goods by Road (ADR) and Rail (RID) and the International Maritime Dangerous
Goods Code (IMDG);
 The EU waste shipment rules set out in EU Waste Shipment Regulation (Council Regulation
(EEC) No 259/93).
 The Basel Convention requirements relating to transboundary shipments of POPs containing
waste also will be followed.
E. Environmental Impacts and Mitigation Measures
The destruction of obsolete pesticide and capacitor stockpiles will have substantial net environmental and
human health benefits, both local and global. However, the operations involved in this process do have
potentially negative environmental and health risks and impacts which have been identified in the EA.
Environmental impacts associated with the project may result from possible leakages of pesticides or
108
PCBs from capacitors during the handling, dismantling, excavation, containerization, transport and
destruction processes.
Handling of obsolete capacitors. The capacitors will be continuously dismantled by about 9 trained
workers (1 foreman and 4 teams of two) that will be employed by the hazardous waste treatment
contractor. It is proposed to use the same group of workers to dismantle capacitors at all of the
Moldelectrica substations. Capacitors will be lowered carefully to the ground and the ceramic isolators on
top of the capacitors will be protected from damage in order not to create a risk of further PCB leakage. In
case of corroded or damaged capacitors, the IBC container will be partially filled with absorption material
after placement of the capacitors. At the disposal facility the capacitors together with the absorption
material will be destructed.
Health and Safety of Workers. In order to ensure safe working conditions, all the capacitors in elevated
positions will be dismantled with the help of scaffolding. A lowering mechanism will be incorporated into
the scaffold structure to ensure the safe transport of the capacitors to ground level. Before the start up of
dismantling activities the work force will be trained in the safe methods of handling and packaging of
capacitors, as well as personnel health and safety protection measures, including use of suitable protective
clothing; prohibition of smoking, drinking and eating during work in contaminated areas, etc. The
workers will be trained in procedures to prevent leakages and releases of PCBs and in the treatment of
emergency situations should accidents occur. The training will takes place in a one-day training
workshop, as well as in supervised on-the-job training during the initial start up period. Safe dismantling,
handling and packaging procedures as well as health and safety measures will be presented in simple
illustrative form with constant evaluation of performance of the teams by the foreman in charge.
Excavation of PCB Capacitors from Two Pits in Vulcanesti. Two pits each with 1,000 capacitors will be
excavated and the removed capacitors will be placed in IBC containers and shipped. The approximate
locations of the pits are known. Before the start of the excavation, as part of the feasibility study for site
clean up, information of geography, topography, soil morphology, geo-hydrology (in particular,
groundwater depth and flow direction), groundwater use, etc. will be collected and assessed. Further
samples will be taken to determine whether PCDDs/PCDFs have been formed during the explosions. The
eventual presence of PCDDs/PCDFs influences the preventive measures to be taken during the
excavation. Based on this information a more detailed plan for the excavation will be developed.
Before excavation a lined area of 10m x 20 m with a 1.2 m high cofferdam will be prepared beside each
of the pits. The polluted top soil will be removed and stored temporarily in the cofferdam. Once filled, the
cofferdam will be covered by a waterproofed lining on the top of the excavated soil. Procedures for taking
care of leachate water also must be considered (e.g., treatment of the polluted water through activated
carbon filters before release). The capacitors and soil with visible capacitor parts will be excavated and
placed in IBC containers for shipment. Highly contaminated soil removed during the excavation will be
sent for destruction together with the spent capacitors. It is estimated that besides the estimated 110 tons
of capacitors some 50 tons of highly polluted soil will be excavated and sent for destruction.
It may be necessary to install protective steel balustrades in order to prevent soil collapse from the walls
of the excavations into the pits. Groundwater shall be pumped from the excavated area and stored for
analysis and possible future treatment. The further treatment of the two excavation sites and necessary
remediation measures will be assessed as part of the feasibility study.
Provision will be made for draining of water from saturated soil excavated from the pits by sloping the
base of the coffer dams and providing a sump for collection of the drained water. This water will be
pumped into storage tanks from which it will be treated by absorption in activated carbon filters before
109
release. The polluted filter material will be sent for destruction. The detailed procedures for excavation
and removal of capacitors and highly contaminated soil and storage of less contaminated soil will be
specified in the feasibility study.
Handling of obsolete pesticides. Trained teams will also be employed by the hazardous waste treatment
contractor to remove the repackaged pesticides from the centralized warehouses and place them in IBC
containers with absorbent material in the base of the container incase of leakages from liquid pesticide
containing drums. The empty containers will be unloaded at each site from the returning road transport
vehicles and the packaged containers loaded directly for transport to minimize the potential for spillage.
The workers will be required to wear protective clothing and equipment provided by the contractor and
will be trained in all aspects of the safe handling of hazardous wastes. They will be medically examined at
the start of the operation and will receive medical check ups during the period of the contract according to
best practice in the industry.
F.
Analyses of Alternatives
For Component 1, five additional alternatives were considered, but rejected in favour of the proposed
project design:
-
No action. Consideration has been given to leaving the PCB in the sites undisturbed and to leaving
the obsolete and banned pesticides in the 37 centralized storage sites. This was rejected because of
the potential threat to human health and the environment - both in Moldova and globally - posed by
leaking capacitors or leakages or accidents at the centralized storage sites, particularly the 7 sites
which were assessed to pose potential extremely high risk.
-
Medium to long-term storage of POP containing and contaminated pesticides. The storage can be
implemented in the current configuration (37 centralized facilities), in one facility or in a number of
facilities. These storages will remain vulnerable to renewed releases of POPs by natural disaster,
accidents, fires and other human failure. Besides, the selection of district warehouses often resulted
in conflicts between the public and the local authorities and the latter accepted to host the pesticide
stockpiles in exchange for the promise that this is going to be a provisory measure and the stocks are
to be evacuated as soon as possible. If the current situation will last beyond reasonable terms the
recrudescence of local population protests is highly probable. Thus, in the medium to long term this
situation looks unsustainable. The idea of storing the pesticides in one single (existing) place was
tested by the Government11,12 but now it seems irremediably spoiled by two previous failures. The
option of a new store construction is expensive. Besides, Moldova is a densely populated country,
with predominantly rural population and intensive agriculture land-use. Therefore, selecting a site
responding to all health and environmental criteria and resolving associated tenure problems might
turn to be a difficult issue. Irrespective of the configuration chosen, prior to storage the waste
material will require expert repackaging, sampling and analysis (only identified wastes should be
stored in any repository) while storage facilities themselves will have to be upgraded. This option
11
Government Decision No. 474 of 21.05.1997 on measures for collection and centralized storage of obsolete
pesticides.
12
Government Decision No. 30 of 15.01.2001 on measures for centralized storage and neutralization of obsolete
pesticides.
110
requires regular inspection of stores, immediate containment of leakages and spillage's and proper
stacking of available stock. It requires significant operating and maintenance costs while not
providing a final solution to the problem. Since stored POPs will have to be disposed of anyway, this
method increases the cost of final disposal therefore it is not preferred.
-
Collect PCB contaminated capacitors and store for future disposal. Consideration was given to just
collect the PCB containing equipment from the site and moving is into safe storage. This was
rejected because of the potential harm could be exacerbated by leaving the PCB equipment in a
storage vulnerable to renewed release by natural disaster, accidents, fires or other human failures. In
any case the equipment has to be finally destructed and there is no reason for anticipating that
cheaper disposal would be available in the future. Overall the costs would be higher than the selected
alternative if a temporary storage facility is established and the capacitors were stored prior to
disposal.
-
Collect and destruct in a permanent destruction facility in Moldova. At the current time there is no
consideration as to establishing a permanent facility for destruction of hazardous waste in Moldova
due to the small amount of waste that is generated in the country. Discussions have been held with
the private sector operator of a cement plant but considering the very high cost of retrofitting this
plant to process hazardous wastes and to meet EU emission limits on dioxins and furans it is not
feasible to undertake these investments just to treat the stocks of pesticides and capacitors that will
require disposal under this project. The costs per tonne would likely be double that of the proposed
project.
-
Collect and destruct in a mobile facility. Consideration has been given to destruction of the
capacitors and stocks of obsolete pesticides in a mobile incinerator set up at one fixed location. A
mobile incinerator of acceptable standard costs at least about US$ 5-7 million. Using a mobile
incinerator for capacitor destruction would also imply installation of a unit for shredding the
capacitors before treatment at a price of approximately US$ 1 million. Infrastructure costs for setting
up the incinerator would add an additional US$ 1 million to the capital costs, which would likely be
in the range US$ 7 – 9 million. Operation and maintenance costs to dispose of the 4,000 tons of
PCBs and pesticides would add at least an additional US$ 2 million. Thus the total cost would be in
the range US$ 9 – 11 million, compared with US$ 8 million for the proposed project design. There
also could be long delays and public opposition to the setting up of such a facility which would add
to risks of POPs releases and add to the costs. For these reasons this alternative was rejected.
-
Collect and Store until a possible future Regional Hazardous Waste Facility is Built. UNEP is
promoting such a facility under its Strategic Approach to International Chemicals Management
(SAICM). Firstly, there are grave doubts that this facility will ever be built in this region considering
the excess current private sector capacity for hazardous waste treatment in Europe. Moreover, there
is no guarantee that such a facility could treat Moldova’s POPs’ stockpiles at a lower cost than the
private sector. In addition Moldova would be forced to store its POPs stockpiles until such a facility
is built (if ever) greatly adding to its costs and, as argued above, would represent a higher cost
alternative than the proposed project design. For these reasons it was rejected.
The selected project design, therefore, represents the least cost and most environmentally beneficial
option.
111
G. Environmental Management Plan
An Environmental Management Plan (EMP) was developed as part of the EA preparation which specifies
detailed mitigation measures for all of the operations proposed under Component 1 of the project,
including operations involved in the removal, repackaging, transport and final disposal of the POPs
contaminated pesticides and obsolete capacitors. This EMP will be attached to the Contract Conditions
for the international contractor which will carry out all of these operations. The Contractor will be
required to develop an internal EMP for the project taking into account the all of the requirements of the
project EMP, and will be required to have in place an Environmental Management System (EMS) that
can effectively implement the necessary mitigating measures. The EMS will also have to be linked to an
internal Health and Safety Management System to ensure that all workers on the project will be
adequately protected against chemical hazards and that they use safe working practices. In order to ensure
that the Contractor implements these measures the Supervising Consultants scope of work will include
independent verification that the Contractor is meeting all its obligations to protect the environment and
health and safety of employees working on the project. The regular reporting requirements of the
Consultant will include an assessment of these issues.
H. Public Consultation and Information Disclosure
The project’s EA public consultations built on and continued comprehensive nation-wide public dialogue
with diverse national and international stakeholders and awareness campaign which had stared during
POPs NIP preparation in 2002. MENR and PMT arranged national consultations on the draft TOR for EA
and Table of Contents (TOC) for the EA report, and posted both documents together with a project brief
well in advance on web-sites of the PMT and REC, which has a network of over 250 local NGOs. Further
public announcements were made in the media, and PMT sent e-mail invitations to over 150 groups and
individuals.
The first public consultation, at screening/scoping stage of the EA took place on February 18, 2005 with
about 40 people in attendance. The comments were summarized in the public consultation minutes and
subsequently addressed in the EA and EMP. The participants of the first round of public consultations
urged the PMT and MENR to: (a) continue and expand a well-established process of information
dissemination and public dialogue regarding EA/SA and project processing through PMT/REC web-sites
and mass media; (b) post the final EA/SA TOR on the PMT web-site; (c) hold intermediary consultations
with selected affected communities and local NGOs on a draft EA; and (d) ensure that the EA report and
the EMP are publically accessible and available in Moldova.
During the preparation of the EA/SA local town-hall meetings and regional workshops were held with the
participation of with primary stakeholders in all 32 administrative units of the country. These were
supported by focused group discussions on “POPs and Human Health” in selected schools, conducted by
the SA consultant jointly with the Ministry of Education. Three regional workshops followed and took
place in the northern, southern and central parts of Moldova. To facilitate the social assessment projectspecific and POPs-related booklets in Moldovan and Russian languages were prepared and disseminated
at the above-referred meetings. During March-May 2005, the SA consultant developed and implemented
a comprehensive information dissemination and awareness campaign in local media, including national
and local newspapers, radio stations and TV, and the REC network. A series of POPs-related articles
appeared in the Moldovan environmental monthly Natura, which has a wide outreach through the
circulation of about 20,000 and 8,000 subscribers, including all government agencies, local mayor’s
offices, educational establishments and public libraries.
While drafting an EA report, conducting field surveys and pilot sampling to define priorities, the local EA
112
team visited all proposed centralized storage sites and held comprehensive discussions with local
stakeholders ranging from representatives of mayors’ offices to local civil society groups. These local
comments and observations were factored into the EA.
The second formal public consultation meeting to discuss the draft EA report was announced in national
newspapers, as well as the PMT and REC web-sites and network, and took place on May 19, 2005.
Special invitations to participate were sent to mayors of all 32 administrative units, where obsolete
capacitors containing PCB and temporary POPs pesticides storage facilities are or to be located, as well as
to key stakeholders from the government, the private sector, academia and NGOs. Over 50 participants
actively engaged in discussing the draft EA report and supported the proposed alternative to engage a
certified contractor to ensure due diligent, environmentally and social safe collection, transportation and
destruction of POPs pesticides and PCBs in a licensed facility abroad. All participants urged the GRM
and the Bank to finalize and approve the project at the earliest possible date, and particularly to speed-up
its implementation.
At the same time, the participants expressed a number of concerns, particularly related to: the GRM’s
failure to comply with existing regulations on obsolete pesticides repackaging and to keep its promises
regarding the temporary nature of POPs contaminated pesticides storage; poor coordination among
government agencies and donors (e.g. NATO, GEF, National Army and MENR;) inadequate
prioritization and monitoring of activities within the on-going POPs pesticides repackaging and
centralized storage process; potential for environmental and social risks during repackaging, excavation
and transportation of POPs due to human failure; and potential lack of financial resources and technical
means to complete pesticides repackaging and centralized storage on-time. These issues were addressed
in the final EA report and appropriate mitigatory, monitoring and institutional measures were elaborated
in the project’s EMP.
SOCIAL ASSESSMENT
The SA has identified and dealt with potential social issues and concerns of local population and primary
stakeholders in project’s areas of influence. It has been integrated with two public consultations during
EA preparation and institutional assessment. Because the costs and benefits of changes associated with
project’s implementation are anticipated to be felt most acutely on the local level, the focus of the SA has
been affected communities around POPs sites. The broad categories of primary stakeholders have
included: local communities and NGOs, local authorities and experts.
Identifying and addressing social issues early on, managing them and enhancing positive ones actively
throughout the life of the project will create broader social support for the proposed activities and will
increase the likelihood of project’s sustainability and success. No significant adverse social impacts are
anticipated during implementation from project’s activities, and no proposed activities have triggered
Bank’s safeguard policies, particularly on involuntary resettlement, indigenous peoples and cultural
property.
The project is expected to have measurable and significant social benefits by reducing public health risks
associated with past, current and potential future releases of POPs pesticides and PCBs. The benefits of
the project are primarily related to the removal and destruction of selected POPs pesticides and PCBs
stockpiles and avoidance of future costs from accumulating.
The number of Moldovan people likely to directly benefit from the project is estimated to be over 150,000
people living in the vicinity of POPs sites (it should be also noted that the number of people
113
professionally and directly exposed to pesticides at work has been estimated to drop from 34,700 in 1993
to 8,800 in 2002.)
.
The project will reduce opportunity costs that are lost when resources are diverted to management and
replacement of POPs as well as it will lower economic losses associated with: land contamination (lost
productivity;) health impacts (healthcare costs, lost labor;) impacts on livestock (death or illness) and
crops (crop losses or contamination;) degradation of natural resources (water and soil contamination,) and
wildlife impacts (poisoning of natural pest predators.)
Local, regional, regional and global benefits of the project include: reduced pollution of water supplies;
reduced pesticides and PCBs entering regional and global food chain through soil contamination; reduced
impact on poor; reduced impacts on land, biodiversity, transboundary watercourses and international
waters; compliance with international conventions.
The project’s benefits accrue principally through the elimination or avoidance of contamination and its
consequences, caused by the existence of the stockpiles of POPs pesticides and PCBs. It will therefore be
of significant benefit to both local and regional levels, and the health and well being of local and regional
communities that these banned chemicals are safely and completely destroyed as quickly as possible. The
agricultural potential of exporting clean products will be improved as well as aesthetic attractiveness of
Moldovan nature and tourism potential will be enhanced.
During the SA, 600 households and 120 experts from the selected 19 settlements (14 villages and 5 towns
with the total population of 77523 people) were interviewed, 48 people participated in 6 focus group
discussions and over 200 people took part in 3 regional workshops.
Procedures
The SA built on the findings of the rapid SA conducted during preparation of the Moldovan POPs NIP. It
used a variety of quantitative and qualitative techniques, and consisted of a number of components,
namely: training of SA pollsters, collection of background socio-economic and demographic data, indepth stakeholders’ interviews and focus group discussions, information campaign and regional
workshops. It simultaneously employed a rapid household survey, informal interviews and formal
discussions. The household survey consisted of two focused questionnaires that were administered to
some 600 households and about 120 experts respectively. In-depth interviews were conducted in selected
pilot localities.
Over 3000 schoolchildren, teachers, medical professional, farmers and representatives of local public
authorities participated in environmental lessons and town-hall meetings dealing with POPs issues – these
were jointly implemented by the Ministry of Education and the Environmental Movement of Moldova, a
national NGOs. The SA was supported by POPs public information and awareness campaign
implemented by the Environmental Movement of Moldova, an nation-wide umbrella NGO.
Results
In spite of rapid SA conducted during POPs NIP preparation, collective and individual perceptions about
POPs remain poorly studied in Moldova. While general population is concerned with a number of severe
environmental problems, like waste and garbage accumulation and unauthorized burning, water and air
pollution, illegal logging, public POPs awareness still remains inadequate (it is worth noting that while
about 70% of interviewed experts are aware of the POPs NIP adopted in 2004, 20% of experts heard
nothing of it.)
114
The SA noted that in the last two years, the overall national POPs awareness has increased at least ten
times from the 3% reported to be aware of POPs-related problems in 2003 (at the same time, the SA the
absolute majority of Moldovan population is unaware of POPs PCBs, dioxins and furans, and associated
problems do not top public or private sector priorities.)
The SA has also found public POPs communication to be inadequate and poorly structured in spite of the
existing comprehensive legal framework supportive of free and timely ecological information
dissemination.
The SA discovered that vulnerable groups and the poor (68% of all Moldovan poor people live in a
country side) are primarily concerned with their daily survival and are rather indifferent towards POPsrelated problems; in addition, some groups have been reluctant to articulate their concerns fearing censure
and prosecution by authorities.
Following the national pattern of agricultural production and economic development of various parts of
the country, the SA identified a number of educational, occupational and spatial differences in POPs
awareness and concerns:
1. people with secondary and higher education as well as those in public service have higher POPs
awareness then those only with school education, pensioners unemployed and farmers;
2. population in the North of Moldova is better aware and more concerned about POPs-related
problems than people in the Central and Northern parts of the country;
3. population in the South is more concerned with overall state of the environment in and around
their settlement than that in the Center and the North; the Southerners are more in favor of
penalizing non-compliance and environmental violations, while the Northerners attach higher
priority to environmental education and awareness building, and self-responsibility.
4. younger people are less concerned about waste management problems than 40+ year old.
The following are the key findings:





Though one third of respondents agree that wastes and chemicals have a negative impact on
health and the environment, POPs issues do not top the list of environmental priorities of general
Moldovan populations; at the same time, these have been identified by experts as 2 nd or 3rd most
important environmental problems.
Key causes of environmental problems are perceived to be: 1) poor public awareness and
inadequate environmental education; 2) inadequate or lack of local waste management services;
3) enforcement of environmental compliance and prosecution of environmental violations; 4)
non-transparent government decision-making; 5) poor inter-agency and public-private
communications; 6) unclear legal mandate of local public authorities; 7) lack of sufficient
budgetary funds; and 8) overall poverty of the population (about 30% of respondents believe that
poverty contributes to deteriorating environmental situation in the country.)
National network of private agrochemicals stores, where about 60% of population buy necessary
chemicals, sell only registered and labeled pesticides, offer advice and training on their safe and
sustainable use and application, and contribute to spreading knowledge and improving public
awareness on agrochemicals.
Most POPs-related information is believed to be available primarily from mass media, selected
local public experts , NGOs and neighbors.
While about two thirds of respondents support the collection and temporary storage of
POPs/obsolete pesticides in selected locations until the final solution is found, most experts
consider this approach to pose a higher level of danger as many centralized storages are still in
115




poor shape (there are reported accidents of self-ignited POPs pesticides in over-packed storages)
and as they doubt Government’s ability to complete POPs environmentally safe and sound
disposal and destruction without international assistance.
Two thirds of Moldovan population does not support local incineration of POPs wastes due to
lacking local technical and financial capabilities, and because of the fear of negative health and
environmental impacts, and the potential to cause further deterioration of local conditions.
Due to non-transparent decision-making regarding centralization of POPs pesticides and several
accidents, the local population is under increasing psychological stress, and is actively seeking
the final solution to POPs problems.
The majority of those interviewed consider local authorities to be the most appropriate level to
address current and future waste problems in coordination and health and environmental
institutions and the private sector, and think that sustainable solutions require public participation.
Quite unexpectedly, in view of persistent poverty, the SA revealed public willingness to pay
(60% of respondents are willing to pay up to 10 lei) for regular waste management services.
SA Recommendations
The absolute majority of the interviewed consider an expedited implementation of a project aimed at
POPs threat reduction and wastes elimination as a great benefit to every Moldova citizens, first of all to
those living around POPs pesticides and PCB sites.
The SA suggests that creation of a public transparent and timely environmental/POPs communication and
education must be a central project component, and community participation should be enhanced.
The SA findings also suggest a number of actions that should be incorporated to ensure project
sustainability and success:
.
 Create a permanent local service to provide POPs-related information and advice on
environmentally safe and sound chemicals management, or utilizing the existing network of
private agro-chemicals stores.
 Creation of designated centers for collecting obsolete pesticides and prohibited chemicals from
private citizens and judicial persons for further safe disposal and destruction.
 Ensure timely and transparent public consultations regarding selection of temporary centralized
POPs pesticides storages.
 Create a local waste management service, and consider introducing waste management fees.
 Implement consistent and continuous POPs nation-wide awareness campaign, and ensure
transparent government’s POPs-related communication process.
 Establish rigorous and effective POPs monitoring, compliance enforcement and prosecution of
environmental violations.
 Current burning and unauthorized land-filling of domestic garbage and other wastes, including
POPs, shall be prohibited.
The SA also recommended that project include a set of indicators to monitor and evaluate implementation
effectiveness. In addition, indicators should be developed to assess the evolving role of local-level
institutions.
116
Annex 11: Project Preparation and Supervision
MOLDOVA:
PERSISTENT ORGANIC POLLUTANTS (POPS) MANAGEMENT AND
DESTRUCTION PROJECT
Planned
Actual
PCN review
November 22, 2004
Initial PID to PIC
December 14, 2004
Initial ISDS to PIC
December 14, 2004
Appraisal
October 14, 2005
Negotiations
November 3-4, 2005
Board/RVP approval
December 2005
Planned date of effectiveness
March 15, 2006
Planned date of mid-term review
March 31, 2008
Planned closing date
May 31, 2010
Key institutions responsible for preparation of the project:
Ministry of Environment and Natural Resources
Bank staff and consultants who worked on the project included:
Name
Title
Unit
Rita Klees
Task Team Leader
ECSSD
Nora Dudwick
Lead Social Scientist
ECSSD
Ahmet Gokce
Senior Procurement Specialist
ECSPS
Bogdan Constantinescu
Sr. Financial Management Specialist
ECSPS
Daris Goldstein
Counsel
LEGEC
Edward Daoud
Sr. Finance Officer
LOAG1
Valencia Copeland
Program Assistant
ECSSD
Carsten Lassen
Consultant
COWI
Jorn Laurisden
Consultant
Mark Davis
Consultant
Consultants
FAO
117
Arcadie Capcelea
Consultant
ECSSD
Ruxandra Floroiu
Consultant
ECSSD
Bank funds expended to date on project preparation:
1. Bank resources: US$80,000.00
2. Trust funds:
US$78,000.00
3. Total:
US$158,000.00
Estimated Approval and Supervision costs:
1. Remaining costs to approval:
US$50,000.00
2. Estimated annual supervision cost:
US$80,000.00
118
Annex 12: Documents in the Project File
MOLDOVA:
SUSTAINABLE PERSISTENT ORGANIC POLLUTANTS STOCKPILES
MANAGEMENT
1.
National Implementation Plan (NIP), by the Project Manager, the Chief Technical Advisor and
the Project Assistant served as focal point for the development of the NIP, (April 2004)
2.
Inception Workshop, by NCC, PMU and NFP on December 3, 2002
3.
Assessment of the Legal Framework on Persistent Organic Pollutants Management Report, by
Iurie Tugui, (April 2003)
4.
Assessment of the current country’s capacity to the Best Available Techniques (BAT) and the
Best Environmental Practices (BEP) for POPs source categories Report, by Ala Novac, (April
2003)
5.
Evaluation report of existing control infrastructure and its capacity to correspond to Stockholm
Convention in Moldova, by Constantin Mogoreanu, (April 2003)
6.
Report on National Capacities and Institutions for Administrations of Persistent Organic
Pollutants (POPs) in the Republic of Moldova, by Victor Bujac, (April 2003)
7.
Assessment of the POP’s Research and Development Capacity, by Dr. Fliur Macaev, (April
2003)
8.
National Monitoring, Research and Development Capacity Report, by Gavril Gilca, (April 2003)
9.
Report on Assessment of the POPs Statistics Capacity in the Republic of Moldova, by Dr. Jana
Tafi, (April 2003)
10.
Assessment of the relationship between the Stockholm Convention and other international
agreements on chemicals, by Ina Coseru, (May 2003)
11.
Institutional Framework Related to Persistent Organic Pollutants (POPs) Report, by Andrei
Barannik, (May 2003)
12.
Report - Social and Economic Assessment of POP’s Reduction and Elimination, by Tatiana
Belous, (June 2003)
13.
Assessment of the POPs impacts on the Environmental Factors (water, air, soil, animals,
vegetation), by Vladimir Garaba, (June 2003)
14.
Rapid Social and Economic Assessment (RSEA) Related to Persistent Organic Pollutants (POPs),
by Andrei Barannik, (June 2003)
15.
Initial POPs Inventory Report, by Adrain Tertea, (July 2003)
16.
Inventory of potential Polychlorinated Biphenyl’s-Containing electrical equipment in the
Republic of Moldova, by Dr. Valentin Arion, (July 2003)
119
17.
National Inventory of Persistent Organic Pollutants of the Republic of Moldova, by Dr. Valentin
Ciubotaru, (July 2003)
18.
Assessment of National Inventory of Persistent Organic Pollutants of the Republic of Moldova,
by Katarina Magulová, (August 2003)
19.
Report on Priority Setting and Determination of Objectives for NIP Development by Arion
Valentin, Bivol Elena, Gladci Viorica, Melian Ruslan, Mosanu Valeriu, Opopol Nicolae,
Romanciuc Lidia, Tarita Anatol Viktor Simoncic (October 2003)
20.
National Implementation Plan elaboration, by Valentin Arion, Andrei Barannik, Viktor Somincic,
Ion Comendant, Ruslan Melian, Valeriu Mosanu, Nicolae Opopol, Constantin Mogoreanu, (April
2004)
21.
Risk Assessment, Sectoral Environmental Strategy, and National Strategy for Economic Growth
and Poverty Reduction, by the Government of the Republic of Moldova, (February 2004)
22.
National report on Children’s Health and Environment, “The Future for Our Children,” by
Ministry of Health and Ministry of Ecology and Natural Resources (May 2004)
23.
Communication Strategy for the Stockholm Convention, by Alecu Reniţă, Valentin Ciubotaru,
Victoria Reşetnic, Victor Strătilă, Elena Bivol (April 2004)
24.
Strategy for Elimination of POPs in Moldova, by the Ministry of Ecology and Natural Resources
(September 2004)
25.
National Workshop “Joint Actions for the Implementation of the Stockholm Convention on
Persistent Organic Pollutants in the Republic of Moldova” October 29, 2004
26.
Workshop on Project Activities Implementation and Coordination, February 14, 2005.
27.
Workshop on Public Consultation within preparation of an Environmental Impact Assessment,
February 18, 2005.
120
Annex 13: Statement of Loans and Credits
MOLDOVA:
PERISTENT ORGANIC POLLUTANTS (POPS) MANAGEMENT AND
DESTRUCTION PROJECT
Difference
between
expected
and
actual
Original Amount in US$ Millions
Project
FY
Purpose
IBRD
IDA
SF
GEF
disbursements
Cancel. Undisb. Orig.
Frm.
Rev’d
ID
P040558 2004 ENERGY 2
0.00
35.00
0.00
0.00
0.00
36.85
2.75
0.00
P075995 2004 AG
0.00
0.00
0.00
4.95
0.00
4.29
0.30
0.00
P079314 2004 SIF 2
0.00
20.00
0.00
0.00
0.00
19.39
0.01
0.00
P073626 2003 TRADE & TRANS
0.00
7.21
0.00
0.00
0.00
7.47
-0.70
0.00
P074122 2003 AIDS CONTROL
0.00
0.00
0.00
0.00
0.00
5.53
0.50
0.00
P074469 2003 WS & SAN
0.00
12.00
0.00
0.00
0.00
12.58
-0.72
0.00
&
0.00
10.50
0.00
0.00
0.00
5.16
-6.62
-1.06
INVST
0.00
10.00
0.00
0.00
0.00
2.41
0.34
0.15
P051173 1999 SOC PROT
0.00
11.10
0.00
0.00
0.00
7.75
6.92
0.00
P035771 1998 FIRST CADASTRE
0.00
15.90
0.00
0.00
0.00
1.35
1.12
0.16
P035811 1997 PSD 2
0.00
9.00
0.00
0.00
0.00
0.84
0.86
0.00
Total:
0.00
0.00
4.95
0.00
103.62
4.76
- 0.75
POLLUTION
CONTROL (GEF)
FACIL IN SE EUR
P060434 2002 RURAL
INV
SERVS (APL #1)
P051174 2001 HEALTH
FUND
130.71
121
MOLDOVA
STATEMENT OF IFC’s
Held and Disbursed Portfolio
In Millions of US Dollars
FY
Committed
Disbursed
IFC
IFC
Company
Loan
Equity Quasi
Partic.
Loan
Equity Quasi
Partic.
2000/04
FinComBank
1.50
0.00
0.00
0.00
1.50
0.00
0.00
0.00
1997
INCON
5.84
0.00
0.00
0.00
5.84
0.00
0.00
0.00
2000
MEC Moldova
0.00
0.10
0.90
0.00
0.00
0.10
0.90
0.00
2000/04
Moldindconbank
4.00
0.00
0.00
0.00
4.00
0.00
0.00
0.00
2001
UF Moldova
24.29
0.00
0.00
0.00
19.29
0.00
0.00
0.00
2001/04
Victoriabank
5.00
0.00
0.00
0.00
5.00
0.00
0.00
0.00
0.00
0.00
0.30
0.00
0.00
0.00
0.30
0.00
0.10
1.20
0.00
0.10
1.20
0.00
Approval
1999/00/01 VoxTel
Total portfilio:
40.63
35.63
Approvals Pending Commitment
FY
Company
Loan
Equity
Quasi
Partic.
Approval
Total
pending
0.00
committment:
122
0.00
0.00
0.00
Annex 14: Country at a Glance
MOLDOVA:
PERSISTENT
ORGANIC
POLLUTANTS
(POPS)
MANAGEMENT
DESTRUCTION PROJECT
E uro pe &
C e nt ra l
M o ldo v a
A s ia
P O V E R T Y a nd S O C IA L
2003
P o pulatio n, mid-year (millio ns)
GNI per capita (A tlas metho d, US$ )
GNI (A tlas metho d, US$ billio ns)
Lo winc o m e
4.2
590
2.5
473
2,570
1,217
2,310
450
1,038
-0.3
0.2
0.0
0.2
1.9
2.3
..
63
69
31
..
91
3
103
104
102
..
30
58
82
44
75
39
92
99
85
D e v e lo pm e nt dia m o nd*
Life expectancy
A v e ra ge a nnua l gro wt h, 19 9 7 - 0 3
P o pulatio n (%)
Labo r fo rce (%)
M o s t re c e nt e s t im a t e ( la t e s t ye a r a v a ila ble , 19 9 7 - 0 3 )
P o verty (% o f po pulatio n belo w natio nal po verty line)
Urban po pulatio n (% o f to tal po pulatio n)
Life expectancy at birth (years)
Infant mo rtality (per 1,000 live births)
Child malnutritio n (% o f children under 5)
A ccess to an impro ved water so urce (% o f po pulatio n)
Illiteracy (% o f po pulatio n age 15+)
Gro ss primary enro llment (% o f scho o l-age po pulatio n)
M ale
Female
23
46
67
27
..
92
1
85
86
85
GNI
per
capita
Gro ss
primary
enro llment
A ccess to impro ved water so urce
M o ldo va
Lo w-inco me gro up
KE Y E C O N O M IC R A T IO S a nd LO N G - T E R M T R E N D S
19 8 3
19 9 3
2002
2003
GDP (US$ billio ns)
..
2.4
1.7
2.0
Gro ss do mestic investment/GDP
Expo rts o f go o ds and services/GDP
Gro ss do mestic savings/GDP
Gro ss natio nal savings/GDP
..
..
..
..
55.8
39.3
39.8
40.7
21.7
52.3
-3.4
14.1
21.7
53.7
-12.3
11.5
Current acco unt balance/GDP
Interest payments/GDP
To tal debt/GDP
To tal debt service/expo rts
P resent value o f debt/GDP
P resent value o f debt/expo rts
..
..
..
..
..
..
-7.7
0.0
11.7
0.4
..
..
-5.6
2.5
80.0
20.8
74.3
111.3
-9.2
1.7
75.8
10.2
..
..
19 8 3 - 9 3 19 9 3 - 0 3
2002
2003
2003-07
E c o no m ic ra t io s *
(average annual gro wth)
GDP
GDP per capita
Expo rts o f go o ds and services
-3.3
-3.9
..
-1.8
-1.6
5.7
7.8
8.2
19.1
6.3
6.7
20.6
Trade
Do mestic
savings
Investment
Indebtedness
M o ldo va
4.0
5.1
6.3
Lo w-inco me gro up
S T R UC T UR E o f t he E C O N O M Y
19 8 3
19 9 3
(% o f GDP )
A griculture
Industry
M anufacturing
Services
..
..
..
..
32.5
44.0
36.0
23.5
24.1
23.2
17.0
52.7
22.5
24.7
18.4
52.8
P rivate co nsumptio n
General go vernment co nsumptio n
Impo rts o f go o ds and services
..
..
..
44.3
15.9
55.4
87.4
16.1
77.4
94.6
17.7
87.6
19 8 3 - 9 3 19 9 3 - 0 3
(average annual gro wth)
A griculture
Industry
M anufacturing
Services
..
..
..
..
-2.6
-6.1
0.5
1.5
2002
2003
G ro wt h o f inv e s t m e nt a nd G D P ( %)
40
20
0
-20
98
..
..
..
..
7.5
-7.5
-6.8
8.9
2003
3.7
3.9
2.6
7.4
-9.9
13.4
12.8
9.5
40
19.1
20.4
5.8
30.9
-20
123
01
GDI
2002
4.7
21.0
19.0
16.1
00
02
03
-40
GDP
G ro wt h o f e xpo rt s a nd im po rt s ( %)
20
0
98
P rivate co nsumptio n
General go vernment co nsumptio n
Gro ss do mestic investment
Impo rts o f go o ds and services
99
99
00
01
02
-40
Exports
Imports
03
AND
Moldova
P R IC E S a nd G O V E R N M E N T F IN A N C E
19 8 3
D o m e s t ic pric e s
(% change)
Co nsumer prices
Implicit GDP deflato r
19 9 3
2002
2003
Inf la t io n ( %)
50
..
..
788.5
860.5
5.3
10.0
11.7
13.9
40
30
20
G o v e rnm e nt f ina nc e
(% o f GDP , includes current grants)
Current revenue
Current budget balance
Overall surplus/deficit
10
0
..
..
..
26.8
-4.1
-9.0
29.5
0.7
-1.8
31.1
1.4
0.4
98
99
00
01
02
GDP deflator
03
CPI
TRADE
19 8 3
2002
2003
451
26
22
100
631
39
279
33
666
39
106
135
1,052
44
218
147
790
29
120
197
1,403
82
233
214
..
..
..
..
..
..
91
106
85
93
113
82
19 8 3
19 9 3
(US$ millio ns)
To tal expo rts (fo b)
Live animals and animal pro ducts
Vegetable pro ducts
M anufactures
To tal impo rts (cif)
Fo o d
Fuel and energy
Capital go o ds
..
..
..
..
..
..
..
..
Expo rt price index (1995=100)
Impo rt price index (1995=100)
Terms o f trade (1995=100)
19 9 3
E xpo rt a nd im po rt le v e ls ( US $ m ill.)
1,500
1,000
500
0
97
98
99
00
Exports
01
02
03
Imports
B A LA N C E o f P A Y M E N T S
2002
2003
501
705
-204
870
1,287
-417
1,054
1,720
-666
..
..
0
..
151
140
323
144
Current acco unt balance
..
-182
-93
-181
Financing items (net)
Changes in net reserves
..
..
169
13
115
-22
214
-33
M emo :
Reserves including go ld (US$ millio ns)
Co nversio n rate (DEC, lo cal/US$ )
..
..
..
0.8
269
13.6
302
13.9
19 9 3
2002
2003
278
28
0
1,329
186
145
1,489
190
175
(US$ millio ns)
Expo rts o f go o ds and services
Impo rts o f go o ds and services
Reso urce balance
..
..
..
Net inco me
Net current transfers
C urre nt a c c o unt ba la nc e t o G D P ( %)
0
97
98
99
00
01
02
03
-5
-10
-15
E X T E R N A L D E B T a nd R E S O UR C E F LO WS
19 8 3
(US$ millio ns)
To tal debt o utstanding and disbursed
..
IB RD
..
IDA
..
-20
-25
C o m po s it io n o f 2 0 0 3 de bt ( US $ m ill.)
To tal debt service
IB RD
IDA
..
..
..
2
0
0
231
17
1
148
18
1
Co mpo sitio n o f net reso urce flo ws
Official grants
Official credito rs
P rivate credito rs
Fo reign direct investment
P o rtfo lio equity
..
..
..
..
..
18
65
0
0
0
31
-5
-36
111
2
..
-17
33
..
..
Wo rld B ank pro gram
Co mmitments
Disbursements
P rincipal repayments
..
..
..
86
29
0
41
26
9
54
18
11
124
G: 80
A: 190
B: 175
C: 143
F: 684
D: 83
E: 134
A - IBRD
B - IDA
C - IM F
D - Other multilateral
E - Bilateral
F - Private
G - Short-term
Annex 15: Incremental Cost Analysis
MOLDOVA:
PERSISTENT ORGANIC POLLUTANTS (POPS) MANAGEMENT AND
DESTRUCTION PROJECT
OVERVIEW
Consistent with the objectives of the GEF’s Operational Program #14 for helping its member countries
implement the Stockholm Convention on Persistent Organic Pollutants, this project will help Moldova to
accelerate the elimination PCBs, and POPs containing and contaminated obsolete pesticides which
include several of the twelve POPs covered by the Convention. The project will achieve this objective
by: (1) repackaging and destruction of some 1,150 tons of POPs contaminated obsolete pesticides; (2)
destruction of some 1,060 tons of obsolete capacitors containing PCBs including 50 tons of highly
contaminated soil; and (3) substantially upgrading the regulatory system to identify, inventory and
provide safe means of temporary storage and final disposal of PCB contaminated electrical equipment
through out the country.
The project has three components: (1) management and destruction of POPs containing and contaminated
pesticides and obsolete capacitors contaminated with PCBs; (2) development of a regulatory framework
and capacity building for POPs management and control; and (3) institutional strengthening and project
management. The project will be co-financed by a grant from the GEF, government counterpart
contributions, and other donors..
BROAD DEVELOPMENT GOALS
PCBs and PCB-containing equipment have never been produced in Moldova. Large power capacitors
are used by the power transmission companies and large consumers of electricity. According to the
inventory undertaken as part of the NIP preparation, almost 20,000 PCB-containing capacitors are located
in 20 electrical substations throughout the country. The substations with capacitors are all owned by the
two transmission companies "Moldelectrica" and "Dnesterenergo" (in the Transnistria region). Of these,
12,000 capacitors are kept in one assembly consisting of 18 capacitor batteries at the Vulcanesti
substation. About 300 discarded capacitors are kept in closed containers at the station. In addition, two
dumps with approximately 1,000 broken capacitors each are located at this substation giving a total of
14000 spent capacitors in Vulcanesti.
Besides their use in the energy sector, capacitors are widely used by large consumers of electricity. An
inventory of capacitors held by users of electricity has not been undertaken as yet, but based on expert
judgments the total PCB-content of those capacitors is roughly estimated at approximately 20-50 tons.
PCB-containing capacitors may potentially be held by a large number of consumers of electricity within
many sectors.
A detailed inventory of PCBs in transformers, switches and other electrical equipment is also still pending
in Moldova. According to an inventory of the electrical equipment currently in use, undertaken as part of
the NIP preparation, approximately 23,000 power transformers are in use in the country; of these about
2,500 belongs to large consumers of electricity. The total content of oil in the transformers is
approximately 18,000 tons and additionally about 5,400 tons of oils are in use in switches, inductors and
other electrical equipment. Approximately 10% of the transformers in Moldova originate from other
Eastern European countries as former Yugoslavia and the GDR in which countries PCB-containing
125
transformers were also produced. Besides transformers originally filled with PCBs, an unknown number
of the transformers in use may be contaminated by PCBs by cross-contamination by maintenance of
transformers.
POPs Containing and Contaminated Pesticides: It is estimated that about 560 thousands tons of
pesticides were brought into the country during the last 40 years. By the early 1990s, over 1,000
warehouses for pesticide storage have been built in the collective farms of Moldova. During 1991-2003
about 60% of these were destroyed or dismantled with only 20% of the remaining ones maintained in a
satisfactory condition. Significant amounts of obsolete pesticides are stored in the open. The deteriorated
packaging enhances the risk of harmful effect on people’s health and environment, with some warehouses
being situated close to residential areas. Since the pesticides in the old storage locations, during the
repackaging process, were indiscriminately mixed, in bags and drums, there is no way of determining the
compositions of the resultant mixtures in the repackaged plastic and steel drums. Therefore to estimate the
percentage of POP pesticides in the total amount of pesticides, the statistical data for the last 40 years was
analyzed while the project document was developed. However, according to the data from the Ministry of
Agriculture and Food Industry, State Enterprise “Moldselhozhimia” and State Ecological Inspectorate
there is no accurate information on their use and the quantities and types of the chemicals used differ a
lot. An approximate estimation of this data shows that the average amount of POP pesticides out of the
total stock of pesticides is about 20 - 30%.
Storing POPs pesticides in inappropriate conditions has lead to the contamination of adjacent lands. A
survey made by the State Ecological Inspectorate in 2002 in the Nistru River basin revealed a significant
level of soil contamination with organochlorinated pesticides (OCP), including DDT and HCH, around
most of the storage facilities that were monitored. The concentrations of OCPs in soil regularly and
significantly exceeded the maximum allowable concentration even at 200 m from these facilities. In
several cases the contamination of surface waters nearby occurred.
In November 2003, the Ministry of Defense (MOD) and the State Department of Emergency Situations
(SDES) were involved in repackaging and transportation of these obsolete pesticide stocks from the
scattered warehouses and open storage sites to centralized district storage facilities. Currently, the total
amount of obsolete pesticides in Moldova is estimated at 6,940 tons, including about 3,940 tons buried at
the pesticide dump in Cismichioi.
Moldova ratified the Stockholm POPs Convention on February 19, 2004. As a Party to the Convention,
Moldova’s obligations include eliminating the use of PCBs in equipment by 2025 and pursuing “the
environmentally sound waste management” of PCBs and of equipment containing PCBs “as soon as
possible, but no later than 2028.” To meet these obligations, Moldova will implement this POPs project
and develop the national regulations and enforcement capabilities to meet Convention requirements.
BASELINE SCENARIO
Under the baseline scenario, Moldova would apply its existing regulations, policies and management
approach to POPs for PCB’s and POPs contaminated pesticides. Over twenty five legal and regulatory
acts in Moldova deal in general terms with the full life-cycle of managing toxic and hazardous substances
and wastes, which, though not naming specifically, cover POPs regulated by the Stockholm Convention.
Current Moldovan legislation includes general prohibitions and restrictions on production, use, storage,
marketing and disposal of a broad variety of toxic, hazardous, flammable and volatile substances and
waste, including POPs listed in the Convention. The main deficiency in the present legal framework is
that legislation does not specifically mention POPs and only covers use of substances such as plant
protection products, not, for example, biocidal or industrial uses, and it does not regulate unintentional
126
and by-product POPs. As the Convention has both mandatory and aspiration stipulations, and is very
broad in scope, in the sense that the control measures cover the whole cycle of POPs from production to
disposal, Moldovan legislation does not yet fully cover all these measures.
Even if such legislation was in place Moldova currently has limited enforcement and implementation
capability for POPs management and control and so the baseline condition without the GEF project is
business as usual with limited if any control over POPs releases to the environment – i.e., zero control.
Under this scenario Moldova also will continue repackaging, transport and storing the country’s stock of
POP containing and contaminated obsolete and banned pesticides. In total there is expected to be 3000
tons of POPs contaminated pesticides and pesticides contaminated soil and drums for final destruction.
The work on repackaging and storing should be competed by March 2006. While the repackaging of the
stockpiles and the transport to 37 centralized warehouses is an improvement over the past situation, POPs
containing and contaminated pesticides remain vulnerable to renewed releases by natural disaster,
accidents, fires and other human failure, that would further affect human health and the global
environment.
Concerning the PCBs, the baseline scenario will continue be a threat to human health and the
environment - both in Moldova and globally - posed by leaking capacitors or leakages or accidents.
Moldovan authorities and the staff of involved institutions are not undertaking any activities to avoid
further leakage of PCBs, outside only in the case of emergency situations. Until now, only several
capacitors containing PCBs were stored in a temporary containers, after the staff identified they were
leaking.
GEF ALTERNATIVE SCENARIO
Under the GEF Alternative Scenario, the project will deal with the destruction of about 30% of the
stockpiled obsolete pesticides and 80% of electrical equipment containing PCBs and will bring the
remaining known and unknown stocks of PCB contaminated electrical equipment under regulatory
control, thereby complying with the requirements of the Stockholm Convention. In so doing, the project
will give Moldova the practical experience in POPs management and help develop the capacity it needs to
achieve complete disposal of all PCBs by 2028, as specified in the Stockholm Convention. Specifically,
the project will:
(1). Repackage, transport and destroy 1,150 tons of POPs containing contaminated obsolete
pesticides held in 10 storage sites in administrative districts throughout Moldova (of this, GEF
will finance destruction of about 500 tons);
(2). Dismantle 17,300 obsolete capacitors and excavate 2,000 (about 1,060 tons) capacitors buried
in two pits, pack them in closed containers, transport and destruct them in an internationally
approved incinerator including approximately 50 tons highly polluted soil from the Vulcanesti
substation;
(3). Carry out a feasibility study to evaluate the least cost method of decontaminating PCB
contaminated soil on the Vulcanesti substation;
(4). Upgrade the regulatory system for POPs management and control as well as for other toxic
substances as per the requirements of the Convention and carry out an inventory of all PCB
contaminated equipment in the country including provision of test kits and upgrading of
laboratories to provide accurate analysis of PCB’s;
127
(5). Strengthen the MENR capacity with a capability for monitoring and controlling POPs with
modern MIS capabilities linked to other government agencies, private and public enterprises and
institutes as well as through the internet to the general public and international community.
Provision for extensive training of staff in ministries and departments with responsibilities for
management, monitoring and control of POPs.; and
(6). Provide project management oversight through a PMT located in the MENR to meet the
fiduciary/procurement requirements of the GEF/World Bank.
INCREMENTAL COSTS OF THE GEF ALTERNATIVE SCENARIO:
The incremental activities and costs of the GEF Alternative Scenario include all the above activities, as
explained below:

Since the repackaging that was carried out by the Moldovan authorities resulted in unknown cross
contamination of the obsolete pesticides stocks with pesticides containing POPs it has to be
assumed that all of these stocks are potentially contaminated. Moreover, the containers in which
they were repacked do not meet international transport requirements and, therefore, have to be
repacked. The method of storage also presents risks of further leakage, fires, explosions and theft
and continues to present a risk to the environment and human health. Their immediate and final
disposal is, therefore, required and an investigation of potential disposal options indicates that
repackaging, transport and final disposal in an EU approved incinerator in Europe would be the
least cost and most environmentally safe method. Since financing is not sufficient to destroy all
the material, those facilities determined to pose the highest risk to the environment are the ones
for which the stockpiles will be destroyed under this project. GEF will finance only the
incremental cost (i.e. destruction of the POPs materials). The baseline is to leave the stocks in
temporary storage. The GEF supported intervention will bring both domestic benefits and global
benefits due to the nature of POPs contamination of the stocks. The intervention will therefore be
co-financed, as well as incurring incremental costs financed by the GEF.

The current baseline situation is leading to leakage of PCBs from capacitors on elevated racks at
the Vulcanesti substation, as well as from exploded capacitors that have been buried on the site.
Without the GEF project these leaks would continue. The cost of dismantling the capacitors,
excavating the buried ones, packing them in safe containers and transporting them to a hazardous
waste incinerator in Europe for final disposal will bring both domestic benefits and global
benefits. The intervention will therefore be co-financed, as well as incurring incremental costs
financed by the GEF.

With the buried capacitors removed from the site and only the most highly contaminated soil
removed for incineration there will be excavated soils that are also PCB contaminated as well as
surface soils under the removed capacitor batteries which will require decontamination. Rather
than shipping all this soil to the European incinerator for final disposal with the capacitors it was
decided that a feasibility study would be carried out once soils analyses were obtained to see if
there may be lower cost options for removing the PCBs. The full cost of this study, as well as the
cost of the PCB analyses represent incremental costs.

The requirements under the Stockholm Convention bring impetus for Moldova to upgrade its
regulatory controls on
POPs chemicals and carry out a costly inventory of equipment
contaminated with POPs. Neither would there be any immediate need to monitor and manage
these stocks without the Convention’s stipulations in this regard. In view of the domestic benefits
128
that will also accrue from this activity, the intervention will be co-financed, as well as incurring
incremental costs financed by the GEF.

Strengthening of MENR for POPs management and monitoring was one of the recommendations
of the NIP study. The strengthening of MENR represents an incremental cost for POPs
management and control. The MIS that will be developed will initially focus on POPs chemicals,
particularly PCBs identified in the inventory carried out under the PCB component of the project.
In view of the domestic benefits that will also accrue from this activity, the intervention will be
co-financed, as well as incurring incremental costs financed by the GEF.
1.
As summarized in Table 3 the total cost of the Alternative is about US$ 12.60 million and its
agreed incremental cost is US$ 6.35 million. The GoM, bilateral and other donors are contributing
US$7.4
million
towards
the
cost
of
the
129
Table 1. Global and Domestic Benefits/Risks with Baseline and GEF Alternative
Baseline
Alternative
Scenario
Global
Environmental Domestic Benefits/risk
benefits/risks
1. Scattered ad hoc in-country 1. Limited action to limit POPs
operations contribute little to
releases to the environment except
global or regional objectives
repackaging of obsolete pesticides
2. Risk of release of large quantities
but activities not to international
of
POPs
to
the
global
standards and risk still prevails.
environment
Very limited action to prevent
PCB releases to the environment,
2. Very limited general awareness of
POPs and its environmental and
heath impact,
3. Limited institutional capacity to
manage POPs,and
4. No capacity to recover, collect,
and dispose of PCBs or POPs
contaminated pesticides safely.
1. An effective POPs management 1. Building institutional capacity to
and disposal program designed to
mange POPs in an environmentally
address global goals as well as
sound manner,
regional and local needs
2. Raising public awareness of POPs’
2. Overall reduction of the risk in the
risk to the environment and human
release
of
POPs
to the
health,
environment,
3. Eliminating the risks of further
3. Environmentally sound disposal
releases of POPs from leaking
of POPs under control conditions,
storage sites in general and will
4. Developing a long term plan for
ensure
safe
recovery,
complete collection and disposal
transportation, storage and disposal
of PCBs,
of the major obsolete stocks of
5. Assisting Moldova in meeting its
these materials.
obligations under the Stockholm
Convention
Project
Incremental
Cost
Alternative Cofinancing
GEF
Total Costs (million
US$)
0.819
(representing
the investment
for repackaging
of
obsolete
pesticides)
12.60
11.78
6.25
6.35
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Table 2: Matrix of Scenarios Comparing Baseline and GEF Alternatives
Components
Destruction of
Stockpiles
of
POPs containing
and
Contaminated
Obsolete
Pesticides
Baseline
Temporary
storage
of
improperly packaged and
stored POP containing and
contaminated
obsolete
pesticides
with
high
vulnerability to leakage,
fires, explosion and theft.
GEF Alternative
Repackaging, transport and disposal
of the stockpile of 1,150 tons of
POP’s
contaminated
obsolete
pesticides in a hazardous waste
incinerator in Europe that meets EU
environmental and health and safety
standards.
Management of
PCBs
and
Destruction
of
Obsolete
Capacitor
Stockpiles
Continue to contaminate
the environment due to
corrosion of
capacitor
casings and leakage of
buried
capacitors
at
Vulcanesti
Dismantle 17,300 obsolete capacitors
and excavate 2,000 capacitors buried
in two pits, pack them in closed
containers, transport and destruct
them in an internationally approved
incinerator along with up to 50 tons
highly polluted soil from the
Vulcanesti substation.
131
Incremental Cost
Since the repackaging that was carried out by the
Moldovan authorities resulted in unknown cross
contamination of the obsolete pesticides stocks with
pesticides containing POPs it has to be assumed that all
of these stocks are potentially contaminated. Moreover,
the containers in which they were repacked do not meet
international transport requirements and, therefore,
have to be repacked. The method of storage also
presents risks of further leakage, fires, explosions and
theft and continues to present a risk to the environment
and human health. Their immediate and final disposal
is, therefore, required and an investigation of potential
disposal options indicates that repackaging, transport
and final disposal in an EU approved incinerator in
Europe would be the least cost and most
environmentally safe method. The baseline is to leave
the stocks in temporary storage. The GEF supported
intervention will bring both domestic benefits and
global benefits due to the nature of POPs
contamination of the stocks. The intervention will
therefore be co-financed, as well as incurring
incremental costs financed by the GEF.
.
Incremental Cost = US$ 4.55 million
The current baseline situation is leading to leakage of
PCB from capacitors on elevated racks at the
Vulcanesti substation, as well as from exploded
capacitors that have been buried on the site. Without
the GEF project these leaks would continue. . The cost
of dismantling the capacitors, excavating the buried
ones, packing them in safe containers and transporting
them to a hazardous waste incinerator in Europe for
final disposal will bring both domestic benefits and
Components
Baseline
Feasibility
Contaminated soil will
Study of Site continue to be washed into
Clean-up
at watercourses and lead to
Vulcanesti
widespread pollution of the
Substation
environment. With the
excavation of the pit
containing
damaged
capacitors
additional
quantity of contaminated
soil will be exposed.
STRENGTHENING
THE
REGULATORY
FRAMEWORK
AND CAPACITY
BUILDING FOR
POPS
MANAGEMENT.
GEF Alternative
Incremental Cost
global benefits. The intervention will therefore be cofinanced, as well as incurring incremental costs
financed by the GEF.
Carry out a feasibility study to
evaluate the least cost method of
decontaminating PCB contaminated
soil on the Vulcanesti substation.
Current legislation does not Upgrade the regulatory system for
make any reference to POPs management and control as
POPs
management
or well as for other toxic substances as
control
per the requirements of the
Convention and carry out an
inventory of all PCB contaminated
equipment in the country including
provision of test kits and upgrading
of laboratories to provide accurate
analysis of PCB’s.
Incremental Cost = US$ 2.57 million
With the buried capacitors removed from the site and
only the most highly contaminated soil removed for
incineration there will be excavated soils that are also
PCB contaminated as well as surface soils under the
removed capacitor batteries which will require
decontamination. Rather than shipping all this soil to
the European incinerator for final disposal with the
capacitors it was decided that a feasibility study would
be carried out once soils analyses were obtained to see
if there may be lower cost options for removing the
PCBs. The full cost of this study, as well as the cost of
the PCB analyses represent incremental costs.
Incremental Costs = US$ 0.29 million
The requirements under the Stockholm Convention
bring impetus for Moldova to upgrade its regulatory
controls on POPs chemicals and carry out a costly
inventory of equipment contaminated with POPs.
Neither would there be any immediate need to monitor
and manage these stocks without the Convention’s
stipulations in this regard. In view of the domestic
benefits that will also accrue from this activity, the
intervention will be co-financed, as well as incurring
incremental costs financed by the GEF.
Incremental Costs = US$ 2.32 million
Institutional
Strengthening
Some limited support to
build institutional capacity
for the management of
POPs has been provided
Set up a PMT with a capability for
monitoring and controlling POPs
with modern MIS capabilities linked
to other government agencies, private
132
Strengthening of MENR for POPs management and
monitoring was one of the recommendations of the NIP
study. The strengthening of MENR represents an
incremental cost for POPs management and control.
Components
Project
Management
Baseline
through GEF support to the
POPs NIP exercise in the
context of the Stockholm
Convention.
Continued
limited capacity would
constrain
POPs
management and control.
The focus would continue
on repackaging of obsolete
pesticides and placing them
in temporary storage.
Because of limited PCB
awareness,
resources,
regulations and standards,
there
would
be
no
monitoring or evaluation of
PCBs either stored or in use
in Moldova
GEF Alternative
and public enterprises and institutes
as well as through the internet to the
general public and international
community. Provision for extensive
training of staff in ministries and
departments with responsibilities for
management, monitoring and control
of POPs.
Incremental Cost
The MIS that will be developed will initially focus on
POPs chemicals, particularly PCBs identified in the
inventory carried out under the PCB component of the
project. In view of the domestic benefits that will also
accrue from this activity, the intervention will be cofinanced, as well as incurring incremental costs
financed by the GEF.
Incremental Costs = US$ 1.43 million
Provide
project
management Estimated costs of US$ 0.64 million are incremental
oversight through a PMT located in because this activity would not occur without the GEF
the
MENR
to
meet
the project.
fiduciary/procurement requirements
of the GEF/World Bank.
133
Annex 16: STAP Roster Review
MOLDOVA:
PERSISTENT ORGANIC POLLUTANTS (POPS) MANAGEMENT AND
DESTRUCTION PROJECT
May 21, 2005
STAP Roster Reviewer Comments
Mr. G. Victor Buxton, M.Sc., P.Eng
Hazardous Chemicals International Consultant
Ottawa, Ontario, Canada
Background13
The Republic of Moldova is a small landlocked country of approximately 33,840 km2, geographically
situated near the northwest section of the Black Sea between the Ukraine and Romania. It is strategically
located at the crossroads between Central, Southeast and Eastern Europe. Moldova is one of the newly
independent European States, the smallest, in terms of territory, after Armenia. In relation to OP#10, the
biggest rivers in Moldova are the Nistru and the Prut. The underground water reserves, mostly drinking
water, are estimated at 200 million cubic meters. With regard to OP#4, the Moldova central region is the
Basarabian Plateau with forested and mountainous highlands up to 400 meters in elevation.
With regard to public health protection considerations and in particular OP#14, Moldova, with a
population of approximately 4.2 Million is one of the most densely populated European countries
(approximately 128 persons per km2) and therefore vulnerable to enhanced exposure. The population is
fairly evenly divided between urban and rural areas.
Unfortunately, poverty remains a defining
characteristic with per capita income less than $500 US.
Moldova has no known significant wealth-producing mineral deposits. Major mineral deposits and natural
resources consist of cement components and gypsum, limestone, sand and raw materials for bricks and
tiles. Natural oil and brown coal deposits have been discovered in the South. However, the Republic's
greatest natural resource is its fertile 'chernozem' soils (the world's most fertile soil) which cover nearly
75% of its territory, 86% of which is being utilized by agriculture.
Thus, the major industries in Moldova are agriculture, viniculture and food processing (fruits and
vegetables. The country is an important regional producer of grapes and grape products, and its orchards
produce significant amounts of fruit, including plums, apricots, cherries, and peaches. Fruit production is
concentrated in the north, in the central region, and in the Nistru River area. Sugar beets are grown
throughout the republic and provide raw material for a substantial (although antiquated) sugar-refining
industry, and sunflowers are grown for their oil. Cereal crops, including wheat, are grown widely (corn is
the leading grain) and are used for domestic consumption, export, and animal feed. Meat accounts for less
than half of total agricultural production. Probably, the most widely known products of Moldova are its
wines, sparkling wines, cognacs and brandies, which were recognized as among the finest in the former
Soviet Union.
13
Material presented is paraphrased from the “republic of Moldova website@WWW. Moldova.org/abouto1.html and Worldbank.org
134
The Pesticide History
POPs pesticides were used in large quantities in the past in Moldova and still persist in the local
environment. In the 1950-1990s an estimated total amount of 560,000 tons of pesticides were used in
Moldova including 22,000 tons of organochlorinated pesticides (OCPs). Pesticides use registered a peak
in 1975-1985 but reduced dramatically over the last 10-12 years (from 38,300 tons in 1984 to some 2,800
tons in 2000, as active ingredient). The share of persistent OCPs also decreased, in favor of other
pesticide groups. During 1976-1990, soil samples showed pesticide contamination levels exceeding the
maximum allowable concentration (MAC) from five times in the Southern zone to 50 times in the Central
zone. Research undertaken by the Institute for Experimental Meteorology of the State Committee for
Meteorology of the FSU showed that in 1979-1985 about 60% of soil samples were polluted with DDT
exceeding the MAC, in spite of the fact that DDT was prohibited in 1970. Beginning in 1989, due to
reduction in pesticide application, investigations showed an anticipated decrease of pesticides-related
pressure both in annual and perennial crops. During 1990-1995, the regional Centers of Preventive
Medicine of the MOH analyzed the contents of 28 pesticides’ residuals in 10 agricultural crops and
foodstuffs. Pesticide residuals were found in 56.4% of the tomato samples and in 40 % of the grape
samples.
While Moldova has bans in place pertaining to pesticide production, use and import of these chemicals,
there remains stockpiles which must be safely stored and disposed of in an environmentally appropriate
and safe manner. This is not the current situation in Moldova and thus inadequate management has led to
the contamination of adjacent lands. In several cases, the contamination of nearby surface waters has
occurred as well.
Currently, as per the draft PAD, the total amount of obsolete pesticides in Moldova is estimated to be
approximately 5,650 tons, including about 3,940 tons buried at the pesticide dump in Cismichioi and
1,712 tons stored in 344 poorly equipped or unfitted facilities, which lack proper monitoring and security.
The composition of only 777 tons out of the total amount is known; and, of this, there is only a small
portion of POPs pesticides, 80 kg of heptachlor and 1600 kg of toxaphene. There is no knowledge of the
amount of POP pesticides that may be among the rest of the 935 tones of unidentified obsolete pesticides
stored in facilities14. These pesticides, especially the POPs components, pose a serious threat to human
health and the environment because they are stored in open, dilapidated warehouses (or literally fully
exposed to the environment in unlined, unsanitary landfills), exposed to the rain and thus transported to
soil, water and air were they can disburse and continually expand the circle of contamination and
concomitant threats and risks. Most of these sites are located near people and the resources upon which
their livelihoods depend – largely the rural poor.
The draft PAD notes that about 1700 tons of obsolete pesticides have been repackaged and restored in
centralized storage. It also notes that the Government expects by the end of 2005 to finish the job and
to repackage the whole amount of obsolete pesticides in centralized storage. The indication is that the
total amount of pesticides could be at the level of 2200-2500 tons. However in an Annexed document it
says there are 1700 of stockpiled POPs (inferring this amount is pesticides and PCBs) with only 777
tons being obsolete pesticides and just some of this pesticide amount might be POPs. These figures are
not consistent This begs the question how much POPs pesticides are we really talking about? This
needs to be clarified.
Electricity generation ranks second among industrial activities. Among the most pressing difficulties
facing the republic's economy is a near total lack of energy resources. Moldova's own primary energy
14
Tentative expert estimates suggest that Stockholm POPs may represent no more than 20% of existing stock of obsolete
pesticides.
135
sources, accounting for 1% of its energy needs, consist of: two small hydroelectric power plants
(Dubasari on the Dniester River) and Costesti-Stinca (on the (Prut River); a natural gas and coal fired
power plant with a capacity of over 2.250 million kilowatts (this was built in Transnistria over 30 years
ago). Chisinau power plants produce 30% of the electricity needs based on natural gas imported from
Russia. At the moment, none of the power plants are fuelled by coal. Much of the country's generating
equipment (which is not produced by Moldova) and approximately one-quarter of its transmission and
distribution lines are in need of repair. This implies that anticipated maintenance and upgrade
schedules need to be key considerations in the master plan for taking PCB equipment out of service
and anticipating PCB quantities to be destroyed.
PCBs are among the largest single group of organohalogen compounds by concentration in soil, sediment
and biota in remote environments along with DDT, chlordane, toxaphene and chlorobenzene-related
compounds. Monitoring in Moldova has detected and verified the movement of PCBs in soils in the
vicinity of contaminated sites. PCBs are almost invariably the major organohalogen contaminant in
environments near urban and industrial areas, a reflection of their broad application in the electrical power
industry, primarily in capacitors and transformers, but also their historical open uses in paints, oils and
plastics in some countries.
In addition to being ubiquitous and having a tendency to biomagnify, PCBs and their metabolites in
higher organisms have a broad spectrum of toxic effects. Considering their persistence, ubiquity,
relatively high concentration and wide range of effect, PCBs are probably the POP compound class of
most concern globally.
As noted on the draft PAD, the deterioration of the populations’ health since 1991 is in part linked to
environmental pollution and one of Moldova’s strategic objectives is to preserve and improve the quality
of the environment as a factor for ensuring public health. In particular, the burden of morbidity in
Moldova from the acute and chronic effects of exposure to POPs (in particular with POPs pesticides) is
significant. For example, in the 1980s, the frequency of detected pesticide residuals (including DDT and
HCH) in Moldovan foodstuffs was high and increasing, ranging from 5.6% (1984) to 19.8% (1990). The
most contaminated foods were fruits, canned goods, dairy products and meat.
Although the contamination frequency decreased during the 1990s, it is still a significant problem. The
most recent foodstuff data (2000) indicates that pesticide residuals are present in 3.1% out of about
12,000 analyzed samples of food crops.
Investigations undertaken in Moldova by health authorities in the peak period of pesticide application
(mid 1980s) found a significant exposure of humans to OCPs including HCH and DDT. HCH and DDT
were identified in the breast milk of women living in villages where significant amounts of these
pesticides were applied15. Between 87% and 96%, depending on the village, of breast milk samples were
contaminated with HCH and DDT. The concentrations of pesticides in body fluids also showed a clear
correlation with the level of pesticide application in the fields. The health impacts of OCPs on exposed
people included reproductive dysfunctions; other functional disturbances in women; and increased
frequency of male sterility. The incidence of these problems was positively correlated to the level of
pesticides use.
As noted in the draft PAD, Moldova has a large amount of stockpiled obsolete pesticides – amongst the
highest of any country in the world. (But not necessarily POPs pesticides – this case remains to be
15
Volneanschi A., Romanciuc P. Hygienic evaluation of the content of organochlorinated pesticides in breast milk (Rom.)
Proceedings of the III Congress of hygienists, microbiologists, epidemiologists and parazitologists of the Republic of Moldova,
Chisinau, 1992. P. 68-70.
136
made.) Of the 1,700 tons of stockpiled obsolete pesticides in warehouses/facilities (and over 4,000 tons
in a landfill), 777 tons are thought to possibly contain POPs.
The PCB Story in Moldova
Similarly, PCBs in Moldova are primarily used in the energy sector as dielectric fluids in power
installations, especially transformers and capacitors. There are currently no disposal requirements for
equipment contaminated with PCBs and tons of such material is stockpiled throughout the country. The
recent POPs inventory, undertaken in the context of the development of the national implementation plan
(NIP) for POPs, identified approximately 26,300 transformers, 17,000 capacitors and other electro-energy
equipment containing a total amount of dielectric oils of approximately 23,900 tons much of which is
expected to contain PCBs. The approximate breakdown reported is: capacitors from the electric industry
– 380 tons; other capacitors – 20-50 tons; electrical transformers – 18,000 tons; and, switches – 5,400
tons for a total of approximately 23,900 tons. Much of this equipment is no longer in use, e.g. only 1,000
of the capacitors are in use with the remainder primarily at one location (Vulcanesti) but unsafely
stockpiled there. Since PCBs can be readily released into the environment via equipment failures,
leakages, and vandalism, stockpiles of this equipment pose a significant risk to both human health and the
environment.
Scope and Objective of the Work
Given the relevant and priority issues identified in the previous description of the background, the stated
main development objective of this project is “sustainable POPs Stockpiles Management” with a view to
eliminating future POPs pollution from two main sources: POPs pesticide storage and PCB stockpiles and
equipment containing PCBs.
The title of “Sustainable Stockpile Management” seems to be a misnomer in that it implies an objective
of sustaining stockpiles where the correct notion is that the project will contribute to sustainable
development by eliminating stockpiles of POPs in the most efficacious manner possible and in the
quickest feasible timeframe.
The project has three major components:
Component I. Environmentally Sound Management and Disposal of Obsolete POPs Stockpiles
“This component will support on-the-ground investments for environmentally safe disposal of obsolete
POPs, including co financing for repackaging and centralized safe storage of obsolete pesticides, and
PCBs in the energy sector, as well as their final destruction.”
The POPs Pesticide Component
I have already noted the pesticide quantification inconsistencies that need to be clarified and made
consistent in the PAD. The key issue under this chapeau is that the following statement was
enunciated in the draft PAD and underpins the basis for action in the project document but appears to
be problematic “The composition of only 777 tons out of the total amount (of 5,650 tons or 13.7%) is
known and of this there is only a small portion of POPs pesticides, 80 kg of heptachlor and 1600 kg of
toxaphene. There is also no acknowledgement of the amount of POP pesticides that may be among
the rest of the 935 tons of unidentified obsolete pesticides stored in facilities. These statements seem to
suggest that there is an inadequate problem definition, especially from the perspective of POPs
designated pesticides. This further suggests that the major driver for this project component is pesticide
137
cleanup in general and not the POPs threat. The best problem solutions, from the point of view of
technical and economic considerations, are predicated on good problem definitions and it is clear that
this is lacking with respect to the POPs component of the local pesticide problem. Whereas obsolete
pesticides are a concern they all need not pose the same level of concern (or cost implications for
cleanup) as the POPs. However, under the circumstances, the costs of improving the problem
definition (better quantifying the POPs component of the pesticides which are the more dangerous)
might be outweighed by the mitigation cost considerations. Justification for the proposed “shotgun” or
“umbrella cleanup” approach needs to be better elaborated in the PAD.
Also, it is difficult to understand the basis for the pesticide component of the cost estimation provided
given the lack of precision on the obsolete pesticide problem.
Regarding disposal, the simplest solution from a management perspective, is always to recommend
packaging and shipment to an industrialized country for destruction / disposal. This implies that
almost everything is to be done by outside contractors. However, such an approach is costly, does not
contribute to the creation of sustainable means locally, or regionally, does not build the local
infrastructure and capacity to properly dispose of hazardous chemicals, does not create a sustainable
means of disposing of hazardous chemicals yet to be identified and leaves countries such as Moldova
totally dependent on foreign assistance or international aid programs to manage (especially destroy)
hazardous chemicals.
However, on the other hand, the storage and regional destruction option can not likely occur in the
near term (perhaps within the next 5-8 years) and thus the risks associated with delaying collection and
destruction (exposure will remain) is a counterbalance to this consideration. Perhaps. during the
conduct of this project it may be wise to promote consideration (in future) of the relevant agencies
working towards the provision of safe storage and the creation of a regional waste destruction facility
which is likely to be a key future consideration in relation to the Strategic Approach to International
Chemicals Management (SAICM).
Reference is made that since Moldova has a few hundred pesticide polluted hot spots, it is proposed to
pilot cleanup / remediation at three sites (cost estimate US $0.3 million per site). What is a few
hundred … 2 hundred? - 8 hundred? Is there no clearer estimate than this vague reference? What is
the basis for this cost estimate? If the estimate of significant sites are, for example, 400 and average
costs might be in the order of $0.3 million per site, we are looking at about $120 million US for
replication costs implied. Where will this money come from? Or, if there is no money available for
replication, what percentage of the existing problem is to be addressed via this project? These aspects
need to more clearly described in the PAD. Also, is the driver to clean up pesticide contaminated sites
or POPs pesticides contaminated sites?
The POPs PCB Component
Regarding the PCB component, and as previously noted, a good solution emanates from a good
problem definition and the reviewer strongly supports the observations in the draft PAD on the need
for the development and maintenance of an inventory of all PCB-containing equipment. There are
several aspects of the PCB inventory issue, however, that needs to be better discussed in the PAD. For
example, the idea of data collection via forms supported by a “hot line” will not likely ensure a
comprehensive data flow unless there is a regulation in place that makes mandatory that holders of
PCB-containing equipment notify the government; that clear accountabilities are assigned in the
private sector; that all staff that must participate have been trained and are aware of all aspects of the
problem; that the means to test (kits and/or labs) are available; that a national database has been
created and there are clear accountabilities within government for database management, especially
138
quality control.
The inventory must identify the level of PCBs (concentration) in each piece of equipment because this
in turn will affect safe storage requirements and management options as well as future destruction /
disposal options. These elements need to be emphasized in the PAD. This level of inventory precision
will demand greater stakeholder capacity building / engagement and creation of problem ownership
which will result in enhanced sustainable management practices.
The draft PAD reflects a comprehensive survey of the literature regarding the available technologies
for destruction. Since Moldova has a cement industry and thus cement kilns are readily available,
greater discussion should be included in the PAD regarding this destruction option; especially, why
this indigenous option has been ruled out.
Furthermore, if further inventory work identifies that there is a significant amount of equipment that
has low concentrations of PCBs, (mineral oils contaminated with PCBs) then the dechlorination
options will become more economically feasible. Also, this will enhance the case for creating safe
storage with a view to destruction in a mobile or even a regional facility that could be built in future.
This is an important point because much of the PCBs are located in equipment still in service and as
this comes out of service safe storage will be required. Also, the PAD should identify the need and
discuss what needs to be considered in the development of a series of management protocols: labeling,
monitoring, inspection, phase out schedule based on risk assessment criteria.
The draft PAD notes that holders of PCBs should develop detailed management plans for preventing
accidents and releases of PCBs. This is good but probably not enough. There should also be a
regulatory requirement to reporting all spills and significant penalties for any repeat contraventions.
Although the draft PAD acknowledges that there are likely a number of smaller products contaminated
with PCBs that will need to be dealt with (example, fluorescent lamp ballasts), the draft PAD does not
quantify this component, or more importantly, suggest how the destruction might be managed as it will
not make economic sense to package possibly a million or more such lamps for export.
The draft PAD notes that significant PCB contamination likely exists at many formerly state-own
plants / lands. Many of these may now be owned by the private sector or private land owners. In North
America, we refer to these as “orphan sites” because they usually pose a very difficult legal problem
and funding problem. How are these sites to be dealt with in Moldova? Is the Government to assume
problem ownership?
The draft PAD raises the issue of the available capacity for laboratory analysis and training and
outreach. It is recognized that the document does note that “support will be provided to strengthen the
lab capacity” but what is also needed is an explanation of what is there now, what is needed, how it
might be provided (via the Universities?, Government Agencies, Private Sector?) and the contribution
to made via this project.
The draft PAD acknowledges that, at the moment, there are no facilities in Moldova for PCB
destruction and creation of one could take 10 years, but again, contribution to a regional facility
should be considered (with contributions from a number of projects or from a new and additional
project) with future capacity building and sustainability in mind. What we should be working toward is
suitable regional infrastructure to facilitate the sound management of chemicals. Rest assured, there
will be new and additional hazardous chemicals in future that will need to be destroyed.
The draft PAD notes “The development of a hazardous waste management system in Moldova is still in
139
its very preliminary stages and this has been overcome in developing a project design in which all
operations can be undertaken within the existing legislation.” This statement seems overly optimistic
and is not sufficiently substantiated within the PAD.
The draft PAD also notes that consideration was given to just collect the PCB containing equipment
from the site and moving it into safe storage. This was rejected because the potential harm could be
exacerbated by leaving the PCB equipment in a storage vulnerable to renewed release by natural
disaster, accidents, fires or other human failures. In any case, the equipment has to be finally
destroyed and there is no reason for anticipating that cheaper disposal would be available in the future.
In total, the costs would be higher by establishing a temporary storage facility and store the
capacitors.”
I don’t agree. Safe storage is being practiced around the world and in many developing countries as
well. Safe storage would build capacity toward the ongoing management (including future needs) with
respect to managing hazardous chemicals. It would also create a supply of chemical to serve as
feedstock if a regional destruction facility was pursued.
The experience of the reviewer in other developing countries where PCBs have been used is that they
have historically been considered “non-problematic” in the work place. In fact, in one Asian country
visited, used PCB transformer oil was seen as a precious commodity and subsequently used to lubricate
sewing machines. This points to the criticality of educating with respect to the dangers and long term
consequences of exposure. It appears that the custodians of the PCBs in Moldova are well informed as
to the dangers of PCBs. If project implementation demonstrates otherwise, then careful attention, in
the PAD, will need to be given to awareness raising with respect to worker safety.
On a final note, it is clear that PCBs probably pose the largest POPs threat in Moldova. Priority
therefore needs to be given to identifying and restricting access to PCB contaminated sites. This
aspects also requires better elaboration in the PAD document.
COMPONENT II. STRENGTHENING THE LEGAL, REGULATORY AND INSTITUTIONAL FRAMEWORK
FOR POPS MANAGEMENT
Within this component it is proposed to undertake a series of activities related to: (a) Strengthening POPs
Institutional capacity; (b) Inventory, monitoring and enforcement activities; and (c) Training and capacity
building for POPs handling.
Open uses and minor electrical uses of PCBs (paints, varnishes, lubricants, motor capacitors,
fluorescent lighting fixture ballasts) pose a management and disposal problem that is not fully
addressed in the draft PAD. It is important that the existing inventory of PCBs be identified and
destroyed to the degree possible, since development of sites contaminated with PCBs will undoubtedly
enhance their loss to the environment. The question remains … is it better to safely store all; or, parts
of the problem, or, proceed with the more expensive export option.
Although not the first priority, it is also important to consider industrial sources (adventitious
production) of POPs emissions especially PCBs, Dioxins and Furans. Although Moldova is not
heavily industrialized in the sectors that normally create these emissions, a prime source of PCB
wastes, in turn, can, and will, generate in situ production of dioxins and furans via municipal
incinerators and capacity needs in this area need to be acknowledged.
In the “Inventory, monitoring and enforcement activities” section, reference is made to developing
“innovative financial mechanisms” .. what is it that the PAD designers have in mind? This needs to be
better elaborated in the PAD.
There is also reference to upgrading the laboratory capacity for POPs...what is in mind here? …
upgrading Government facilities? … Universities? …. .regional lab capacity? A fuller explanation
140
would be useful.
Similarly, reference is made to “targeted NATO assistance” in this regard with respect to pesticides
..this targeted assistance needs to be better described as well.
Component III. Project Management and Setting up of Center for Chemicals Management
This component would support public awareness and a participation program on POPs related
environmental and health problems, as well as replication of project results across the Region. The
project would also support improving inter-agency information sharing and information management
systems as well as strengthening of the National Environmental Information Center. This is in relation to
EIONET and relevant international Convention Secretariat’s; database of comprehensive, accurate and
regularly updated aggregated information quantifying POPs, with the possibility for upgrading (by other
sources and projects) for other relevant environmental information.
There is virtually nothing new or innovative about this project. All of the techniques and practices
have been utilized elsewhere many times. Therefore, there is little, if anything, that requires any
focused mechanisms for replication. Replication of any new or innovated aspects that arise during
implementation will likely be lead by industry through normal communications regionally within the
sector.
Also, the draft PAD properly acknowledges the critical role of stakeholder engagement. It appears
from the draft PAD that those that should be engaged will be engaged.
One estimate of world production of PCBs is 1.3 million tons (Watanabe et al., PCB Symposium 2003 in
Malaysia). Based on this assessment of the global problem of PCBs, this project addresses a very small
part of a large environmental concern.
It would be useful to put into the PAD, the scale of this PCB project component in a global context
(Moldova’s percentage contribution to the global problem) along with supporting rationale as to why it
is nonetheless important to proceed. It needs to be made clear that the cleanup of the known PCBcontaining equipment is likely to have a very significant impact on PCB loadings in Moldova (with
related reductions in health risks) and a small, but nonetheless meaningful, contribution to the
reduction of releases (and thus threats) to the global environment.
Perhaps, in a similar vain, it would be useful to elaborate more on the role that mitigation and cleanup
of these pesticides and PCBs play in relation to immediate risk reduction and the associated awareness
and capacity building this creates that will accrue additional benefits in future in the context of
international (and GEF) cleaner production initiatives and with respect to the current ongoing exercise
to develop a suitable framework for the Strategic Approach to International Chemicals Management
(SAICM).
Key issues
a.
Scientific and technical soundness of the project
Generally speaking, the project has been well thought out, and is technically sound. All of the
proposed technology and proposed actions have been proven / deployed elsewhere.
The biggest problems relate to the lack of problem definition that can greatly impact risk assessment,
risk management and costs and also lack of innovation and regional consideration with respect to the
current and future needs with respect to the sound management of chemicals.
141
A good analysis was made of the PCB component of the problem. However, what was obvious from
the analysis is that there is currently inadequate source management with respect to PCB-containing
equipment. A better PCB problem definition will facilitate a better technical discussion, for example,
the use of mobile dehalogenation equipment. Also, there may exist, but not described, a plan for
decommissioning existing and in-use PCB-containing equipment.
b.
Identification of the global environmental benefits and/or drawbacks of the project
POPs, especially PCBs are now being detected in breast milk and flesh content in animals in very remote
places. The buildup of the contaminates do not contribute to the physical well being of the planet or any
and all of its inhabitants and every effort must be made to reduce body burdens through lessening
exposure via improved management wherever such releases are occurring. This project will contribute,
albeit it a small way, to the reduction of the global POPs burden and the ongoing contamination of the
global food supply especially via reducing Moldova’s contribution to contamination of the aquatic
environment via long range transport.
Reductions in releases of POPs to the Moldovan environment will also contribute to improvements in
transboundary water quality.
As discussed under Scope and Objective of the Work, Moldova is very much an agriculturally dependent
country and there is therefore an urgent need of assistance to avoid POPs without undue economic impact
on its ongoing efforts with regard to poverty alleviation. Although Moldova possesses a relatively small
proportion of the world’s PCBs, and is therefore likely to be a minor contributor to the global PCB
burden, POPs is nonetheless, a major local health issue that needs to be addressed and to not be
allowed to increase the global POPs burden.
c.
How the project fits within the context of the goals of GEF, as well as its operational
strategies, programme priorities, GEF Council guidance and the provisions of the relevant
conventions.
Due to the geography and nature of resource use in Moldova, this projects will make a contribution to a
large number of GEF operational programs. Listed on the basis of the reviewers sense of the relative
priorities, these are briefly summarized as follows:
OP#14 – Persistent Organic Pollutants (POPs)
As noted in OP#14 – POPs is a global problem that can only be remedied by global action and this project
which addresses the major POPs contribution from Moldova (POPs pesticides and PCBs) is a clear fit.
The actions outlined are consistent with the objectives of the Stockholm Convention, the Basel
Convention and the Biodiversity Convention. There is evidence of strong country commitment, problem
ownership and an enabling environment. This program is, as is this project, all about taking action to
reduce and eliminate releases of POPs into the Environment. Thus, the project is also an excellent fit to
the goals of OP#14:
OP#15 – Sustainable Land Management
POPs adversely affect the ecological integrity of the agricultural land and also impacts adversely on
biological diversity. Thus, actions to mitigate these impacts address the intent of the Biodiversity
Convention. They also contribute to unsustainable agricultural practices and this context, this project is a
clear fit.
142
OP#10 – Contaminant-Based Operational Program
This project builds capacity to deal with PCB and POPs pesticide disposal in Moldova. Stakeholder
involvement and participation is to be built into the project. This OP specifically references the “Global
Contaminant Aspect and there is no clearer example of this than the POPs which this project addresses.
OP# 13 – Conservation and Sustainable Use of Biological Diversity Important to Agriculture.
This project, inter alia, addresses the aspect of soil conservation and restoration (contaminated site
cleanup) which is a defining characteristic of this OP and is thus a fit here as well.
OP# 4 – Mountain Ecosystems
The nature of the geography of Moldova creates a linkage with this OP.
d.
Regional context
The draft PAD does not address sufficiently the regional context of this project especially from the
point of view of commonality of problems and concerns and the need for capacities that might only be
affordable if pursued on a regional basis. Nonetheless, demonstration of success in achieving the goals of
this project may provide considerable encouragement to other countries in the region to undertake similar
POPs management and disposal projects.
e.
Replicability of the project (added value for the global environment beyond the project
itself)
The draft PAD speaks to replicability of component parts (example, clean up of contaminated sites) but
without sufficient detail to facilitate informed comment. There is little evidence of innovation and this
project is unlikely to create any new or revised model for POPs pesticides or PCB management and
disposal.
f.
Sustainability of the project
The short-term goal of the project is to find, collect and destroy the retrievable POPs pesticides and PCB
inventory in Moldova. This will likely be successful in relation to the stockpile of POPs thorough
addressing the totality of obsolete pesticides and through addressing equipment now out of service that
may have contained PCBs. However, the draft PAD acknowledges that cleanup of POPs contaminated
sites will be undertaken at just a few of the worst sites and there are probably several hundred remaining.
The worry is that lack of resources may preclude any further cleanup and the legacy of the project will be
that it cleaned up the high profile and current problem elements in Moldova aspect but not the historical
problem elements.
Sustainabilty of the project infers that this project will set in motion a program that will deal totally and
comprehensively with the POPs issue (current and future). There is little evidence that this is the case.
g.
In the case of target research project, it will be necessary to address the issue of the extent
to which the project will contribute to the improved definition and implementation of GEF's strategies
and policies, thus paving the way for more effective international, technical cooperation, assistance
and investment projects.
This is not a targeted research project.
Secondary
issues
143
a.






b.
Linkages to other focal areas
The GEF has six focal areas:
Biodiversity
Climate Change
International Waters
Land Degradation
The Ozone Layer
Persistent Organic Pollutants (POPs)
As already noted, this project relates to Biodiversity, International Waters; Land Degradation, Persistent
Organic pollutants and in a less obvious way it also contributes to Climate Change. The Climate Change
linkage is via the selection of destruction and/or remediation technologies that produces less green house
gases per tonne of POPs destroyed. The only focal area not addressed is the stratospheric ozone layer
protection.
Linkages to other programmes and action plans at regional or sub-regional levels
The draft PAD does not identify linkages to other programs at the regional or sub-regional level other
than other POPs projects undertaken in Moldova with the assistance of the World Bank and the GEF.
c.
Other beneficial or damaging environmental effects
This project is but one small but, nonetheless, meaningful step forward in the reduction of the human and
ecosystem body burden in relation to POPs.
d.
Degree of involvement of stakeholders in the project
To be successful, and to sustain results to be achieved, will require that all levels of government, affected
industries (especially the power industry), impacted farmers, concerned NGOs and the general public buy
into the necessity of this project, and work together to develop the appropriate regulations, trained
personnel and infrastructure to carry it out. The success of this project is likely tied much more to this
aspect than it is with the technical feasibility of destruction.
Efforts appear to have been expended to identify and include stakeholders. It is not clear, however, to
what degree the Universities, private sectors, community-based organizations and other NGOs will be
engaged, where and how they will be engaged (i.e. will they be engaged in a meaningful way). Projects
that have proven historically to be the most successful have some common attributes: transparency,
inclusiveness and clear accountabilities. It is not clear that this is the case for this project based on the
information provided in the draft PAD.
e.
Capacity-building aspects
The project is primarily about clean-up and capacity-building appears to be more of an ancillary
consideration. Capacity will clearly need to be built and the concern of this reviewer is that great
opportunities for needed capacity to be built in critical component areas will be lost if the problem
remediation experience is largely exported as suggested in the draft PAD.
f.
Innovativeness of the project
The draft PAD shows no evidence of being technically innovative, since all aspects have been deployed
elsewhere.
144
145
STAP Review Comments and Answers
#
Comments/Questions
Scope and objectives of the work
1.
The title of “Sustainable Stockpile Management” seems to
be a misnomer. The correct notion is that the project will
contribute to sustainable development by eliminating
stockpiles of POPs in the most efficacious manner possible
and in the quickest feasible timeframe.
Component I. Management and Destruction of POPs
a. The POPs Pesticide Component
2.
How much POPs pesticides are we really talking about?
3.
There is no acknowledgement of the amount of POP
pesticides and an inadequate problem definition from the
perspective of POPs designated pesticides.
4.
It is difficult to understand the basis for the pesticide
component of the cost estimation provided given the lack
of precision on the obsolete pesticide problem.
5.
It may be wise to promote consideration (in future) of the
relevant agencies working towards the provision of safe
storage and the creation of a regional waste destruction
facility.
146
Answers
Done The revised DO
clarifies this point and the
title has been changed to”
Persistent Organic Pollutnats
Management and Destruction
Project. .
Total of 6,940 tons as
follows: 3,940 tons in
Cismichioi landfill; 3,000
tons in 37 warehouses, of
which some 500 tons is
highly contaminated soil and
old drums.
As explained throughout the
PAD, there is no such
estimate. Due to the poor
storage conditions in the 344
warehouses, the entire stock
of obsolete pesticides has to
be assumed to be potentially
contaminated with POPs. It
will cost an estimated US$
9.74 million to test all of the
packages and drums that will
be in the 37 warehouses after
repackaging is completed in
order to make this estimate. It
will cost about US$ 6 million
to fully destroy this stock.
The cost estimates have now
been completed in detail, but
there is still some uncertainty
about final quantity of
repackaged pesticides that
will require disposal. This
uncertainty will be indicated
in the bidding and contract
documents.
See Section B 5 on the issue
of regional facility in respect
of this project.
6.
Concerning pesticides polluted hot spots about $120
million US for replication costs implied. Where will this
money come from? What percentage of the existing
problem is to be addressed via this project?
b. The POPs PCB Component
7.
The maintenance and upgrade schedules need to be key
considerations in the master plan for taking PCB
equipment out of service and anticipating PCB quantities
to be destroyed
8.
9.
10.
11.
Agree. The proposal to carry
out three pilot remediation
projects
at
POPs
contaminated sites has been
dropped from the proposed
project.
Agree provisions will be
made in the Management
plans that will be developed
under project Component 1.2,
Activity 1.
There are several aspects of the PCB inventory issue, that
need to be better discussed in the PAD regarding: (a) the
data collection via forms supported by a “hot line” and
need for a regulation in place that makes mandatory that
holders of PCB-containing equipment notify the
government; (b) clear accountabilities that should be
assigned in the private sector; (c) the issue that all staff that
must participate have been trained and are aware of all
aspects of the problem; that the means to test (kits and/or
labs are available); (d) the need to create a national
database and of the clear accountabilities within
government for database management, especially quality
control.
Done
Annex 4 description of Subcomponent 1.2.1 now has a
clear description of the
different PCB components.
The involvement of the
Ecological Inspectorate has
been strengthened and the
laboratory of the Inspectorate
will be responsible for PCB
detection using testing kits.
The Inspectorate also will be
provided with kits for control
inspections. The preparation
and maintenance of a PCB
database will be stipulated in
the Moldovan PCB regulation
and an MIS database will be
developed in PMT.
The inventory must identify the level of PCBs Done
(concentration) in each piece of equipment because this in See Component description in
turn will affect safe storage requirements and management Annex 4
options as well as future destruction / disposal options.
These elements need to be emphasized in the PAD.
Since Moldova has a cement industry and thus cement Done
kilns are readily available, greater discussion should be See Section B 5
included in this report regarding this destruction option;
especially, why this indigenous option has been ruled out.
If further inventory work identifies that there is a
significant amount of equipment that has low
concentrations of PCBs, (mineral oils contaminated with
PCBs) then the dechlorination options will become more
economically feasible. Also, this will enhance the case for
creating safe storage with a view to destruction in a mobile
or even a regional facility that could be build in future
147
Done
Mobile
facilities
for
dechlorination
of
PCBcontaminated transformer oils
are readily available in
Europe on a commercial basis
e.g. from the company ABB.
In Annex 1 it is specifically
12.
13.
14.
15.
16.
16.
17.
mentioned that this process
should be considered for
future treatment of such oils.
The PAD should identify the need and discus what needs Done
to be considered in the development of a series of See Annex 4 Sub-component
management protocols: labeling, monitoring, inspection, 1.2, Activity 1.
phase out schedule based on risk assessment criteria.
The PAD notes that holders of PCBs should develop Agree
Guidelines
for
detailed management plans for preventing accidents and environmentally
sound
releases of PCBs. There should also be a regulatory management
of
PCBrequirement to reporting all spills and significant penalties containing equipment will be
for any repeat contraventions
prepared as part of Subcomponent 1.2, Activity 1.
Although the PAD acknowledges that there are likely a Today there is no available
number of smaller products contaminated with PCBs that information on type-numbers
will need to be dealt with (example, fluorescent lamp of small capacitors produced
ballasts), the document does not quantify this component, in the former Soviet Union. In
or more importantly, suggest how the destruction might be Annex 1 it is mentioned that
managed as it will not make economic sense to package all small capacitors produced
possibly a million or more such lamps for export.
before
1990
must
be
considered PCB-containing.
Considering the life-time of
the
equipment,
most
capacitors
are
probably
already disposed of with the
equipment. Consistent with
Annex A, part II of the
Stockholm
Convention,
equipment containing more
than 5 liters of PCBcontaining liquid is assigned
the highest priority and
addressed within this project.
How are the previously PCB polluted “orphan sites” to be Done
dealt with in Moldova? Is the Government to assume More discussion about the
problem ownership?
"orphan sites" and the
regulatory implications has
been added to Annex 4.
The PAD raises the issue of the available capacity for Done
laboratory analysis and training and outreach. It is More details about the
recognized that the document does note that “support will laboratory capacity building
be provided to strengthen the lab capacity” but what is also have been added to Annex 4
needed is an explanation of what is there now, what is
needed, how it might be provided (via the Universities?,
Government Agencies, Private Sector?) and the
contribution to made via this project.
What we should be working toward is suitable regional See Section B5 regarding
infrastructure to facilitate the sound management of such a facility
chemicals.
The PAD notes “The development of a hazardous waste Done
148
18.
management system in Moldova is still in its very
preliminary stages and this has been overcome in
developing a project design in which all operations can be
undertaken within the existing legislation.” This statement
seems overly optimistic and is not sufficiently
substantiated within the PAD.
I don’t agree that the storage of obsolete POPs and POPs
contaminated equipment it is not a viable solution. Safe
storage is being practiced around the world and in many
developing countries as well. It would build capacity
toward the ongoing management (including future needs)
with respect to managing hazardous chemicals.
The statement is deleted
Safe storage is practicable,
but is deemed to increase the
total costs. There is no reason
for expecting the costs of
future destruction of the POPs
to be lower than today's. The
estimates indicate that the
costs of transport to a facility
in Western Europe are
approximately 10% of the
total costs for destruction.
19. Priority needs to be given to identifying and restricting The
known
PCB
access to PCB contaminated sites.
contaminated sites are all
situated on fenced substations
with restricted access. Proper
marking of the sites within
the substations should be a
part of a management plan for
the
sites
prepared
by
Moldelectrica on the basis of
the
experience
of the
feasibility study.
Component II. Strengthening the Legal, regulatory and Institutional Framework for POPs
Management
20. Open uses and minor electrical uses of PCBs (paints, Management of PCBs from
varnishes, lubricants, motor capacitors, fluorescent lighting open applications and minor
fixture ballasts) pose a management and disposal problem uses is beyond the scope of
that is not fully addressed via this project.
the present project. See the
answer to comment 14.
21. It is important to consider industrial sources (adventitious The unintentional production
production) of POPs emissions especially PCBs, Dioxins of POPs in Moldova is
and Furans.
beyond the scope of the
present project.
In the “Inventory, monitoring and enforcement activities” Reference is deleted
section, reference is made to developing “innovative
financial mechanisms” - what is it that the project
description has in mind?
23. There is a reference to upgrading the laboratory capacity Three laboratories will be
for POPs...what is in mind here? - upgrading Government upgraded under the project.
facilities? Universities…. .regional lab capacity.
See Annex 4 Description of
Similarly, a reference is made to “targeted NATO Sub-component 2.2. Another
assistance” in this regard with respect to pesticides, - this laboratory in MAFI will be
targeted assistance needs to be better described as well.
upgraded by NATO
Component III. Project Management and Setting up of Center for Chemicals Management
22.
149
24.
It would be useful to put into the project document, the Done
scale of this PCB project component in a global context
Information has been added
to Annex 1, indicating that
the
project
significantly
contributes to reducing the
PCB problem in Moldova
taking the size of the country
into account.
25.
It would be useful to elaborate more on the role that Done
mitigation and cleanup of the pesticides and PCBs play in
relation to immediate risk reduction and the associated
awareness and capacity building.
Key issues
a. Scientific and technical soundness of the project
26.
The biggest problems relate to the lack of problem Done
definition that can greatly impact risk assessment, risk The PCB problem definition
management and costs and also lack of innovation and has been clarified to the main
regional consideration with respect to the current and part of the PAD
future needs with respect to the sound management of
chemicals.
27.
A better PCB problem definition will facilitate a better
technical discussion. Also, there may exist, but not
described, the plan for decommissioning existing and inuse PCB containing equipment.
Today
no
plans
for
decommissioning of in-use
PCB-containing equipment
exist in Moldova. This will be
addressed by the preparation
of a PCB management plan
based on the results of the
inventory.
d. Regional context
The draft PAD does not address sufficiently the regional To the extent this is possible,
context of this project
this has been done in Annex
1.
c. Replicability of the project
29.
The PAD speaks to replicability of component parts but On a global scale the project
without sufficient detail to facilitate informed comment. is not innovative and does not
There is little evidence of innovation and this project is intend to be. However, the
unlikely to create any new or revised model for POPs experience obtained in this
pesticides or PCB management and disposal.
project
regarding
management
of
PCBcontaining equipment and site
clean-up will be very useful
for the future managements of
PCBs and PCB contamination
in Moldova.
f. Sustainability of the project
30.
Sustainabilty of the project infers that this project will set Done
in motion a program that will deal totally and Annex 4 descriptions of
comprehensively with the POPs issue (current and Components 2 and 3 address
future). There is little evidence that this is the case.
this issue in detail.
28.
150
Secondary issues
31.
The PAD does not identify linkages to other programs at
the regional or sub-regional level other than other POPs
projects undertaken in Moldova with the assistance of the
World Bank and the GEF.
32.
It is not clear, to what degree the Universities, private
sectors, community-based organizations and other NGOs
are engaged, where and how they will be engaged (i.e.
will they be engaged in a meaningful way).
151
Done
Annex
2
deals
comprehensively with this
Done
Sub-component 3.1 Activities
3 and 4 deal with this. These
organizations also have been
actively
involved
in
consultations on the NIP and
EA
ANNEX 17: MAPS
152