UNITED NATIONS INDUSTRIAL DEVELOPMENT ORGANISATION INSTITUTE OF ENVIRONMENTAL PROTECTION POLAND PROJECT GF/POL/01/004 ENABLING ACTIVITIES TO FACILITATE EARLY ACTION ON THE IMPLEMENTATION OF THE STOCKHOLM CONVENTION ON PERSISTENT ORGANIC POLLUTANTS (POPs) CRITERIA AND PRIORITIES FOR DEVELOPMENT OF THE NATIONAL STOCKHOLM CONVENTION IMPLEMENTATION PLAN OF POLAND TECHNICAL REPORT OF THE PHASE III PRIORITY ASSESSMENT AND OBJECTIVE SETTING (January/March – May 2003 r.) Director of the Institute of Environmental Protection Prof. Barbara Gworek National Project Manager Prof. Maciej Sadowski Warsaw, May 2003 GF/POL/01/004 Project Lead Authors: Maciej Sadowski, Krzysztof Czarnomski, Wanda Kacprzyk, Wiesław Kolsut, Krzysztof Olendrzynski Technical Report of the Phase III GF/POL/01/004 Project Technical Report of the Phase III TABLE OF CONTENTS Page INTRODUCTORY REMARKS ................................................................................................ 4 INFORMATION AND DATA GAPS ....................................................................................... 5 DETAILED ANALYSIS OF PROVISIONS OF THE STOCKHOLM CONVENTION AND ITS ANNEXES................................................................................................................. 7 SWOT ANALYSIS .................................................................................................................... 8 DEVELOPMENT OF CRITERIA FOR PRIORITY SETTING ............................................... 8 PRIORITY SETTING BASED ON THE ADOPTED CRITERIA ......................................... 11 DETERMINING LONG AND SHORT TERM GOALS ........................................................ 14 ASSESSMENT BY THE STEERING COMMITTEE ............................................................ 16 NATIONAL VALIDATION WORKSHOP ............................................................................ 16 APPENDICES Appendix 1. Analysis of the Stockholm Convention provisions Appendix 2. SWOT Analysis Appendix 3. Criteria and priorities adopted for the development of the National Stockholm Convention Implementation Plan Appendix 4. Preliminary list of tasks for the development of the National Stockholm Convention Implementation Plan for Poland in the light of adopted priorities Appendix 5. List of reports distributed during the National Validation Workshop Appendix 6. Cost efficiency analysis IEP, Stockholm Convention Focal Point, Warsaw, Poland 3 GF/POL/01/004 Project Technical Report of the Phase III INTRODUCTORY REMARKS Implementation of the Stockholm Convention requires undertaking and implementation of activities aiming at prevention of the persistent organic substances (POP) penetration into the environment as well as elimination of residues, remaining after use and production of substances and preparations containing POPs, from the environment. These activities must be performed in a sequence resulting from real and potential threats caused by the POPs presence in the environment and the probability of their release from the existing landfills, warehouses and installations1. In accordance with the scope and implementation schedule of the GF/POL/01/004 Project, the task of the Priority Setting Phase was the determination of criteria for priority setting, definition of priority national goals and establishment of long and short-term targets as a base for the formulation of the National Stockholm Convention Implementation Plan (NIP). This report reflects the activities performed in this respect. The superior goal derives from the National Environmental Policy of Poland, which, among others indicates the necessity to undertake the following tasks: “abandon production and use, or reduce using hazardous substances and materials, controlled by the EU Directives and international legal regulations containing …, persistent organic pollutions …” and “elimination and reclamation of old burial grounds where pesticides and other toxic substances were stored, …” Activities, the implementation of which should be included in the NIP, are subdivided into three basic groups: Aimed at prevention against POPs penetration into the environment; Aimed at POPs elimination from the environment; Ensuring, in accordance with the requirements of the Stockholm Convention, control over compliance with that Convention. Prevention against POPs penetration into the environment are concerned with: use, turnover, and manufacturing2 of substances subject to the Stockholm Convention. Activities concerning elimination of POPs include: elimination of residues from the environment after their use, elimination from use (applies to PCBs), removal of stock of plant protection chemicals and other POPs containing materials3, removal of POPs from industrial waste dumps (or prevention of their releases into environment), neutralization of POPs containing waste generated during current activities. Each activity concerning the three POPs: Pesticides, PCBs, and POPs from technical processes (undesired by-products) undergoes separate assessment. 1 installations containing POPs or polluted by them as an undesired product of technical processes 3 stored under conditions causing a high risk of environmental releases 2 IEP, Stockholm Convention Focal Point, Warsaw, Poland 4 GF/POL/01/004 Project Technical Report of the Phase III Control of POPs presence is performed by tracking changes in their environmental concentrations both by the measuring and the analytical systems, ensuring institutional capacity, human resources and management efficiency for functioning of the system as well as development of methods of control or updating the existing methodology. According to the guidelines, the two documents mentioned below were taken as basic for studies on identification of criteria for priority selection: Firstly, the report “National POPs Profile. Poland” containing the basic information about the situation concerning the persistent organic pollutions covered by the Stockholm Convention with reference to all elements of environment. It provides a comprehensive review of the current situation concerning POPs issues in Poland and presents a good base for further analyses. The document describes the specifics of the Polish situation concerning POPs, revealing, through the inventories results, equally the most important achievements and the main deficiencies. However, since no identification of information gaps in the collected material was foreseen by the design of the National POPs Profile a separate review covering that aspect was performed during the Priority Setting Phase. Below, after the description of the main issues resulting from the POPs situation inventories carried out during the 2nd Project Phase, the scope of information shortage has been presented. It will be, as much as possible, supplemented during the execution of the projects 4th Phase. In order to define gaps in the processed material and make the review of results of the Inventory Phase a SWOT analysis concerning implementation of the Stockholm Convention was carried out (Appendix 2). It was found, upon analysis of the file of gaps, that this additional information present a significant supplementation of the scope of tasks for future implementation within the framework of the established priorities and provide a supporting criteria for the assessment priority setting correctness. Secondly, the provisions of the Stockholm Convention and its annexes containing about 80 clauses directly or indirectly related to Polish conditions indicating tasks for implementation (Appendix 1). They were also among the premises for the development of the National POPs Profile. Review of those provisions in terms of the situation in Poland, including identification of the scope of tasks for implementation, was subject of special activities of the Priority Setting Phase. Tasks imposed by the Stockholm Convention overlapped to some extent with tasks defined during the preliminary stage of the Inventory Phase, stressing the importance of some issues for the implementation of the Convention as such. INFORMATION AND DATA GAPS Gaps concerning POPs releases into specific environmental components From data of inventories systematically conducted since a number of years, concerning environmental releases of POPs (PCDDs, PCDFs, PCBs and HCBs) from their unintentional generation, a significant differentiation in data completeness presenting emissions to specific environmental components as well as specific pollutions was detected, namely: Considerable supplementing is required by the database of POPs release factors from unintentional generation into wastewater. Creation of database on sources of unintentional production of POPs polluting wastewater in surface waters should be pursuit. IEP, Stockholm Convention Focal Point, Warsaw, Poland 5 GF/POL/01/004 Project Technical Report of the Phase III The least volume of available information refers to releases into solid waste in industrial production and power generation processes. An important complement of the above information is the fact, that Poland has an abundant set of results from analytical studies concerning actual POPs content from their unintentional production in gaseous releases into air from all the basic high temperature processes. These tests are still systematically conducted. Much lesser volume of accumulated data exists in respect of the remaining environmental components. Thus, in both cases performance of measurements allowing elaborating the release factors will be required. Gaps concerning POPs environmental releases from their unintentional production Emission factors, concerning polychlorinated dibenzodioxins and polychlorinated dibenzofurans, applied for inventories of air emissions, are basically complete and currently verified by taking measurements in the applied high temperature processes. They require just minor supplementations. The situation concerning factors related to emission of HCBs and PCBs requires considerably more supplementation requiring analytical investigation of specific processes, including releases into wastewater, solid waste and into the manufactured products. The latter took place primarily during the decades of 1960 and 1970, thus when HCH, PCNB and PCP were produced in Poland. Gaps in information about the quantities of pesticides containing substances subject of the Stockholm Convention imported to Poland in the past Data on quality describing composition of the imported pesticides containing substances subject of the Stockholm Convention imported to Poland are available. However, assessments on quantities of active substances imported in that manner are missing. They have been determined by assessment, because the composition of preparations deposited in burial grounds is not known. Lack of quantitative data is not very important for activities to performed in future on development and implementation of the NIP, even more so, because no real chances exist that the relevant statistical data will be available. Lack of central database on PCB polluted equipment and waste in Poland A number of partial inventories were carried out in Poland. At present, a complex inventory, based on a detailed ordinance of the Minister of Economy, is being carried out throughout the country under the supervision of the voivods (regional governors). Results of this exercise will be available by the end of this year. Information obtained will allow assessing the volume of equipment requiring decontamination as well as the amount of PCB and PCB containing waste and also assessing a detailed action plan in this respect. Shortage of information about industrial waste dumps of works, which in the past produced or still produce organic chloride substances Full information about the producers of organic chloride substances operating landfills of production waste. However no complete information about the present state of those wastes and about the opportunities or time frame of their neutralization is available. This problem is particularly significant at the Jaworzno Chemical Works, where apart waste from past production of DDT and HCH deposited on the landfill also other substances covered by the Stockholm Convention are present. In addition to that the land filling process as such was IEP, Stockholm Convention Focal Point, Warsaw, Poland 6 GF/POL/01/004 Project Technical Report of the Phase III conducted without proper selection. The remaining enterprises do operate adequate waste management or neutralisation facilities, though data on processing waste from landfills were not available. Complete data concerning the presence of wastes containing POPs on landfills operated by the enterprises and POPs environmental releases from these landfills are not available too. Gaps in data concerning POPs concentrations in living organisms (men and animals) Assessment of POPs concentrations in living organisms provides the base for assessment of exposure and human health risk as well as environmental risk. Studies of those aspects carried out to date provide insufficient evidence for reliable determination of the exposure intensity in Poland and the relevant human health risk. This is particularly valid in relation to exposure to dioxins and dibenzofurans as well as to a large extent to PCBs. Without filling-up that gap the complex assessment of the POPs situation in Poland, in the context of compliance with provisions of the Stockholm Convention, will not be possible. Lack of data, confirmed by Polish research, on transformation of active substances of pesticides as well as PCDDs/PCDFs and PCB in the soil environment It is necessary to initiate research activities on transformation of primarily DDT and toxaphen (which use until 1980 was the largest in agriculture and forestry) in the soil environment. Reports on some partial studies, for instance describing the run-off of substances included in the Stockholm Convention into rivers and their concentration in bottom sediments, waters and aquatic living organisms. Bu the available information cannot be regarded as comprehensive and complete. DETAILED ANALYSIS OF PROVISIONS OF THE STOCKHOLM CONVENTION AND ITS ANNEXES Upon completion of the Inventory Phase additional analysis of the Stockholm Convention and its Annexes was carried out having in mind the elaboration of criteria for priority setting and the priorities as such as well as for the determination of specific tasks of the NIP for Poland. In result 80 tasks arising from provisions of the Convention and its Annexes were identified (Appendix 1). In respect of these provisions the Present situation in Poland, indicating tasks already completed or in course of implementation, and the lack of activities in certain areas, as well as Tasks proposed for implementation with the aim to fulfil possibly best the Stockholm Convention have been described. In course of the Inventory Phase main attention was focussed on the situation concerning production, use and releases of POPs generated intentionally and unintentionally and on particular components of environment. The scope of analysis and inventory of municipal waste management and hazardous waste, with emphasis on outdated pesticides and the situation about the PCBs management, was particularly extensive. During the final phase of project implementation special attention will be turned to the issues of public communication, information about threats and to the education system aimed at continuous rise on public awareness etc. IEP, Stockholm Convention Focal Point, Warsaw, Poland 7 GF/POL/01/004 Project Technical Report of the Phase III The issues analysed may be subdivided into four groups: Issues connected with the activities performed during the Inventory Phase and establishment of diagnosis of the current situation in Poland. Results reflected practically almost completely the conclusions of the inventory report. Issues not covered by the Inventory Phase but linked to the National Environmental Policy, national strategy of environmental protection against POPs (encompassing implementation of the Aarhus Protocol and the Stockholm Convention provisions), provisions of other conventions as well as with relevant legal regulations of the EU and Poland. The situation in this respect can be assessed positively in the light of these studies. Issues including, in broader terms, the institutional support of the Stockholm Convention at country level, including monitoring of the situation in Poland, feasibility of extending the Stockholm Convention requirements on further substances, reporting system etc. This group of issues does not have the final and effective organisational shape and is under development. Social and economic issues, including raising public awareness on POPs and combating negative effects caused by them in the environment as well as the system of research and development capacities. Results of this analysis were considered when criteria followed by priorities and NIP tasks were formulated. Problem included into the elaborated list were obviously compatible with the results of works performed to-date and the main statements of the National POPs Profile Poland. This is also thru for the legal system and the necessity for its amendment. The list of analysed provisions of the Stockholm Convention, together with the description of the Polish situation, constitutes the Appendix 1 to this report. SWOT ANALYSIS The scope of issues, described above, including analysis of particular provisions of the Stockholm Convention with reference to the Polish situation, analysis of main conclusions of the inventory activities and the analysis of the main gaps concerning information required for proper implementation of the Stockholm Convention requirements, presents a rich and diversified material, and therefore quite difficult for versatile review and utilisation. In order to make it easier, for the above-mentioned reasons, the SWOT analysis, based on results of works performed and conclusions reached during the Inventory Phase, was carried out. Appendix 2 to this report presents results of that analysis. This analysis, together with the list of gaps provided above was used in priority setting procedure. DEVELOPMENT OF CRITERIA FOR PRIORITY SETTING The first step in preparatory activities for the selection of priority setting criteria and defining, based on these criteria, priorities required for further work on development of the National Stockholm Convention Implementation Plan, was the detailed review of the Inventory Phase report. This allowed, together with the remaining analyses mentioned above, making a IEP, Stockholm Convention Focal Point, Warsaw, Poland 8 GF/POL/01/004 Project Technical Report of the Phase III preliminary selection of issues resulting from the need for filling the existing gaps and influencing the criteria elaboration process. Another, secondary goal of this activity was the final edition and supplementation of the inventory report aimed at its preparation for publishing. Most of the effort made in preparation of criteria was carried out during frequent meeting of the team of experts leading the main groups of problems of the project’s subject matter, under chairmanship of the Project Manager. Several versions of criteria sets were developed and expert simulations on their impact on priority setting, completeness and compatibility of these priorities as well as opportunities to determine long and short-term goals to attain in accordance with those priorities. The approach to criteria and priority setting was based on expert evaluation of importance of specific problems and was concluded by preliminary formulation of criteria and their ranking followed by setting priorities based on the said criteria. Material prepared in such a manner was presented to the Steering Committee and later to experts and stakeholders gathered at the National Validation Workshop for final discussion and acceptance. Finally five criteria described below were formulated and endorsed, with weights presented in Tables 1 and 2 attached to them: Criteria K-1. Importance for implementation of main groups of tasks defined by the inventory process Under this criteria the selection of such priority tasks (in most cases complex in character) was anticipated, the implementation of which would lead to final solution of problems important in terms of the Stockholm Convention. This criterion is significant for the assessment of one of the most important priorities concerning final and ultimate elimination of POPs from production, use and from the accumulated stocks of waste. Criteria K-2. Importance for the implementation of the Stockholm Convention provisions This criterion serves the assessment of priorities in terms of their importance under the conditions of Poland. It is significant for the adaptation of the Stockholm Convention requirements to the Polish conditions concerning both, the use of POPs and the residues remaining after such use. Criteria K-3. Suitability for evaluation of the Stockholm Convention implementation progress. Assessment of priorities determining terms of control and monitoring of activities performed under the NIP will be enabled by this criteria. It promotes actions aiming at creation of information bases providing for the assessment of the extent of human health and environmental hazards. IEP, Stockholm Convention Focal Point, Warsaw, Poland 9 GF/POL/01/004 Project Technical Report of the Phase III Criteria K-4. Advancement of implementation to date This criteria was adopted in order to give preference to undertakings, which implementation is already considerably advanced or activities on execution of certain tasks are conducted systematically, as is the case with emission inventories, bans of production and use of POPs subject of Stockholm Convention. It was found during investigations by the expert team, that the above criteria, though apparently quite general, made the selection and comprehensive analysis of priorities, prior to their final endorsement, possible. This analysis has taken in mind all factors, significant in terms of the situation in Poland as well as provisions of the Stockholm Convention and currently implemented tasks. The group of criteria described above was developed in such a manner, that each single priority was evaluated for its importance for the implementation of groups of tasks deriving from POPs inventories and execution of other provisions of the Stockholm Convention as well as for their suitability to check the degree of implementation of the Convention provisions. Such set of assessments resulted in the total of points, determining the hierarchy of importance of particular priorities. Table 1 presents the scope of weight points attached to particular criteria. Table 1. Criteria and the range of weight points Criteria Importance for implementation of main groups of tasks defined by the inventory process Importance for the implementation of the Stockholm Convention Suitability for evaluation of the Stockholm Convention implementation progress. Advancement of implementation to date Symbol K-1 Weight 60 - 100 K-2 K-3 40 – 80 30 – 60 K-4 20 - 40 Criteria K-5. Additional set of criteria Experts, participating in developing criteria, regarded advisable to add an additional set of criteria K-5 deriving from the GF/POL/01/004 Project requirements (Guidance for developing a National Implementation Plan for the Stockholm Convention) taking in consideration the: required implementation deadlines, financial requirements, state and requirements of the technical back-up, state of human resources, impact on human health Point score adopted within the framework of the K-5 group presented a component of the total of assessment of particular priorities (Table 2). IEP, Stockholm Convention Focal Point, Warsaw, Poland 10 GF/POL/01/004 Project Technical Report of the Phase III Table 2. Additional criteria (K-5) resulting from requirements of the GF/POL/01/004 Project Timeliness v. urgent - 20 Financial requirements high -5 urgent - 15 moderate - 10 not urgent- 10 low - 15 Technical backup facilities Human resources Health impacts needed - 10 good - 10 high - 10 not needed - 5 sufficient - 5 moderate - 5 low - 2 low - 2 PRIORITY SETTING BASED ON THE ADOPTED CRITERIA A number of possible solutions were considered in course of formulating the list of priorities. Examples of options discussed are presented below: Recording and registration of waste landfills and POPs neutralisation enterprises (incinerators); Management of PCB/PCT waste; Plans of POPs containing waste management; PCB neutralisation and burial grounds elimination and reclamation action plans; Plans for removal of POPs from landfills of industrial waste and safe-guard such landfills; Introduction of market mechanisms into POPs management schemes; Maintenance of records of wastes and installations for their elimination; Control and monitoring programme for the existing waste landfills; Monitoring of POPs concentrations in food products; Recording PCB contaminated enterprises and facilities and development of action plans for their safe decontamination; Preparing emission reduction programmes of POPs (PCBs/PCTs, HCBs) from industrial and power generation processes; Action plan to eliminate POPs emission from timber incineration processes; Inventory of industrial works and facilities unintentionally releasing POPs; Programme for minimisation of unintentional POPs releases; Development of emission standards for incineration plants, power plants and industrial works (processes); Proposals for amendments of legal regulations; Limiting or elimination of primary pollutions from raw materials being incinerated or processed; Focus attention on large POPs emission sources. In addition to that a number of other proposals was considered, for instance: supervision arrangements on implementation of the Stockholm Convention provisions, introduction of alternative technologies into waste neutralisation practice, development of the monitoring system, use of cement factories for hazardous waste management and many others and they were considered during the NIP development. Their weight scores, in course of the priority setting process, were much lower than those attained by the 10 priorities listed below. The IEP, Stockholm Convention Focal Point, Warsaw, Poland 11 GF/POL/01/004 Project Technical Report of the Phase III latter have been selected as the main priorities of the National Stockholm Convention Implementation Plan. I. Establishment of comprehensive conditions preventing production or renewal of production of POPs and insurance for the improvement of the control system on production and handling of pesticides as well as chemical substances and preparations containing substances subject of the Stockholm Convention (with due regard of the Aarhus Protocol to the Geneva Convention on POPs and the EU regulations) II. Elimination from the environment of PCBs contained in electrical installations out of use and in discarded electrical equipment III. Elimination outdated pesticides from the environment (removal of burial grounds and stocks still resting in warehouses) The three priorities mentioned above are in principle, apart from elimination of possibilities for renewal of intentional production of POPs, concerned with the complex elimination of historical residues of POPs from environment. The latter include primarily outdated pesticides containing substances subject of the Stockholm Convention and PCBs being still in use and electrical equipment out of use. IV. Development of principles for the improvement of the inventory system of environmental releases of PCDD/PCDF, HCB and PCB from production processes and from other extra-industrial sources with verification of emission factors. V. Keeping record of POPs emission sources in accordance with the PRTR (Pollutant Release & Transfer Register). List of identified waste landfills containing POPs (pesticides and PCBs are subject of a separate registration) VI. Prevention of emissions of PCDD, PCDF and PCB generated unintentionally, beginning with sources of the largest share in total emissions The No. IV, V and VI priorities are primarily concerned with emissions and emission sources of POPs generated unintentionally and aimed at their limitation. Their execution will also provide elevation of data credibility gathered in result of annual emission inventories and support use of real, not theoretical emission factors from specific thermal processes. So far, general activities (production volumes), published by the Polish statistics, were used to calculate the emission of POPs generated unintentionally. These data did not distinguish between specifics of particular thermal processes. Introduction of the PRTR system will eliminate this handicap of the present public statistics. VII. Development of the national strategy for exchange of information, education, communication and raising awareness within the Stockholm Convention provisions. Advancement of priority VII is very low in Poland. Neither adequate information materials nor education system exist. Deficiencies in public awareness in this respect are particularly felt at the lower levels of regional authorities. Implementation of this priority will obviously be slowed down by the fact of considerable technical complication of the entire POPs complex. IEP, Stockholm Convention Focal Point, Warsaw, Poland 12 GF/POL/01/004 Project Technical Report of the Phase III VIII. Reduction of POPs emissions in processes of waste disposal Emission of POPs (PCDD/PCDF, PCB, HCB, HCH) is taking place through incineration of waste containing organic chloride compounds. These phenomena can be prevented by ensuring, that waste incineration is performed under adequate conditions (high temperature, longevity of the process endurance, excess of oxygen in combustion gases). Standards valid in Poland are determined by the PCDD/PCF concentrations and the content of TOC compliant with the EU regulations. Potentially, however, waste incineration may pose a considerable source of POPs air emission, because of the commonness of burning waste as fuel substitute. It is necessary to make efforts aimed at setting new technologies working as well as at prevention of POPs precursors to appear in waste. IX. Management of waste from cleaning of combustion gases and waste & wastewater containing POPs Waste from cleaning combustion gases from processes, in which POPs are generated as a byproduct, wastewater sludge (as a secondary source of POPs) and other by-products of technical processes containing POPs require particular control, being potential sources of environmental releases of those substances. It is necessary to identify and register these sources and set up requirements for removal and neutralization of these wastes. X. Solving the problem of industrial landfills of waste containing POPs In result of the project Inventory Phase landfills of industrial waste, on which POPs waste from POPs or pesticides production processes containing substances subject to the Stockholm Convention are or may be present. It turned out, that gathering additional information on these landfills is necessary as well as elaboration of guidelines concerning elimination or reduction/prevention of environmental POPs releases from these landfills. Priorities VIII, IX and X present an attempt of a comprehensive solution of waste management problems with simultaneous elimination of hazards to human health and environment caused by POPs. The first of them aims at improvement of waste neutralization processes, including alternative processes versus elimination by incineration. The second leads towards neutralisation of by-products generated in the course of cleaning stack gases and solid waste from thermal processes. The third closes the complex of waste by the identification of the state of industrial waste landfills and elimination of POPs therein remaining from the period when substances covered now by the Stockholm Convention were produced in Poland. Table 3 presents the selected priorities with scores of their weight points. Detailed information in this respect has been included in Appendix 3. IEP, Stockholm Convention Focal Point, Warsaw, Poland 13 GF/POL/01/004 Project Technical Report of the Phase III Table 3. Hierarchy of priorities based on weight point scores attached to the particular five criteria DESCRIPTION OF PRIORITY I. Establishment of comprehensive conditions preventing production or renewal of production of POPs and insurance for the improvement of the control system on production and handling of pesticides as well as chemical substances and preparations containing substances subject of the Stockholm Convention (with due regard of the Aarhus Protocol to the Geneva Convention on persistent organic pollutions and the relevant regulations of the European Union). II. Elimination from the environment of PCBs contained in electrical installations out of use and in discarded electrical equipment. III. Elimination outdated pesticides from the environment (removal of burial grounds and stockpiles still kept in warehouses). IV. Development of principles for the improvement of the inventory system of environmental releases of PCDD/PCDF, HCB and PCB from production processes and from other extra-industrial sources with verification of emission factors. V. Keeping record of the POPs emission sources in accordance with the Pollutant Release & Transfer Register. List of identified waste landfills containing POPs (pesticides and PCBs is subject of separate records). VI. Prevention of emissions of PCDD, PCDF and PCB generated unintentionally, beginning with sources of the largest share in total emissions. VII. Development of the national strategy for exchange of information, education, communication and raising awareness within the Stockholm Convention provisions. VIII. Reduction of POPs emissions in processes of waste disposal IX. Management of waste from cleaning of combustion gases and waste & wastewater containing POPs X. Solving the problem of industrial landfills of waste containing POPs. WEIGHT POINTS 330 300 300 295 277 265 257 220 200 195 DETERMINING LONG AND SHORT TERM GOALS After the criteria for priority setting were selected and the priorities endorsed, the long term goals aimed at implementation of the Stockholm Convention and the short term goals supporting the achievement of long term goals were formulated. Long-term goals The fundamental long-term goals, enabling full implementation of the Stockholm Convention in Poland, were formulated. They include sets of tasks for implementation, which identification was based on results of the Inventory Phase and some more detailed tasks, deriving from priorities listed above, which implementation was found necessary. IEP, Stockholm Convention Focal Point, Warsaw, Poland 14 GF/POL/01/004 Project Technical Report of the Phase III 1. Elimination (removal from the environment) of POPs, accumulated in result of past activities: intentional production, import and use of POPs containing substances with particular consideration of polychlorinated biphenyls, hexachlorobenzene and chloroorganic pesticides covered by the Stockholm Convention as well as decontamination of equipment and packaging material containing POPs residues. 2. Reduction polychlorinated dibenzo-p-dioxins (PCDDs), polychlorinated dibenzofurans (PCDFs), polychlorinated biphenyls (PCBs), and hexachlorobenzene HCB), generated unintentionally in fuel and waste combustion processes as well as in other industrial processes performed under high temperatures, through application of BAT and other technical solutions. 3. Creation and maintenance of sustainable organisational, scientific, technical and legal conditions ensuring possibly high degree of provisions of the Stockholm Convention and adequate control of the environmental emissions of POPs in Poland. The last mentioned goal, referring to multi-plane organisational arrangements does not result directly from the knowledge gained during the implementation of the Inventory Phase nor from priorities set, but it constitutes the indispensable condition for effective implementation of the NIP in Poland. Short-term goals The scope of the short-term goals includes complex tasks determining proper implementation of long-term goals and allowing proper assessment of the degree of progress in implementation of the NIP tasks. Five such goals are described below: Completion of the necessary inventories of the existing situation concerning POPs. These inventories will, in particular include old stocks of pesticides, stocks of electrical equipment and insulation oils polluted by PCBs, industrial dumps of POPs polluted waste and others. Achieve, in respect of PCDD/PCDFs, HCBs and PCBs releases into water, ground, waste and chemical products, such level of knowledge as already attained with reference to the state of knowledge on releases of these substances into the air. (The latter is at present satisfactory. POPs release factors into the remaining environmental components are bring about considerable doubts.) Establishing a system for registration (inventory) of POPs emission sources in accordance with PRTR scheme. Perform necessary technical and economic studies needed to correctly determine the required capital development projects. These studies should include consideration on the need for building a POPs decontamination facility, determine the purposefulness for further extension of processing capacities of POPs polluted liquid and solid substances incineration, opportunities and expediency of using alternative technologies for POPs elimination in Poland, which are defined in detail in the NIP. Review of reciprocal links and impacts of the implementation of the Stockholm Convention provisions on the scope of implementation of the Aarhus Protocol to the Geneva Convention as well as implementation of legal regulations of the European Union. IEP, Stockholm Convention Focal Point, Warsaw, Poland 15 GF/POL/01/004 Project Technical Report of the Phase III The above listed short term goals will significantly run ahead of the implementation of the long term goals, ensuring simultaneously the possibility of their complete and economically justified execution. ASSESSMENT BY THE STEERING COMMITTEE After the expert team concluded their activities, the prepared material was submitted for consideration to the National Steering Committee. The report included all the issues discussed above concerning criteria, priorities and goals. In addition to that, in order to better justify the scope of tasks covered by the priorities the “Preliminary list of tasks for the development of the National Stockholm Convention implementation plan in Poland in light of the priorities adopted. Members of the Steering Committee received the following documents prior to the meeting: Draft of “Criteria and Priorities for the Development of the National Stockholm Convention Implementation Plan for Poland” prepared by the GF/POL/01/004 Project. Draft of the „Preliminary list of tasks to be addressed in course of development of the National Stockholm Convention Implementation Plan, selected according to the set priorities”. After discussion and explanations, the Steering Committee did not make any changes in the proposed criteria, priorities nor goals and targets. Discussion of the preliminary list of tasks to be performed under the NIP turned out to be very useful. A number of comments were made by the Steering Committee. In addition to that, the departments of the Ministry of Environment submitted their written suggestions. All these comments and suggestions will allow to avoid possible misunderstandings or unclearness in future work on the development of the National Stockholm Convention Implementation Plan. The amended preliminary list of tasks is presented in Appendix 4. All conclusions and resolutions of the Steering Committee will be taken into account during further activities of the GF/POL/01/004 Project. NATIONAL VALIDATION WORKSHOP Two main objectives were subject of the Validation Workshop concluding the activities of the Priority Setting Phase: Transfer of information about results of the Inventory Phase. After the conclusion of this phase (December 2002) only a business workshop of the team of authors of the detailed inventory technical reports was held. The results of the inventory were not finalized at that time. It was therefore decided to present and discuss these results at this occasion. Discuss the results of activities of the Priority Setting Phase, i.e. the selected priorities and the goals/targets to be attained. IEP, Stockholm Convention Focal Point, Warsaw, Poland 16 GF/POL/01/004 Project Technical Report of the Phase III Ten presentations4 concerning the results of the Inventory Phase and the main outputs of the Priority Setting Phase were prepared and presented at the workshop. Appendix 5 provides the list of these presentations. The presented papers showed the basic scope of issues subject of the “National POPs Profile”, supplemented by the complex of problems connected with selection of criteria, setting priorities and goals to be attained in result of the project implementation. The subject matter of presentations included also the results obtained after the Inventory Phase was concluded, hence the actual situation to the workshop date. During discussions attention was drawn to the following issues concerning the inventories: Lack of sufficient data to assess the risks of human exposure to POPs; New sources of information about alternative POPs elimination techniques (Danish report); Discrepancy in the assessment of numbers and content of burial grounds and their status as hazardous waste dumps, with simultaneous recognition of impossibility to determine with more detail the composition of the dumped pesticides; Conclusion from the measurements performed, that there is no need to neutralise chloroorganic pesticides because of their low concentration in water, should be verified since the possibility of spot contamination exists. It was also recognised, that, in addition to the above remarks, the following issues require further explanation: Type and volume of POPs emission in production of aluminium; Feasibility of using existing waste incineration plants for POPs decontamination in terms of technical and economic reasons; The issue of ownership and responsibility of the power industry for the application of PCB containing products in electrical equipment. The following activities have been recommended: Monitoring of adequate action concerning executive regulations ensuring full compliance of legislation with the requirements of the Stockholm Convention; Preparation of a list indicating the priority in burial grounds clearance, with due regard of the of the environmental risk carried out with the use of the State Geological Institute and with consideration of information in hand about the burial grounds located on flooding areas (about 50); Repeated review of the domestic capacities for PCB destruction, because since the year 2000 an installation is in operation at the ANVIL Chemical Works. It allows for decontamination of equipment and substances containing PCBs. Discussing the draft report of the Priority Setting Phase the need for following actions was expressed: Better assessment of the relation between the environmental effects and the costs of different options of POPs elimination; Change the weight points for the criteria “Technical back-up”, because the lack of necessity to possess such back up is rather an advantage, not a fault (however this 4 texts of presentations are accessible on the Project’s www sites IEP, Stockholm Convention Focal Point, Warsaw, Poland 17 GF/POL/01/004 Project Technical Report of the Phase III criteria should be interpreted as a measure of the need to create such back-up, because its lack when needed presence a threat for successful completion of tasks). In result of discussions the following conclusions were formulated: The selection of criteria does not raise reservations, though the adopted criteria should be better justified. Ranking of priorities and the proposed targets have been accepted without reservation. The educational strategy should cover all management levels and all social and age groups. The information strategy should consider operational exchange of information between national institutions dealing with POPs, among others to avoid duplicating of activities. Particular attention was paid to issue of cost efficiency of the activities proposed Appendix 6). It was concluded in results of discussions that a meeting between the technical and economic expert groups would be necessary to discuss and select the method for evaluation of specific activities, including the option of abandoning activities. A statement was made in the summery of discussions, that the latter renders recommendations for the future, stressing clearly, that both, the inventory of emissions and releases as well as the NIP are of a preliminary character and will need to be verified in accordance with existing national requirements. Therefore, the NIP should include proposals for further activities including the necessary studies, periodical meetings and updating of action plans. The NIP should also anticipate co-ordination of activities aimed at implementation of the Stockholm Convention and other international legal acts (for instance the Basel Convention on transboundary movement and disposal of hazardous waste and the Rotterdam Convention (PIC) on procedures in international trade of chemical substances and pesticides). The adopted criteria, priorities and goals constitute the base for the formulation of activities aimed at development of the National Stockholm Convention Implementation Plan for Poland. IEP, Stockholm Convention Focal Point, Warsaw, Poland 18