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Project Name
Region
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Project ID
GEF Focal Area
Borrower(s)
Implementing Agency
Environment Category
Date PID Prepared
Estimated Date of
Appraisal Authorization
Estimated Date of Board
Approval
Report No.: AB5630
GEF Egypt: Sustainable POPs Management Project
MIDDLE EAST AND NORTH AFRICA
Central government administration (50%); Sub-national
government administration (50%)
P116230
Persistent Organic Pollutants
GOVERNMENT OF EGYPT
Egypt Environmental Affairs Agency
30 Misr
Helwan Agri. Road, Maadi
Cairo
Egypt, Arab Republic of
Tel: (20-2) 526-1419/1421
[email protected]
[X] A [ ] B [ ] C [ ] FI [ ] TBD (to be determined)
March 31, 2010
September 23, 2010
November 4, 2010
1. Key development issues and rationale for Bank involvement
In completing its NIP in 2005, Egypt committed to the elimination of POPs as a national
priority. The proposed Project will build upon the work carried out by the government to
date, supported by GEF, JICA and CIDA (Annex 2). With enhanced POPs management
capacity and demonstrated approaches to control and prevent exposure risks from key
sources of POPs, Egypt will pave the way for the elimination of PCBs and obsolete
pesticides, as well as for significant reductions of dioxin and furan emissions, using an
integrated and sustainable POPs management approach.
Local and global benefits: The implementation of the proposed activities would provide
many local benefits by reducing the impact of POPs on public health and the
environment. The project would address land degradation, by preventing soil pollution
by various POPs and by demonstrating site remediation techniques. The project will also
provide the following global benefits: (i) reduced threats to 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 trans-boundary 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.
Commitments of the Egyptian authorities: National commitment to POPs elimination
has been shown in the following ways: i) Egypt’s ratification of the Stockholm
Convention; ii) its submission of a NIP to the Convention Secretariat; iii) its adoption of
laws and regulations that ban the use of the POPs pesticides and provide for the
management of hazardous chemicals in general; iv) its requests to the GEF for assistance
in preparing and implementing a POPs project; and, v) its offer to provide up to $7
million as its contribution to the project. On the other hand the inability of the CIDA
consultants to gain access to some of the sites of concern may indicate that GOE
commitment is less than complete. POPs issues cut across many sectors, including
health, agriculture, environment, energy, and transport and inter-sectoral coordination
and management issues generally will be particular challenges.
Conformity with GEF Operational Programs (OPs): The project is consistent with GEF
OP 14: Persistent Organic Pollutants. It is oriented to on-the-ground activities, aimed at
implementing specific POPs stockpile sustainable management practices and phase-out
measures, as well as strengthening the country’s capacity to implement the Stockholm
Convention. The project will assist the GOE in addressing three of the 13 articles of the
Stockholm Convention1. During its June 2009 meeting, the GEF Council approved a
POPs Project Information Form (PIF) for Egypt, and included it in its Work Program.
Conformity with the Bank’s Country Assistance Strategy (CAS) for Egypt: The CAS
for the period FY06 to FY09 (the latest approved) has three strategic objectives:
facilitating private sector development; enhancing the provision of public services; and,
promoting equity. The proposed project fits within the second objective and is especially
relevant to the sub-objectives of improving air and water quality, effective management
of water resources, and provision of health services. The CAS also stresses donor
coordination, which is a feature of the project.
Rationale for Bank Assistance: With its very limited capacity, Egypt is unlikely to make
timely progress on POPs management without external support. The Bank has had
extensive experience in working with Egypt on environmental matters, going back to the
National Environmental Action Plan of 1990, which led to the formation of EEAA
Currently, the Bank is working with EEAA on the Environmental Protection and
Management Project II and the Alexandria Coastal Zone Management Project. The Bank
is also gaining experience in assisting countries around the world with POPs
management, with projects such as those in Tunisia (which deals partly with PCBs),
Moldova, Nigeria, the Philippines, Vietnam and China.
1
Article 3: “Reduction/elimination of releases from intentional production and use of POPs”;
Article 6: “Reduce and eliminate releases from stockpiles/wastes”; and, Article 10: “Promote and facilitate public
information and awareness.”
2. Proposed objective(s)
The Project Development Objective would be to assist Egypt to strengthen its technical
and management capacity for minimizing exposure to POPs. This would be achieved
through activities for the safe storage and disposal of obsolete pesticides and PCBs and
preparatory activities for the sustainable management of dioxins and furans in the
industrial sector. Key development indicators may include: percent of obsolete pesticides
securely stored; percent of obsolete pesticides disposed of safely; percentage of PCBs
securely stored; percentage of PCBs and contaminated equipment safely decontaminated,
recycled or destroyed; development of a comprehensive management plan for dioxins
and furans in the industrial sector; development of public sector management capacity for
POPs; number of persons trained in the sustainable management of POPs.
The Global Objective would be to assist Egypt to meet its obligations under the
Stockholm Convention by strengthening its technical and management capacity for
minimizing exposure to POPs. The above key indicators would also be applicable.
3. Preliminary description
It should be recognized that POPs management is a relatively new subject, in which
Egypt at present has minimal capacity. While the needed actions are rather well defined
for pesticides, they are less so for PCBs, while knowledge of dioxin/ furan emissions and
the best mechanisms for control are much less clear. Moreover, development of
institutional capacity will be time-consuming. These factors argue for a two-stage
approach. This first project would provide a comprehensive solution for the obsolete
pesticides (although it may be anticipated that additional stores of hazardous products
may be discovered in the course of project execution), will demonstrate the safe storage/
disposal of PCBs but will focus on preparatory activities only for dioxins and furans,
given the challenges of completing the inventory, the selection of effective technical
solutions, and the need to engage the public and private sector enterprises through
equitable incentives and financial mechanisms. The first project will also aim to put in
place a capable institutional system that can manage remaining POPs needs. As an
informed and involved public is crucial for the success of any environmental initiative,
the project would also emphasize these elements. An integrated approach covering the
three categories of POPs is preferred, as all three are national priorities, as shown in the
NIP, and they can be efficiently addressed by EEAA in one package. This approach
would allow cross-fertilization of ideas and experiences between the three themes.
The second project would likely complete the disposal of dated pesticides and PCBs, as
well as demonstrating sustainable methods for reducing dioxin/ furan emissions.
The proposed first-phase project composition is very similar to that set out in the PIF
already approved by GEF, although slightly repackaged. The only major difference is
that work on dioxins and furans has been scaled back to preparatory activities only and
the project cost reduced accordingly. Tentatively, the following components and
activities are envisioned (subject to further review during preparation):
Component 1: Policy and Legal Development2 US$3.0 million, including $0.3 million
GEF) – The objective of this component is to strengthen the GOE policy framework to
implement the Stockholm convention and to prepare the necessary laws and regulations
for POPs management in Egypt. The project would support:
Sub-Component 1.1: Policy strengthening: Preparation of a policy statement affirming
Egypt’s commitment to the Stockholm Convention, setting targets and assigning
institutional responsibilities for the sustainable management of POPs and setting out a
framework for dealing with the enterprise sector, both public and private, including costsharing mechanisms. Models of POPs management from other countries will be
consulted.
Sub-Component 1.2: Legal Development: Consistent with the results of sub-component
1.1, review of the current legal framework and identification of gaps; review of
legislation from other countries; drafting and passage of legislation (with stakeholder
consultation); development of regulations and institutional responsibilities.
Component 2: Capacity Building (US$1.0 million, including $0.3 million GEF) – Very
limited institutional capacity is currently the main constraint to POPs management and,
consequently, its development is a major aim of the project. A needs assessment will be
made under the proposed PPG.
Sub-Component 2.1: Strengthening of EEAA – Establishment of a POPs Unit in EEAA,
to act as the PMU, with a senior staff member as Director and three to four other staff,
development of inter-ministerial coordination mechanisms; operational manuals in
Arabic; development of a GIS-based inventory system3 and a tracking mechanism for
POPs, maintenance of monitoring (of stockpiles, remediated sites, and emissions) and
laboratory systems.
Sub-Component 2.2: Strengthening of Ministry of Agriculture – recruitment of a POPs
liaison officer, development of POPs procedures.
Sub-Component 2.3: Strengthening of Ministry of Electricity and Energy – recruitment
of a POPs liaison officer, development of POPs procedures.
Sub-Component 2.4: Strengthening of Ministry of Industry– recruitment of a POPs
liaison officer, development of POPs procedures, oversight of a self-monitoring system
for industries.
Sub-Component 2.5: Staff Training – in-service training for all project staff, including a
study tour.
2
Consideration is being given to including part of this component (together with part of Component 2.1) in a GEF
Project Preparation Grant (PPG), in view of the foundational nature of the policy statement and the long lead time
needed for legal and institutional development.
3
Off the shelf systems are available.
Sub-Component 2.6: Public Awareness and Participation – use of various media to
inform the public about the hazards of POPs and the purposes of the project, possibly
using NGOs; participation in legal and regulatory development.
Component 3: Management of Obsolete Pesticide Stocks (US$ 3.8 million, including
$1.5 million GEF) - The 2009 CIDA survey found that a total of 2,232 tons of obsolete
pesticide exist at various locations in the country. Of this amount, at least 6.5 tons are
POPs4. This component would aim to destroy all known stocks of POPs and provide
secure storage of other pesticides, if it is found that destruction is not immediately
feasible, and will include the following:
Sub-Component 3.1: Secure storage of obsolete pesticides: Ensure that all identified
stocks are securely stored and that any presently unknown stocks are identified and
secured5;
Sub-Component 3.2: Destruction of existing stocks of obsolete pesticides: All identified
existing stocks of POPs will be destroyed, using environmentally sound methods and
technologies. Existing storages and their surroundings will be decontaminated 6.To the
extent possible, in-country capacity for pesticide destruction and site remediation will be
developed. Consideration will be given to starting a similar program for non-POP
pesticide stocks, using GOE funding.
Sub-Component 3.2: Development and implementation of sustainable strategies for the
future management of pesticides: Sound pesticide lifecycle management policies and
practices, integrated pest management practices and management of pesticide waste will
be promoted to all stakeholders, including farmers. Capacity building throughout the
pesticide supply chain and all pesticide users will be undertaken to train them on
sustainable management of pesticides.
Component 4: Improved Management of PCBs (US$ 7.0 million, including $3.0
million GEF) – The CIDA project estimated that there was a minimum of 7,000
transformers containing more than 8,400 tons of PCB contaminated oils (>50ppm). In
addition, they found a widespread dispersion of diluted PCB contaminated oils with
concentration <50ppm. After the JICA survey in 2006 found that PCBs (along with other
oils) were being recycled for various purposes (including the manufacture of cosmetics),
the government banned the practice but no one is aware of the extent of the
contamination that may have resulted over the years, nor of the manner in which used
transformer oils are being currently handled by users.
This component would aim to protect the public from exposure to PCBs and demonstrate
safe methods of PCB destruction and would comprise the following:
4
Non-POPs pesticides are also hazardous to human health and the environment but are more of national rather than
global concern.
5
This has already been done for the main Ministry of Agriculture storage of 650 tons.
This is mentioned in the NIP (Sections 3.3.8 and 3.3.9) but no details are provided on possible methods. Sites for
decontamination would be based ona risk assessment in each case.
6
Subcomponent 4.1: Sound and sustainable management of PCB stockpiles and off-line
PCB contaminated equipment: All off-line PCB-contaminated electrical equipment will
be safeguarded, using environmentally sound methods. It is expected that about ten
percent of the identified PCBs or contaminated equipment will be decontaminated and/or
disposed of under the project, in order to demonstrate sound methodology. For
decontamination, appropriate technical options will be analyzed and an appropriate
method selected. A strategy for the complete destruction of PCBs/ decontamination of
equipment would be developed. Further, all cross-contamination, dilution and dispersion
of PCB-contaminated oils will be stopped.
Subcomponent 4.2: Management plan for on-line PCB contaminated electrical
equipment: All on-line contaminated equipment will be identified and safeguarded,
through the continuation of the inventory. A monitoring plan will be prepared until final
decommissioning and disposal, as per the Stockholm convention obligations.
Component 5: Management of Dioxin and Furan emissions (US$2.0 million,
including $1.0 million GEF) – According to the NIP, the largest combustion source,
contributing to roughly 50 percent of the estimated emissions, is open burning of waste.
The GOE intends to address these sources primarily through regulatory efforts combined
with modern solid waste management programs7. Medical waste incinerators, of which
over 140 in 27 cities were accounted for in the NIP, were also among the top three
categories of emitters. Emissions of dioxins and furans from medical incinerators will not
be included under this project, because the GOE intends to address these sources
primarily through regulatory efforts combined with sound medical waste management
programs. However, the contribution of these sources, especially to local concentrations
of dioxins and furans, may be covered, at least on a pilot basis, under the monitoring and
tracking provisions of this component.
The remaining major emitters are significant and involve mostly industrial processes that
are not being addressed by any present or planned government program. More
specifically, metallurgical industries (e.g. iron and steel, copper, aluminum), fossil fuel
fired boilers and thermal processes (e.g. lead, asphalt, brick, and lime production) are
primary sources of dioxin and furan emissions. Resources from CIDA were recently used
to assess practices from these pre-identified industrial sectors and to determine, based on
current local practices, which are the worst dioxin and furan emitters (Annex 2).
It is envisaged that this component would phase in as Component 1 is completed, as it
will not be possible to undertake emission reduction actions in the absence of a legal
framework. Design of the component would also seek to exploit synergies with ongoing
industrial pollution control projects, supported by the Bank, JBIC, EIB and other donors.
While the ultimate objective of this component would be the minimization of dioxin and
furan emissions from the industrial sector, it should be recognized that considerable
preparation work remains to be done – development of a policy and legal framework
(Component 1), development of institutional capacity (Component 2), inventory
improvements and identification of priority sites (using GIS), definition of Best Available
Technology/ Best Environmental Practice (BAT/BEP) for those sites, detailed design of
7
Support from the EU and/or the Bank is being sought.
the adopted solutions, establishment of cost sharing formulae, and negotiation of
agreements with the enterprises concerned. It must be recognized that anything less than
full subsidy will not be welcomed by the enterprises and delaying tactics can be expected.
For these reasons, it is proposed that this project will only prepare a set of pilot projects,
with implementation left to a future GEF or other project.
Sub-Component 5.1: Development of a national strategy and action plan for reduction
of dioxin and furan emissions: Based on the work already done in the NIP and
Component 1.1, a detailed strategy would be developed, based upon a multi-stakeholder
approach, including representatives of the key industries concerned. The action plan
would set out priorities, a phased program of investments, institutional responsibilities, a
cost sharing formula, and would identify sites for early action. At the same time,
inventories would be improved, monitoring intensified under Components 2.1 and 2.4,
and institutional capacity would be developed under Components 2.1, 2.4 and 2.5.
Sub-Component 5.1: Preparation of Pilot Projects: Based on the results of Component
5.1, two to four8 industrial sites would be selected and BAT/BEP demonstration projects
designed to the level needed for appraisal by an external financing agency.
Component 6: Project Management (US$1.6 million, including $0.7 million GEF)
Sub-Component 6.1: Project Management Unit (PMU): This sub-component would
provide incremental financing for implementation of the project, incremental operating
cost of the PMU within EEAA for technical services, procurement, financial
management, and audit, and monitoring and evaluation.
Sub-Component 6.2: Preparation of a follow-up project: During the final year of the
proposed project, studies, including environmental and social assessments, would be
done for a potential follow-up project, focused mainly on PCBs and Dioxins/Furans.
Safeguard Issues. Given the risks that the chemicals dealt with in the project have for
human health and for the environment, it is proposed that the project be classified as ‘A’
for the purposes of OP 4.01(and the equivalent Category C under Egyptian legislation).
A full Environmental Impact Assessment (EIA) would therefore need to be done prior to
appraisal9. Inter alia, the EIA would deal with mitigating the risks from accidental leaks
of POPs during collection, storage, transport and disposal. A brief social assessment
would also be made. Involuntary resettlement is highly unlikely to be needed but will be
further checked under the environmental and social assessments and a resettlement
framework prepared, if needed. However, language would be incorporated in the
documents on chance archeological finds.
8
The PIF mentions two sites for implementation under the project. However, preparation of a larger number would
allow a greater range of industries to be covered and would allow for some attrition before implementation in a
future project.
9
The GOE is prepared to fund the EIA from its own resources, another indication of commitment to the project.
Estimated Project Cost. Total project costs are preliminarily estimated at US$17.5
million, with an expected GEF contribution of $7.7 million (implying a leverage ratio of
1.3). This compares with the US23.6 million (with GEF contribution of $8.1 million)
approved in the PIF. Costs will be further reviewed during the planned preparation
mission.
4. Safeguard policies that might apply
[Guideline: Refer to section 5 of the PCN. Which safeguard policies might apply to the project
and in what ways? What actions might be needed during project preparation to assess
safeguard issues and prepare to mitigate them?]
5. Tentative financing
Source:
BORROWER/RECIPIENT
Global Environment Facility (GEF)
Total
6. Contact point
Contact: Faisal Abdulrahaem Al-Hothali
Title: Senior Environmental Specialist.
Tel: (202) 458-4795
Fax: (202) 477-1981
Email: [email protected]
($m.)
15.5
8.1
23.6