Management and Disposal of PCBs in Rwanda

Report Cover Image
Evaluation Plan:
2013-2018, Rwanda
Evaluation Type:
Final Project
Planned End Date:
12/2018
Completion Date:
12/2018
Status:
Completed
Management Response:
Yes
Evaluation Budget(US $):
17,200

Share

Document Type Language Size Status Downloads
Download document TOR PCBs Final Evaluation final.docx tor English 1062.47 KB Posted 33
Download document Evaluation_Report_Rwanda_Final_14Dec18.docx report English 605.81 KB Posted 35
Download document Annex12_ManagementResponseTemplate TE Dec2018 SR.doc related-document English 135.50 KB Posted 24
Download document Annex13_Clearance_signed.pdf related-document English 133.13 KB Posted 37
Title Management and Disposal of PCBs in Rwanda
Atlas Project Number: 61958
Evaluation Plan: 2013-2018, Rwanda
Evaluation Type: Final Project
Status: Completed
Completion Date: 12/2018
Planned End Date: 12/2018
Management Response: Yes
Corporate Outcome and Output (UNDP Strategic Plan 2018-2021)
  • 1. Output 1.2.2 Enabling environment strengthened to expand public and private financing for the achievement of the SDGs
Evaluation Budget(US $): 17,200
Source of Funding: GEF and UNDP Funding
Evaluation Expenditure(US $): 17,200
Joint Programme: Yes
Mandatory Evaluation: No
Joint Evaluation: No
Evaluation Team members:
Name Title Email Nationality
Dalibor Kysela
GEF Evaluation: Yes
GEF Project Title: Management and Disposal of PCBs in Rwanda
Evaluation Type: Terminal Evaluation
Focal Area: Persistent Organic Pollutants
Project Type: MSP
GEF Phase: GEF-4
GEF Project ID: 4014
PIMS Number: 4274
Key Stakeholders: Rwanda Environment Management Authority
Countries: RWANDA
Comments:

This is the terminal evaluation of the GEF-4 project 'Management and Disposal of PCBs in Rwanda' as planned during the project formulation. It is added to the ERC System due to its importance for documentation, donor reporting and to add into future programming the lessons learnt.

Lessons
1.

The project from the very outset faced the challenge of lack of national capacities in the technical area of PCBs and PCB waste management. REMA as the leading national implementation partner initially did not assign sufficient workforce to the project management team. Analysis of the project timelines and progress reports leads to a conclusion that the initial project implementation delays could have been avoided if sufficient attention was paid to the assessment of existing national capacities for management of international development projects in the technical area of PCB management. The fact that the insufficient national capacities in the technical area of PCB management was not incorporated into the risk matrix in the Project Document suggests that the risk management planning at the project inception stage was not satisfactory.

Before the first meeting of the Project Steering Committee, the project implementation was slow since not all project stakeholders were aware of the project purpose and its objective. As soon as regular meetings of PSC were scheduled and organized, the implementation of the project remarkably accelerated. A dedicated Project Steering Committee with representation of the key stakeholders was therefore an effective instrument for awareness raising of the project stakeholders and information sharing.

Development assistance projects addressing highly technical areas usually struggle in attempts to inform and raise awareness general public due to the diversity of the target audiences. The awareness raising workshop for 32 journalists from 32 different media organized in the first year of the project implementation period is considered a very cost-effective tool for reaching out to the general public. Printed and electronic media had the power to attract relatively large audiences and had therefore far better outreach power than any other public awareness modality. Moreover, the journalists helped to translate the technical language of the project into a colloquial language easily understandable by a wide section of the public at large and performed thus a bridging function between the project direct and ultimate beneficiaries.

The REMA project team established a technical peer review group comprising of experts from prime national academic institutions in order to assess deliverables produced by international as well as national consultants that were directly working on assignments under this project. This practice considerably enhanced quality of the studies, technical guidelines and the legal framework and also enhanced the capacity of peer reviewers in the technical area of PCBs.

Specifically, appointment of lecturers from the University of Rwanda as national consultants and involvement of UR students in the inventory of transformers has contributed to integration of the PCB topic into educational programmes of national higher education institutions and enhanced sustainability of the project capacity building component beyond the project time boundary.

Results of the PCB inventory were transformed into maps showing location of PCB-contaminated electrical equipment, PCB-waste sites and potentially contaminated sites. The maps became an important supplementary tool to support arguments necessary to push on for developing legal and regulatory frameworks for management of PCB as hazardous waste.

Another good practice was clustering of activities for international consultancy instead of dividing up into several short consultancy assignments. The clustered contract also included task of procurement of sampling equipment. This practice started in 2015. Given the fact that the project faced problems with protracted procurement of both goods and services since the very beginning, this approach has significantly reduced the time required for recruitment and procurement of goods and services in comparison with the first years of the implementation period. Moreover, it also enhanced the continuity of implementation since longer engagement in the project enabled the qualified international consultant to take a more holistic view of the project. This approach resulted in accelerated delivery of the planned outputs as well as in finding a solution to the final disposal of PCB liquid waste stockpiles that is so far unprecedented in the region.

Another example of a good practice was the review and comparison of the PCB waste disposal options under the project component 4. The review was in fact a return to the “drawing board” that was conducted without limiting itself to the disposal option that was presupposed in the Project Document (i.e. export of PCB waste abroad). Such review finally paved way towards finding a cost-effective and efficient final PCB waste disposal solution in compliance with the Stockholm Convention. Moreover, it also established a precedential problem-solving option for the Africa region.   

One of the elements of success of the project was sensitization of senior politicians of the country including the Office of the President to the issue of health and environmental risks of PCBs and management of PCB waste. This practice ensured high-level political support to the project and was also instrumental in the efforts to establish an important partnership with the private sector. This cooperation leveraged co-financing contribution for testing and piloting of the national option for environmentally safe disposal of PCB liquid waste.

The sustainability of project accomplishments is greatly enhanced by the commitment to the sound PCBs management developed during the project by the participating national institutions and utility firms. Through sizeable in-kind and in-cash contributions to the project the key project stakeholders have indicated strong ownership of the project and contributed to the effective implementation of the project.


Findings
1.

The project has helped establish solid foundations for sound management of PCBs in Rwanda by contributing to removal of several barriers to effective implementation of the country’s obligations under the Stockholm Convention that had been identified at the PIF/PPG stage.

The main achievement of the project is elimination of PCB waste oil by incineration in a local cement kiln, contrary to the originally planned export of waste oils for incineration abroad.  This was enabled by a completed feasibility study of the PCB disposal by co-incineration in the locally available cement kiln at CIMERWA in line with the Best Available Techniques and Best Environmental Practices under the Stockholm and Basel Conventions. The contract for incineration concluded with the Rwanda’s integrated cement manufacturer envisages incineration of up to 50 tonnes of PCB liquid waste with a provision to increase the amount if necessary at the cost of 150 US$/ton. By the time of the terminal evaluation, 5.2 extra tons were incinerated hence incineration of 55.2 tonnes of PCB-oil was completed under the project.

Another important deliverable of the project at the time of TE has been the updated inventory of transformers that helped to substantially reduce the information gap on the physical extent of PCB contamination in the country as it provided new information in terms of quantities and location of PCB-contaminated transformers. The updated inventory not only contributed to better identification of the national stock of PCB-containing transformers in terms of levels of PCB concentration but also enabled to establish a plan for a gradual phase-out of in-service transformers and decommissioning of out-of-service transformers. The national technical capacity for elaboration of PCB management strategies and action plans has been enhanced as well.

The information on the level of PCB-contamination of transformers in the updated inventory was obtained through field testing by rapid analytical methods and could therefore be considered as more information than the 2005 survey. However, as the national capacity for PCB laboratory analysis by more accurate analytical techniques (such as GC/ECD and GC/MS) has not been established. The absence of accredited national laboratory capacity for analysis of PCBs in PCB oils and environmental matrices at the project closure is a serious impediment to the management of PCBs in the country. The implementing partners have recently started discussion about a follow-up project on management of POPs. Accredited and operational national laboratory will be absolutely critical for any future PCB- and POPs-related activities such as inventory of small PCB holdings and assessment and remediation of PCB/POP contaminated sites.

The project provided the technical support and assistance in the development of a draft Law on PCBs Disposal and Management in Rwanda to cover all aspects of the PCB cycle, assign roles and responsibilities for PCB management, oversight, reporting and enforcement to public administration agencies, PCB users and other stakeholders. The proposed regulation was developed through a participatory process with the participation of all relevant stakeholders.

However, the project did not succeed in getting the PCB Law approved and enacted due to the length and complexity of the legislative process in Rwanda, particularly to the fact that the country was at the same time preparing a revision of the Organic Law on Environment. Consequently, the legislative process for the new law on PCB was put on hold and a change in the format of the new PCB law was considered to ensure consistency with the revised Organic Law on Environment and simplify the adoption process. The evaluation noted that the draft law had passed almost through all mandatory review stages and that the final approval of the draft Law has been beyond the control of the project implementing partners. At the time of the TE Report preparation, the framework Organic Law has been enacted while the specific PCB Law was in the Ministry of Environment out of control of the project implementing partners. The Organic Law has therefore been serving as a temporary legislative base for PCB management. Nevertheless, despite the contribution to the capacity building for understanding and formulation of PCB-related legislation, the full strengthening of the national regulatory capacity for sound management of PCBs was not achieved.

The project has also developed and cultivated keen awareness of the risks posed by PCBs, and of options to manage these risks among the relevant enforcement agencies, electricity utilities, educational institutions and public at large. Although it is difficult to measure the level of success in awareness-raising, there are indicators that better understanding of the risks of PCBs to human and environmental health increase political willingness and action of relevant authorities (including senior politicians) and PCB holders to safeguard and gradually phase-out PCBs.

It has to be noted that the project has also contributed to improvements in communication about the PCB issue in the country. Prior to the project, REMA voluntarily disclosed insufficiencies in PCB management to the stakeholder community including journalists. All stakeholders and environmental journalists in particular had been updated through targeted project activities about improvement in PCB management during the project. This has contributed to changed perception and reputation of REG/EUCL as the principal PCB holder. The collected data and established procedures under the project not only provided more information but also contributed to better understanding of duties and obligations of the key stakeholders, i.e. the electric utility company, national enforcement agency and general public and enabled all stakeholders to be much more forthcoming on the topic in comparison with the situation before the project. Moreover, the implementation of the PCB waste oil incineration has also enhanced the capacity of CIMERWA for safe handling PCBs and has enabled creation of an important partnership for management of PCBs in the future.

The national technical capacity for environmentally sound management of PCBs was strengthened and enhanced through elaboration and adoption of four technical guidelines on various aspects of the PCB waste management cycle. The guide on servicing, repairing and maintaining PCB-containing equipment provided instructions to REG/EUCL and other PCB holders for prevention of cross-contamination, spills and illegal discharges or disposals. It also contributed to building capacities of the PCB holders in decontaminating and cleaning up equipment and materials contaminated with PCBs. Through development of two other technical guidelines, the project provided required technical tools in support of the regulatory control and facilitated creation and establishment of infrastructure and operational capacity for environmentally safe safeguarding and management of PCB-contaminated oil and materials.

At the same time, however, the evaluation noted the reported slow uptake of the standardized procedures for safeguarding, handling, transport and storage of PCB-contaminated materials as well as lack of commitment to the procedures on proper packaging and transport of PCB-containing or -contaminated oil, equipment and materials to ensure public health and safety, and preservation of the environment. One of the reasons for the slow uptake of the standardized procedures could be inability of the national stakeholders to promptly allocate equipment for loading, unloading, handling and pre-treatment of PCB oil and PCB-contaminated equipment. This issue was finally addressed and resolved by the implementing partners when EUCL provided a forklift for loading of drums from the temporary storage to the trucks and CIMERWA provided another forklift for offloading drums from the trucks to the pre-incineration storage.

The project has helped establish solid foundations for sound management of PCBs in Rwanda by contributing to removal of several barriers to effective implementation of the country’s obligations under the Stockholm Convention that had been identified at the PIF/PPG stage.

The main achievement of the project is elimination of PCB waste oil by incineration in a local cement kiln, contrary to the originally planned export of waste oils for incineration abroad.  This was enabled by a completed feasibility study of the PCB disposal by co-incineration in the locally available cement kiln at CIMERWA in line with the Best Available Techniques and Best Environmental Practices under the Stockholm and Basel Conventions. The contract for incineration concluded with the Rwanda’s integrated cement manufacturer envisages incineration of up to 50 tonnes of PCB liquid waste with a provision to increase the amount if necessary at the cost of 150 US$/ton. By the time of the terminal evaluation, 5.2 extra tons were incinerated hence incineration of 55.2 tonnes of PCB-oil was completed under the project.

Another important deliverable of the project at the time of TE has been the updated inventory of transformers that helped to substantially reduce the information gap on the physical extent of PCB contamination in the country as it provided new information in terms of quantities and location of PCB-contaminated transformers. The updated inventory not only contributed to better identification of the national stock of PCB-containing transformers in terms of levels of PCB concentration but also enabled to establish a plan for a gradual phase-out of in-service transformers and decommissioning of out-of-service transformers. The national technical capacity for elaboration of PCB management strategies and action plans has been enhanced as well.

The information on the level of PCB-contamination of transformers in the updated inventory was obtained through field testing by rapid analytical methods and could therefore be considered as more information than the 2005 survey. However, as the national capacity for PCB laboratory analysis by more accurate analytical techniques (such as GC/ECD and GC/MS) has not been established. The absence of accredited national laboratory capacity for analysis of PCBs in PCB oils and environmental matrices at the project closure is a serious impediment to the management of PCBs in the country. The implementing partners have recently started discussion about a follow-up project on management of POPs. Accredited and operational national laboratory will be absolutely critical for any future PCB- and POPs-related activities such as inventory of small PCB holdings and assessment and remediation of PCB/POP contaminated sites.

The project provided the technical support and assistance in the development of a draft Law on PCBs Disposal and Management in Rwanda to cover all aspects of the PCB cycle, assign roles and responsibilities for PCB management, oversight, reporting and enforcement to public administration agencies, PCB users and other stakeholders. The proposed regulation was developed through a participatory process with the participation of all relevant stakeholders.

However, the project did not succeed in getting the PCB Law approved and enacted due to the length and complexity of the legislative process in Rwanda, particularly to the fact that the country was at the same time preparing a revision of the Organic Law on Environment. Consequently, the legislative process for the new law on PCB was put on hold and a change in the format of the new PCB law was considered to ensure consistency with the revised Organic Law on Environment and simplify the adoption process. The evaluation noted that the draft law had passed almost through all mandatory review stages and that the final approval of the draft Law has been beyond the control of the project implementing partners. At the time of the TE Report preparation, the framework Organic Law has been enacted while the specific PCB Law was in the Ministry of Environment out of control of the project implementing partners. The Organic Law has therefore been serving as a temporary legislative base for PCB management. Nevertheless, despite the contribution to the capacity building for understanding and formulation of PCB-related legislation, the full strengthening of the national regulatory capacity for sound management of PCBs was not achieved.

The project has also developed and cultivated keen awareness of the risks posed by PCBs, and of options to manage these risks among the relevant enforcement agencies, electricity utilities, educational institutions and public at large. Although it is difficult to measure the level of success in awareness-raising, there are indicators that better understanding of the risks of PCBs to human and environmental health increase political willingness and action of relevant authorities (including senior politicians) and PCB holders to safeguard and gradually phase-out PCBs.

It has to be noted that the project has also contributed to improvements in communication about the PCB issue in the country. Prior to the project, REMA voluntarily disclosed insufficiencies in PCB management to the stakeholder community including journalists. All stakeholders and environmental journalists in particular had been updated through targeted project activities about improvement in PCB management during the project. This has contributed to changed perception and reputation of REG/EUCL as the principal PCB holder. The collected data and established procedures under the project not only provided more information but also contributed to better understanding of duties and obligations of the key stakeholders, i.e. the electric utility company, national enforcement agency and general public and enabled all stakeholders to be much more forthcoming on the topic in comparison with the situation before the project. Moreover, the implementation of the PCB waste oil incineration has also enhanced the capacity of CIMERWA for safe handling PCBs and has enabled creation of an important partnership for management of PCBs in the future.

The national technical capacity for environmentally sound management of PCBs was strengthened and enhanced through elaboration and adoption of four technical guidelines on various aspects of the PCB waste management cycle. The guide on servicing, repairing and maintaining PCB-containing equipment provided instructions to REG/EUCL and other PCB holders for prevention of cross-contamination, spills and illegal discharges or disposals. It also contributed to building capacities of the PCB holders in decontaminating and cleaning up equipment and materials contaminated with PCBs. Through development of two other technical guidelines, the project provided required technical tools in support of the regulatory control and facilitated creation and establishment of infrastructure and operational capacity for environmentally safe safeguarding and management of PCB-contaminated oil and materials.

At the same time, however, the evaluation noted the reported slow uptake of the standardized procedures for safeguarding, handling, transport and storage of PCB-contaminated materials as well as lack of commitment to the procedures on proper packaging and transport of PCB-containing or -contaminated oil, equipment and materials to ensure public health and safety, and preservation of the environment. One of the reasons for the slow uptake of the standardized procedures could be inability of the national stakeholders to promptly allocate equipment for loading, unloading, handling and pre-treatment of PCB oil and PCB-contaminated equipment. This issue was finally addressed and resolved by the implementing partners when EUCL provided a forklift for loading of drums from the temporary storage to the trucks and CIMERWA provided another forklift for offloading drums from the trucks to the pre-incineration storage.


Recommendations
1

REMA in cooperation with REG/EUCL should make update of the national PCB database to reflect the transformer drainage and decontamination operations conducted in 2017-2018.

2

REMA in cooperation with REG/EUCL should make update of the national PCB database to reflect the transformer drainage and decontamination operations conducted in 2017-2018.

3

REMA should make the database of PCB-contaminated transformers as well as other related information (such as territorial maps of locations PCB-contaminated transformers) available to a wider audience through publication on its web site.

4

REMA in cooperation with UNDP CO should ensure that all materials prepared by the project, in particular technical guidelines, awareness raising materials, videos, publications and booklets, are posted on the website of REMA and eventually create a dedicated part of the website for information on PCB management. 

5

REMA should transfer the Jabana site ownership to REG/EUCL as the main PCB holder in the country in order to ensure the necessary operational upgrade of the new temporary storage of PCB-waste at Jabana. In the future, all PCB-contaminated materials should be stored exclusively at Jabana and ensure their storage inside the building in order to avoid risk of environmental pollution by PCBs.

6

REMA in cooperation with other law enforcement agencies and support of UNDP CO should submit the developed specific PCB-related legislative framework for approval through an abridged procedure. The legal framework on the PCB management cycle should be enacted through a relevant legal instrument and/or short-term measures, that can be established directly by the Government without requirement of parliamentary approval.

7

REMA should follow-up with minority PCB holders for implementation of the submitted plans for phase-out of PCBs in transformers and closely monitor implementation of the phase-out plans until disposal or decontamination of the transformers.

8

REMA and EUCL should develop a formal management plan for the Askarel transformers. The plan should include regular inspections to check the condition of the transformer in operation in order to prevent overloading, overheating and leakage as well as transport of the transformers removed from service to the new temporary storage at Jabana once the storage site is upgraded to guarantee safety of the operation and storage.

9

REG/EUCL should identify funding for additional equipment for retro-filling of PCB-contaminated transformers. Two different explosion-proof pumping lines will have to be provided: one for draining out (PCB-contaminated oil) and the other for refilling (PCB-free oil) to prevent any cross contamination.

8b: REG/EUCL should develop a strategy for securing the long-term investment needed to ensure steady progress in the retro-filling of the in-service PCB-contaminated transformers.

10

REMA should develop and implement a procedure of meticulous supervision of all operations for storage, transport and acceptance of the PCB-contaminated oil for incineration.

 

11

Prior to start of the future project(s) related to management of chemical wastes including PCBs, UNDP should conduct an in-depth assessment of capacity of the project partners and determine their commitment (staff allocation and time, co-financing) to active participation in the project implementation and as well as their capacity to achieve the results that they will become responsible for.

Procurement planning for goods and services should require particular attention as national procurement procedures continue to be lengthy and complicated and will have to be streamlined. It is therefore proposed that future procurement of goods and services from international suppliers is conducted by UNDP.

12

In order to establish capacity for PCB analysis, REMA should consider concluding cooperation with a laboratory abroad that has accreditation for PCB analysis. In parallel, UNDP in cooperation with the key national stakeholders (REMA and REG) should identify sources of support for establishment of a national laboratory for POPs analysis and ensure international technical assistance is provided to the designated national laboratory for improving skills in sampling and analysis of POPs/PCBs.

13

REMA should consider upgrade of the PCB database from the simple Excel sheet to a more robust information system that would better support reporting according to the Stockholm Convention. REMA and REG/EUCL should also make a commitment to manage the system in the future (e.g. by signing an MoU).

14

UNDP CO in cooperation with relevant national partners should consider inclusion of capacity building components for national customs authorities in future project(s) on POPs/PCBs management.

15

REMA should establish and eventually implement a plan for a national inventory of other PCB applications such as dielectric fluids for capacitors, voltage regulators, and hydraulic and heat transfer fluids.

1. Recommendation:

REMA in cooperation with REG/EUCL should make update of the national PCB database to reflect the transformer drainage and decontamination operations conducted in 2017-2018.

Management Response: [Added: 2018/12/18]

REMA will update the excel database of transformers and reflect the drainage / decontamination conducted in 2017/2018.

Key Actions:

2. Recommendation:

REMA in cooperation with REG/EUCL should make update of the national PCB database to reflect the transformer drainage and decontamination operations conducted in 2017-2018.

Management Response: [Added: 2018/12/18]

REMA will update the excel database of transformers and reflect the drainage / decontamination conducted in 2017/2018.

Key Actions:

3. Recommendation:

REMA should make the database of PCB-contaminated transformers as well as other related information (such as territorial maps of locations PCB-contaminated transformers) available to a wider audience through publication on its web site.

Management Response: [Added: 2018/12/18] [Last Updated: 2018/12/18]

The inventory database and map are already in the REMA IT office, awaiting to be uploaded on the website.

Key Actions:

4. Recommendation:

REMA in cooperation with UNDP CO should ensure that all materials prepared by the project, in particular technical guidelines, awareness raising materials, videos, publications and booklets, are posted on the website of REMA and eventually create a dedicated part of the website for information on PCB management. 

Management Response: [Added: 2018/12/18] [Last Updated: 2018/12/18]

There are already several PCB guidelines on the REMA website, however only accessible through search engines and difficult to find from the website top page. The remaining key documents are with REMA IT and will be uploaded to the website resource page during the website upgrading process which is now being undertaken.

It will be difficult to have a section dedicated to PCB on the REMA website, as the current design only has links to documents per department. However, all guidelines and documents can be linked under the Environmental Regulations and Pollutions Control Department (titled PCB management) and/or the Climate Change and International Obligations Department (titled Stockholm Convention) in order to ensure smooth access from both ends

Key Actions:

5. Recommendation:

REMA should transfer the Jabana site ownership to REG/EUCL as the main PCB holder in the country in order to ensure the necessary operational upgrade of the new temporary storage of PCB-waste at Jabana. In the future, all PCB-contaminated materials should be stored exclusively at Jabana and ensure their storage inside the building in order to avoid risk of environmental pollution by PCBs.

Management Response: [Added: 2018/12/18]

4.1  REMA will start the transfer of site ownership to REG/EUCL immediately.

4.2 Exclusive storage of PCB-contaminated material will need to be continuously addressed through future projects, as this will involve identifying different PCB-contaminated equipment other than transformers . Streamlining of storage in Jabana will be discussed with REG/EUCL for further partnerships.

Key Actions:

6. Recommendation:

REMA in cooperation with other law enforcement agencies and support of UNDP CO should submit the developed specific PCB-related legislative framework for approval through an abridged procedure. The legal framework on the PCB management cycle should be enacted through a relevant legal instrument and/or short-term measures, that can be established directly by the Government without requirement of parliamentary approval.

Management Response: [Added: 2018/12/18]

This option will be considered. However, as this weakens the enforcement of the legislation, the route will be taken only when the current draft law cannot be enacted before the end of year 2019 or is not feasible. Until then, actions will be based on the overarching Organic Law.

Key Actions:

7. Recommendation:

REMA should follow-up with minority PCB holders for implementation of the submitted plans for phase-out of PCBs in transformers and closely monitor implementation of the phase-out plans until disposal or decontamination of the transformers.

Management Response: [Added: 2018/12/18]

The Environmental Regulation and Pollution Control Department will continuously follow up with the minor PCB holders for the implementation of the phase out plan.

PCB phase out will be a component in a future project on hazardous waste and chemicals management which is currently under development within the GEF-7 framework.

Key Actions:

8. Recommendation:

REMA and EUCL should develop a formal management plan for the Askarel transformers. The plan should include regular inspections to check the condition of the transformer in operation in order to prevent overloading, overheating and leakage as well as transport of the transformers removed from service to the new temporary storage at Jabana once the storage site is upgraded to guarantee safety of the operation and storage.

Management Response: [Added: 2018/12/18]

REMA and EUCL will develop a formal management plan for the 3 Askarel transformers. 2 out of 3 transformers will be transported to Jabana site, and the remaining 1 will be inspected once every three months.

The Askarel transformers contain pure PCB, therefore need to be diluted or destroyed overseas. This will be added as a component to the hazardous chemicals and waste management project proposal currently under development within the GEF-7 framework.

Key Actions:

9. Recommendation:

REG/EUCL should identify funding for additional equipment for retro-filling of PCB-contaminated transformers. Two different explosion-proof pumping lines will have to be provided: one for draining out (PCB-contaminated oil) and the other for refilling (PCB-free oil) to prevent any cross contamination.

8b: REG/EUCL should develop a strategy for securing the long-term investment needed to ensure steady progress in the retro-filling of the in-service PCB-contaminated transformers.

Management Response: [Added: 2018/12/18]

The two different pumps are already in the procurement plan for year 2019.

A new source of PCB-free oil was identified through the project and secured for replacement and retro-filling of transformers. A strategy will be developed in line with the phase out plan by REMA.

Key Actions:

10. Recommendation:

REMA should develop and implement a procedure of meticulous supervision of all operations for storage, transport and acceptance of the PCB-contaminated oil for incineration.

 

Management Response: [Added: 2018/12/18]

This is highly needed and will be a component under the new hazardous chemicals and waste management project under development within the framework of GEF-7.

Key Actions:

11. Recommendation:

Prior to start of the future project(s) related to management of chemical wastes including PCBs, UNDP should conduct an in-depth assessment of capacity of the project partners and determine their commitment (staff allocation and time, co-financing) to active participation in the project implementation and as well as their capacity to achieve the results that they will become responsible for.

Procurement planning for goods and services should require particular attention as national procurement procedures continue to be lengthy and complicated and will have to be streamlined. It is therefore proposed that future procurement of goods and services from international suppliers is conducted by UNDP.

Management Response: [Added: 2018/12/18]

For future projects especially on hazardous chemicals and waste, UNDP will conduct a capacity assessment of the project partners and determine their commitment as well as identify necessary external technical capacity.

For future projects on hazardous chemicals and waste, where the goods and services must be procured internationally, UNDP will streamline to avoid unnecessary delays in project implementation.

Key Actions:

12. Recommendation:

In order to establish capacity for PCB analysis, REMA should consider concluding cooperation with a laboratory abroad that has accreditation for PCB analysis. In parallel, UNDP in cooperation with the key national stakeholders (REMA and REG) should identify sources of support for establishment of a national laboratory for POPs analysis and ensure international technical assistance is provided to the designated national laboratory for improving skills in sampling and analysis of POPs/PCBs.

Management Response: [Added: 2018/12/18]

The two-step approach will be useful to ensure a continued approach. In the short term REMA will work with national laboratories to have a memorandum of understanding (MOU) with international accredited laboratories.

Capacity building of national laboratories will be a component in the hazardous chemicals and waste management project which is under development within the framework of GEF-7.

Key Actions:

13. Recommendation:

REMA should consider upgrade of the PCB database from the simple Excel sheet to a more robust information system that would better support reporting according to the Stockholm Convention. REMA and REG/EUCL should also make a commitment to manage the system in the future (e.g. by signing an MoU).

Management Response: [Added: 2018/12/18]

Upgrading of the inventory into an information system and its management arrangement will be a component in the future hazardous chemicals and waste management project which is under development within the framework of GEF-7.

 

Key Actions:

14. Recommendation:

UNDP CO in cooperation with relevant national partners should consider inclusion of capacity building components for national customs authorities in future project(s) on POPs/PCBs management.

Management Response: [Added: 2018/12/18]

Capacity building of inspectors was done on general POPs, however gaps may still remain on PCBs. A capacity assessment will be undertaken as part of project development and be addressed through future projects.

Key Actions:

15. Recommendation:

REMA should establish and eventually implement a plan for a national inventory of other PCB applications such as dielectric fluids for capacitors, voltage regulators, and hydraulic and heat transfer fluids.

Management Response: [Added: 2018/12/18]

This is highly needed. In addition to the comprehensive inventory of non-transformer PCB applications, clean up of contaminated sites will be components for the new hazardous chemicals and waste management project within the framework of GEF-7.

2019 - 2025

REMA / UNDP

 

 

* The implementation status is tracked in the ERC.

Key Actions:

Latest Evaluations

Contact us

220 East 42nd Street
20th Floor
New York, NY 10017
Tel. +1 646 781 4200
Fax. +1 646 781 4213
erc.support@undp.org