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Mid-term evaluation for Comprehensive Environmentally Sound Management of PCBs in Montenegro
Commissioning Unit: Montenegro
Evaluation Plan: 2017-2021
Evaluation Type: Project
Completion Date: 12/2019
Unit Responsible for providing Management Response: Montenegro
Documents Related to overall Management Response:
 
1. Recommendation:

Recommendation 1: PMU should initiate the analysis of the technical and economic feasibility of disposal of low-concentration PCB waste as a matter of the highest priority and investigate the legislative requirements and timelines necessary for securing relevant permits for different technology options.

Management Response: [Added: 2019/12/31] [Last Updated: 2021/01/27]

Havin in mind that work on development of PCB inventory is in the final stage we have enough information on PCB quantities present in the country. Following the recommendation, the PMU start with this activity. 

Key Actions:

Key Action Responsible DueDate Status Comments Documents
Analysis of the technical and economic feasibility of disposal of low-concentration PCB
[Added: 2019/12/31] [Last Updated: 2020/12/24]
PMU 2020/12 Completed Analysis of the technical and economic feasibility of disposal of low-concentration PCB is finalized. History
2. Recommendation:

Recommendation 2: PPMU in cooperation with PSC should develop a road map for continued coordination of PCB management in the country, including consideration of temporary institutionalization of PSC beyond the project completion date.

Management Response: [Added: 2019/12/31] [Last Updated: 2021/01/27]

The PMU will initiate discussion on this with the PSC and propose development of PPP model with the business plan until 2025, in order to have clear strategy for the establishment of such entity. Since the new Law on PPP is still pending adoption, we will guide our work with the final draft of this Law.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
Discuss this on PSC meeting
[Added: 2019/12/31] [Last Updated: 2020/12/24]
PMU 2020/12 Completed This activity is approved by PSC in activity plan for 2020. History
Engage consultant to work on the PPP model and business plan
[Added: 2019/12/31] [Last Updated: 2020/12/24]
PMU 2020/12 Completed The consultant was engaged and the work on PPP model has been finalized. History
Implement proposed and accepted model of PPP
[Added: 2019/12/31]
PMU, PSC 2021/12 Not Initiated
3. Recommendation:

Recommendation 3:  PMU in cooperation with CEDIS, and other owners of the recently identified potentially PCB-contaminated equipment and CETI should initiate sampling and analysis of this equipment, including capacitors owned by CEDIS and transformers owned by other entities including the so called “unknown owners” in order to establish the amounts of PCB-contaminated equipment and waste for disposal or decontamination.

Management Response: [Added: 2019/12/31] [Last Updated: 2021/01/27]

PMU initiated discussion with CEDIS and they agreed to collect and provide us with data on this equipment. After that on PSC meeting, we will decide on how to proceed since during the sampling of the oil equipment can be damaged and we need to know who will be responsible to resolve the issue if occur.

 

Key Actions:

Key Action Responsible DueDate Status Comments Documents
Discuss on PSC meeting on how to proceed with this
[Added: 2019/12/31] [Last Updated: 2020/12/24]
PMU, PSC 2021/06 Initiated PSC still did not decide hot to approach this issue and resolve it. History
CEDIS to collect data on this equipment
[Added: 2019/12/31] [Last Updated: 2020/12/24]
PMU 2020/12 Completed Data are collected. History
Execute the decision of PSC
[Added: 2019/12/31] [Last Updated: 2020/12/24]
PMU 2021/12 Not Initiated After the final decision on this the PMU will execute it. History
4. Recommendation:

Recommendation 4: PMU should solicit necessary external expertise for assessment of available technological and financial options in order to determine feasible alternatives for decontamination or disposal of the special transformers at Uniprom-KAP.

Management Response: [Added: 2019/12/31] [Last Updated: 2021/01/27]

Project already has international expert on contract but if project partners express their interest that someone other than this expert do the assessment, we will solicit other expertise. This will also be discussed at the PSC meeting.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
Prepare ToR for the service
[Added: 2020/01/03] [Last Updated: 2020/12/24]
PMU 2020/12 Completed All project partners and PSC are satisfied with the expert support provided by the international expert engaged by the project and there is no need to solicit the services of additional one for the same scope of work. History
Select expert
[Added: 2020/01/03] [Last Updated: 2020/12/24]
PMU 2020/12 Completed Same as the previous key action: All project partners and PSC are satisfied with the expert support provided by the international expert engaged by the project and there is no need to solicit the services of additional one for the same scope of work. History
Development of the assessment
[Added: 2020/01/03] [Last Updated: 2020/12/24]
PMU 2020/12 Completed The assessment has been developed and the project will follow the recommendations from it. History
Actions to be taken based on the recommendations from the Assessment
[Added: 2020/01/03]
PMU 2021/12 Not Initiated
5. Recommendation:

Recommendation 5:  PMU should ensure provision of international expertise in enforcement of PCB legislation for hands-on training of the national environmental inspectors.

Management Response: [Added: 2019/12/31] [Last Updated: 2021/01/27]

PMU initiated discussion with the national environmental inspection and will intensify the work on building their expertise.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
Prepare plan for the trainings
[Added: 2020/01/03] [Last Updated: 2021/05/12]
PMU 2021/12 Initiated This activity has been initiated, as the project team started the negotiations/communication with partners. Due to Covid-19 pandemic this activity is pending as the authorities introduced a number of measures in order to protect health of the citizens and hands-on trainings are not possible to be organized. History
Implementation of the plan
[Added: 2020/01/03]
PMU 2021/12 Not Initiated
6. Recommendation:

Recommendation 6: PMU in collaboration with MoSDT should consider elaboration of a proposal for legal and financial incentives to encourage the PCB holders to take early actions for phase out of the in-service electrical equipment well in advance of the 2025 deadline. In addition, the PMU in collaboration with CEDIS and Uniprom-KAP should consider introducing presentation of maintenance plans of online PCB equipment at PSC meetings and discuss timelines for replacement and disposal of online PCB equipment well before the project ends in 2021.

Management Response: [Added: 2019/12/31] [Last Updated: 2021/01/27]

The recommendation on incentives will be further investigated and discussed vit the PSC and the MoSDT.

The part about presentation of maintenance plans on PSC meetings will be implemented on the meetings that will be organized at the beginning of 2020.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
Discuss this recommendation on PSC meeting
[Added: 2020/01/03] [Last Updated: 2020/12/24]
PM, PSC 2021/12 Not Initiated History
7. Recommendation:

Recommendation 7: PMU in cooperation with MoSDT should ensure cooperation with the on-going research project on health impact of PCBs that is being implemented by the Montenegrin Institute for Public Health. The cooperation should focus on monitoring PCB health impacts for workers with electrical equipment and communities living in the neighbourhood of the temporary PCB storage facilities.

Management Response: [Added: 2019/12/31] [Last Updated: 2021/01/27]

CO already started with the formalization of the cooperation with the Institute for Public Health (IPH). This recommendation will be fully implemented.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
Monitoring of PCB impact on health
[Added: 2020/01/03] [Last Updated: 2020/12/24]
PM, IPH 2021/12 Initiated Due to COVID-19 outbreak this activity is put on hold. History
Prepare and sign cooperation agreement with IPH
[Added: 2020/01/03] [Last Updated: 2020/12/24]
PMU 2020/12 Completed The cooperation agreement with IPH has been signed. History
8. Recommendation:

Recommendation 8: PMU in cooperation with the main PCB holders should consider practical involvement of students of higher education in activities on PCB management, for example through participation of students in the preparation of the next export shipment of PCB waste.

Management Response: [Added: 2019/12/31] [Last Updated: 2021/01/27]

Ensure participation of students

Key Actions:

Key Action Responsible DueDate Status Comments Documents
Ensure participation of students in next export of PCB waste
[Added: 2020/01/03]
PMU 2021/12 Not Initiated
9. Recommendation:

Recommendation 9: PMU in cooperation with MoSTD and other relevant governmental agencies should consider pilot testing on sampling and analysis of PCBs in caulk, glazing and painting materials in older buildings.

Management Response: [Added: 2019/12/31] [Last Updated: 2021/01/27]

This activity is not part of the PCB project that we were approved to implement. We will investigate the willingness of the Government to do some investigation to determine is there a PCB in caulk, glazing and painting materials in older buildings. This could be considered as an idea for another chemicals project.

This activity needs to be approved by the donor in order to be financed from already approved financial resources.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
Discuss the issue on the PSC and agree on how to proceed with it.
[Added: 2020/01/03] [Last Updated: 2020/12/24]
PM, PSC 2021/07 Initiated History
10. Recommendation:

Recommendation 10: PMU should consider a revision of the project results framework to ensure its consistency and full compliance with the principles of the results-based management.

Management Response: [Added: 2019/12/31] [Last Updated: 2021/01/27]

The project was designed based on a number of years of implementation of similar programmes. We will review results framework again and decide on the PSC the proposed revision.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
Review the results framework and discuss to need to change it
[Added: 2020/01/03] [Last Updated: 2020/12/24]
PMU, PSC 2021/12 Initiated History
11. Recommendation:

Recommendation 11: PMU in cooperation with MoSDT and the two major PCB holders should develop and agree clear rules for accounting of the in-kind contributions to the project.

Management Response: [Added: 2019/12/31] [Last Updated: 2021/01/27]

This recommendation will be implemented, and all in-kind contribution will be recorded.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
Develop clear rules for accounting the in-kind contributions
[Added: 2020/01/03] [Last Updated: 2020/12/24]
PMU 2020/12 Completed PMU will provide guidelines for the in-kind contributions accounting to project partners. History
Collect data on in-kind co-financing from the partners
[Added: 2020/01/03]
PMU 2021/12 Not Initiated
12. Recommendation:

Recommendation 12: PMU should conduct a thorough reassessment of the project risks after the MTR stage and ensure that critical risks are properly identified and addressed in the Critical Risk Management section of the annual PIRs together with the corresponding assessment from the side of RTA.

Management Response: [Added: 2019/12/31] [Last Updated: 2021/01/27]

The PMU will do the reassessment of the project risks and continue to follow it on a quarterly basis. Every risk that is considered to be critical will be reported in the annual PIR.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
Quarterly follow up of the risks
[Added: 2020/01/03]
PMU 2021/12 Initiated
Reassessment of project risks
[Added: 2020/01/03] [Last Updated: 2020/12/24]
PMU 2020/12 Completed Risks are reassessed. History

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