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Management and Disposal of PCBs in Rwanda
Commissioning Unit: Rwanda
Evaluation Plan: 2018-2023
Evaluation Type: Project
Completion Date: 12/2018
Unit Responsible for providing Management Response: Rwanda
Documents Related to overall Management Response:
 
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:

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