NATIONAL IMPLEMENTATION PLAN for the MANAGEMENT of PERSISTENT ORGANIC POLLUTANTS (POPS) in the REPUBLIC of BULGARIA Full Version Project GF/2732 – 02 - 4454

REPUBLIC OF BULGARIA

NATIONAL IMPLEMENTATION PLAN FOR THE MANAGEMENT OF PERSISTENT ORGANIC POLLUTANTS (POPS) IN THE REPUBLIC OF BULGARIA Full version Project GF/2732 – 02 - 4454

National Implementation Body & Coordinator Ministry of Environment and Water

Sofia, March 2006

Title: National Implementation Plan for the Management of Persistent Organic Pollutants (POPs) in the Republic of Bulgaria National Ministry of Environment and Water of the Republic of Bulgaria Implementing body

Publisher: Ministry of Environment and Water 67, W.Gladstone Str. Sofia, 1000 www.moew.government.bg The National Implementation Plan for the Management of POPs in the Republic of Bulgaria was developed under Bulgarian sub-project GF/2732-02-4454 within the global project” GEF/UNEP: GF/2732-02-4452 “Deevelopment of 12 pilot country NIPs for the management POPs” by POPs team of experts of Ministry of Environment and Water (MoEW) and contribution of national consultants of „Balkan Science and Education Centre of Ecology and Environment”(BSECEE), Sofia This publication is composed on the full version of National Implementation Plan for the Management of Persistent Organic Pollutants (POPs) in the Republic of Bulgaria, March 2006. Project Manager Dr. Dzhevdet Chakarov Minister of Environment and Water National Coordinator Prof. Georgi Antov, PhD, DMSc Responsible Svetla Krapcheva, MSc, Experts Department Chief of “Operative Control and Management of Hazardous Chemicals”, MoEW MoEW e-mail: [email protected] eng. Tsvetanka Dimcheva, senior expert of MoEW e-mail: [email protected] , etc BSECEE Prof. eng. Ivan Dombalov, PhD, Director BSECEE, Sofia Consultants e-mail: [email protected] Assoc.prof. eng. Ekaterina Todorova, PhD, FU, Sofia e-mail: [email protected] eng.ecologist Evgeni Sokolovski, MSc, UCTM, Sofia e-mail: [email protected] etc. International United Nations Environmental Programme Implementing UNEP Chemicals, Agency International Environment House 15 Chemin des Anémones, CH-1219, Châtelaine Geneva, Switzerland www.chem.unep.ch Project Manager Dr.David Piper, GEF/UNEP: Task Manager “POPs enabling activities”, Division of GEF Coordination GF/2732-02-4452 UNEP Chemicals, “12 pilot country NIPs for POPs” Geneva, Switzerland e-mail: [email protected] All rights reserved First WEB Edition, March 2006

2 D E C I S I O N dated 23 of March 2006 of the National Coordinating Committee (NCC) under Bulgarian GF/2732-02-4454 project The members of the National Coordinating Committee (NCC), coordinating and assisting the development of Bulgarian GF/2732-02-4454 project “National Implementation Plan (NIP) for the Management of Persistent Organic Pollutants(POPs) in the Republic of Bulgaria”: Recognizing that persistent organic pollutants possess toxic properties, resist degradation, bioaccumulate and are transported, through air, water and migratory species, across international boundaries and deposited far from their place of release, where they accumulate in terrestrial and aquatic ecosystems, Aware of the human health concerns, especially in the regions with potential for formation and release of these chemicals to the environment, resulting from the negative effects of persistent organic pollutants, in particular impacts upon women and, through them, upon future generations, Recognizing the important contribution that the private sector and non-governmental organizations can make to achieving the reduction and/or elimination of emissions and discharges of persistent organic pollutants, Conscious of the need to take measures to prevent adverse effects caused by persistent organic pollutants at all stages of their life cycle, Recognizing the importance of developing and using environmentally sound alternative processes and chemicals, Determined to protect human health and the environment from the harmful impacts of persistent organic pollutants, Have considered on its meeting on 23 March 2006 the final draft of the National Implementation Plan (NIP)for the management of Persistent Organic Pollutants(POPs) in the Republic of Bulgaria”and have agreed the following

D E C I S I O N:

The National Coordinating Committee (NCC) approves and endorses the final draft of the National Implementation Plan (NIP) for the management of Persistent Organic Pollutants(POPs) in the Republic of Bulgaria”. The endorsed NIP includes a set of measures which implementation shall allow safe storage of POPs and obsolete pesticides stockpiles, gradually phasing out of PCBs equipment and the reduction of unintentional production of POPs releases derived by different industrial sectors.

The successful implementation of the present NIP by responsible authorities and institutions will prepare Bulgaria to meet its obligations set under the Stockholm Convention on POPs.

National Coordinator Bulgarian GF/2732-02-4454 project: (Prof. Georgi Antov, PhD, DMSc)

MINISTER of Ministry of Environment and Water: and Chairman of NCC and Project Manager: (DR. DZHEVDET CHAKAROV)

ACKNOWLEDGEMENT

The Ministry of Environment and Water of the Republic of Bulgaria acknowledges the United Nations Environmental Programme for its assistance in obtaining the GEF support for the the Global project “Development of National Implementation Plans for the Management of Persistent Organic Pollutants (POPs)” for twelve pilot countries, including the Republic of Bulgaria.

This publication is a result of a collaborative effort and was prepared during the development of the UNEP/GEF Bulgarian Sub Project GF/2732-02-4454 “Development of National Implementation plan (NIP) for the Management of Persistent Organic Pollutants (POPs) in the Republic of Bulgaria” under the provisions of the Stockholm Convention on Persistent Organic Pollutants (POPs) with the support of the Ministry of Environment and Water of the Republic of Bulgaria experts, National Coordinating Commette members, international and national experts.

That document was developed due to the contribution and support of all listed persons, members of the National Co-ordination Committee, Representatives of interested institutions, ministries, universities, organizations, NGOs and national experts.

We are most grateful to Krizstina Kiss, Project Manager GEF/UNEP-12 pilot country NIPs for POPs for the period August 2002 – June 2005 and Dr. David Piper, Task Manager (POPs enabling activities), UNEP Division of GEF Coordination, Project Manager GEF/UNEP-12 pilot country NIPs for the period June 2005 – March 2006, for their support and encouragement in the work. We express our gratitude also to Victor Ogbuneke (Fund Programme Management Officer, Division of GEF Coordination, UNEP HQ, Nairobi, Kenya) for the prompt and professional assistance on NIP’s financial and budget issues.

Special thanks go to the following international consultants for their contribution and methodological support: Peter J. Peterson, Senior Special Fellow Chemicals and Waste Management, United Nations Institute for Training and Research (UNITAR) (Switzerland), John Vijgen , International HCH PA (Denmark), Yves Guibert (France); we also thank Dr. Heidelore Fiedler, Scientific Affairs Officer, UNEP Chemicals (Switzerland), for the appropriate and promt UNEP peer review.

For their creativity and co-ordination of the entire preparatory process, we express our gratitude to the Minister of MoEW Dr. Dzhevdet Chakarov, Chairman of NCC and Project Manager and prof. Georgi Antov, PhD, DMSc, National coordinator of Bulgarian POPs subproject. We highly appreciate the contribution of the experts of MoEW’s POPs team and the national project consultant „Balkan Science and Education Centre of Ecology and Environment”(BSECEE), Sofia with expert group manager prof. eng. Ivan Dombalov, PhD for the active and professional participation within the formulation and development of Bulgarian NIP for POPs and special thanks go to them. Last, but not least, we express our gratitude to all members of the National Coordinating Commette for their assistance and expert support for the successful finalizing of this project.

Ministry of Environment and Water of the Republic of Bulgaria

NATIONAL IMPLEMENTATION PLAN FOR THE MANAGEMENT OF PERSISTENT ORGANIC POLLUTANTS (POPS) IN THE REPUBLIC OF BULGARIA Full version Project GF/2732 – 02 - 4454

MINISTRY OF ENVIRONMENT AND WATER

Sofia, March 2006

TABLE OF CONTENTS DECISION ...... 3 ACKNOWLEDGEMENT...... 4 LIST OF ABREVIATIONS ...... 8 UNITS OF CONCENTRATION ...... 10 EXECUTIVE SUMMARY...... 11 1. INTRODUCTION ...... 28 1.1. STOCKHOLM CONVENTION ON PERSISTENT ORGANIC POLLUTANTS ...... 31 1.2. OBJECTIVES AND PROVISIONS OF STOCKHOLM CONVENTION...... 31 1.2.1. Annex А – Elimination, part І...... 32 1.2.2. Annex А – Elimination, part ІІ...... 33 1.2.3. Annex B – Restriction part І ...... 33 1.2.4. Annex B – restriction part ІІ...... 33 1.2.5. Annex C, Unintentional production, part І ...... 34 1.2.6. Annex C, Unintentional production, part ІІ ...... 34 1.2.7. Annex C, unintentional production, part ІІІ...... 34 2. COUNTRY BASELINE ...... 35 2.1. COUNTRY PROFILE...... 35 2.1.1. Geography and Population ...... 35 2.1.2 Political and economic profile...... 37 2.1.3. Profiles of economic sectors ...... 39 2.1.4 Environmental overview ...... 45 2.2. INSTITUTIONAL POLICY AND REGULATORY FRAMEWORK ...... 49 2.2.1. Environmental Policy, Sustainable Development and General Legislative Framework ...... 49 2.2.2. Roles and Responsibilities of Ministries, Agencies and other Governmental Institutions involved in POPs management ...... 49 2.2.3. Relevant international commitments and obligations...... 58 2.2.4. Description of existing Legislation and Regulations addressing POPs (manufactured chemicals and unintentionally produced POPs)...... 68 2.2.5. Key approaches and procedures for POPs chemical and pesticides management, including enforcement and monitoring requirements...... 74 2.3. ASSESSMENT OF THE POPS ISSUE IN THE COUNTRY...... 80 2.3.1 Assessment with respect to Annex A, part І chemicals & Annex B (POPs pesticides) of Stockholm Convention...... 87 2.3.2 Assessment with respect to Annex A, Part II chemicals – PCBs in equipment...... 134 2.3.3. Assessment with respect to Annex B chemicals - DDT...... 158 2.3.4. Assessment of rleases from unintentional production of Annex C chemicals (PCDD/PCDF, HCB and PCBs) ...... 158 2.3.5. Information on the state of knowledge on stockpiles, contaminated sites and wastes, identification and data on releases from sites ...... 189 2.3.6. Summary of future production, use and releases of POPs...... 192 2.3.7. Existing programmes for monitoring releases and environmental and human health impacts .193 2.3.8. Current level of information, awareness and education among target groups; existing systems to communicate such information to the various groups...... 198 2.3.9. Relevant activities of non-governmental stakeholders...... 201

6 2.3.10. Overview of technical infrastructure for POPs assessment, measurement, analysis, management, research and development ...... 203 2.3.11. Identification of impacted populations or environments...... 210 2.3.12. Detals of any relevant system for the assessment and listing of new chemicals ...... 210 3. STRATEGY AND ACTION PLAN ELEMENTS OF THE NATIONAL IMPLEMENTATION PLAN...... 212 3.1 POLICY STATEMENT ...... 212 3.1.1. Project activities ...... 212 3.1.2. Action Plan elements...... 212 3.1.3. NIP outcomes...... 213 3.1.4. Institutional arrangement, Participants and Stakeholders...... 213 3.2. Implementation strategy...... 214 3.2.1. Guiding Principles of the Implementation Strategy ...... 214 3.2.2. SWOT – Analysis on the possibilities to meet the provisions of Stockholm convention in R Bulgaria...... 214 3.2.3. Strategic goal and national objectives of NIP for POPs (Objectives tree) ...... 216 3.2.4. Criteria for priority setting ...... 216 3.2.5. Identified Priorities of National significance...... 217 3.3. ACTIVITIES, STRATEGIES AND ACTION PLANS...... 217 3.3.1. POPs Specific Action Plans ...... 219 3.4. DEVELOPMENT AND CAPACITY-BUILDING PROPOSALS AND PRIORITIES ...... 243 3.4.1. Technological & laboratory infrastructure...... 243 3.4.2. Strengthening of the administrative capacity of the institutions responsible for management of POPs ...... 244 3.4.3. Personnel qualification raising & training and technical resources for the copmpetent institutions responsible for POPs management ...... 244 3.4.4. Public participation and awareness raising on POPs issues ...... 245 3.4.5. Draw up Project Proposals and apply for providing funding from Global Environment Facility.247 3.5. TIMETABLE ...... 248 3.6. PRELIMINARY ASSESSMENT OF THE FINANCIAL RESOURCES OF POPS ACTION PLAN...... 252 3.6.1. Financial cost of the minimisation and neutralisation of pesticides and pesticide warehouses.252 3.6.2. Financial costs to minimise and neutralise PCBs in equipment ...... 252 3.6.3. Financial costs to minimise and eliminate POPs in emissions ...... 253 3.6.4. Financial costs for soil remediation and polluted sites decontamination ...... 253 3.6.5. Financial costs for control and monitoring laboratories...... 253 3.6.6. Alternative sources of financing ...... 254 3.6.7. Required funds to implement the NIP for POPs in Bulgaria ...... 254

L I S T O F A B B R E V I A T I ON S

ABEITR Association of the Bulgarian Enterprises for International Transport and Roads ADI Acceptable Daily Intake BAS Bulgarian Academy of Sciences BB Cube A reinforced concrete container for storage of hazardous substances BCC Bulgarian Chamber of Commerce BCCI Bulgarian Chamber of Chemical Industry – non-governmental organisation BCCI Bulgarian Chamber of Commerce and Industry BD Basin Directorate BSECEE Balkan Science and Education Centre of Ecology and Environment CEFIC European Chemical Industry Council CPSA Civil Protection State Agency DDD/DDE Metabolites of DDT DDT Dichlorodiphenyltrichloroethane DLPCBs Dioxin-like PCBs EA BAS Executive Agency Bulgarian Accreditation Service EAGLI Executive Agency of the General Labour Inspectorate. EC European Commission EEA European Environmental Agency. EEA Executive Environment Agency. EIA Environmental Impact Assessment ESM Environmentally sound management EMEP Co-operative Programme for Monitoring and Evaluation of the Long-Range Transmission of Air Pollutants in Europe EU European Union FAO Food and Agriculture Organisation of the Unated Nations GEF Global Environment Facility GDC General Directorate “Customs” GVA Gross Value Added GDP Gross Domestic Product HCB Hexachlorbenzene HEF Higher Education Facility IAC Interagency Committee IACEE Inter-agency Council of Environmental Experts IARC International Agency for Research on Cancer IERS International Emergency Response System IHE (RIPHPC) Institute of Hygiene and Epidemiology (Regional Inspectorate for Public Health Protection and Control). IPPC Integrated Pollution Prevention and Control I-TEQ International Toxicity Equivalence

KAW Air/Water Partition Coefficient

KOW Octanol/ Water Partition Coefficient

LD50 Median Lethal Dose LRTAP Long Range Transport Air Pollutants MDL Minimum Detectable Level MRL Maximum Residue Limit MoAF Ministry of Agriculture and Forestry MoCT Ministry of Culture and Tourism MoD Ministry of Defence

8 MoEE Ministry of Economy and Energy MoEER Ministry of Energy and Energy Resources MoEW Ministry of Environment and Water MoF Ministry of Finance MoH Ministry of Health MoI Ministry of Interior MoLSP Ministry of Labour and Social Policy MoTC Ministry of Transport and Communications MPATH Multi-Profile Active Treatment Hospital. NCHMEN National Centre for Hygiene, Medical Ecology, and Nutrition NCPHP National Centre for Public Health Protection NCRRP National Centre for Radiology and Radiation Protection NEPF National Environment Protection Fund at the MoEW NESAP National Environmental Strategy and Action Plan NGOs Non-Governmental Organisations NHIC National Health Information Centre NHIF National Health Insurance Fund NIMS National Institute for Medicinal Substances NIS National Institute of Statistics. NPP Nuclear Power Plant NPPS National Plant Protection Service NRA Nuclear Regulation Agency NROD National Register of Occupational Diseases NSFES National Service for Fire and Emergency Safety OMO Occupational Medicine Office PCBs Polychlorinated Biphenyls PCDDs Polychlorinated Dibenzodioxins PCDFs Polychlorinated Dibenzofurans PCPPCE Permanent Commission for Protection of the Population during Calamities and Emergencies PCPPCEC Permanent Commission for Protection of the Population during Calamities and Emergencies and Catastrophes PIC Prior Informed Consent POPs Persistent Organic Pollutants, as defined in the Stockholm Convention. PPCA Post-Privatisation Control Agency REACH Registration, Evaluation and Authorisation of Chemicals RHC Regional Healthcare Centre RIEW Regional Inspectorate of Environment and Water SAICM Strategic Aproach to International Chemicals Management SCEE Supreme Council of Environmental Experts SMSA Standardisation and Metrology State Agency SNCC State National Construction Control TEQ Toxicity Equivalents TP Traffic Police TPP Thermal Power Plant UNEP Unated Nations Environmental Programme UNIDO Unated Nations Industrial Development Organisation WHO World Health Organisation

Units of concentration mg/kg milligram(s) per kilogram. Corresponds to parts per million (ppm) by mass. µg/kg microgram(s) per kilogram. Corresponds to parts per billion (ppb) by mass. ng/kg nanogram(s) per kilogram. Corresponds to parts per trillion (ppt) by mass. Mg megagram (1,000 kg or 1 tonne) kg kilogram mg milligram ng nanogram Nm3 normal cubic metre; refers to dry gas, 101.3 kPa and 273.15 K kW kilowatt kWh kilowatt-hours MJ megajoule million 106 billion 109 trillion 1012 ppm parts per million ppb parts per billion ppt parts per trillion

EXECUTIVE SUMMARY

1. INTRODUCTION The aim of the Stockholm Convention is to protect human health and the environment from Persistent Organic Pollutants (POPs) impacts. POPs possess toxic properties, resist degradation, bioaccumulate and are transported, through air, water and migratory species, across international boundaries and deposited far from their place of release, where they accumulate in terrestrial and aquatic ecosystems. Annex A, B & C list 12 Persistent Organic Pollutants (POPs) – the POPs pesticides (aldrin, dieldrin, endrin, mirex, toxaphene, hexachlorbenzene, heptachlor, chlordane and DDT), the industrial chemicals – polychlorinated biphenyls (PCBs) and the POPs chemicals, formed and released unintentionally from anthropogenic sources (Polychlorinated dibenzo-p- dioxins and dibenzofurans - PCDD/PCDF, Hexachlorobenzene - HCB and Polychlorinated biphenyls - PCBs). The Republic of Bulgaria signed the Stockholm Convention on POPs on 23 May 2001 at the Conference of Plenipotentiaries held in Stockholm, Sweden. On 30 September 2004, the Convention was ratified with a Law by the National Assembly (SG No. 89/ 12.10.2004). and it is effective for Bulgaria from 20 March 2005. With funds granted by GEF (Global environmental facility) and with the assistance of the United Nations Environment Programme the Ministry of Environment and Water, Bulgaria has developed the present National Implementation Plan for the Management of POPs (NIP) drawn up under sub-project GF/2732-02-4454 within the frame of Global Project GEF/UNEP: GF/2732-02-4452 “Development Of National Implementation Plans for the Management of Persistent Organic Pollutants (POPs)” for twelve pilot countries. The NIP preparation took 4 years and all the activities were coordinated by a National Coordinating Committee (NCC), appointed by the Bulgarian Project Manager. A number of experts, representatives from interested institutions, ministries, universities, organizations, NGOs, etc., included in the NCC took part actively within the process of formulating and development of Bulgarian NIP for POPs. The present National Implementation Plan for the management of POPs in Bulgaria is developed on the basis of the requirements of Article 7 of Stockholm convention. Bulgaria shall transmit its implementation plan to the Conference of the Parties within two years of the date on which the Convention enters into force for it, i.e. until 20 March 2007. The NIP includes a set of measures which implementation shall allow safe storage of POPs and obsolete pesticides stockpiles, gradually phasing out of PCBs equipment and the reduction of unintentional production of POPs releases derived by different industrial sectors. Generally the present NIP comprises targeted activities that will prepare Bulgaria to meet its obligations set under the POPs Convention. The National Implementation Plan for the Management of POPs in the Republic of Bulgaria (NIP) comprises two main parts. The First part of NIP summarises: 1. Country Baseline 2. Assessment of the POPs issue in the country, based on the preliminary POPs inventories. The Second Part of the NIP includes: 1. Strategy and action plan elements of the national implementation plan 2. Implementation strategy 3. Specific Action plans: Action plan for POPs Pesticides - Aldrin, Chlordane, Dieldrin, Endrin, Heptachlor, Hexachlorobenxene, Mirex, Toxaphene and DDT;

11 Action plan for PCBs in Equipment; Action plan for POPs releases from unintentional production (PCDD/PCDFs, PCBs and HCB). 4. Development and capacity-building proposals and priorities 5. Timetable for plan implementation and measures of success 6. Resource requirements preliminary assessment for NIP implementation The results of the assessment on POPs issues in the country, based on national preliminary POPs Inventory indicate the following:

2. ASSESSMENT OF POPS ISSUE IN R BULGARIA BASED ON INVENTORY RESULTS 2.1.ASSESSMENT WITH RESPECT TO POPS AND OBSOLETE PESTICIDES

POPs pesticides have never been manufactured in the Republic of Bulgaria. Most POPs pesticides have been applied mainly as pest control preparations to treat termites and soil insects. The use of POP pesticides has been largest in the 60s in quantities 100-200 t annually. The import and use of aldrin, dieldrin, endrin and DDT was banned in 1969, toxaphene in 1985 and heptachlor in 1991. Mirex, hexachlorobenzene and hlordane have not been imported and used in the country. All POPs pesticides are banned for import and use in agriculture.

Table 1POPs pesticides: Production, import, export and year of ban POPs Pesticides Production Import Period of Imported Export Year of Ban Import Amount, t/y for import and use

Aldrin No Yes 1960-1969 135-200 No 1969

Dieldrin No Yes 1960-1969 100 No 1969

Endrin No Yes 1960-1969 100 No 1969

Mirex No No No

Toxaphene No Yes 1960-1985 100-150 No 1985

Hexachlorobenzene No No No

Heptachlor No Yes 1960-1990 100 No 1991

Chlordane No No No

DDT No Yes 1950-1965 No 1969

The obsolete and useless pesticides, including POPs are stored in centralized and municipal warehouses and BB cubes (steel-concrete containers with size 195x195x195 cm, hermetically sealed with useful volume 5 m3). The available obsolete pesticides stockpiles, including also POPs pesticides and mixtures, consisting of or contaminated with POPs in RBulgaria at the end of 2004 are:

Table 2Available obsolete pesticides stockpiles and assumed POPs pesticides amounts in RBulgaria at the end of 2004

№ Obsolete and useless pesticides stockpiles (OP) Unit Quantity

1 . OBSOLETE PESTICIDES Total OP stockpiles in warehouses and BB cubes t 11,222

In warehouse, including t 7011 in 84 centralized warehouses t 4703 in 477 unrepaired municipal warehouses t 2308 In 1255 BB cubes t 4211

Total OP stockpiles, stored in safe centralized warehouses, conforming to all requirements and in BB cubes t 8914

2. POPS PESTICIDES AND MIXTURES Total POPs pesticides stockpiles in warehouses, including t 52,313

POPs pesticides assumed stockpiles, including t 22,255 Aldrin t 1,395 Dieldrin t 1,595 Endrin t 0,204 Toxaphene t 0,720 Heptachlor t 7,592 DDT t 10,749 Mixtures of ‘unknown’ obsolete pesticides, consisting of or contaminated with POPs t 30,058

After the ban of POPs pesticides for import and use, the country took measures for their replacement with alternative registered in Bulgaria insecticides, suitable for agricultural application in any specific case. In August 2000 under the project “Destruction of Risk Pesticides from Bulgaria in the Netherlands”, 27680 kg of POP pesticides such as DDT, aldrin and dieldrin from Bulgaria’s regions Sofia, Plovdiv, Shumen and Burgas have been exported to Netherlands, and destroyed in an incinerator in Rotterdam.

The assumed POPs pesticides stockpile at the end of 2003 in Bulgaria is in the range 22.25 t - 25.82 t . The obsolete pesticides mixtures, consisting of or contaminated with POPs comprise approx. 30.06 t. These could not be identified because of the absence of labels, torn packages and mixing with other Obsolete pesticides. The assumed total POPs pesticides stockpile is thus between 52.3 t and 55.9 t. To identify the specific POPs pesticides, contained in 2308 t obsolete pesticides with ‘unknown ‘ composition, stored in 477 unrepaired municipal warehouses, the implementation of detailed POPs pesticides Inventory is required.

2.1.1. MONITORING

Surface and Ground water POPs pesticide monitoring indicates excellent condition of surface and groun dwater on the whole territory of the country. During 2003 in R Bulgaria there are no surface and ground water, polluted with POPs pesticides.

Soil In all studied regions of R Bulgaria no soils polluted with the following POPs pesticides (aldrin, dieldrin, endrin, heptachlor and hexachlorbenzene) exist. DDT and metabolite residues in soils are still registered in the environment of almost all regions of the country. The summarized analytical data show that about 95% of soils in the country are not polluted with DDT. No new POPs soil pollution levels were recorded in 2003. At all points the measured content of POPs pesticides, PCBs and HCB is considerably below the reference background values and no potential threat exists from POPs soil pollution. Isolated local cases of DDT soil pollution were registered. The monitoring results show that at this stage the agricultural activities do not result in further soil load. That fact is due on the one hand to the reduced fertilizer and pesticides consumption , but also to the performed programs for environmental-friendly agriculture and biological production.

Food No presence of any residues of POPs pesticides exceeding the maximum admissible residual concentration (MARC) in the tested 2200 foodstuffs from vegetable and animal origin for the Year 2003 has been detected. No cases of acute and chronic intoxication with persistent chlororganic pesticides have been registered in the Republic of Bulgaria.

No presence of any residues from POPs pesticides ncluding such as Aldrin, DDT, Heptahlor epoxide and PCBs in the tested samples of Live Animals, Fresh Meat, Poultry, Fish, Farmed & Wild Game, Raw Milk, Hen Eggs and Bee Honey in Bulgaria for the Year 2003 has been detected.

2.1.2. EXISTING POLICY

During the period 2001 - 2004, steady improvements were made in the management and safe storage of banned and obsolete pesticides.

The construction of centralized municipal warehouses and BB cubes conforming to the legislative requirements for safe disposal, liable storage of available obsolete pesticides stockpiles and cleaning up of emptied warehouses are activities that illustrate consistency in environmental protection policy and sustainable management of obsolete pesticides.

The funds allocated by the Enterprise for Management of Environmental Protection Activities (EMEPA) and National Plant Protection Service (NPPS) have been increasing constantly during the period 1998- 2004 for safe storage of obsolete & unusable pesticides, repairing of warehouses, cleaning up of premises and sites, collection, re-packing, and shifting of chemicals from warehouses in the small urban centres to municipal and centralised warehouses, or disposal in BB cubes. The totally allocated funds by EMEPA for safe storage of obsolete pesticides for the period 1998-2005 equals to approx. 7,5 million BGN as only for 2004 the funds are almost 2 millions BGN. The decreasing of old warehouses and the environmentally sound storage of obsolete pesticides has reduced the threat of environmental pollution and human health risk.

Nevertheless the steady positive trends observed during recent years and constantly increased funds allocated by Bulgarian state for the management of POPs and obsolete pesticides , the Republic of Bulgaria can not cope alone with final solving of POPs and Obsolete pesticides stockpiles without international financial support, due to limited national funding available and the fact that Bulgaria is in Currency Board. To reduce the risk of POPs pesticides impacts on human health and the environment measures should be taken for safe storage and/or environmentally sound disposal abroad, due to absence of appropriate disposal facility in the country. For this purpose the Republic of Bulgaria needs to be supported by providing financial resources from GEF and other international, bilateral, regional and multilateral twinning programmes.

2.2.ASSESSMENT WITH RESPECT TO PCBS IN EQUIPMENT

In Bulgaria PCBs were used mainly dielectric fluids in electrical equipment such as transformers and capacitors. The manufacturers of transformers and capacitors in Bulgaria are 5 companies and of transformer and capacitor oils – 6 companies. None of the these manufacturers have never produced equipment and oils, containing PCBs. For the period 1970 г.÷1990 г. in the country totally 1954 transformers have been imported, out of which most likely to contain PCBs are the transformers imported from PCBs manufacturing countries – the USSR, West Germany, East Germany, and Czechoslovakia.

Table 3 Annex A, Part II chemicals: PCBs production, import, export, year of ban in RBulgaria for 2003. Annex A, Part II Production Import Export Year Chemicals of Ban PCBs in equipment and oils No Yes No 1985 1954 transformers

The inventory of equipment (transformers and capacitors) and oils, carried out on the territory of Republic of Bulgaria in 2003, has found out the following. In 2003 a total of 43644 transformers and 45715 t oils and 17689 capacitors have been inventoried. The preliminary inventory of PCBs in equipment found out the availability of electric equipment, containing PCBs with concentration > 0,05 % by weight and volume > 5 dm3.

Table 4 Electric equipment with volume > 5 dm3 and oils, containing PCBs with concentration > 0,05 % and > 0,005 % < 0,05% by weight Electric equipment PCBs oils, PCBs equipment Remark tones number In-use transformers with PCBs concentration > 327,2 158 The equipment and oils 0,05 % by weight and volume > 5 dm3, including with PCBs assumed are waste and fresh oils not included here. In-use transformers with PCBs concentration > 1642,1 41 Only the amount of 0,005 % by weight and < 0,05 % by weight and oils, containing PCBs volume > 5 dm3 had been identified, but not the weight of Capacitors, containing PCBs, including in-use, 7,9 2415 contaminated phased-out and spare equipment equipment Total oils/equipment, containing PCBs 1977,2 2614

Out of the total of 61333 items of electric equipment inventoried, 2614 transformers and capacitors and 1977,2 t oils, containing PCBs > 0,05 % by weight have been identified (table 4). Holders of that PCBs equipment are mainly companies from electric power sector, metallurgy, mining and chemical industry. Table 5 shows detailed data for the status of equipment and oils, containing PCBs.

Table 5 In-use, phased-out and spare equipment, containing PCBs and oils,containing PCBs, including in-use, waste and fresh on stock in Bulgaria for 2003 № Equipment and oils, containing PCBs and PCBs assumed Unit Quantity 1. TRANSFORMERS In-use transformers with PCBs concentration > 0,05 % by weight and volume > 5 dm3 pcs 158 In-use transformers with PCBs concentration > 0,005 % by weight and volume > 5 dm3 pcs 41 In-use transformers with PCBs assumed pcs 3082 2. TRANSFORMER OILS In in-use transformers with PCBs concentration > 0,05 % by weight and volume > 5 dm3 t 310,5 In in-use transformers with PCBs concentration > 0,005 % by weight and volume > 5 dm3 t 1642,1 In in-use transformers with PCBs assumed t 2483,6 3. WASTE TRANSFORMER OILS waste transformer oils with PCBs concentration > 0,05 % by weight t 9,88 waste transformer oils with PCBs assumed t 10,24 4. FRESH TRANSFORMER OILS ON STOCK fresh transformer oils with PCBs concentration > 0,05 % by weight t 6,8 fresh transformer oils with PCBs assumed t 36,84 5. CAPACITORS In-use capacitors, containing PCBs pcs 1769 In-use capacitors with PCBs assumed pcs 2159

16 6. SPARE CAPACITORS ON STOCK Spare capacitors, containing PCBs pcs 32 Spare capacitors with PCBs assumed pcs 245 7. PHASED-OUT CAPACITORS ON STOCK Phased-out capacitors, containing PCBs pcs 614 Phased-out capacitors with PCBs assumed pcs 230 8. CAPACITOR OILS In in-use capacitors, containing PCBs t 7,9 In in-use capacitors with PCBs assumed t 3,3

Only PCBs transformer & capacitor oils have been identified. The weight of PCBs equipment has not been reported , causing gaps in the data declared. In many cases, PCBs equipment owners declared either the number of items of equipment or the oil quantity but not both. Hence the PCBs quantity in equipment and oils is assumed to be higher than the found out by the inventory. To identify the actual PCBs quantity a detailed inventory of PCBs is needed.

2. 3.ASSESSMENT OF PCDD/PCDF, HCB AND PCBS RLEASES The emissions are calculated in relation with National CORINAIR - 94 methodology, approved by the Minister of Environment and Waters. It was developed by adapting the emission inventory Guide - CORINAIR-94, SNAP-94 for the Bulgarian conditions, taking into account the national specificities concerning the respective activity, technologies and equipment.

National annual POPs emissions (Dioxins/Furans, PCBs and HCB) In comparison to base year 1990, the annual emissions of dioxin/furans for 2003 show a downward trend of 53,9% or 2,2 times had been observed, following the European trend. According to official data for PCDDs/PCDF emissions in Europe within the period 1990-2003,the decrease is 2,7 times (63%). The annual PCBs emissions for the period 1990-2003 are almost the same. For the period 1990-2003, the HCB emissions in the atmosphere show a significant downward trend. Compared to the base year 1990, for the HCB emission in 2003, a sharp decrease with 91,7% or 12,1 times has been registered due to the decline of industrial production.

Table 6 National annual emissions of POPs releases in the atmosphere for the period 1990-2003

Year 1990 1995 1996 1997 1998 1999 2000 2001 2002 2003

PCDDs/Fs, g I-TEQ/y 554,2 456 340,9 309,7 288,3 245,2 232,5 200,9 218,5 255

PCB, kg/y 258,5 382,3 261,7 226,9 252,8 234,3 228,5 211,9 250,1 260,7

HCB, kg/y 544 79 87 47 76 46 54 42,5 38 45

17 Dioxin/Furans emissions by years g I-TEQ/year 600

500

400

300

200

100

0 1990 1995 1996 1997 1998 1999 2000 2001 2002 2003 years

Figure 1 Annual PCDDs/PCDFs releases in the atmosphere by years

kg/y PCBs and HCB emissions by years

600

500

400

300

200

100

0 1990 1995 1996 1997 1998 1999 2000 2001 2002 2003 years

PCBs, kg/y HCB, k g/y

Figure 2Annual PCBs and HCB releases in the atmosphere by years

National annual sector POPs emissions by category sources POPs releases, generated in Bulgaria in the past 5 years are within the range as follows: Dioxins/Furans: 200 - 255 g I-TEQ/y, and in 2002 have reached 254,9 g I-TEQ/y. PCBs: 212 ÷ 261 кg/y, and for 2003 have reached 260,7 kg. HCB: 38 ÷ 54 kg/y, and for 2003 being 45 kg. Compared to the base year 1990, PCDDs/PCDFs and HCB note a sharp decline, respectively with 53,9% or 2,2 times and with 91,7% or 12,1 times. The annual PCBs emissions for the same period are almost the same, which could be explained with upward or downward change of the PCBs emissions formed by various category sources.

18 Table 7 Unintentional Production of POPs Releases for 2003 by category sources Categories of POPs releases PCDDs/Fs, PCBs, HCB, g/y kg/y kg/y Combustion processes in energy generation and transformation 122,6 46,14 0 Combustion processes in public and household sectors 70,9 164,61 0 Industrial combustion processes 9,7 2,26 0 Production processes 23,5 0 21 Road transport 10,5 37,05 0 Other motor vehicles and machines 10,5 10,51 0 Waste treatment and disposal 7,3 0,14 24 Total annual POPs releases 254,983 260,71 45 The registered decline in PCDDs/Fs emissions into the atmosphere for 2003 compared to base year 1990 is due mainly to the categories “waste treatment and disposal” – 95%, “combustion processes in industry” – 88%; “industrial processes” - 46% and “road transport and other motor vehicles and machines” – 43%. The lowest decline show category sources “combustion processes in trading, administrative and household sectors, in agriculture, in agriculture, forestry and fishing” – 25% and “combustion processes in energy generation and transformation” – 23%. The registered decline in PCBs emissions into the atmosphere for 2003 compared to base year 1990 is due mainly to the categories“road transport and other motor vehicles and machines” – 54% and “combustion processes in energy generation and transformation”- 18%. PCBs emissions from categories “combustion processes in trading, administrative and household sectors, in agriculture, in agriculture, forestry and fishing” have increased considerably with 88,8%, which could be explained mainly with the growth in the consumption of wood and coal in household sector during past 5 years. The main sources of HCB emissions in air for 2003 are the categories “waste treatment and disposal” and “industrial processes” with lasting downward trend. Compared to base year 1990 a sharp decline of HCB emissions with 91% or 11 times is registered for the category “waste treatment and disposal” . The combustion processes are the main source of PCDDs/Fs and PCBs emissions for 2003. Thermal electric power stations emit about 48,1% of total annual dioxinx/furans emissions, followed by combustion processes in household sector – 27,8%, combustion processes in industry – 13% and road transport and other motor vehicles and machines – 8,2%. The biggest source of PCBs emissions in 2003 are the combustion processes in trading, administrative and household sectors, in agriculture, in agriculture, forestry and fishing, representing 63,1% of total PCBs annual sector releases, followed by road transport and other motor vehicles and machines – 18,2% and the combustion processes in energy generation and transformation – 17,7%. The main sources of HCB emissions in 2003 are the categories “waste treatment and disposal”- 53,4% and “industrial processes” – 46,7%, being for 2003 – 45 kg.

2.3.1. MONITORING The monitoring data of PCBs and HCB in soil , ground water and food indicate: In soil The total PCBs content of soils is significantly (by a multiple factor) below the levels of concern which allows the assumption that no potential threat exists for pollution of soil with PCBs. There are no HCB polluted soils in Bulgaria.

19 In ground water In Bulgaria for 2001 there are no ground water polluted with PCBs. All values were below the ecological threshold and this classifies the ground water as ground water in excellent condition. There is no HCB polluted ground water in Bulgaria for the investigated period. All values were below the minimum detection level in the period 1998 – 2002 and this classifies the ground water as ground water in excellent condition.

In food No presence of any residues from PCBs in the tested samples of Live Animals, Fresh Meat, Poultry, Fish, Farmed & Wild Game, Raw Milk, Hen Eggs and Bee Honey in Bulgaria for the Year 2003 has been detected.

In wild animals The analysis of PCB in subcutaneous fat of a bear killed in April 2004 in Central Stara Planina, Troyan area, showed 142 ng/g fat of polychlorinated biphenyls.

In Human body No presence of any residues from PCBs in the tested samples of Live Animals, Fresh Meat, Poultry, Fish, Farmed & Wild Game, Raw Milk, Hen Eggs and Bee Honey in Bulgaria for the Year 2003 has been detected. No investigations for PCDDs/PCDFs and HCB in food had been performed. WHO carried out periodically monitoring programmes on the levels of PCDD/PCDFs and dioxin-like PCBs in human milk. The results of the third round of the WHO 2001-2002 co-ordinated exposure study show that the lowest levels of PCDDs/Fs have been found in Bulgaria (median value of 6,14 pg WHO-TEQ/g fat) and of dioxin-like PCBs – being one of the lowest (median value of 4,21 pg WHO-TEQ/g fat) after Hungury.

2.3.2. POPS EFFECTS ON HUMAN HEALTH

Many laboratory experiments have been conducted to test the relationship between POPs exposure and a range of adverse outcomes in animals. Table 8 shows some possible effects that can be produced by some of POPs – dioxins/furans, PCBs and HCB and Category of carcinogenicity by IARC.

20 Table 8 Potential effects of individual POPs

Types of Effects PCDDs PCDFs PCBs HCB

Reproduction and/or development X X X X Cytochrome P450 system X X X X Porphyria X X X X Immune system X X X X Thyroid and retinol effects X X X X Skeletal changes X X X Endocrin disruptor X X X Carcinogenic effects X X X X Category of carcinogenicity Group 1 – Group 3 - Group 2A - Group 2B – JARC* carcinogen to humans : Not classifiable probable possible Only for 2,3,7,8- Cl4DD as carcinogen to carcinogen to carcinogen Group 3 – not classifiable as humans humans to humans carcinogen to humans: For all other PCDDs * IARC – Classification of agents, mixtures and exposures according to their carcinogenic risk to humans in accordance with the procedures adopted as standard IARC practice: Group 1 - carcinogenic to humans; Group 2A - probably carcinogenic to humans; Group 2B - possibly carcinogenic to humans; Group 3 - not classifiable as to carcinogenicity to humans.

The risk is negligible in all regions if the risk quotient DI/Netherlands TDI is used for the calculation. The annual average concentration of DDT and Dieldrin in all monitored districts present no health risk for the general population. One of the lowest levels of PCBs and PCDDs/PCDFs in breast milk within the European countries have been found in Bulgaria for the period 2001 – 2002. Potential risk for environmental pollution in case of accidents in the regions close to old non- repaired warehouses for storage of obsolete pesticides. Regions with potential for formation of POPs emissions (PCDDs/PCDFs, PCBs and HCB) are theregions, close to the big thermal electric power stations, using lignite coal and mazut, the large industrial manufacturers, using mazut as fuel and the large cities, where the main roads and R.W. lines of the country pass by. The risk of air pollution with dioxins/furans and PCBs from forest fires, the municipal waste disposal sites and uncontrolled burning of solid municipal waste, stubbles and tires should not be neglected.

3. STRATEGY AND ACTION PLANS OF NIP FOR POPS Based on the results obtained from preliminary inventory of various POPs categories SWOT analysis on the possibilities to meet the provisions of Stockholm convention in R Bulgaria has been implemented. Based on the SWOT analysis, the major objectives for the future development of the country in the field of management of persistent organic pollutants (POPs). Strategic goal and specific objectives are presented as a major long-term strategy and specific national objectives in medium-term and short-term, the country is facing out (Objectives tree). Within the technology of strategic planning SWOT-Analysis (Strengths, Weaknesses, Opportunities and Threats) is of key importance for the strategic planning process. It helps to prioritise the results of the environmental scan analysis and to structure them in such a way as to allow for the setting of the strategic goals and specific objectives of the Republic of Bulgaria to be pursued in the coming years. The analysis showed that R Bulgaria has good institutional, professional and scientific capacity to meet its obligations under Stockholm convention.

21 The implementation strategy of NIP for POPs is based on the following principles: Adherence to Stockholm Convention provisions; Adherence to EU directives provisions; Adherence to “the polluter-pays” principle; Adherence to and enforcement of international standards; Integration within overall environmental management and sustainable development policies; Public and stakeholder participation and transparency of the decision making process regarding POPs issues; Transparency in information sharing and exchange on POPs issues; Provision to the public of available information on POPs and training of professionals on the implementation of measures and activities, included in the NIP for POPs; The longterm strategic goal of the National Implementation Plan for management of POPs in R Bulgaria is: to protect human health and the environment from harmful impact of Persistent Organic Pollutants based on the environmental policy for sustainable development. The National implementation plan for management of POPs formulates the following 8 major national objectives addressed to: 1. Develop and Strengthen Insititional and Administrative Capacity at national, regional and municipal levels; 2. Eliminate intentional production and use of POPs; 3. Minimize or prevent releases from sources of unintentional production of POPs (Dioxin/Furans, HCB and PCBs); 4. Reduce or eliminate obsolete pesticides stockpiles, containing and/or contaminated with POPs; 5. Develop and endeavour to apply Action plans for implementation of measures, envisaged in the NIP; 6. Encourage and promote research, development and monitoring pertaining to POPs including on their: presence and levels in humans and the environment; effects on human health and the environment. 7. Raise public awareness with regard to POPs; 8. Attract investments and encourage activities with regard to POPs management. During the NIP development process the following 10 priorities of national significance among POPs categories were defined: 1. Development and enforcement of plan for environmentally sound management stockpiles and wastes in order to reduce/eliminate obsolete pesticides, containing/contaminated with POPs; 2. Development of plan for identifying and remediation of contaminated sites. 3. Development of strategy for identification, marking and step-by-step phase-out of use of PCBs operating equipment; 4. Development of an action plan for safe storage and environmentally sound disposal of equipment and oils, containing PCBs; 5. Development an action plan for reduction/elimination of releases from unintentional production (D/Fs, HCB and PCBs); 6. Evaluation of negative POPs impacts on human health and monitoring of POPs levels in humans and the environment; 7. Encouragement and support for research on POPs effect on humans and the environment; 8. Promotion and facilitation of public awareness raising with regard to POPs; 9. Securing the financial resources for the implementation of NIP measures by attracting investments from international finance institutions and donors. 10. Integration of the NIP in the existing National Environmental and Sectoral policies; 22 To achieve the main national objectives, three specific Action plans for each POPs were developed building on the findings of the preliminary assessment on POPs inventories results: Action plan for POPs - Pesticides Action plan for PCBs in Equipment Action plan for POPs releases from unintentional production (D/Fs, PCBs and HCB). The proposed Action plans cover the period 2006-2028 and includes the major measures and activities envisaged for the implementation of the NIP for POPs. By the adoption and the implementation of the present plans, it is aimed that optimal balance between the different legislative, institutional, economic and technical measures and implementation of integrated approach for POPs management to be achieved. The plans determine also the responsibilities of the various institutions and organizations related to the implementation of the proposed activities in NIP, the expected costs and the probable sources of funding. Table 9 Short Summary of the proposed activites, included in the Specific Acton Plans for each POPs category № Action plan Activities 1. Enforcement and Effective enforcement of existing legislation, regulating POPs Regulatory management: strengthening measures - Enforcement of existing legislation, regulating POPs pesticides for POPs management management ; - Enforcement of existing legislation, regulating the management of PCBs in equipment; - Enforcement of existing legislation, regulating the Emission Limit Values of D/Fs, released into atmosphere from facilities and activities with stationary point sources. 2. Measures for providing Development of Obsolete and POPs Pesticides Storage and Stock control methodology support for Manual and Guidelines for the environmentally sound Management of the enforcement of obsolete and unwanted pesticides. POPs management Development of technical Manual and Practical Guidelinesq legislation supporting the enforcement of PCBs Regulation – for for carrying out inventory of PCBs equipment; for labelling , decontamination/clean-up and dismantling of PCBs equipment, and safe storage of PCBs waste oils . Updating of “Methodology for Determination of the Emissions of Dioxin and Furan Releases in the Air” based on CORINAIR Methodology. 3. Administrative capacity Strengthening of municipal administrative capacity for control and safe strengthening of storage of obsolete pesticides’ stockpiles, including appointment of authorities, responsible additional personnel. for POPs management Strengthening of administrative capacity of RIEWs for control and inspection of operating PCBs equipment and for the conditions for storage of dismantled equipment and wastes, containing PCBs 4. Measures for personnel Carrying out Seminars and Training Workshops for qualification raising of qualification experts of relevant state authorities over the NIP implementation. raising/training and Training Workshop for qualification raising of industry professionals and technical resources personnel, engaged in MoEW in regard to: - Carrying out detailed PCBs equipment inventory; - ES storage, decontamination and disposal; - Control of PCBs equipment and wastes, containing PCBs; Strengthening of laboratory infrastructure for control and analysis of PCBs and HCB in waste gases, waste water, soils, air, food of vegetable and animal origin . Strengthening the laboratory infrastructure for analysis of POPs pesticides in the environmental media, in foods of vegetable and animal origin and the levels in human tissues; including delivery of necessary equipment, personnel training and lab accreditation.

23 № Action plan Activities Strengthening the laboratory infrastructure for analysis of PCBs in oils and accreditation of sufficient labs. 5. Measures to ensure Updating NIP for POPs every 5 years. sufficient and reliable Annual updating of the data base for obsolete pesticides stockpiles data on POPs Carrying out of a Detailed inventory of 2308 t of “unknown” obsolete pesticides not yet secured, stored in 477 unrepaired in-use warehouses with the aim to identify the assumed available between 22.3 t ÷ 25.8 t POPs pesticides and approx. 30 t mixtures, consisting of or contaminated with POPs, if international funding is provided. Carrying out of a Detailed inventory of equipment (in-use and phased out) and oils, containing PCBs. Establishment of Sofware and data base for in-use and phased out PCBs equipment and waste, containing PCBs and its regular updating. Annual updating of data base for Dioxins/Furans, PCBs & HCB in emissions . 6. Measures to reduce or Observing the ban for import and use of POPs pesticides . eliminate releases from Observing the ban for import and export of PCBs. Obeying the permitted intentional production use of PCBs in closed systems – transformers and capacitors. and use, according Article 3. 7. Measures to reduce or Promote the application of available, feasible and practicle measures for a eliminate releases from realistic and meaningful level of POPs release reduction or source unintentional elimination by including in the requirement of the issued Imtegrated production, according permits of BAT and BEP for the facilities from energy, metallurgy, Article 5. chemical and cement industries and domestic solid waste burning p lants, where it deems appropriate. 8. Measures to reduce or Environmentally sound storage Obsolete pesticides stockpiles - eliminate releases from Handling, collecting, repacking, transporting and storing in an stockpiles and waste, environmentally sound manner of obsolete pesticides in newly constructed according Article 6. or repaired centralized and municipal storages facilities or capsulation in BB-cubes . Development of a long-term business plan for gradual disposal of POPs and obsolete pesticides currently in long-term storage and site remediation.

Safe and environmentally sound disposal of obsolete pesticides stockpiles : - Removal and disposal abroad of 2308 t of “unknown” obsolete pesticides, stored in 477 unrepaired in-use warehouses and site remediation, if international funding is provided; - Removal and partial disposal of obsolete pesticides, identified as consisting of or contaminated with POPs abroad, if international funding is provided; - Gradual disposal of obsolete pesticides stockpiles currently in long-term storage and site remediation. Safe operation of in-use PCBs equipment (transformers and capacitors) and gradual phasing out: - Prepare short-term plan for labeling and decontamination/ retrofilling of in-use PCB equipment; - Prepare long-term plans for phase out of in-use PCBs equipment, dismantling, decontamination, safe storage, appropriate disposal ahead of national legislation deadlines; - Develop detailed business plans for environmentally sound end-of-life management for highest risk PCBs equipment and waste; - Labelling of in-use PCBs equipment – transformers and capacitors; - Decontamination of transformers with PCBs concentration above 0,05 %

24 № Action plan Activities 3 by weight and volume above 5 dm ; - Gradual Phasing-out of equipment with PCBs concentration above 0,05 % by weight and volume above 5 dm3 . Collection and safe storage of phased-out equipment and oils, containing PCBs: Provision of the necessary storage sites for safe storage of phased out PCBs equipment and wastes, containing PCBs – transformer and capacitor oils. Disposal of the equipment and wastes, containing PCBs: - Export for disposal of 20,12 t waste PCBs transformer oils abroad, if international funding is provided; - Export for disposal of 844 phased out PCBs capacitors abroad, if international funding is provided; - Gradual disposal of highest risk phased out equipment with PCBs concentration above 0,05 % by weight and volume above 5 dm3. 9. Measures for control Exercising permanent control over the implementation of legal and monitoring, requirements for safe storage of obsolete and unusable pesticides stockpiles according Article 11. and regular inspections of storage facilities status. Development of a Manual for the procedures and requirements for monitoring, and inspections of the PCBs equipment. Exercising permanent control over in-use PCBs equipment and over the conditions for storage of dismantled equipment and wastes, containing PCBs . Observing of existing admissible emission norms for Dioxins/Furans, PCBs and HCB by exercising permanent control over the implementation of the requirements of the issued Imtegrated permits. Exercising permanent control over the implementation of existing limit values of PCBs releases in the air of working media. Monitoring of soils with local spot POPs pollution, including spot points where DDT and metabolites values exceeding the maximum admissible concentration and intervention concentration level were registered. Monitoring of ground waters for POPs content in the regions close to storages for obsolete and out-of-use pesticides. 10. Information exchange, Facilitate and undertake the exchange of information relevant to according Article 9. POPs: - Performance of information exchange among the stakeholders, responsible for POPs management; - POPs information dissemination & networking of scientific publications, developed projects, seminars and scientific forums on POPs Web-page of MoEW. 11. Measures for Public Educational and Public awareness raising programmes on POPs information, awareness issues: and education, - Development of educational public awareness programmes on POPs according Article 10. issues, as well as on their health effects , especially for women, children and the least educated; - Development of educational programmes and suitable school text books for pupils and students knowledge on POPs issues. Provision of Public access and awareness raising on POPs issues: - Publication of NIP for POPs on the Web page of MoEW; - Updating of MoEW’s Web page by including available information on POPs; - Publication and dissemination of NIP for POPs – hard copy of NIP Executive summary; - Provision to the public available information on POPs trough Information centers at MoEW, EEA and at RIEWs; - Providing opportunities for public input, opinions and statements and raise

25 № Action plan Activities questions & responses , addressing POPs management through the Forum “Green Graphite” on the MoEW’s Web site; - Carrying out Information Campaigns by ecological NGOs for POPs effects on human health and the environment at regional level. Development and dissemination of public awareness materials at the national level for POPs and their health and environmental effects: - Development, publication and dissemination of POPs popular brochures for their human health and environmental effects; - Development, publication and dissemination of POPs popular brochures and leaflets for awareness raising on POPs pesticides and their effects on human health and the environment among the farmers and rural population; - Development, publication and dissemination of POPs popular brochures and leaflets for PCBs issues and their effects on human health among operators of PCBs equipment; - “POPs: Be careful” Strengthening NGOs' capacity in realization of the information campaigns and improve communications with local community and other counterparts; - Sharing information about POPs Public awareness campaign on POPs “Planet without POPs”- dissemination of POPs popular brochure. Development and carrying out “round-tables” discussions for public awareness raising on POPs effects oh human health and the environment with gender focus on young people and target groups of local communities and other counterparts. 12. Measures to encourage Carrying out representative research investigations for POPs levels of research and accumulation in risky groups of population, especially women and children development, according in rural areas close to the storages for obsolete pesticides. Article 11. Carrying out representative research investigations for POPspesticides levels in soils and products of vegetable origin in field farming areas close to the storages for obsolete pesticides. Carrying out investigations on identifying PCBs level accumulation in human tissue and population health status assessment with priority to risky groups in the regions with high concentration of PCBs equipment.

Carrying out representative investigations of PCBs accumulation levels in breast milk and fat tissue in women – suckling mothers in the regions with high concentration of PCBs equipment. Undertake research works geared on alleviating the effects of POPs on reproductive health. Carrying out representative comparable investigations for Dioxin/Furans & PCBs content in chicken eggs in the regions close to the large thermal power plants (TPP). Carrying out investigations for Dioxin/Furans & PCBs concentrations in food (hen eggs and eggs products, milk and diary products, fresh meat and animal products,reach in fats, sea and river fish). 13. Reporting according Development of a Progress Report for the the NIP implementation and Article 15. providing it to Secretariat.

Based on the measures and activities envisaged in the NIP for the management of POPs, a preliminary assessment of the funds required for the successful implementation of NIP has been performed. The total budget required to implement all activities planned under the NIP exceeds 50 millions BGN (approx. 30 millions US $), excluding the costs needed for the construction of the National centre for treatment of hazardous waste (87 million BGN) and lab infrastructure for DIOX/Fs determination in environmental media (approx. 6 million BGN).

26 To implement the most urgent activities related to reduce the negative impacts of POPs on human health and the environment , the Republic of Bulgaria requires funds amounting to 27 455 000 BGN(approx. 17 069 000 US $). The state budget could cover about 10%, mostly as contribution in-kind, providing necessary experts support, offices, technics (computer and copy equipment), communications (Internet, telephone, fax, mail services), office supplies, etc. The Republic of Bulgaria can not cope alone with the full incremental costs of meeting the obligations of the Stockholm Convention and requires international financial support. To reduce the risk to human health and the environment of POPs stockpiles urgent measures should be taken for safe storage and/or environmentally sound disposal abroad, due to absence of appropriate disposal facility in the country. For this purpose the Republic of Bulgaria needs to be supported by providing financial resources from GEF and other international, bilateral, regional and multilateral twinning programmes.

The Republic of Bulgaria requires urgently funding amounting to 21,7 million BGN (approx. 13,6 million US $) for the following activities: For carrying out a detailed inventory and disposal abroad of 2308 t obsolete pesticides stored in 477 unrepaired operating warehouses – 14,7 million BGN (approx. 9,2 million US $); For carrying out a detailed inventory of PCBs equipment and wastes, containing PCBs and disposal abroad of 844 phased out PCBs capacitors and 20,12 t waste transformer oils, containing PVBs - 7 million BGN (approx. 4,4 million US $);

The implementation of the POPs NIP will also require capacity strengthening in both technological/ laboratory infrastructure and human resources/qualification raising as wll as management capacity building.

For the implementation of the NIP for the management of POPs, it should endeavour to provide financial resources by attracting investments on international and national source funding scale, as well as to promote taking measures by the enterprises’ operators, intentionally or unintentionally producing and/or using POPs [construction of facilities for treatment and destruction of POPs, introducing the best available techniques (BAT) & the best environmental practices (BEP), etc.

To enable Bulgaria to implement the measures set out in the POPs action plans, international financing will be sought. Bulgaria will promote multiple-source funding approaches & arrangements, twinning programmes and funding through other bilateral, regional and multilateral sources and channels. Efforts shall be put to use the existing financial mechanism of the Global Environment Facility (GEF) and bilateral, regional and multilateral finance resources.

27 1. INTRODUCTION The proposal of the “National Implementation plan (NIP) for the management of Persistent Organic Pollutants (POPs) in the Republic of Bulgaria” is drawn up within the Global project “Development of National Implementation Plans for the Management of Persistent Organic Pollutants (POPs)” for twelve pilot countries (Barbados, Bulgaria, Chile, Ecuador, Guinea/Conakry, Lebanon, Malaysia, Mali, Micronesia, Papua New Guinea, Slovenia and Zambia).

Bulgarian Sub Project No: GF/2732-02-4454 Executing Agency: United Nations Environment Programme (Chemicals Unit) Project Managers GEF/UNEP-12 pilot country NIPs for POPs: Krizstina Kiss - Project Manager for the period July 2002 – June 2005; Dr. David Piper, Project Manager for te period June 2005 – March 2006. Implementing Agency: Ministry of Environment and Water, Sofia, Bulgaria

Bulgarian Project Managers : Manoela Georgieva – Deputy minister of MoEW for the period July 2002 ÷ June 2005 Dr. Dzhevdet Chakarov - Minister of MoEW for the period July 2005 ÷ March 2006 National Co-ordinator for Bulgarian GEF project: Prof. Georgi Antov, DMSc. National Focal Point for the Stockholm Convention: Katya Vasileva, senior expert MoEW National consultant of BG project: „Balkan Science and Education Centre of Ecology and Environment”(BSECEE), Sofia with expert group manager prof. eng.Ivan Dombalov, PhD. The Bulgarian Sub project is financed by GEF (Global Environmental Facility) with co-financing, in-cash by the Government of Germany. The project comprises targeted activities that will prepare the Republic of Bulgaria to meet the obligations set under the POPs Convention. At the national level, the objectives for Bulgaria are: i) the capacity to implement the POPs Convention through the development of a National Implementation Plan for the management of POPs; ii) the elaboration of detailed specific action plans that will identify effective national responses, processes and measures that would reduce releases of POPs. The NIP is expected to meet the initial reporting obligations of Bulgaria towards the Convention. The main output of the project will be NIP for the management POPs in the Republic of Bulgaria in order to meet future activities for implementing Stockholm convention. The following activities had been carried out to achieve the main output: 1. Determination of coordinating mechanisms and organisation of process 2. Establishment of a POPs inventory and assessment of national infrastructure and capacity 3. Priority setting and determination of objectives 4. Formulation of a prioritised and costed National Implementation Plan, and specific Action Plans on POPs 5. Endorsement of NIP by stakeholders The NIP preparation took 4 years and all the activities were coordinated by National Coordinating Committee, appoined by the Bulgarian Project Manager. The present National Implementation Plan for the management of POPs in Bulgaria is developed on the basis of the requirements of Article 7 of Stockholm convention. Bulgaria shall transmit its implementation plan to the Conference of the Parties within two years of the date on which the Convention enters into force for it, i.e. until 20 March 2007. NIP’s main purpose is to protect human health and the environment from persistent organic pollutants and to contribute to the sustainable development of the Republic of Bulgaria by integrated framework for the POPs management, to increase the polluters responsibilities, and to encourage the investments in POPs management.

28 A number of experts, representatives from interested institutions, ministries, universities, organizations, NGOs, etc., included in the National Coordinating Commettee (NCC) took part actively within the process of formulating and development of Bulgarian NIP for POPs, as follows: NATIONAL COORDINATING COMMETTEE Name Position Organisation Position in NCC 1 Dzhevdet Chakarov Minister Ministry of Environment and water Project Manager NCC Chairman 2 Manoela Georgieva Deputy Minister Ministry of Environment and water Project Manager NCC Chairman 3 Prof. Georgi Antov, DMSc toxicologist Ministry of Environment and water National coordinator 4 Katya Vasileva Senior Expert Ministry of Environment and water member 5 Svetla Krapcheva, MSc Department Chief Ministry of Environment and water member

6 eng. Tsvetanka Dimcheva Senior Expert Ministry of Environment and water member

7 Rosen Belevski Chief Department Ministry of Environment and water member

8 Parvoleta Luleva Senior Expert Ministry of Environment and water member 9 Veselka Nedyalkova Junior Expert Ministry of Environment and water member 10 Michail Mollov, PhD Expert Ministry of Environment and water, member Water Monitoring EEA 11 Maria Ninova Junior expert Ministry of Environment and water member Waste management 12 Ivanka Todorova Head of Department Ministry of Environment and water, member EEA 13 Angel Kostov Department Chief Ministry of Environment and water, member EEA 14 Dr.Maria Tasheva, PhD toxicologist National Centre for Public Health member Protection 15 Dr.Zhivka Halkova , PhD toxicologist National Centre for Public Health member Protection 16 Stefan Uzunov Director National Service for Plant Protection member Int.Cooperation Ministry of Agriculture and Forestry Directorate 17 Prof.Lachezar Petrov, DSc Director of Bulgarian Academy of Science member Institute of Catalysis 18 Prof.Elena Zheleva, DSc Head of Ecology University of Forestry member Department 19 Tsvetan Popov engineer SA”Civil Protection” member 20 Andonov Svetoslav Chemistry eng. SA”Civil Protection member 21 Kalina Petkova expert Ministry of Labour and Social member Policy 22 Asen Petkov,PhD Assoc. Professor University of Chemical Technology member and Metallurgy 23 Iliana Pavlova economist Bulgarian Industrial Chamber member 24 Dr. Iliana Popova expert Ministry of Health member 25 Dr.Svetla Nikolova engineer NGO “AGROLINK Dr” member 26 Vuchkova Kapka State Expert Ministry of Foreign Affairs member 27 Vasilka Hristova State expert Ministry of transport member and communication 28 Ivailo Hlebarov ecologist NGO “For the earth” member 29 Zlatanov Ivo Associate Prof Bulgarian chamber of Chemical member Industry 30 Emil Kojuharov Doctor National Veterinary and Medical member Service, MoAF

29 The following experts have been involved in the working group as follows: Name Position Organisation Ivan Dombalov Prof., PhD, chem. eng. Director of BSECEE Ekaterina Todorova PhD, chem.eng. FU Ioncho Pelovski Assoc. Prof., PhD ,chem.eng. UCTM Evgeni Sokolovski MSc, Ecology eng. UCTM Ralitza Angelova Eng. BALBOK LTD Ada Bainova Prof., Dr., PhD, DMSc NCHMEN Dilianka Bezlova Assoc. Prof. PhD, eng. BSECEE Dora Bogdantzalieva chem. eng. BCCI Chavdar Bonev Prof., chem.eng., PhD,DSc BAS Ana Vasileva Chemist BSECEE Chavdar Vladov PhD, chem..eng. BAS Aleksandrina Vlahova Doctor "Alexandrovska Hospital” Pravda Gecheva chem.eng. Interproducts Kiril Gramatikov PhD, chem.eng. BSECEE Mariana Doncheva Assoc. Prof. PhD, eng. FU Borislav Zdravkov MSc, Ecology eng. UCTM Slavi Ivanov Prof., chem.eng., PhD,DSc SEBE Alexander Ivanchev Iconomist Ecotech Consult Ltd Nina Ilieva MSc, Ecology eng. UCTM Georgi Kadinov PhD, chem. eng. BAS Kazaldjiev Galabin MSc, ecologist BSECEE Nikolai Kirkov chem.eng. АЕBTRI Petya Kostadinova chem.eng. UCTM Svetla Karova Expert BCIC Ludmila Malinova Assoc. Prof.. PhD, eng. BSECEE Boryana Milusheva Eng. Technotest Ltd Naiden Naidenov chem.eng. BCS Nino Ninov Eng. BSECEE Ekaterina Pavlova Prof., PhD, eng. BSECEE Marinela Panaiotova chem.eng. UMG Petar Petrov MSc, ecologist BSECEE Nikolay Pipkov Assoc.Prof. PhD, eng. BSECEE Slavcho Racovski Prof., chem.eng. BAS Stefan Stamenov Eng. Ecotech Consult Ltd Alexander Takov Agronomist BSECEE Varbinka Hristova Eng. UCTM Liliana Tzaneva Eng. BCCI Alexander Tzachev chem.eng. Chimkomplekt Margarita Tzenova Chief Expert NPPS Miroslava Tzolova Eng. FU

The following international consultants & experts have contributed and supported the development of Bulgarian NIP project: Dr. David Piper Project Manager GEF/UNEP-12 Task Manager “POPs enabling UNEP Switzerland pilot country NIPs for POPs activities”, Division of GEF Chemicals, Coordination Geneva Krizstina Kiss Project Manager GEF/UNEP-12 Project Manager UNEP Switzerland pilot country NIPs for POPs Chemicals, Victor Ogbuneke Fund Programme Management Fund Programme Management UNEP HQ, Kenya Officer GEF/UNEP-12 pilot Officer, Division of GEF Nairobi country NIPs for POPs Coordination Yves Guibert International Consultant UNEP peer review Freeland France consultant John Vijgen International Consultant Director International IH& Holte Denmark Pesticides Association Dr. Heidelore Fiedler International Consultant Scientific Affairs Officer UNEP Switzerland Chemicals, Peter J. Peterson, International Consultant Senior Special Fellow Chemicals UNITAR Switzerland and Waste Management

1.1. STOCKHOLM CONVENTION ON PERSISTENT ORGANIC POLLUTANTS In May 1995, the Governing Council of the United Nations Environment Programme (UNEP) took a decision that an international assessment process be undertaken of the impact of 12 dangerous substances and preparations named after persistent organic pollutants (POPs), because of they possess toxic properties, resist degradation, bioaccumulate and are transported through air, water and migratory species, across international boundaries and deposited far from their place of release, where they accumulate in terrestrial and aquatic ecosystems. POPs are aldrin, dieldrin, chlordane, endrin, heptachlor, DDT, Hexachlorobenzene, Mirex, Toxaphene, Polychlorinated Biphenyls (PCBs), Polychlorinated dibenzo-p-dioxins and dibenzofurans (PCDD/PCDF). From 22 to 23 May 2001, at a Conference of Plenipotentiaries held in Stockholm, Sweden a Convention on POPs, named later a Stockholm convention on POP, was adopted and opened for signature. The convention was signed at the formal ceremony on 23 May 2001 by 92 States and the European Community. The convention remained open for signature from 24 May 2001 until 22 May 2002, when it was closed after 151 States signatures. On 17 May 2004, three months after the date of deposit of the 50-th ratification instrument, the Stockholm Convention officially enters into force for the Parties on the Convention. Bulgaria signed the Stockholm Convention on POPs on 23 May 2001 at the Conference of Plenipotentiaries held in Stockholm, Sweden. On 30 September 2004, the Convention was ratified with a Law by the National Assembly and with Decree No. 309 of the President of the Republic of Bulgaria its promulgation in the State Gazette is enacted ( SG No. 89/ 12.10.2004). The Stockholm convention is effective for Bulgaria from 20 March 2005. 1.2. OBJECTIVES AND PROVISIONS OF STOCKHOLM CONVENTION Mindful of the precautionary approach as set forth in Principle 15 of the Rio Declaration on Environment and Development,

The objective of the Convention is to protect human health and the environment from the harmful impact of Persistent Organic Pollutants.

According to Article 3 each Party shall take measures to reduce or eliminate POPs releases from intentional production and use: (a) to prohibit and/or take the legal and administrative measures necessary to eliminate its production, import/export and use of the chemicals listed in Annex A; (b) to restrict its production and use of the chemicals listed in Annex B According Article 5 each party shall take measures: (a) to reduce or eliminate the total POPs releases from unintentional production of each of the chemicals listed in Annex C, with the goal of their continuing minimization and, where feasible, ultimate elimination; (a) Develop an action plan within two years of the date of entry into force of thе Convention for it, and subsequently implement it . According to Article 6 each Party shall take measures to reduce or eliminate releases from stockpiles and wastes in order to ensure that stockpiles consisting of or containing chemicals listed either in Annex A or Annex B and wastes, including products and articles upon becoming wastes, consisting of, containing or contaminated with a chemical listed in Annex A, B or C, are managed in a manner protective of human health and the environment. Each Party shall:

31 (a) Develop appropriate strategies; (b) Identify the stockpiles consisting of or containing chemicals listed either in Annex A or Annex B on the basis of the strategies; (c) Manage stockpiles in a safe, efficient and environmentally sound manner; (d) Take appropriate measures to handle, collect, transport and store in an environmentally sound manner and to dispose POPs waste of in such a way that the persistent organic pollutant content is destroyed or irreversibly transformed so that they do not exhibit the characteristics of persistent organic pollutants or otherwise disposed of in an environmentally sound manner; (e) Endeavour to develop appropriate strategies for identifying sites contaminated by chemicals listed in Annex A, B or C. Persistent Organic Pollutants (POPs) listed in Annex A,B and C in the Stockholm convention are: 1.2.1. ANNEX А – ELIMINATION, PART І Chemical Activity Specific exemption Aldrin* Production None CAS No: 309-00-2 Use Local ectoparasiticide Insecticide Chlordane* Production As allowed for the Parties listed in the CAS No: 57-74-9 Register Use Local ectoparasiticide Insecticide Termiticide Termiticide in buildings and dams Termiticide in roads Additive in plywood adhesives

Dieldrin* Production None CAS No: 60-57-1 Use In agricultural operations Endrin* Production None CAS No: 72-20-8 Use None Heptachlor* Production None CAS No: 76-44-8 Use Termiticide Termiticide in structures of houses Termiticide (subterranean) Wood treatment In use in underground cable boxes Hexachlorobenzene Production As allowed for the Parties listed in the CAS No: 118-74-1 Register Use Intermediate Solvent in pesticide Closed system site limited intermediate

Mirex* Production As allowed for the Parties listed in the CAS No: 2385-85-5 Register Use Termiticide Toxaphene* CAS No: Production None 8001-35-2 Use None Polychlorinated Biphenyls Production None (PCB)* Use Articles in use in accordance with the provisions of Part II of this Annex

32 1.2.2. ANNEX А – ELIMINATION, PART ІІ Polychlorinated biphenyls Each Party shall: - With regard to the elimination of the use of polychlorinated biphenyls in equipment (e.g.transformers, capacitors or other receptacles containing liquid stocks) by 2025; - Consistent with the priorities in subparagraph (a), promote the following measures to reduce exposures and risk to control the use of polychlorinated biphenyls; - Notwithstanding paragraph 2 of Article 3, ensure that equipment containing polychlorinated biphenyls, as described in subparagraph (a), shall not be exported or imported except for the purpose ofenvironmentally sound waste management;; - Except for maintenance and servicing operations, not allow recovery for the purpose of reuse in other equipment of liquids with polychlorinated biphenyls content above 0.005 per cent; - Make determined efforts designed to lead to environmentally sound waste management of liquids containing polychlorinated biphenyls and equipment contaminated with polychlorinated biphenyls having a polychlorinated biphenyls content above 0.005 per cent, in accordance with paragraph 1 of Article 6, as soon as possible but no later than 2028; - In lieu of note (ii) in Part I of this Annex, endeavour to identify other articles containing more than 0.005 per cent polychlorinated biphenyls (e.g. cable-sheaths, cured caulk and painted objects) and manage them in accordance with paragraph 1 of Article 6; - Provide a report every five years on progress in eliminating polychlorinated biphenyls and submit it to the Conference of the Parties pursuant to Article 15.

1.2.3. ANNEX B – RESTRICTION PART І Chemical Activity Acceptable purpose or specific exemption DDT Production Acceptable purpose: (1,1,1-trichloro-2,2- Disease vector control use in accordance bis(4- with Part II of this Annex chlorophenyl)ethane) Specific exemption: CAS No: 50-29-3 Intermediate in production of dicofol Intermediate Use Acceptable purpose: Disease vector control in accordance with Part II of this Annex Specific exemption: Production of dicofol

Intermediate

1.2.4. ANNEX B – RESTRICTION PART ІІ DDT (1,1,1-trichloro-2,2-bis(4-chlorophenyl)ethane)

Each Party shall: - to eliminate the production and use of DDT and to establish the DDT Register; - to notify the Secretariat and the World Health Organization as soon as possible in order of DDT use for disease vector control; - to provide information for DDT use to the Secretariat and the World Health Organization in Every three years; - to promote research and development of safe alternative chemical and non-chemical products posing less risk to human health and the environment.

33 1.2.5. ANNEX C, UNINTENTIONAL PRODUCTION, PART І This Annex applies to the following persistent organic pollutants when formed and released unintentionally from anthropogenic sources:

Chemical Polychlorinated dibenzo-p-dioxins and dibenzofurans (PCDD/PCDF) Hexachlorobenzene (HCB) (CAS No: 118-74-1) Polychlorinated biphenyls (PCB)

1.2.6. ANNEX C, UNINTENTIONAL PRODUCTION, PART ІІ Source categories Polychlorinated dibenzo-p-dioxins and dibenzofurans, hexachlorobenzene and polychlorinated biphenyls are unintentionally formed and released from thermal processes involving organic matter and chlorine as a result of incomplete combustion or chemical reactions. The following industrial source categories have the potential for comparatively high formation and release of these chemicals to the environment: (a) Waste incinerators, including co-incinerators of municipal, hazardous or medical waste or of sewage sludge; (b) Cement kilns firing hazardous waste; (c) Production of pulp using elemental chlorine or chemicals generating elemental chlorine for bleaching; (d) The following thermal processes in the metallurgical industry: (i) Secondary copper production; (ii) Sinter plants in the iron and steel industry; (iii) Secondary aluminium production; (iv) Secondary zinc production. 1.2.7. ANNEX C, UNINTENTIONAL PRODUCTION, PART ІІІ Source categories Polychlorinated dibenzo-p-dioxins and dibenzofurans, hexachlorobenzene and polychlorinated biphenyls may also be unintentionally formed and released from the following source categories, including: (a) Open burning of waste, including burning of landfill sites; (b) Thermal processes in the metallurgical industry not mentioned in Part II; (c) Residential combustion sources; (d) Fossil fuel-fired utility and industrial boilers; (e) Firing installations for wood and other biomass fuels; (f) Specific chemical production processes releasing unintentionally formed persistent organic pollutants, especially production of chlorophenols and chloranil; (g) Crematoria; (h) Motor vehicles, particularly those burning leaded gasoline; (i) Destruction of animal carcasses; (j) Textile and leather dyeing (with chloranil) and finishing (with alkaline extraction); (k) Shredder plants for the treatment of end of life vehicles; (l) Smouldering of copper cables; (m) Waste oil refineries.

34 2. COUNTRY BASELINE 2.1. COUNTRY PROFILE 2.1.1. GEOGRAPHY AND POPULATION

Location: The Republic of Bulgaria is situated in Southeast Europe and occupies the eastern part of the Balkan Peninsula between 41st degree and 43rd degree northern latitude. To the north it borders on river Danube and Romania, to the east on the Black Sea, to the south on Turkey and to Greece and to the west on the Republic of Macedonia and the Serbia & Montenegro.

Figure 3Map of Republic of Bulgaria

Territory: The territory of Republic of Bulgaria is 110 993.6 km2. The total length of Bulgarian frontier is 2 245 km, of which 1181 km (52.6%) are land frontier, 686 km (30.6%) – riverside and 378 km (16.8%) – sea coastline . A natural north border of Bulgaria is the river Danube , which is navigable along the Bulgarian bank for passenger and cargo ships. Black Sea is natural eastern border of Bulgaria. The length of road net is 36720 km and that of R.W. – 4300 km. The average altitude of the country is 470 meters above sea level.

Relief: Extremely varied: large plains and lowlands, low and high mountains, valleys and lovely gorges. The southwest of the country is mountainous, containing the highest point of the Balkan Peninsula, the Musala at 2,925 m. The range of the Balkan mountains or Stara Planina runs west- east through the middle of the country, north of the famous Rose Valley, deviding the country into North and South part. Hill country and plains are found in the southeast, along the Black Sea coast in the east, and along Bulgaria's main river, the Danube in the north. Other major rivers include the Struma and the Maritsa river in the south. In all there are 526 rivers more than 2,3 km long, and the longest, the Iskar, is 368 km. Other big rivers are Maritza, Tundzha and Struma.

35 Lakes, Flora and Fauna: There aren’t many natural lakes in Bulgaria, although there are no fewer than 260 high-mountain alpine glacial lakes. These can mostly be found in the Rila and Pirin mountains at altitudes of 1900 to 2400 metres. The lakes and swamps along the Danube have been drained with the exception of Sreburna lake, which has the status of an UNESCO reserve due to its unique flora and fauna. However numerous dams have been built. Bulgaria is one of the countries richest in thermal spas in Europe, ranking third after the Czech Republic and Spain in number of mineral springs. These vary in mineral content and temperature and are thus used as remedies for a wide variety of ailments. Of particular balneological importance are the thermal spas at Bankya, Velingrad, Kyustendil, Sapareva Banya, Momin Prohod and Hissarya. Bulgaria’s rich biodiversity is home to over 12 350 plant species and over 15 000 animal species, including many rare species. The forests cover 35% of Bulgarian territory. Three national parks and 89 reserves and other protected areas help preserve this variety. Bulgaria has the largest number of biosphere reserves in the world. Climate: Temperate continental with clearly marked four different seasons – spring, summer, autumn and winter. The average annual temperature is 10.5°C. The higher mountainous regions have relatively low temperatures, heavy rainfall and continuous year-round snow. Natural Resources: Bulgaria has large areas of high-quality arable land and forests. A wide variety of mineral resources- copper, gold, iron, lead, and zinc are extracted commercially. Population: According to the 2001 census there are 240 towns and 5 096 villages. The capital is Sofia city with more than 1, 3 million citizens. With more than 100 thousand inhabitants are 9 towns – Plovdiv, Varna, Burgas, Russe, Stara Zagora, Pleven, Sliven and Dobrich. In 2003 in the towns live 69,8% of country population, and the rural population – 30,2%. The average population density is 70.3 people/km2. Table 10Country Demographic data: Demographic data: 01.03.2001 г.1) 31.12.2004 г.2) Population 7 973 671 7 761 049 Men 3 888 440 3 767 610 Women 4 085 231 3 993 439 Urban Population 5 500 695 5 431 800 Rural Population 2 472 976 2 329 200 Average population age 40,4 41,0 Average lifespan age 71,88 72,07 Birth rate, ‰ 8,6 9,0 Mortality rate, ‰ 14,2 14,2 Population growth, % -5,6 – 5,2 Population at working age 4 673 219 4 782 000 Labour force,total,eop,num 3 265 000 3 322 000 Employees,total,eop,num 1 878 849 2 109 478 Unemployment level, % 19,5 12,2 Literate population, % 98,2 98,6 1)Demographic data of NSI from the 2001 census 2) Demographic data of NSI – 31.12.2004

Official language: Bulgarian is the official language, using the Cyrilic alphabet.

36 Ethnic structure : Bulgarians - 83, 9 %;Turks - 9,4 %;Roma - 4,7 %;Russians - 0,2 %; Armenians -0,1 %; Others - 1,7 % Religions: Eastern Orthodox – 83,9%; Islam – 12,1%; Roman Catholicism – 1,6 %; Protestant denominations – 0,5%; Judaism – 0,8 %; atheists and undeclared – 1,1 %

2.1.2 POLITICAL AND ECONOMIC PROFILE 2.1.2.1. Political system Bulgaria is a Parliamentary Republic and the basic power in the country is the legislative one. The Parliament (The National Assembly) exercises the legislative power. Its mandate is 4 years and consists of 240 MPs. They are elected by direct vote on the basis of the proportional system. The government (The Council of Ministers) is the main body of the executive power, headed by the Prime Minister. The President is the Head of State and is elected with direct elections once in every five years, for not more that two mandates. Bulgaria has an independent judiciary and based on Three-Instances-procedure. The Supreme Administrative Court and the Supreme Court of Cassation oversee the application of all laws by lower courts and judges the legality of government actions. A separate Constitutional Court rules on the constitutionality of laws and treaties. Judicial reforms are being implemented to bring Bulgaria’s judiciary to European Union standards. The Supreme Judicial Council was established to organize the activities of the judiciary.

2.1.2.2. Administrative-territorial Structure The country is divided into 28 regions and 264 municipalities. The status and powers of the local executive authorities depend on the territory structure of the country. The municipality is the main administrative territorial unit for the local government. Every municipality is ruled by a Mayor, elected by direct vote once per every 4 years. The region is the bigger administrative territorial unit. A regional governor, assigned by the Council of Ministers, rules each region.

2.1.2.3. Economics The Republic of Bulgaria has concluded successfully the accession negotiations with the European Union and On 25 April Bulgaria has signed the Treaty of Accession to the European Union and is expected to join the European Union on 1st of January. 2007. On 11 May 2005 The National Assembly ratified the Treaty of Accession of Bulgaria to the European Union. Following the severe economic crisis in 1996/97, the currency board arrangement introduced in July 1997 and economic reforms have been crucial for stabilising the economy on a continued growth path. The improved business climate is reflected in a rising share of private investment in GDP and substantial net inflows of foreign direct investment with a record high in 2003. Bulgaria is a functioning market economy. Macroeconomic stability enhances the performance of a market economy and has allowed sustained economic growth. Private ownership has become predominant in the economy. A well-developed financial sector improves the efficiency of the economy.

Basic macro-economic indicators

The performance of the macroeconomic indicators shows that sustainable growth in the Bulgarian economy persisted well also into 2004. The currency board arrangement remained stable, enhancing the country’s macroeconomic stability(Table 11). Thanks to the increasing tendency of stable economic growth in the last few years, 2004 saw the highest GDP growth for the last ten years – 5.6%. The real growth of GDP is considerably higher than that in the EU countries -2.3% for 2004 .

37 In nominal terms, the annual GDP for 2004 has a value of BGN 38 billions (23.8 billion USD). GDP per capita is 4885 BGN (3101 USD). The accelerated growth in terms of GDP consumption in 2004 relates to higher growth for export goods and services. For 2004 as a whole exports grew by 13.1 % (by 5 percentage points faster than growth in the previous year) and import growth fell to 14.1 % (from 15.3 % in 2003). The nominal growth of exports and imports is almost equal (about 20 % in 2004). The foreign trade balance deficit increased, exceeding USD 3.3 billion in 2004.The current account deficit registers decrease (7.5 % of GDP against 9.3 % in 2003) despite the higher balance of trade deficit (14.0 % of GDP against 12.5 % in 2003). Due to the above dynamics, the foreign trade deficit registers slower growth compared to 2003.

Table 11 Basic macro-economic indicators for the period of 2002-2004 Basic macro-economic 2002 2003 2004 indicators

GDP 32 335 083 15 568 534 34 410 244 19 855 882 38 008 406 23 799 878 thousand BGN thousand USD thousand BGN thousand USD thousand BGN thousand USD GDP per capita 4 108 BGN 1 978 USD 4 398 BGN 2 538 USD 4 885 BGN 3 101 USD Real growth of GDP, % 4.8 4.3 5,6 11 857,9 5 692.1 13 041,9 7 444,8 15 634.6 9 888.0 Export (FOB) million BGN million USD million BGN million USD million BGN million USD 15 166.9 7 286.6 17 343.9 9 922.8 20 950.05 13 257.1 Import (FOB) million BGN million USD million BGN million USD million BGN million USD 3 Commercial balance - 1 594.5 - 2 473.8 369.1 million USD million USD million USD Inflation, % 3.8 5.6 4.0 Employees, total, eop,num 1 911 216 2 005 369 2 109 478 Average salary ,BGN 257,6 273,3 301,5 Public sector 322,6 343,1 365,5 Private sector 217,8 232,5 266,4 Unemployment rate , % 16.3 13.5 12,2 Exchange rate BGN/USD

(average for the period) 2.077 1.733 1.597 Source: NSI – up to date 15.06.2005 г.

Economic activity in 2004 increased as a result of higher employment growth than unemployment decline. According to NSI data from labour force survey (LFS) the number of economically active persons in 2004 is 3,322.0 thousand persons aged over 15. The employment rise was mostly due to the jobs created in the private sector of the economy. On a 12- month basis, 2004 growth in employment is estimated at about 3%.

Unemployment exhibited a steady decline both in absolute number and as a ratio. The unemployment rate based on the labour force survey methodology fell from 13.52 percent of the labour force in 2003 to 12.16 percent in 2004.

The up-going trend of average wages in the economy, viewed since 1998, continues in 2004 also. On annual basis the 2004 average wages went on the increase (301 BGN) in both nominal (7.1%) and real (0.3%) terms, still running considerably higher in the public sector vis-à-vis the private sector. However, private-sector wages reported a faster real-term growth rate of 2.2% vs. a bare 0.3% in the public sector. 38 Inflation ran as expected and was kept on a relatively low levels. Two main factors are influential to 2004 inflation – international oil price dynamics has a purely market effect, while the changes of administered prices (fuels, tobacco products, electricity and thermal energy, telephone services and railway transport) contribute more significantly to the overall consumer price dynamics. 2004 inflation amounted to 4,0%, and 6.1% on a yearly average.

The downwards BGN/USD exchange rate trend continued due to the headlong depreciation of the US currency in 2004. 2.1.3. PROFILES OF ECONOMIC SECTORS

Marked positive dynamics is observed in some sectors and industries (for example, tourism, high technology and communications, banking system, capital market). The policy implemented in some areas can also be given a positive assessment (employment and unemployment policy, environmental policy). The record-breaking levels of direct foreign investments and the confirmed trend of improved business climate confirm the higher attractiveness and potential of the Bulgarian economy.

For the last four years, Bulgaria has attracted $ 6, 3 billion foreign direct investments (FDI). In 2004 only, USD 2 601, 6 billion were invested in the country, which marks the highest result for the last 13 years.

The Bulgarian economy registered accelerated growth throughout the whole 2004. The value added in business activity for 2004 amounts to BGN 32, 9 billion at current prices. The overall dynamics of the value added in the private and the public sector results in 5.4 % total value added growth for the economy (Table 12). Table 12Gross Domestic Product and Gross Value Added By Economic Sector for 2001 - 2004

Indicator 2001 2002 2003 2004

GDP, million BGN 29 709 32 335 34 410 38 008 Real growth of GDP, % 4,1 4,9 4,5 5,6 GVA, million BGN 26 356 28 526 30 227 32 942 Real growth of GVA, % 3,9 5,0 4,2 5,4 By economical sectors - agriculture, million BGN 3 533 3 459 3 498 3 581 in % of GVA 13,4% 12,1% 11,7% 10,9% - industry, million BGN 7 804 8 289 8 972 9 878 in % of GVA 29,6% 29,1% 29,7% 30,0% - services, million BGN 15 019 16 777 17 757 19 483 in % of GVA 57,0% 58,8% 58,7% 59,1% By type of ownership - private, million BGN 18 781 20 813 22 291 25 203 in % of GVA 71% 73% 74% 77% - public, million BGN 7 533 7 713 7 936 7 739 in % of GVA 29% 27% 26% 24%

Source:NSI up to date: 21.06.2005 г. All sectors of the economy made a positive contribution to value added growth, with services in the lead with 6,0%. (Fig.4).

Figure 4 Distribution of GVA by sectors, million BGN The services sector implements 59,1% of the value added for the economy. The accelerated value added growth in services (6 % against 4 % in 2003) is the driving force behind output GDP in 2004, and registers once again higher growth relative to industrial production. The industry branch stands for 30% of the value added in economy 2004. Despite intensive real estate construction, value added in industry overall decelerates (5.3 per cent against 6.8 per cent in 2003). Value added in agriculture is 2.2 per cent, up following a 1% decline in 2003. In 2004 the agriculture sector contributed 10, 9% of the value added in the economy (Fig.5).

Figure 5 Share of Economic Sectors in GVA for the period 2003-2004 in % The relative share of the value added from public services is 23.5 %.The reason lies in the rather slow decline of the value added in the public sector (0.6 percent), which offsets the accelerated growth of 2 percentage points in the private sector (7.5 in 2004 against 6.5 in 2003). Private sector continues its up going share and creates 76, 5% of the value added, registering real growth of 7,5% vis-à-vis 2003. Growth in the private sector is not yet sufficient to achieve the desired acceleration of economic growth.

Planning regions Bulgaria is divided into six planning regions. North West; North East; North Central; South West; South East and South Central Planning Regions. The areas are the main administrative, territorial, government and information modules comprising the targeted development regions. The planning regions conform to level II of the Statistical Classification of Territorial Structures NUTS (Fig.6).

Figure 6 Planning regions in Bulgaria During the last six years the economic growth in Bulgaria is positive as since 2000 it is characterized with sustainable rate of 4% annually. Most of the planning regions also had registered increase in GDP. With highest growth rate in GDP are the South West and the South Central Planning Regions. GDP by planning regions is presented in Table 13.

Table 13 Gross Domestic Product by Regions for 2002-2003

2002 2003 Planning Regions Thousand Thousand Thousand USD Thousand USD BGN BGN Total 32 335 083 15 568 534 34 410 244 19 857 785 North-West 1 915 726 922 374 1 990 502 1 148 698 North Central 4 222 695 2 033 122 4 385 818 2 531 009 North-East 4 497 815 2 165 585 4 836 051 2 790 833 South-East 2 674 218 1 287 569 3 128 720 1 805 551 South Central 6 507 938 3 133 410 6 975 941 4 025 741 South-West 12 516 691 6 026 474 13 093 211 7 555 952

Exchange rate BGN/USD (average for the period) 2003. – 1.73283 Exchange rate BGN/USD (average for the period) 2002 г. - 2.07695 * Source: NSI – up to date 31.12.2003 г.

The Gross Domestic Product (GDP) is unevenly allocated within planning regions. In 2003 South West region generates 38% in GDP, followed by South Central – 20, 3%. North - West region has the lowest relative share of the national GDP - 5, 8%. The remaining three regions contribute within approx. 9 – 14% in GDP (fig.7).

41 Share in GDP by planning regions for 2003, in % 5,8% 12,7% 38,1%

14,1%

9,1% 20,3% North-West North Central North-East South-East South Central South-West

Figure 7 Share in GDP by planning regions for 2003, in %

The structure of Gross value added (GVA) by planning regions for the period 2002-2003 is characterized with variable trends in sector’s share, from which it may be concluded that economic restructuring in the planning regions is still in progress, looking for its sustainable and balanced structure.(Table 14). Table 14 Gross Value Added By Economic Sector For 2002 - 2003

Planning Agriculture Industry Services Gross Value Added Regions And Forestry

2002 2003 2002 2003 2002 2003 2002 2003 Thousand BGN Total 3 459 494 3 435 392 8 288 804 9 020 113 16 777 487 17 633 363 28 525 785 30 088 868 North-West 372 639 188 432 498 783 603 888 818 618 948 207 1 690 040 1 740 527 North Central 675 466 811 268 1 124 714 785 114 1 925 052 2 238 648 3 725 232 3 835 030 North-East 762 477 939 213 865 997 658 020 2 339 468 2 631 487 3 967 941 4 228 720 South-East 380 079 513 808 613 779 755 452 1 365 319 1 466 543 2 359 177 2 735 803 South Central 871 023 576 440 1 859 326 2 089 848 3 010 909 3 433 587 5 741 258 6 099 875 South-West 397 810 406 231 3 326 205 4 127 792 7 318 122 6 914 891 11 042 137 11 448 913

Source: NSI – up to date 13.04.2004 г.

In 2003 the structure of gross value added by economic sectors and planning regions follows the general tendencies typical for the preceding years. Real growth rates of GVA in various sectors vary substantially. The dynamics in industry were extremely positive in 2003. With highest share in GVA from industry sector is South-West region (38.1%), which almost twice higher than the second region – South-Central (20.3%), and the lowest share contributes to North-West region (5.8%). Low is the share of North-Central region (12.7%) and North-East region (14.1%) in GVA, compared to their potential for development.

42 % Share in GVA by economic sectors and planning regions for 2003

North-West

North Central

North-East

South-East

South Central

South-West

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Agriculture Industry Services

Figure 8 Share in GVA by economic sectors and planning regions for 2003 in % The agriculture sector in 2003 generated 11,4% from GVA in Bulgaria. With highest relative share in this sector are the North-East (22,2%), North-Central (21,2%) and the South-East (18,8%) planning regions. This sector is characterized with fragmentation of agrarian farms, low efficiency and low level of commercial production (Fig.8). The economic structure in all planning regions of the country is characterized with the highest relative share – 58.6% of total GVA in 2003 and up going trend in the services sector. (fig 8). Exclusion in this trend is the South-West region, where the share decreases since 1999, due to the dynamic development of industrial sector, but nevertheless the region is with the highest relative share in GVA from services (60, 4%) after North-East region. The most dynamic branches in services sector during last years are the communications due to fast development of mobile communications and financial services. After 2000 with growth rates near to average for the country, the services sector is developed in North-Central, North-East and South-East planning regions, with lower growth rates than the average – in North-West and South-Central regions and with highest growth rates – in South-West region. Small and medium - sized enterprises Small and medium-sized enterprises (SMEs) are a major drive for accelerating economic growth, developing high-tech productions and high value added products, improving economic competitiveness. Their dynamics contributes directly to decreasing regional differences, solving the unemployment problem, and improving the living standards. In 2002 the number of SMEs was over 200 thousand or 90% of all non-financial enterprises. Micro- enterprises (1-10 employed) are predominant among small and medium-sized enterprises (MSE) in Bulgaria, though small enterprises (11-50 employed) have the highest potential. A major characteristic of the small and medium-sized business in Bulgaria in 2002 continued to be the great number of micro-enterprises (91.1%) which, however, had a very low average employment level and low labour productivity, which was twice as low compared to both the class of small and the class of medium - sized enterprises. The number and share of micro-enterprises in 2002 was decreasing compared to 2001. At the same time, the number and share of enterprises with 11 to 50 employed was increasing, and these demonstrate highest growth potential among SMEs (1-100).

43 Table 15 Structure of the enterprises by groups according to the number of employed persons during the period 1999 – 2002 in %

Groups of enterprises 1999 2000 2001 2002 Total 100.0 100.0 100.0 100.0 Micro - up to 10 employed 92.4 92.3 91.9 91.1 Small - 11 - 50 employed 5.5 5.7 6.1 6.8 Moderately Small - 51 - 100 employed 1.0 1.0 1.0 1.1 Medium - 101 - 250 employed 0.4 0.4 0.7 0.7 Large - over 250 employed 0.7 0.6 0.3 0.3 Source: NSI Trade continued to be the most attractive sector for development of private small and medium-sized business followed by the manufacturing industry. The small and medium - sized enterprises create most jobs in "Trade and repairing activities", "Manufacturing" and "Real estate, renting activities and other business activities". In 2002 the labour force of the small and medium business is concentrated in these sectors respectively: 34.3, 24.8 and 8.3%. The firms with most insignificantly participation (with up to 100 employed persons) in the economic activity groupings "Electricity, gas and water supply" and "Mining and quarrying" assured respectively only 0.2 and 0.3% of the labour force in the sector of small and medium - sized enterprises (Figure 9).

Figure 9 Structure of employment in SMEs by economic activities in 2002 SMEs are a source of fast economic growth. Value added of SMEs grew faster than the value added of all enterprises in the surveyed range and faster than the value added of the economy as a whole. In 2002 small and medium-sized enterprises generated value added at the amount of BGN 3 556.3 m, which represents 34% of the total value added generated by all enterprises in the nonfinancial sector versus 31% in the previous year. The real annual growth rate of value added in small and medium-sized enterprises in Bulgaria in 2002 exceeded 13%. This growth rate is almost two and a half times faster than the growth rate of the value added for the economy as a whole (5,4%).

44 Large territorial disproportions in the characteristics of small and medium-size business in Bulgaria are preserved. According to all the six indicators (number of enterprises, number of persons employed, number of employees, turnover, value added, fixed assets) the concentration was highest in the South-West planning region, followed by the South Central one. North-East and North Central regions had similar shares which in turn were twice to three times lower than those in the South-West region. The South-East and the North-West regions had the lowest contribution in the SME characteristics by planning regions, the differences between them being from two to five times, and the differences between the North-West and the South-West are from 6 to 20 times. Over 50% of the enterprises, of employment and of the activities of SMEs (turnover, value added and fixed assets) were concentrated in only two of the 6 planning regions – South-West (from 30.8% to47%) and South Central (from 18.0% to 22.8%). The reasons for the increasing importance of SMEs are related to the maintained macro-economic stability, ongoing processes of production restructuring, including those in large enterprises, and improvement of the business environment that creates more favourable conditions for development of entrepreneurship and business start-up.

2.1.4 ENVIRONMENTAL OVERVIEW The ecological situation in the country reflects the generally economic condition as well as the technological structure of production. It depends of the measures (legislative, financial and others), which the society and the state undertake for environment protection. The social and economic problems which have affected the quality of life of many Bulgarians are juxtaposed with an environmental legacy which, at one point in the 1980s made Bulgaria one of the most polluted countries in Europe. Though one of the consequences of the transition has been the relative improvement in the environment, due to falling production, the damage caused by past poor management of natural resources means that restoring the environmental balance in the country and eliminating the impact of pollution on citizens' health and quality of life will take a number of years, and the commitment of decision makers. The process of industrial privatization in Bulgaria was used as a tool to bring industries in compliance with the environmental legislation. A national policy for remediation of past damages caused by industrial plants’ activities is being carried out through involving the Governmental institutions in the process. There is a stable downward trend for atmospheric air pollution from industrial sectors in Bulgaria (mainly because of decrease in production). This decreases the number and the significance of burst pollution of the environment (water, air, soil) caused by the manufacturing process of industrial plants over the whole country’s territory.

2.1.4.1. Environmental media Pollution Atmospheric Air Pollution

In general, no deteriorating air quality trends are observed in Bulgaria.

There are little changes in the emissions of contaminants into the atmosphere in 2003 compared to the previous year. The emissions of nitrogen oxides and carbon dioxides increase - respectively by 6% and 9%. At the same time the emissions of the rest contaminants decrease or remain at previous year levels (Table 16). The production of electricity and heat is a biggest source of the emissions of sulphuric oxides and other contaminants.

45 Table 16Emissions of contaminants in the air*

Contaminants 1997 1998 1999 2000 2001 2002 2003

Thousand tons Sulphuric oxides 1 365 1 251 942 982 940 965 968 Nitrogen oxides 225 224 202 186 191 198 210 Methane 538 559 486 604 618 652 656 Non- methane volatile compounds 282 296 283 288 301 295 292 Carbon oxide 518 678 641 706 756 743 744 Carbon dioxide 64 240 64 028 56 778 49 033 48 606 47 454 51 674 Dinitrogen oxide 46 45 41 33 42 39 39 Ammonia 77 66 65 56 56 57 52 *From industrial combustible and production processes, road transport, agriculture and households

Source: NSI - Published on 13.12.2004

Static industrial sources generate about 64% of dioxins and furans. Atmospheric air quality at industrial sites is influenced by diffused sources of pollution. Some slag dumps or tailings ponds that are not properly operated or are not closed according to requirements are creating local problems concerning air quality caused by secondary pollution.

Surface water contamination Anthropogenic activities have had negative impacts on surface water and its quality through alteration of flow regimes and discharging of faecal and industrial wastewater. Some indirect factors are atmospheric pollution by rainfalls and sediments in water catchers. The industrial sector is responsible for about 87% of the wastewater generated by the “industry” sector. Main polluters are the petroleum industry, chemical and metallurgical industry. Approximately 25% of all treated wastewater is treated by mechanical means, and the rest are subject to biological treatment. The use and storage of pesticides, mineral fertilizers and various agricultural chemicals are a potential threat danger to surface water because of their capability of easy penetration of surface and ground water and, thus, pollute large areas. The surface-water quality monitoring system is well organized.A management and information system for the status of waste water has been implemented. The trend toward improved and stable surface and coastal sea water is improving as an integral result of technological renovation of production processes and closing down of non-efficient and heavily polluting industrial plants in the process of privatization, and of increased water-quality management efficiency through improved pollution control and construction or rehabilitation of urban waste water treatment plants and industrial waste water treatment facilities.

Ground water pollution In general, groundwater quality is good and the main groundwater quality parameters are not in excess of the admissible limit values (ALV) for ground water pollution. Some cases of local pollution of underground water with nitrates or other pollutants have been identified. Only few analyses show separate cases of pollution with petroleum products, phenols and pesticides.

Drinking water contamination The general status of Drinking water quality in RBulgaria is estimated as “excellent”.

Soil contamination The main sources of soil contamination in Bulgaria continue to be the large industrial plants, mines and industrial wastewater as well as the production, use and storage of pesticides and fertilizers. No lands and soils have been registered as polluted with banned for use POPs pesticides and PCBs. DDT and metabolite residues are still registered in soils in Bulgaria in isolated cases .

Wastes There is a tendency of decrease of generated wastes during the period 1998 – 2003 (Table 17). Table 17 Wastes generated

1997 1998 19991 2000 2001 2002 2003

Thousand tons Generated waste - total 236 576 223 088 179 703 97 316 91 156 84 188 88 855 Hazardous waste 2 1 098 548 853 758 756 611 626 Non - hazardous industrial waste 230 669 218 437 174 709 92 335 86 397 79 632 84 313 of which: Waste resulting from exploration, mining, dressing and further treatment of minerals and quarry 222 161 210 048 166 990 84 170 78 213 71 622 75 200 Municipal waste 4 809 4 103 4 141 4 224 4 003 3 945 3 916 of which:collected at the landfill 3 628 3 197 3 213 3 318 3 211 3 199 3 209 1)As of 1999 the survey is based on a new waste classification EWC Source: EEA – Bulgaria, NSI - Published on 29.10.2004

The waste generated in 2003 is 88.9 millions tons. The predominant part in the total volume of the industrial waste is the non-hazardous waste, resulting from exploration, mining, dressing and further treatment of minerals and quarry. In 2003 are generated 84.3 millions tons industrial non- hazardous waste, 89% of which - by mining and quarrying. The hazardous wastes are 626 thousand t. Thirty enterprises are source of 97% of all generated hazardous waste. According to information from the municipal administration 3.2 millions tons municipal waste is collected at controlled landfill sites in 2003.

2.1.4.2. Areas with cumulative environmental problems The areas with cumulative environmental problems have emerged from the overlapping of steady, in some cases irreversible distortions of the environmental components – atmospheric air, waters and soils of certain areas. In certain areas overlapping of damages of two environmental components may occur, in others – of all the three. In the majority of cases air or water pollution entails environmental problems in soils. The reverse case is also possible – deterioration of water quality as a result of washing away of soils with heavy metals and organic waste content above the norms.

Figure 10Areas with cumulative environmental problems In the Northwestern Region there are no areas with cumulative environmental problems. The decommissioning of certain production facilities in the region has improved the environmental situation as compared to that in the rest of the regions. In the North Central Region damaged areas exist in the municipalities of Pleven and Dolna Mitropolia. At isolated sections overlapping of environmental problems has been registered, including air, water and soil pollution above the permissible norm rate. Air pollution is caused by space heating, transport and industrial activities. Waters are polluted by discharge of untreated wastewater. In the municipalities of Veliko Tirnovo and Gorna Oryahovitsa existence of areas with pollution of both the air and waters above the norms has been found. The region suffers also from trans-border pollution (Russe, Nikopol) from neighboring Romania and landslide processes along the river Danube banks. In the Northeastern Region only the Municipality of Varna has high level of air and soil pollution. Industrial activities in the region, including in Devnia and Provadia, are potential sources of air pollution and hence of soil pollution. The Southwestern Region is classified on the second place by the size of the areas with cumulative environmental problems. The environmental problems are connected with the concentration of industrial enterprises from the mining, energy generation and metallurgical industries in the zone of Kremikovtsi, Pirdop – Zlatitsa – Anton – Etropole, Pernik – Batanovtsi, Ellin Pelin, Svoge etc. The South Central Region has been identified as the most gravely polluted region with respect to air, waters and soils. Situated in this region is also the largest number of areas with cumulative environmental problems. In the Municipality of Kardjaly areas with heavy pollution of air, water and soils have been identified. The air and soils on some areas in the municipalities of Plovdiv, Assenovgrad, Radnevo and Dimitrovgrad show high levels of pollutants emitted by the metallurgy, the energy sector, mining, transport and the residential sector. It is worth noting, however, the existence of well preserved environmentally clean areas in the mountains on the area of the region. The environmental problems in the Southeastern Region are localized in the city of Burgas and the Burgas Bay. The reason for the high levels of recorded polluters above the norms is attributed to the industrial activities and the activities in the urbanized territories. Cases of pollution with oil products and wastewaters along the beaches, the surface waters and the seawater have been reported.

48 2.2. INSTITUTIONAL POLICY AND REGULATORY FRAMEWORK 2.2.1. ENVIRONMENTAL POLICY, SUSTAINABLE DEVELOPMENT AND GENERAL LEGISLATIVE FRAMEWORK

Environment policy aims to promote sustainable development and protect the environment for present and future generations. These fundamental principles are incorporated in The National Strategy for the Environment 2000-2006 (NSE). NSE is a natural continuation of the implementation of the environmental policy in the Republic of Bulgaria.

The National Environmental Strategy aims to balance the immediate requirements, related to the EU accession process and strategic environmental goals of the country.This document aims at revealing key issues, priorities and challenges in the field of environment which Bulgaria faces, at assessing major implications as well as setting way foreward which could lead to most substantial benefits for the population and the country’s economy.

The long-term strategy of the country in the field of environment is to improve the quality of life of the population by ensuring healthy and favorable environmental conditions and preservation of the rich nature based on sustainable management of the environment by:

Ensure sufficient quantity of high quality water for the population and industry sectors; Improvement of environmental quality in urban and rural areas; Protection of nature and rich biological diversity; Closer of inintegration of environmental protection policy into the sectoral and regional economic and social development policies; Ensuring effective management and monitoring of the environment; Implementation of Bulgarian commitments for solving of global environmental issues.

2.2.2. ROLES AND RESPONSIBILITIES OF MINISTRIES, AGENCIES AND OTHER GOVERNMENTAL INSTITUTIONS INVOLVED IN POPS MANAGEMENT Chemicals, including POPs are managed by several governmental institutions with respective competences and rights and obligations under Bulgaria’s current legislation. (fig.11).

49 PARLIAMENT

COUNCIL OF MINISTERS

Ministry of Ministry of Ministry of Ministry of Ministry of Ministry of Ministry of Civil National Environment Health Agriculture Labour and Finance Interior Transport and Protection Institute of and Water and Forests Social Policy Communications State Agency Statistics

Executive State Sanitary National Plant Executive Agency Customs National Fire and Environment Control Protection “General Labour Agency Emergency Protection Agency Service Inspectorate” Safety Service

Regional Regional National Inspectorate of Inspectorate for Veterinary Environment and Public Health Service Water Protection and Control

Environmental National Centre Protection for Public Health Activity Care Management Enterprise

Figure 11State Institutions responsible for the management of Chemicals, including POPs

50 MINISTRY OF ENVIRONMENT AND WATER National Implementation Plan for the Management of POPs in the Republic of Bulgaria

The responsibilities, functions, obligations and rights of individual ministries are identified with the respective regulations.

MINISTRIES AND GOVERMENTAL INSTITUTIONS Ministry of Environment and Water (MoEW) The main responsibilities, functions and responsibilities of the Ministry of Environment and Water (MoEW) are related to: − conservation of the environment for the present and the future generations and protection of human health; − conservation and use of environmental media; − control and management of the factors of environmental damage; − control and management of the state of the environment and the sources of pollution; − prevention and limitation of pollution; − establishment and operation of the National System for Environmental Monitoring; − elaboration and implementation of environmental protection strategies, programmes and plans; − collection of, and provision of access to, environmental information;

The mandate of the MoEW includes setting of regimes for conservation and use of the environmental media, control of the condition and use of environmental media and the sources of environmental pollution and damage, sets emission limit values and environmental quality standards, manages the environmental media and factors, conducts environmental impact assessments (EIA), issues permits for prevention, limitation and control of pollution, designates and manages the territories that are subject to special protection regimes, develops the system of monitoring of environmental media, introduces economic regulators and financial mechanisms for environmental management, etc.

Ministry of Environment and Water is the competent authority for notification and assessment of the risks from new chemical substances, and of the import, export, prohibition, and restriction of hazardous chemicals, and issues permits to enterprises that are subject to the Regulation on the Terms and Procedures for Issuance of Permits for Construction and Operation of New and Operation of Existing Enterprises and Facilities, where systems for prevention of large accidents involving hazardous substances or limitation of their consequences are introduced, and keeps registers of notified chemical substances and of imported and exported hazardous chemical substances, according to the Regulation on the Import and Export of Hazardous Chemicals in Bulgaria. Consistent with the Law on Protection against the Harmful Impact of Chemical Substances and Preparations, the MoEW controls the hazardous chemicals for which import and export conditions have been set, the intermediary products for which limited research programmes are allowed, and the compliance with the storage requirements for the chemicals or preparations as indicated by the manufacturer in the Material Data Safety Sheets. The MoEW controls the export, import, disposal and destruction of hazardous waste according to the current legislation and coordinates and control the enforcement of the requirements for treatment and transporting of used oils and waste petrochemicals, polychlorinated biphenyls/polychlorinated triphenyls, batteries and accumulators; the coordination and control during design, construction and operation of urban waste disposal facilities and plants, and compliance with the requirements during sitting of waste treatment facilities; the coordination and control of the enforcement of production and hazardous waste treatment and transporting requirements.

The MoEW develops and coordinates the implementation of national and sector action programmes to fulfil Bulgaria’s commitments under the Stockholm Convention on Persistent Organic Pollutants, the Protocol for the Persistent Organic Pollutants at the 1979 Convention Long-Range Transboundary Air Pollution, the Framework UN Convention on Climate Changes, and the related European legislation. The MoEW carries out its activities at national and regional levels by means of the Executive Environment Agency (EEA) and its regional structures – the 15 Regional Inspectorates of Environment and Water (RIEW). The EEA carries out monitoring of environmental media and factors (including polychlorinated biphenyls, hexachlorobenzene, dioxins, furans, and polyaromatic hydrocarbons) throughout Bulgaria.

The RIEW carries out regulation (develop documents or conduct activities related to the state policy on environment protection and sustainable use of nature), control (monitors compliance with the quality of environmental media, and their registered deviation from the regulations; controls the activities, authorities or persons that can do cause environmental pollution or damage; controls the compliance with the Environmental Impact Assessment /EIA/ statements; inspects, monitors and measures environmental media, enforces administrative measures), and provides information (studies and analyses the results from measurements at the points of the National System for Environmental Monitoring /NSEM/, and submits information about the state of the environment and water).

The enterprise for management of environmental protection activities /EMEPA/ is created in 2002, incorporated pursuant of the Environment Protection Act. The main operational purpose of EMEPA is to implement environmental projects and activities pursuant of national and municipal strategies and programmes in the environmental area. Consistent with its activities, EMEPA provides funding in the form of grants and interest-free or low interest loans.

Ministry of Health (MoH): The Ministry of Health controls the categorization, packaging and labelling of chemicals, the notification of chemical substances and of hazardous chemicals that are subject to trading and use restrictions or prohibitions aimed to protect the health of the population. The MoH organises and controls the state sanitary and epidemiological control, and carries out immunotherapy. It develops and proposes for acceptance hygiene standards and sanitary rules regarding the conditions required for the natural, occupational, study, and household environment; regarding the safety of food, drinking water and all goods with health impacts; regarding issues of radioactivity protection, etc. The MoH plans and organises the studying of specific public-health impacts caused by the factors of the natural, occupational, study, and household environment, and of the behaviour of individuals, assesses the health risks, develops and proposes measures to prevent the harmful public-health effect from environmental risks, and from unsafe behaviour of individuals; collects, processes and submits to the Inspectorates of Hygiene and Epidemiology information about the hazardous chemicals; develops and proposes for establishment and introduction additional hygiene standards and requirements, or special conditions at work, training and movement of the population in the event of radioactivity accidents, industrial accidents, natural calamities or epidemic spreading of particularly hazardous infections, to protect the public. The Ministry of Health (MoH) guides, coordinates and controls the Inspectorates of Hygiene and Epidemiology (IHE), now remaned to Inspectorates for Public Health protection and Control (RIPHPC) as territorial units of the State Sanitary and Epidemiological Control, and the integrated prevention of diseases and promotion of health. National Centre of Hygiene, Medical Ecology and Nutrition (NCMEN), now renamed to National Centre of Public Health Care (NCPHC) is a specialized authority of Ministry of Health for public health protection and expert and consultant body of Regional Inspectorates for Public Health protection and Control (RIPHPC).

The MoH prohibits the marketing of chemicals which are hazardous to human health, and orders their destruction or processing and re-use for other purposes. The importing of psychotropic materials, substances and controlled chemicals used to manufacture narcotics, requires advance agreement with the Ministry of Health.

Ministry of agriculture and forestry (MoAF): The main responsibilities of the Ministry of Agriculture and Forestry are to: protect plants and plant products from diseases, pests and weeds by means of preventive measures during their transboundary transition, occurrence, and distribution in Bulgaria; introduce the introduction and improvement of methods for integrated control of plant and plant product pests; enforce the requirements for the plant protection chemicals and fertilizers, the regime of testing, permitting, import, production, trading, and control of their use to protect human health, animals, and the environment; enforce the requirements for phytosanitary quality and control of plants and plant products meant for the domestic market and for export; control the specialized requirements for plant protection techniques; control pollutants in plants, soils, and irrigation water;

The Ministry of Agriculture and Forestry (MoAF) carries out biological testing and allows import and use of plant protection preparations, soil improvement preparations, and artificial fertilizers, and controls their proper application.

The Ministry of Agriculture and Forestry controls the plant protection chemicals released on the market. Through its local and regional structures, the National Plant Protection Service (NPPS) controls the import, trading in, and use of, plant protection preparations in Bulgaria for content of active substance in the formulation, labelling, content of labels, and their relation to the plant protection product.

National Veterinary Service (NVS) is a specialized body of Ministry of Agriculture and Forestry (MoAF) for organization, coordination, management and control of veterinary-medical activity. The National Veterinary Service (NVS) is the national competent authority responsible for the State Veterinary Sanitary and Border Veterinary Control and Quarantine and for Control on Residues in live animals and animal products. NVS exersizes control on the manufacturing, production,import, export, storage, trade in and use of veterinary medicinal preparations in Republic of Bulgaria.

Ministry of Labour and Social Policy (MoLSP):

The Ministry of Labour and Social Policy (MoLSP) develops, coordinates and conducts the state policy for securing of healthy and safe working conditions . MoLSP carries out the integrated control through the Executive Agency “General Labour Inpectorate” (EAGLI) of legislative compliance and of the fulfilment of the obligations to ensure healthy and safe work conditions in all sectors and activities, regardless of the form of ownership.

Ministry of Transport and Communications (MoTC):

The transport of hazardous chemicals is regulated by the Ministry of Transport and Communications (MoTC), whose competences include the determination of limit values for harmful emissions from the transport vehicles and control over their implementation.

The Customs Agency (CA) of the Ministry of Finance (MoF) controls all goods entering or leaving Bulgaria, consistent with the Customs Act. It participates in the development of the customs policy; participates in the creation of and maintains the information subsystem of categorization of

chemicals; studies, collects data and specifies the types of high-risk goods for the purpose of helping customs offices in risk management through tariffs.

The Agency organizes, coordinates, guides, and controls the activities of customs offices to counteract violations and crime related to the customs activities and hard currency; the measures against illegal trafficking of narcotics and precursors; the receiving, storage and destruction of narcotics and precursors, etc.

Consistent with the Control of Foreign Trade in Weapons and in Goods and Technologies of Possible Dual Use Act, the Customs Agency controls the foreign trade in weapons and in goods and technologies of possible dual use, while the Ministry of Interior (MoI) participates, by means of the National Fire and Emergency Safety Service (NFESS), into the limitation and mitigation of industrial accidents involving chemicals.

State Agency For Civil Protection (SACP)

Civil protection is an element of the national security of the Republic of Bulgaria. It is a system of state, organizational, economic, and social activities aimed at protecting the population and the national economy during crisis situations in peace and war time. The Agency implements the state policy in the area of the protection in crisis situations caused by natural factors and by technical activities. It is a working body of the Standing Committee on the Protection of the Population in the Cases of Disasters and Accidents at the Council of Ministers.

National Statistical Institute (NSI) The National Statistical Institute (NSI) has the status of a State Agency and is directly subordinated to the Council of Ministers. Mission of the National Statistical System is the effective production and dissemination of qualitative statistical information, satisfying the users needs on the state and changes of economy, demography, social sphere and environment. NSI prepares statistical information about emissions in the atmosphere, industrial and municipal wastes, industrial and municipal water use, generated and purified waste water, environmental expenditure and investments.

Within their competences, the municipalities control the activities of generation, collection, separate storage, transporting, recovery and disposal of urban and construction waste; and the disposal of industrial and hazardous waste and the implementation of programs for their management by organising and controlling the closing, reclamation, and follow-up monitoring of landfills in the territory of the respective municipality.

PERMANENT GOVERNMENT COMMITTEE (PGC) Consistent with the Rules of the Organization and Activities to Prevent the Consequences of Accidents, Emergencies and Catastrophes, a Permanent Government Committee for Protection of the Population from Calamities and Emergencies has been established at the Council of Ministers and is lead by a minister. The Committee includes representatives of all interested ministries, of committees and of the academic community. The Permanent Committee is assisted by the Civil Protection State Agency. It studies the likelihood of emergencies and develops plans for preventive work to reduce losses during accidents, and conducts rescue operations during industrial accidents. The Agency organises the mitigation of the effects from accidents for protection of the public and of the environment. The permanent committees carry out the following main objectives in the municipalities: − analysis of the condition and readiness of their dependent structures and of the respective commercial companies and enterprises of sole proprietors to participate in the prevention and elimination of the effects of calamities, accidents and catastrophes, and development of programs, plans and measures for improvement of readiness; 54

− organising of scientific research for protection of the population and the national economy in the event of calamities, emergencies and catastrophes; − organising and carrying out of activities to prevent and reduce the harmful consequences from calamities, emergencies and catastrophes; − create and maintain ready means of notification, and of collective and personal protective equipment for the workers and officials; − plan, organise, guide and control the submission and participation of formations and funds for rescue and urgent emergency restoration work upon request by the permanent committee at the Council of Ministers, and by the regional and municipal permanent committees; − collect information about calamities, emergencies and catastrophes from their dependent structures and promptly inform the permanent committee at the Council of Ministers and the regional and the municipal permanent committees on whose territory are the sites and the endangered population about the situation, about the measures to eliminate the effects and about the manner of behaviour and action, and make requests for assistance.

INTERAGENCY COMMISSIONS

Depending on the specifics and on the problems, several inter-agency permanent committees exist in Bulgaria, as well as temporary inter-agency working groups. The work of each committee or working group is governed by certain mechanisms.

Table 18 presents inter-agency commissions and mechanisms for coordination of the management of chemical substances, including POPs. Table 18 Review of some inter-agency commissions and coordination mechanisms related to POPs Information Term of Type of mechanism Members Delegated rights presented in operation Section 7.2 Supreme Council of Environmental MoEW, MoH, permanent EIA related decisions yes Experts MoAF, MoRDPW, and assessment of • Main staff; MoF, MoE, PPCA, environmental • Specialised staff: RIEW, BD, SNCC, damages; approval of - Inter-agency Council of NDF programs for Environmental Experts; compliance with the - Inter-agency Committee. environmental legislation; TORs for designing and investment projects to implement the environmental damage mitigation programmes; evaluation of plans and programs, etc. Working group 22 “Environment” MoEW, EEA, MoAF temporary Draws up and yes MoEER, MoD, MoH, approves the draft MoE, MoRDPW, position for MoTC, MoAF, MoF, negotiations on the MJ, CPSA, SAMTS, Environment sector; NIS, NRA, EA BAS, Discusses new drafts BCC, BCCI, of regulations based Podkrepa Union, on the acquis, etc. CIUB, NGO Vazrazhdane

Information Term of Type of mechanism Members Delegated rights presented in operation Section 7.2 The Inter-Agency Committee on MoAF/NPPS, temporary organising of disposal no neutralisation of past pollution with MoEW, MoE, MoH pesticides Permanent committee for protection DPSA, MoD, MIA, permanent Emergency action no of the public in the case of calamities, MoE, MoH, emergencies and catastrophes, at the MoRDPW, MoEW, Council of Ministers MoAF Inter-Agency Committee for Control MoH, MoE, MoF, permanent Controls production, no of Precursors at the Minister of MoIA, MoI processing, use in Economy other processes, storage, trading, import, export, re- export, and transit of precursors; controls compliance with Article 12 of the UN Convention to Combat the Illegal Traffic of Narcotics and Psychotropic Substances. The National Council on Work staffed by permanent Coordination, no Conditions representatives of the consultancy and Council of Ministers; cooperation in the National Insurance development and Institute; national implementation of the representative policy to secure employer healthy and safe organizations; occupational national environment at the representative worker national level and employee organizations; Council on plant protection products MoAF, MoH, permanent Marketing and use of no MoEW, CPSA, plant protection Agricultural chemicals are academy, and other allowed with an order specialists by the Minister of Agriculture and Forests upon proposal by the Council on Plant Protection Products Inter-Agency Committee Of Experts MoEW, MoAF, temporary Evaluation and yes on Plant Protection Preparations NPPS, CPSA, MoF, control MoIA, MoLSP

Note: The frequency of meetings is defined by the needs. The decision making procedures are defined by an act of the government.

Each mechanism for coordination of activities for proper management of chemicals operates by means of a specialized authority created in the Ministry of Environment and Water (MoEW) under the name Supreme Council of Environmental Experts (SCEE).

Rules, approved by the Minister of Environment and Water, define the procedures and activities of the SCEE.

The SCEE meets with the following staff: 1. Main staff – under provisions of the Regulation on the Terms and Procedures for Environmental Impact Assessment of investment proposals for construction, activities and technologies; 2. Specialised staff – Inter-Agency Council of Environmental Experts (IACEE) – under provisions of the Regulation on the Terms and Procedures for Determination of the Responsibility of the State for Environmental Damage Caused by Past Action or Inaction during Privatization; 3. Specialised staff – Inter-Agency Committee (IAC) – under provisions of the Regulation on the Carrying out of Environmental Impact Assessment of National, Regional, and District Development Plans and Programmes, of Urban Development Plans and their Amendments.

The IACEE of the SCEE fulfils the following tasks: reviews, assesses and proposes for approval terms of reference, feasibility studies, tender documents, technical and technological solutions, project implementation stages, design documents at each stage of the programme to remove environmental damage, and the results from work commissioned to eliminate environmental damage; observes the procedures under the Public Procurement Act conducted by the program implementing authority; under orders by the Minister, conducts on-site control of activities under the programme to remove environmental damage; proposes for approval six-month progress reports on the programmes to eliminate past environmental damage.

The Inter-Agency Committee at the SCEE reviews terms of references for Environmental Impact Assessment of plans and programmes, and the submitted documents.

The Regional Councils of Environmental Experts (RCEE) are specialized authorities of the RIEWs, directly subordinated to the RIEW Directors. The RIEW controls the implementation of the decisions of the EIA council of experts and submits the results to the MoEW. The MoEW maintains a registry of EIA decisions by the competent authorities – the SCEE or the RCEE.

Working Group 22 “Environment” (WG 22) – To improve the dialogue with the EU institutions, a Coordination Council for Preparation of Bulgaria for Accession to the European Union was established at the Ministry of Foreign Affairs. Thirty working groups were established under this council. The Ministry of Environment and Water is the leading agency in Working Group 22 “Environment”, and it involved representatives of various ministries and agencies, including non- governmental organizations concerned with the issues of the “Environment” area. The objectives of Working Group 22 are: Draws up and approves the draft position for negotiations on the Environment sector; Discusses new drafts of regulations based on the acquis communitaire; Conducts constant comparison of the membership requirements arising from the acquis communitaire of the European Union and from the latest regular report of the European Commission on Bulgaria’s progress; When preparing draft negotiation positions, advises the representatives of the economic and of the social partners and of civil society on issues within its competence; Discusses inter-sectoral issues to harmonise the efforts of the different working groups; Analyses the country’s priorities in the Environment sector, which is the basis for the drawing up of a motivated proposal for specific activities in the National Programme for Adoption of the Acquis Communitaire.

An Inter-Agency Committee of Experts on Plant Protection Preparations (IACEPPP) was created to coordinate the work related to pesticides. This Inter-Agency Committee was created with an order by the Minister of Environment and Water and by the Minister of Agriculture and Forestry, pursuant to Decision 11/16.01.1996 of the Council of Ministers, and to the Rules for the Activities of the Council for Regional Policy, Transboundary Infrastructure Systems and Local Authorities to resolve the problems of collection, packaging, loading and unloading, transporting, guarding, and destruction of prohibited, obsolete and unusable plant protection preparations. The Inter-Agency Committee is lead by a chair person. When implementing the tasks of collection, storage and destruction of prohibited, obsolete and unusable pesticides, the Chairman may involve additional experts, other than the ones who are permanent members of the Committee. The Inter-Agency Committee of Experts on Plant Protection Preparations has the following objectives: Make an informed national-level assessment of the state of pesticide storage facilities; Update the regulations dealing with the issues of collection, packaging, loading and unloading, transport, guarding, and destruction of prohibited, obsolete and unusable plant protection preparations; Review regional and national-level proposals and drafts and propose them for financing to the Environmental Activity Management Enterprise at the MoEW, or to the MoAF’s target funds; Continue studies involving Bulgarian or foreign companies and organisations in the searching of environmentally sound ways to destroy the unusable pesticides; Ensure financing by updating the calculations and the draft budget of the MoAF for each subsequent year should provide the necessary financing until the problem is resolved; Control the expending of funds for collection, loading and unloading, transport, guarding and destruction of prohibited, unusable and obsolete plant protection preparations.

To implement Bulgaria’s commitments under Stockholm Convention, with Order of Minister of Environment and Water a National Steering Committee (NSC) was created to develop a National Implementation Plan for Management of Persistent Organic Pollutants (NIP), as required by the Stockholm Convention. It comprises representatives of the following governmental and non- governmental organizations: MoEW, EEA, MoEE, MoLSP, MoF, MoH, NCHMEN, MoTC, NPPS, MoAF, NSVM, NVMS, the Civil Protection State Agency, BCC, BCCI, BAS, FU, UCT, the Eco- Association “For the Earth”, and the “Protect the Women” Association.

2.2.3. RELEVANT INTERNATIONAL COMMITMENTS AND OBLIGATIONS Bulgaria ratified and signed most international environmental conventions and agreements and despite the difficulties of its economic transition, it has expressed its political will and is involved actively in the efforts of the international community to resolve regional and global environmental issues.

The Law on Ratifying the Agreement for Bulgaria’s Participation into the European Environmental Agency (EEA), adopted by the National Assembly, has made Bulgaria a fully authorised member of this EU institution. The International Conventions, ratified by R Bulgaria and the Multi-Lateral Environmental Agreements with Bulgarian Participation are indicated in Table 19 and Table 20.

Table 19 International Conventions

1. Basel Convention on the Control of Transboundary Movement of Hazardous Wastes and their Disposal, ratified with a law, SG 8/26.01.1996, effective 16.05.1996. 2. Geneva Convention on Long-Range Transboundary Air Pollution, ratified with a law, SG 16/1981, effective 16.03.1983. 3. Persistent Organic Pollutants Protocol under the Geneva Convention on Long-Range Transboundary Air Pollution, ratified with a law, SG 42/2001, promulgated SG 102/2003, effective since 23.10.2003. 4. Convention for the Protection of the Black Sea from Pollution, ratified with a law, SG 99/1992, effective 15.01.1994. 5. Convention on the Cooperation for Protection and Sustainable Use of the Danube, ratified with a Law, SG 30/02.04.1999, effective 6.04.1999, amended SG 53/28.05.2002 6. Rotterdam Convention on the Prior Informed Consent Procedure for Certain Hazardous Chemicals and Pesticides in International Trade, ratified with a law, SG 55/2000, SG 33/23.04.2004, effective 24.02.2004. 7. The Stockholm Convention on Persistent Organic Pollutants, signed by the Republic of Bulgaria on May 23, 2001 in Stockholm, ratified by the National Assembly with a Law on 30.09.2004, SG 89/12.10.2004, in force from 20.03.2005. 8. Convention on the Transboundary Effects of Industrial Accidents, signed by R Bulgaria on 18 March 1992 in Helsinki, Finland;ratified, SG 28/1995,entered into force for the Republic of Bulgaria on 12.05.1995. Protocol on Civil Liability and Compensation for Damage Caused by the Transboundary Effects of Industrial Accidents on Transboundary Waters, signed on 21.05.2003 in Kiev, Ukraine. 9. Convention on the Environmental Impact Assessment in a Transboundary Context, Signed by RBulgaria on 25 February 1991 in Espoo, Finland, Ratified, SG 28/1995, entered into force on 10 .09.1997, Amended, SG 89/1999. 10. The United Nations Framework Convention on Climate Change - Kyoto Protocol, Bulgaria ratified the UN Convention on Climate Change in 1995 and the Kyoto Protocol in 2002. 11. Aarhus Convention on Access to Information, Public Participation in Decision-making and Access to Justice in Environmental Matters, signed by RBulgaria on 25.06.1998 in Aarhus, Denmark, ratified by the Parliament on 2 .10.2003, entered into force on 16.03.2004. 12. Convention on the Protection and Use of Transboundary Watercourses and International Lakes, Signed by RBulgaria on 18.03.1992 in Helsinki, Finland, Ratified, SG 86/30.09.2003,entered into force on 26.01.2004; Protocol on Civil Liability and Compensation for Damage Caused by the Transboundary Effects of Industrial Accidents on Transboundary Waters, signed on 21.05.2003 in Kiev, Ukraine.

Successful bilateral cooperation has continued with EU countries in order to strengthen our institutional capacity for environmental management, to implement the EU legislation transposed in our national legislation, and to find a practical solution of priority environment protection issues. The period 2001-2003 has seen the signing of 16 new bilateral cooperation agreements, some with EU-member states such as Greece, Austria, the Netherlands and Italy.

Table 20 Participation in international agreements/procedures related to the management of chemicals International agreements Leading responsible institution Relevant national scale activities Agenda 21 – Sustainable Inter-agency Council for Sustainable The national programme, related to Development Committee Development environment and health protection The Rotterdam Convention on the The Ministry of Environment and Management of hazardous chemicals Prior Informed Consent (PIC) Water in cooperation with the and preparations Procedure for Certain Hazardous Ministry of Health Chemicals and Pesticides in International Trade The Vienna Convention on the Ministry of Environment and Water Inventory has been conducted, and a Protection of the Ozone Layer, and national programme is implemented. the Montreal Protocol on Ozone Depleting Substances UN recommendations for transposing Ministry of Transport and Licensing of hazardous cargo haulers; of hazardous cargoes Communications control The Basel Convention on the Control Ministry of Environment and Water Management of hazardous waste of Transboundary Movement of Hazardous Waste and their Neutralization The Stockholm Convention on Ministry of Environment and Water Development of a National Persistent Organic Pollutants Implementation Plan for Management of Persistent Organic Pollutants. Regional Treaty for Economic Ministry of the Foreign Affairs, Elaboration of a development plan for Cooperation of the Countries from the Ministry of Environment and Water the Black Sea Region focusing on Black Sea Region environment protection Bilateral cooperation with Ministry of Environment and Water Environment protection activities, Macedonia, the Czech Republic, including public access to Germany, China, Romania, Greece, environmental information. Slovakia, Poland, the Netherlands, Italy The Convention on the Ministry of Environment and Water Transboundary Impacts of Industrial Transboundary Impacts of Industrial Accidents Accidents The Convention on the Ministry of Environment and Water EIA in the transboundary context environmental impact assessment (EIA) in the Transboundary Context The Geneva Convention on Long- Ministry of Environment and Water Clean Air Act Range Transboundary Air Pollution

The new Environmental Protection Act of 2002 (EPA) is the key frame law governing the environmental control of economic activity, including provisions for Strategic Environmental Assessment (CEA), Environmental Impact Assessment (EIA), Integrated Pollution Prevention and Control (IPPC) and Seveso – Industrial risk prevention directive. It also introduces the key objectives of sectoral legislation.

With the new Environmental legal framework has been created legislative grounds for transposition of the following EU Directives and Regulations in the national legislation:

Directive 2003/4/EC on public access to environmental information and repealing Council Directive 90/313/EEC; Directive 85/337/EEC, amended by 97/11/EC on the assessment of the effects of certain public and private projects on the environment, amended and supplemented by Directive 2003/35/EC providing for public participation in respect of the drawing up of certain plans and programmes relating to the environment ; Directive 96/61/EC on integrated pollution prevention and control (IPPC); Directive 96/82/EC Seveso II on the control of major-accident hazards involving dangerous substances and Directive 2003/105/EC of the European Parliament and of the Council of 16

December 2003 amending Council Directive 96/82/EC on the control of major-accident hazards involving dangerous substances; Regulation (EC) No 761/2001 of the European parliament and of the council of 19 March 2001 allowing voluntary participation by organisations in a Community eco-management and audit scheme (EMAS); Directive 2001/42/EC on environmental impact assessment of certain plans and programmes; Framework Directive 96/62/EC on AAQ Assessment and Management; Directive 2001/80/EC of the European Parliament and of the Council of 23 October 2001 on the limitation of emissions of certain pollutants into the air from large combustion plants; Directive 75/442/EEC on waste; Directive 91/689/EEC on the hazardous waste; Regulation EEC/259/93 on the supervision and control of shipments of waste within, into and out of the European Community; Directive 2000/76/EC on the incineration of waste; Directive 99/31/EC on landfill of waste; Directive 86/278/EEC on protection of the environment, and in particular of the soil, when sewage sludge is used in agriculture; Directive 2000/60/EC establishing a framework for Community action in the field of water policy, amended by Decision No 2455/2001/EC establishing the list of priority substances in the field of water policy; Directive 80/68/EEC on the protection of groundwater against pollution caused by certain dangerous substances, amended by Directive 91/692/EEC; Directive 76/464/EEC on pollution caused by certain dangerous substances discharged into the aquatic environment of the Community, amended by Directive 91/692/EEC, amended by Directive 2000/60/EC establishing a framework for Community action in the field of water policy; Council Directive 67/548/EEC of 27 June 1967 on the approximation of laws, regulations and administrative provisions relating to the classification, packaging and labelling of dangerous substances; Council Directive 93/67/EEC laying down the principles for risk assessment for men and environment of new chemical substance; Council Directive 76/769/EEC of 27 July 1976 on the approximation of the laws, regulations and administrative provisions of the Member States relating to restrictions on the marketing and use of certain dangerous substances and preparations; Regulation (EC) No 304/2003 of the European Parliament and of the Coucil of 28 January 2003 concerning the export and import of dangerous chemicals; Council Directive 88/320/EEC of 9 June 1988 on the inspection and verification of Good Laboratory Practice (GLP); Directive 98/8/EC on the placing of biocides on the market; Regulation (EC) No 850/2004 of the European Parliament and of the Council of 29 April 2004 on persistent organic pollutants and amending Directive 79/117/EEC; Council Directive 92/32/ЕЕС on the approximation of laws, regulations and administrative provisions relating to the classification, packaging and labelling of dangerous substances;

Directive 1999/45/EC of the European Parliament and of the Council of 31 May 1999 concerning the approximation of the laws, regulations and administrative provisions of the Member States relating to the classification, packaging and labelling of dangerous preparations; Commission Directive 91/155/EEC of 5 March 1991 defining and laying down the detailed arrangements for the system of specific information relating to dangerous preparations in implementation of Article 10 of Directive 88/379/EEC (Safety Data Sheet); Regulation (EC) No 850/2004 of the European Parliament and of the Council of 29 April 2004 on persistent organic pollutants and amending Directive 79/117/EEC ; Directive 98/8/EC on the placing of biocides on the market; Council Regulation (EEC) No 793/93 laying down the principles for the assessment of risks to man and the environment of existing substances; Commission Regulation (EC) No 1488/94 of 28 June 1994 laying down the principles for the assessment of risks to man and the environment of existing substances in accordance with Council Regulation (EEC) No 793/93; Decision 2001/118/EC on waste classification catalogue; Regulation EEC/259/93 on the supervision and control of shipments of waste within, into and out of the European Community; Regulation (EC) No 2557/2001 of 28 December 2001 amending Annex V of Council Regulation (EEC) No 259/93 on the supervision and control of shipments of waste within, into and out of the European Community; Directive 75/439/EEC on waste oils; Directive 91/157/EEC on batteries and accumulators containing certain dangerous substances; Directive 94/62/EC on packaging and packaging waste; Directive 96/59/EC on the disposal of polychlorinated biphenyls and polychlorinated terphenyls (PCB/PCT); Decision 2001/68/EC of 16 January 2001 establishing two reference methods of measurement for PCBs pursuant to Article 10(a) of Council Directive 96/59/EC on the disposal of polychlorinated biphenyls and polychlorinated terphenyls (PCBs/PCTs); Directive 2000/53/EC on end-of life vehicles.

The EU Directives & Regulations, transposed into Bulgarian legislation for the managements of chemicals and that might have been related to POPs are: Council Directive 67/548/EEC of 27 June 1967 on the approximation of laws, regulations and administrative provisions relating to the classification, packaging and labelling of dangerous substances; Law on Protection against Harmful Impact of Chemical Substances and Preparations (Published in SG 10/04.02.2000, amended SG 91/25.09.2002, SG 86/30.09.2003, SG No.114/30.12.2003, in force since 31.01.2004) Regulation on classification, packaging and labelling of existing and new chemical substances and preparations (published in SG 5/17.01.2003, in force as of 01.01.2004, amended and suppl. SG 66/2004, in force as of 01.01.2005) Council Directive 92/32/ЕЕС on the approximation of laws, regulations and administrative provisions relating to the classification, packaging and labelling of dangerous substances; Law on Protection against Harmful Impact of Chemical Substances and Preparations (Published in SG 10/04.02.2000, amended SG 91/25.09.2002, SG 86/30.09.2003, SG No.114/30.12.2003, in force since 31.01.2004); Regulation on the notification of new chemical substances ( published in the SG110/17 December 2004, in force from 1 January 2005); Directive 1999/45/EC of the European Parliament and of the Council of 31 May 1999 concerning the approximation of the laws, regulations and administrative provisions of the Member States relating to the classification, packaging and labelling of dangerous preparations; Law on Protection against Harmful Impact of Chemical Substances and Preparations (Published in SG 10/04.02.2000, amended SG 91/25.09.2002, SG 86/30.09.2003, SG No.114/30.12.2003, in force since 31.01.2004) Regulation on classification, packaging and labelling of existing and new chemical substances and preparations (published in SG 5/17.01.2003, in force as of 01.01.200, amended and suppl. SG 66/2004, in force as of 01.01.2005) Commission Directive 91/155/EEC of 5 March 1991 defining and laying down the detailed arrangements for the system of specific information relating to dangerous preparations in implementation of Article 10 of Directive 88/379/EEC (Safety Data Sheet); Law on Protection against Harmful Impact of Chemical Substances and Preparations (Published in SG 10/04.02.2000, amended SG 91/25.09.2002, SG 86/30.09.2003, SG No.114/30.12.2003, in force since 31.01.2004); Regulation on classification, packaging and labelling of existing and new chemical substances and preparations (published in SG 5/17.01.2003, in force as of 01.01.2004, amended and suppl. SG 66/2004, in force as of 01.01.2005); Council Directive 93/67/EEC laying down the principles for risk assessment for men and environment of new chemical substances; Law on Protection against Harmful Impact of Chemical Substances and Preparations (Published in SG 10/04.02.2000, amended SG 91/25.09.2002, SG 86/30.09.2003, SG No.114/30.12.2003, in force since 31.01.2004); Regulation on the procedure and method of the assessment of risks to man and the environment of notified chemical substances, published in SG 110/17.12.2004; Council Directive 76/769/EEC of 27 July 1976 on the approximation of the laws, regulations and administrative provisions of the Member States relating to restrictions on the marketing and use of certain dangerous substances and preparations; Law on Protection against Harmful Impact of Chemical Substances and Preparations (Published in SG 10/04.02.2000, amended SG 91/25.09.2002, SG 86/30.09.2003, SG No.114/30.12.2003, in force since 31.01.2004); Regulation relating to bans and restrictions on the marketing and use of certain dangerous substances and preparations (SG 69/17.07.2002, amended and suppl. SG 62/2004);

Regulation (EC) No 304/2003 of the European Parliament and of the Coucil of 28 January 2003 concerning the export and import of dangerous chemicals;

Law on Protection against Harmful Impact of Chemical Substances and Preparations (Published in SG 10/04.02.2000, amended SG 91/25.09.2002, SG 86/30.09.2003, SG No.114/30.12.2003, in force since 31.01.2004); Regulation on the procedure and method of import and export of dangerous chemical substances and preparations on the territory of the Republic of Bulgaria, (SG 63/20.07.2004q effective from 01.01.2005);

Regulation (EC) No 850/2004 of the European Parliament and of the Council of 29 April 2004 on persistent organic pollutants and amending Directive 79/117/EEC

Directive 98/8/EC on the placing of biocides on the market; Law on Protection against Harmful Impact of Chemical Substances and Preparations (Published in SG 10/04.02.2000, amended SG 91/25.09.2002, SG 86/30.09.2003, SG No.114/30.12.2003, in force since 31.01.2004); - - Regulation on the terms and procedure for placing of biocides on the market, SG 110/17.12.2004 Regulation No 8 on the requirements for desinsection and deratization (SG No 49/1992); Regulation No 27 on the import of goods for the health of the population (SG No 75/1995); Regulation No 17 for the management of stations for desinsection and deratization (SG 87/1992); Regulation No 194/3.10.1991 on the organization of measures against insects and rodents-pests. Council Regulation (EEC) No 793/93 laying down the principles for the assessment of risks to man and the environment of existing substances; Commission Regulation (EC) No 1488/94 of 28 June 1994 laying down the principles for the assessment of risks to man and the environment of existing substances in accordance with Council Regulation (EEC) No 793/93; Council Directive 88/320/EEC of 9 June 1988 on the inspection and verification of Good Laboratory Practice (GLP); Regulation on the principles, inspection and verification of the Good Laboratory Practice (GLP)

The EU Directives & Regulations, transposed and to be transposed into Bulgarian legislation for the waste management and that might have been related to POPs are: Directive75/442/ЕЕС on waste; Law on Waste Management (State Gazette No 86/2003, amended SG 70/2004, effective 01.01.2005); Regulation No 10 on the filling out of the report and the waste management information documents (State Gazette No 151/1998); Regulation on the requirements for treatment and transportation of industrial and hazardous waste (SG 151/1998); Directive 91/689/EEC on dangerous wastes; Regulation on the requirements for treatment and transportation of industrial and hazardous waste (SG 29 /1999); Regulation No 6 on the procedure for filling out of report and information documents for the waste management activities, SG 78/07.09.2004. Decision 2001/118/EC on waste classification catalogue; Regulation No 3/01.04.2004 on Waste classification, SG 44/25.04.2004. Regulation No 6 on the procedure for filling out of report and information documents for the waste management activities, SG 78/07.09.2004. Regulation EEC/259/93 on the supervision and control of shipments of waste within, into and out of the European Community Regulation on the treatment and transportation industrial and hazardous waste, CM Decree 53/19.03.1999, SG 29/30.03.1999.

Regulation (EC) No 2557/2001 of 28 December 2001 amending Annex V of Council Regulation (EEC) No 259/93 on the supervision and control of shipments of waste within, into and out of the European Community; Law on Waste Management (State Gazette No 86/2003, amended SG 70/2004, effective 01.01.2005); Regulation for the cases when a permit is required for the import, export and transportation of waste and the conditions and order of the issuing the permit (State Gazette No 67/2000). Law on Ratification of the Basel Convention on the Control of Transboundary Movements of Hazardous Waste and their Disposal; Regulation on the Procedures and Manner of Importing, Exporting and Transit of Waste and on the Cases Requiring Bank Guarantees or Insurances, SG 102/26.10.2004. Directive 75/439/EEC on waste oils Regulation on the Requirements for Treatment and Transporting of Used Oil and Waste Oil Products, SG 59/21.07.2000, in effect since 01.01.2001; Directive 91/157/EEC on batteries and accumulators containing certain dangerous substances Regulation on the requirements for the production and placing on the market of batteries and accumulators and for treatment and transportation of spent batteries and accumulators, CM Decree 134/17.07.2000, SG 61/25.07.2000. Directive 94/62/EC on packaging and packaging waste Law on Waste Management (State Gazette No 86/2003, amended SG 70/2004, effective 01.01.2005); Regulation on Packaging and Packaging Waste, SG, SG 19/09.03.2004. Directive 86/278/EEC on protection of the environment, and in particular of the soil, when sewage sludge is used in agriculture; Regulation on the Procedures and Manner of Using of Waste-Water Treatment Sludge in Agriculture, SG 112/23.12.2004; Directive 96/59/EC on the disposal of polychlorinated biphenyls and polychlorinated terphenyls (PCB/PCT) Decision 2001/68/EC of 16 January 2001 establishing two reference methods of measurement for PCBs pursuant to Article 10(a) of Council Directive 96/59/EC on the disposal of polychlorinated biphenyls and polychlorinated terphenyls (PCBs/PCTs) ; Regulation on the requirements for the order and the manner of inventory, labeling and decontamination of equipment, containing PCBs as well as the treatment and transportation of waste, containing PCBs, adopted by MC Decree No 50/09.03.2006, promulgated in SG 24/21.03.2006. Directive 2000/53/EC on end-of life vehicles Regulation on the terms and conditions for reduction of contamination caused by waste from end-of-life vehicles, CM Decree 257/09.11.2001, SG 98/16.11.2001, amended SG 110/21.12.2001, SG 104/26.11.2004 Directive 2000/76/EC on the incineration of waste - forseen to be harmonized. Directive 99/31/EC on landfill of waste Regulation 7 on the Requirements for the Sites for Waste Treatment Facilities, SG 81/17.09.2004; Regulation 8 on the Terms and Requirements for Construction and Operation of Waste Recycling and Disposal Landfills and Other Facilities, SG 83/24.09.2004.; Regulation (EC) No 850/2004 of the European Parliament and of the Council of 29 April 2004 on persistent organic pollutants and amending Directive 79/117/EEC The EU Directives, transposed into Bulgarian legislation for industrial pollution and risk management & Major Accident Prevention and Control and that might have been related to POPs are: Directive 96/61/EC on integrated pollution prevention and control (IPPC); Environmental Protection Act, adopted SG No 91/2002, amended SG 98/2002, suppl. SG 70/2004, effective from 01.01.2005 (Chapter Seven, Section II “Integrated Permits”)

Regulation on the Conditions and Procedures for Issuing of Integrated Permits for Construction and Operation of New and Existing Industrial Plants and Facilities, CM Decree 62/12.03.2003, SG 26/2003, amended SG 29/2003. Council Directive 96/82/EEC Seveso on the Control ofMajor Accident Prevention and Control, involving dangerous substances; The Environmental Protection Act, adopted SG 91/2002, amended SG 98/2002, suppl. SG 70/2004, effective from 01.01.2005 (Chapter Seven, Section I “Prevention of Major Industrial Accidents”) Regulation on the conditions and procedure for issuing of permits for construction and operation of new Enterprises and Facilities and for operation of existing Enterprises and Facilities implementing a system for the prevention of major accidents involving dangerous substances or the limitation of their consequences, SG 38/23.04.2003. In the period between 1997 and the present, Bulgaria has found it exceptionally important to strengthen its administrative capacity for complete harmonisation with the EU legislation. It is particularly important to increase the professional skills of the administrative capacity. One of the main tools for training of personnel are the projects implemented under PHARE. Twinning projects have been developed between the MoEW and the German Federal Ministry of Environment, Nature Protection and Nuclear Safety, the Austrian Federal Ministry of Environment, and the French Ministry of Spatial Planning and the Environment. The period 1999-2002 has seen the implementation of 14 twinning projects. Table 21 presents data about the involvement of Bulgaria in projects related directly or indirectly to the management of chemical substances.

Table 21 Involvement of the MOEW in projects on technical assistance in the management of chemicals Project Name Organisation of financing and Completed work partners BG9807 – Elaboration of an overall • PHARE – Twinning Project Draft strategy of the MOEW and updating strategy of the MOEW and updating of the of the National Environment Protection National Environment Protection Plan Plan (harmonisation of the Bulgarian environmental legislation) BG99EN01В – Transposing of the • PHARE – Twinning Project Transposing the IPPC and Seveso environmental legislation and introduction directives of, and support for, the implementation of the IPPC and Seveso directives Drawing up of the EIA statement for the • PHARE EIA statement for the “National Hazardous “National Hazardous Waste Treatment Waste Treatment Centre” project Centre” project • DEPA A hospital waste incinerator is Hospital waste incinerator in Sofia • Environment Protection Activity commissioned Management Enterprise Creation of a database on polychlorinated • Germany National database on polychlorinated biphenyls and polychlorinated triphenyls in biphenyls and polychlorinated triphenyls Bulgaria Construction of an integrated system for • Greece Integrated system for constant monitoring constant monitoring and for reduction of and for reduction of VOC emissions the VOC emissions Updating of the National Waste • Belgium Updating of the National Waste Management Programme Management Programme Sub-project 1 – Elaboration of a national • PHARE National Environmental Strategy and environmental strategy and reviewing of • Federal Ministry of the National Environmental Plan 2000-2006. the National Environmental Plan Environment, nature Protection, and Nuclear Safety, Germany • Federal Environmental Agency, Austria • International water service, France • Environment and Energy Management Agency, France Sub-Project 2 – Elaboration of a National • PHARE National Programme for Public Programme for Public Environmental • Federal Ministry of the Environmental Awareness and of an Awareness and of an Action Plan for the Environment, nature Protection, Action Plan for the Implementation of the Implementation of the Programme and Nuclear Safety, Germany Programme

Sub-Project 4 – Elaboration of a Draft • PHARE Regulation on the Access to Regulation on the Access to Environmental • Federal Ministry of the Environmental Information Information Environment, nature Protection, and Nuclear Safety, Germany • Federal Environmental Agency, Austria Sub-Project 8 – Drawing up of draft • PHARE Regulations on the treatment of end-of- regulations on the treatment of end-of-life • Federal Ministry of the life vehicles and of disused electrical vehicles and of disused electrical Environment, nature Protection, equipment equipment and Nuclear Safety, Germany • Federal Environmental Agency, Austria Evaluation of the White Book on the • CEFIC Comparative analysis and report on the Management of Chemicals and • Bulgarian Chamber of the status of Bulgaria’s chemicals legislation Preparations Chemical Industry;

Transposing and implementing the • PHARE Adopted IPPC regulation and a directives on integrated prevention and • Environment Protection Agency, Regulation on the Conditions and control of pollution and on the control of Ireland Procedures for Issuance of Permits for risks of large industrial accidents involving Construction and Operation of New and Operation of Existing Enterprises and hazardous chemical substances Facilities where a System for Prevention of Large Disasters Involving Hazardous Substances or Elimination of their Consequences is Introduced Transposition of the Waste Management • PHARE Draft Regulation on the Neutralization of

Project Name Organisation of financing and Completed work partners legislation • Federal Ministry of the PCBs Sub-Project 2 – Management of waste Environment, nature Protection, Conceptual Scheme for Inventorying of containing polychlorinated biphenyls and and Nuclear Safety, Germany PCB Containing Equipment polychlorinated triphenyls Scheme of the National System for Collection, Transport and Treatment of PCB Containing Waste Action Plan for the Management of PCB Containing Waste Organisation Plan for Neutralisation of PCB Containing Waste BG2001EN01D – Training of experts from • PHARE Training of competent authorities, the RIEWs and from the Industrial Sector • Austrian Environment representing industries to implement for the Implementation of the Directive on Protection Agency Directive 96/82/ЕЕС the Control of Large-Scale Accidents Involving Hazardous Substances Project 4 – Training of RIEW and Industry • PHARE Practical knowledge and approaches for Experts for the Implementation of • Federal Ministry of the IPPC implementation Directive 96/61/EU on Integrated Pollution Environment, nature Protection, Prevention and Control and Nuclear Safety, Germany Project BG2000/IB-EN/01с on • PHARE The European legislation has been Transposing of the Bulgarian Legislation in • Federal Ministry of the transposed, and databases for notification the Chemicals Sector, and first steps in its Environment, nature Protection, of chemicals, a registry of chemicals, etc., implementation and Nuclear Safety, Germany have been established

BG2003/1B/2N01 Enforcement of • PHARE Activities in support of the Regulations under the Protection Against • Federal Ministry of the implementation of the harmonised the Harmful Impact of Chemicals Act Environment, nature Protection, legislation on management of chemicals and Nuclear Safety, Germany Development of a National Action Plan for • GEF Updating of the National Chemicals Management of Persistent Organic • UNEP Management Profile Pollutants. Inventory of POPs in Bulgaria Selection of POP treatment technologies Elaboration of an action plan on POPs management

The projects developed thus far have allowed faster updating of Bulgaria’s legislation and its compliance with the EU and international legislation.

However, Bulgaria needs more financial, scientific, and technical aid in the process of practical implementation of the chemicals management regulations.

2.2.4. DESCRIPTION OF EXISTING LEGISLATION AND REGULATIONS ADDRESSING POPS (MANUFACTURED CHEMICALS AND UNINTENTIONALLY PRODUCED POPS)

Regarding environmental protection, the Republic of Bulgaria is party to a number of international agreements which served as the basis to adopt the regulations on management and control of certain hazardous chemical substances and waste, some aspects of which include also the persistent organic pollutants. Policy for sustainable development of the environment, and a general legislative framework; National commitments, arising from participation in international agreements; Laws and regulations concerning management of hazardous waste and polluted sites (existing quantities and waste); Laws and regulations concerning POP pesticides (“intentionally manufactured POPs”); Laws and regulation extending to industrial chemicals – polychlorinated biphenyls, terphenyls, polybromated biphenyls (“intentionally manufactured POPs”); Laws and regulations concerning the sources that generate and release dioxins and furans, and methods/technologies for mitigation and reduction of such emissions (“unintentionally manufactured POPs”);

All laws, including those ratifying conventions, bilateral and multilateral agreements, contracts and other international treaties, are adopted by the National Assembly and the regulations are issued with decrees by the Council of Ministers or by ministers or heads of agencies. Other legal instruments, rules, instructions, methodologies, tariffs, etc., are approved by relevant ministries and agencies. All legal instruments in the Republic of Bulgaria are announced publicly by means of their promulgation in the State Gazette in the Bulgarian language, and promulgation is the legal prerequisite for enactment. International agreements and treaties prevail over the national legislation. Most key laws have been translated into the English language and published on-line, on the pages of the respective ministries and agencies. R Bulgaria has transposed the main requirements of the Stockholm convention in the Law on protection from harmful impact of dangerous substances and preparations, Clean Air Act, Plant Protection Act, Waste Management Act and their sub- legislative acts.

The legal Acts and Regulations, described below are of key importance to the implementation of the provisions of Stockholm Convention in the Bulgarian regulatory framework.

Environment Protection Act, SG, 91/2002, amended SG 98/2002, supplemented SG 86/2003, amended SG 70/2004, effective 1.01.2005. This Act regulates the social relations with regard to protection of the environment and of human health; biodiversity conservation; conservation and use of environmental media; control and management of environmental damage and pollution sources; pollution prevention and control; establishment and operation of the National System for Environmental Monitoring; environmental protection strategies, programmes and plans; the economic organization of environmental protection activities; collection of, and access to, environmental information; the rights and obligations of the state, the municipalities, the legal and natural persons to protect the environment.

The purposes of this act are achieved by means of: regulation of the regimes of conservation and use of environmental media; control over the status and use of environmental media and of the sources of pollution and damage; establishment of permissible emission levels and of environmental quality standards; environmental impact assessment (EIA); issuance of integrated permits for pollution prevention, reduction and control. The special laws on atmospheric air, water, soil, waste, chemicals, stipulate the rights and obligations of the governmental and municipal institutions, the natural and legal persons, and the requirements for preventive and other activities aiming to ensure better environmental quality and to reduce the environmental and human-health risks. The secondary legislation under the laws on air, water, soil, waste, occupational labour, etc. specify the admissible concentrations of chemical substances which are hazardous to human health and the environment, the competent authorities responsible for monitoring. The regulations provide for compensation schemes for pollution or damages caused to the environment and to human health through enforcement of administrative measures such as fines, sanctions and, where necessary, termination of the industrial activity. In the event of existing industries, temporary standards are introduced as well to allow attainment of compliance with the regulations within the legal schedules. Law on Protection against Harmful Impact of Chemical Substances and Preparations (LPHICSP) SG, 10/2000, effective 5.02.2002, amended SG 91/2002, SG 86/2003, amended and supplemented SG 114/2003, effective 31.01.2004. This Act sets out the terms and procedures for marketing, trading, import, export, storage and use of chemicals, the state control over them, and the rights and obligations of legal and natural persons who market, trade, store, use, import or export these substances for the purpose of protection of human health and life and environmental protection. This act extends also to chemicals in free trading areas in the Republic of Bulgaria.

It defines the procedures and manner of categorizing, packaging and labelling of existing and new chemicals for each person releasing chemical substances or preparation on the market; regulates the procedure for notification of new chemical substances, intermediate products and polymers, and for assessment of their risks for human-health and the environment; defines the terms and procedures for marketing of biocides; stipulates the procedures for permitting of import and registration of exports of hazardous chemicals. The act creates the legal grounds for issuance of the following secondary legislation for its implementation: Regulation on the Procedures and the Manner of Classification, Packaging and Labelling of Chemical Substances and Preparations, CM Decree 316/20.12.2002, SG 5/ 2003, effective 01.01.2004, amended and supplemented CM Decree 174/19.07.2004, SG 66/2004, effective 01.01.2005. This regulation defines the procedures and manner of classifying of chemicals; the requirements for packaging and labelling; additional requirements for marketing of hazardous chemicals meant for professional use; the criteria for selection of alternative names of substances which are part of chemical preparations and can be written on the label of the preparation.. Regulation on notification of new chemical substances, CM Decree 137/03.07.2002, SG 67/2002, effective 01.01.2004, last amendment SG 110/17.12.2004 This regulation defines the procedures and the manner of notification of new chemical substances manufactured or imported in the Republic of Bulgaria independently or as part of a preparation or product; the obligations of the notifying person following receipt of the certificate for registration of notified chemical substances; the requirements concerning the content and format of notification documents; the rights and obligations of the competent authority. Each notifying person must notify of all new chemical substances prior to their releasing into the market. Licenses for registration of notified chemical substances are issued by the Ministry of Environment and Water. Regulation on the Final Risk for Men and Environment of New Chemical Substances, CM Decree 131/01.07.2002, SG 67/2000, effective 01.01.2004., last amendment SG 110/17.12.2004. This regulation defines the methodology for final assessment of the human- health and environmental risks from the impact of new chemical substances, referred to as “final risk assessment”. This regulation applies to all new notified chemical substances. The competent authority issuing final risk assessment certificates is the Ministry of Environment and Water. The final risk assessment certificates are issued following expert assessments of human health risks and of environmental risks. The Ministry of Health carry out expert assessment of human-health risks. The Ministry of Environment and Water conducts expert environmental risk assessment. Regulation relating to bans and restrictions on the marketing and use of Dangerous Chemical Substances and Preparations, CM Decree 130/01.07.2002, SG, 69/2002, effective 01.01.2003, amended and supplemented CM Decree 156/07.07.2004, SG 62/2004.The Annex to the regulation introduces hazardous chemicals whose trading and use are prohibited or restricted to protect human health and the environment. Regulation on Import and Export of Dangerous Chemical Substances and Preparations on the territory of the Republic of Bulgaria, CM Decree 129/01.07.2002,, SG, 66/2002, effective 01.01.2004 new CM Decree 161/12.07.2004, SG 63/2004, effective 01.01.2005. This regulation defines the procedures and manner of importing and exporting certain hazardous chemicals in the Republic of Bulgaria. This new import and export Regulation, which will become effective as of January 1, 2005, defines hazardous chemicals that are subject to import permitting; the conditions for registration of the export of hazardous chemicals and for notification of the countries to which export is directed; the content and the format of documents permitting the import and registration of the import of hazardous chemicals; the hazardous chemicals whose import or export to and from Bulgaria is prohibited; the content of the public register of exported and imported hazardous chemicals. This regulation applies to hazardous chemicals that are subject to prohibitions of

strict restrictions for one or more sub-categories of use; or are subject to the preliminary informed consent procedure in international trading in certain hazardous chemical substances and pesticides, consistent with the Rotterdam Convention; or are identified as required for inclusion in the preliminary informed consent procedure consistent with the requirements of the Convention. The competent authority for the implementation of this regulation is the Ministry of Environment and Water. Clean Ambient Air Act (CAA), SG, 45/28.05.1996, effective 29.06.1996, amended SG 49/1996, amended SG 85/1997, amended and supplemented SG 27/2000, SG 102/2001, amended SG 91/2002, SG 112/23.12.12.2003, and effective 1.01.2004. The Act defines the setting of atmospheric air quality parameters and standards; limitation of emissions; the rights and obligations of state and municipal authorities, and the legal and natural persons, concerning the control, management, and maintenance of atmospheric air quality; the liquid fuel quality requirements, and the enforcement of liquid-fuel quality compliance during marketing. Securing atmospheric air quality (AAQ) consistent with the established standards requires introduction of admissible limit values for harmful substances released into the atmosphere from stationary sources – Dioxins and Furans. The Control and limitation of the emissions of harmful substances released into the atmospheric air are regulated with: Regulation 1 Concerning Norms for Admissible Emissionsof Harmful Substances (Pollutants) Emitted in Atmosphere from facilities and activities with Static Emission Sources, promulgated SG 64/05.08.2005, in force from 06.08.2006; Regulation № 6/ 26.03. 1999 Concerning the Order and Manner for Measure Emissions of Harmful Substances, Emitted in Atmospheric Air from Objects with Static Sources, SG 31/06.04.1999, amended and supplemented SG 52/26.07.2000 and SG 93/21.10.2003. This act introduces special requirements for the design, construction, and operation of sites which are sources of emissions. Consistent with the act, the legal and natural persons carrying out activities involving sources of emissions into the atmospheric air must carry out emission monitoring, perform regular inspections and prepare and implement maintenance programmes for the treatment facilities for compliance with the emission limit values set in the permit. Water Act, SG, 67/1999, effective 28.01.2000, amended and supplemented SG 91/25.09.2002, effective 1.01.2003, amended and supplemented SG 84/23.09.2003, amended SG 107/09.12.2003, SG 6/16.04.2004, amended SG 70/2004, effective 1.01.2005. This act aims to ensure uniform and balanced management of water in the public interest, protection of the public health, and sustainable development of Bulgaria by means of: integrated, multiple and efficient use of the water resources; development and conservation of the water resources to satisfy the needs for water of the present and future generations; restoration of water quality and protection of water against pollution, exhaustion, or other impacts on the regime of water; prevention or elimination of the consequences from the harmful impact on water. Water and water bodies are protected against pollution and damage by means of: prohibition for releasing of hazardous substances in quantities that endanger life and human health, and the biological diversity in the water bodies; restrictions for releases of harmful substances; definition of sanitary protection belts around drinking water sources and facilities, and around mineral water sources; construction of waste water treatment plants; establishment of the regime of irrigation and protection of flood plains; regulating of the prohibitions for disposal of waste and hazardous substances in locations where pollution of water may occur. The act creates legal grounds for creation of regulations on particular elements of the overall water management system, by means of: 9 obtaining of permits for quantities of water used from certain sources; 9 obtaining of waste water discharging permits; 9 admissible limit values for various pollutants and other water quality parameters; 9 requirements for the treatment plants and facilities; 9 monitoring system requirements; 71

9 administrative and penal liabilities The following regulations transpose the provisions of the Water Act into the legislation of Bulgaria: Regulation 12/18.06.2002 on the Quality Requirements for Surface Water Intended for Drinking Water and Household Supply, SG 63/28.06.2002. Regulation 6/09.11.2000 on the Limit Values for Admissible Contents of Dangerous and Harmful Substances in Waste Water Discharged in Water Bodies, SG 97/28.11.2000, amended and supplemented SG 24/23.03.2004. Regulation 1/07.07.2000 on the Exploration, Use and Protection of Groundwater, SG 57/14.07.2000, amended SG 64/04.08.2000. Regulation 3/16.10.2000 on the terms and procedures for exploration, design, approval and operation of sanitary protected areas around water sources and installation for drinking and domestic water supply and around the sources of mineral water used for therapeutic, preventive, drinking and hygienic purposes, SG 88/27.10.2000. Regulation 10/27.07.2001 on the Issuing Permits for Waste Water Discharge into Water Bodies and Setting Individual Emission Limits Values for Point Sources of Pollution, SG 66/27.07.2001. Regulation 4 on the quality of waters supporting fish and shellfish organisms' life , SG 88/27.10.2000; Law on Waste Management, SG 86/24.03.2003 amended SG 70/2004, effective 1.01.2005. This act defines the environmentally sound management of waste as a set of rights and obligations, solutions, actions and activities related to the generation and treatment of waste, and the forms of control over these activities. Waste management aims to prevent, reduce or restrict the harmful impact of waste on human health and on the environment. This act creates the legal grounds for creation of regulations on the various aspects of waste management – transport, treatment, disposal, and the requirements for the landfills for various types of waste, the import and export of waste, and the respective permit regimes; categorization of hazardous waste. The act regulates the creation of regulations on the terms and procedures for reduction of pollution from automotive waste; treatment and transporting of used oil and waste petroleum products; treatment and transporting of waste batteries and accumulators. The following regulations introduce its requirements of this act into the national legislation: Regulation 3/1.04.2004 on Waste classification, SG 44/25.04.2004 Regulation on Packaging and Packaging Waste, SG, SG 19/09.03.2004 Regulation No 6 on the procedure for filling out of report and information documents for the waste management activities, SG 78/07.09.2004. Regulation 7 on the Requirements for the Sites for Waste Treatment Facilities, SG 81/17.09.2004 Regulation 8 on the Terms and Requirements for Construction and Operation of Waste Recycling and Disposal Landfills and Other Facilities, SG 83/17.09.2004. Regulation on the treatment and transportation industrial and hazardous waste, CM Decree 53/19.03.1999, SG 29/30.03.1999. Regulation on the Procedures and Manner of Importing, Exporting and Transit of Waste and on the Cases Requiring Bank Guarantees or Insurances, SG 102/26.10.2004. Regulation on the Requirements for Treatment and Transportation of Waste Lubricants and Waste Petrol-chemical Products, CM Decree № 131/13.07.2000, SG 59/21.07.2000 Regulation on the Procedures and Manner of Using of Waste-Water Treatment Sludge in Agriculture, SG 112/23.12.2004. Regulation on the requirements for the order and the manner of inventory, labeling and decontamination of equipment, containing PCBs as well as the treatment and transportation of waste, containing PCBs, adopted by MC Decree No 50/09.03.2006, promulgated in SG 24/21.03.2006.

Law on the Preservation of Agricultural Lands, SG 35/24.04.1996 amended and supplemented SG 28/ 23.03.2001 amended and supplemented SG 112/23.12.2003, effective 01.01.2004. The act establishes the obligation of owners and users of agricultural lands to protect these against erosion, pollution, salinization, acidification, swamping, and other damage. To meet this basic obligation, owners are prohibited from using pesticides, mineral leaf feed fertilizers and micro fertilizers, and biologically active substances which have not received biological and toxicological registration by specialized commissions and councils of the Ministry of Agriculture and Forestry, the Ministry of Health, and the Ministry of Environment and Water. Also, it is prohibited to use organic sludge from production and other water, and of urban waste, on agricultural land without permission by the specialized authorities of the Ministry of Agriculture and Forestry, to irrigate with water containing harmful substances and to use waste above the admissible levels, etc. Law on the Protection of Soil against Pollution, SG 67/27.07.1999, effective 28.01.2000, amended SG 113/28.12.1999. The Law defines the measures for protection of soil from pollution, the rights and obligations of state control authorities and of farmers. The requirements of Law on the Preservation of Agricultural Lands and Law on the Protection of Soil against Pollution are provided for through the following legislation: Regulation 3 on the admissible content of harmful substances in soils, SG 36/08.05.1979, amended and supplemented SG 5/1996, last amended SG 39/16.04.2002. Regulation 26/2.10.1996 on the Reclamation of Damaged Terrains, Improvement of Unproductive Lands, Removal and Utilization of the Humus Layer, SG 89/1996, amended and supplemented SG 30/2002. CM Decree 50/10.03.1993, Agricultural Lands Polluted from Industrial Production Activities, SG G 24/26.03.1993. Law of Health, SG 70/2004, effective since 01.01.2005. This law defines the social relationships related to the protection of the health of citizens and helps in the creation of favourable conditions for complete physical, psychological, and social welfare of the population; sets forth compulsory hygiene standards and requirements, and sanitary rules, on all issues of hygiene, radiation protection and epidemiology. State control is exercised over the production, import, transporting, storage, and use of hazardous chemicals, plant protection chemicals, artificial fertilizers, growth regulators, and preparations for veterinary purposes. Law on Health and Safe Work Conditions, SG 124/23.12.1997, amended SG 114/2003, effective 31.01.2004, amended and supplemented SG 70/2004, effective 01.01.2005. This act defines the rules and obligations of: the state; employers; workers and officials to ensure healthy and safe working conditions. Secondary legislation under the Law of Health and Law on Health and Safe Work Conditions, introducing the requirements for hazardous chemicals and POPs are: Regulation 31/29.12.2003 on the maximum admissible quantities of pesticide residue in food, SG 14/2004, effective 20.02.2004. Regulation 31 on the maximum admissible quantities of pollutants in food, SG 88/08.10.2004 Regulation 13/30.12.2003 on Workers Protection from Risks, Related to Chemical Agents’ Exposure at Work, SG 8/20.01.2003, effective 31.01.2005. Regulation 10/26.09.2003 on the Workers Protection from Risks, Related to the Carcinogenic and Mutagenic Substances Exposure at Work, SG 94/24.10.2003, effective 25.10.2004. Regulation 27/17.08.2005 on the Import of Goods Important for the Public Health, SG 75/1995, amended SG 78/02.09.2003, SG 4/2004, SG 15/2004, effective 31.01.2005 Customs act, SG 15/1998; amended SG. 83/1999 amended and supplemented SG. 63/2000, SG 110/2001, suppl. SG 76/2002, amended and supplemented SG 37/2003, suppl. SG 95/2003, suppl. SG 38/2004. This Act determines the organisation of customs administrative structures and the activity of Customs Administration - customs supervision and control of the import, export and

transit of goods in, out and through the territory of Bulgaria. Bulgarian Customs Act is based on the EU Customs Code.

Law on Fodders, SG 82/1999; amended and supplemented SG 101/2000; SG 58/2003; SG 69/23.08.2005; SG 87/01.11.2005, effective 01.01.2006.The Law stipulates the conditions for production, marketing on the territory of the country, import, export and use of products and substances, intended for animal food. It also defines the rights of state authorities to regulate and control the a.m. activities. Regulation 24 for maximum admissible concentration of unacceptable substances and products in fodders, SG 56/20.06.2003. Law on foods, SG 90/1999, amended and supplemented SG 102/2003; amended SG 70/2004; amended and supplemented SG 87/01.11.2005, effective 01.05.2006.The Law stipulates: the requirements to foods and their public safity; packing, labeling and presentation; the terms & conditions for the production and marketing with foods; the rights and responsibilities of persons producing or marketing with foods; the rights of state authorities to regulate and control of production & and marketing with foods. Regulation 6 for the control measures on residues of veterinary medicinal products and environmental pollutants in life animals and foodstuffs of animal origin, SG 32/29.03.2002. Regulation 31 on the maximum admissible quantities of pesticide residue in food, SG 14/2004, effective 20.02.2004; Regulation 31 on the maximum admissible quantities of pollutants in food, SG 88/08.10.2004; Regulation 25 on the establishment of maximum residue limits of veterinary medicinal products in foodstufs of animal origin, intended for human consumption, SG 94/4.10.2002 .

2.2.5. KEY APPROACHES AND PROCEDURES FOR POPS CHEMICAL AND PESTICIDES MANAGEMENT, INCLUDING ENFORCEMENT AND MONITORING REQUIREMENTS According to Article 3 of Stockholm convention “Measures to reduce or eliminate releases from intentional production and use” each Party shall prohibit and/or take the legal and administrative measures necessary to eliminate the production and use, the import and export of the chemicals listed in Annex A – POPs pesticides and PCBs, and restrict the production and use DDT listed in Annex B.

The existing key approaches and administrative procedures for chemicals management with relevance to POPs are classification, registration, permits, sanctions and control of chemicals and pesticides, as well as risk assessment and the special area of the prevention of major accidents(Table 22 and Table 23).

Table 22 Administrative Procedures for Control and Management of POPs Pesticides (Annex A and Annex B of Stockholm Convention)

Administrative procedure Import Manufacturing Storage Transport Distribution Use Disposal

Categorization, packaging and labelling X X X X X X X

Registration of active substances and products X X X X X

Permits X X X X

Control X X X X X X X

Sanctions X X X X X X X

Information for workers/the public X X X X

(X – Adequately regulated in the legislation)

Table 23 Administrative Procedures for Control and Management of Industrial Chemicals – PCBs and HCB (Annex A and Annex B of Stockholm Convention)

Administrative procedure Import Manufacturing Storage Transport Distribution Use Disposal

Categorization, packaging and labelling X X X X X X X

Notification of new chemical substances X X

Permits X X X X X

Control X X X X X X X

Sanctions X X X X X X X

Information for workers/the public X X X X X

(X – Adequately regulated in the legislation)

Management of chemicals in Bulgaria conforms to the adopted and effective regulations, mechanisms and procedures. Their implementation guarantees prevention to the maximum extent of the impacts from storage, use and transporting (including import and export) of chemicals and preparations on human health and on the environment. Rules for safe use, packaging, labelling, storage, and transport of chemicals and preparations are introduced for the purpose. The above measures ensure environmentally sound use of these substances in the occupational and in the natural environment. Bulgarian legislation for Chemicals Management with relevance to POPs includes: Law on Protection against Harmful Impact of Chemical Substances and Preparations (LPHICSP), SG 10/2000, amended and supplemented SG 114/2003. Regulation on the Procedures and the Manner of Classification, Packaging and Labelling of Chemical Substances and Preparations, SG 66/2004. Regulation on notification of new chemical substances, CM Decree 137/03.07.2002, SG 67/2002, effective 01.01.2004, last amendment SG 110/17.12.2004. Regulation on the Final Risk for Men and Environment of New Chemical Substances, SG 110/17.12.2004. Regulation relating to bans and restrictions on the marketing and use of Dangerous Chemical Substances and Preparations, SG 62/2004.

In an Appendix hereto article 1 (2) of the regulation, the trade and use of polychlorinated byphenils (PCBs) and preparations, including waste oils with content of PCBs more than 0,005% are prohibited. Their use is allowed till the end of 2005 for electrical equipment in close systems – transformers and capacitor. A list of dangerous chemical substances, preparations, and products subject to prohibition or restriction, as well as prohibitions of and restrictions on therein or thereof shall be specified in an Appendix hereto.

Regulation on the requirements for the order and the manner of inventory, labeling and decontamination of equipment, containing PCBs as well as the treatment and transportation of waste, containing PCBs, adopted by MC Decree No 50/09.03.2006, promulgated in SG 24/21.03.2006. The regulation hereto determines: - the order and manner for carrying out inventory and labeling of equipment, containing PCBs; and - the the order and manner decontamination of equipment, containing PCB with the aim of prevention PCBs negative impacts on human health and the environment.

Regulation on Import and Export of Dangerous Chemical Substances and Preparations on the territory of the Republic of Bulgaria, SG 63/2004.

This regulation introduces bans and restrictions for all POPs, listed in Rotterdam and Stockholm conventions,Annex 1 hereto article 3 (1) para 3 and Annex 2 hereto article 2, para 4 (tables 24 and 25). Table 24 List of hazardous chemicals and preparations banned or severely restricted to certain uses determined to be included in the Prior Informed Consent Procedure (PIC) under Rotterdan convention Annex 1 hereto Article 3( 1) para 3

Name of Chemical or Preparation Category of Use Level of Restriction Dicofol, containing less than 78% p,p`-dicophol or Р(1) B more than 1g/kg DDT or DDT related compounds

Legend: Category of Use P(1) – Plant protection product Level of Restriction: B - Banned The regulation hereto determines also the dangerous chemicals and preparations, being POPs which are banned for import and export in and out of the territory of R Bulgaria,as per Appendix 2.

Table25 List of hazardous chemicals and preparations being POPs and are banned for import and export in and out of the territory of R Bulgaria Annex 2hereto Article 2, para 4

Name of Chemical or Preparation CAS № Tariff № 1 Aldrin 309-00-2 2903 59 90 0 2 Chlordane 57-74-9 2903 59 90 0 3 Dieldrin 60-57-1 2910 90 00 0 4 DDT [1,1,1-trichloro-2,2- bis(р-chlorophenyl)ethane] 50-29-3 2903 62 00 0 5 Endrin 72-20-8 2910 90 00 0 6 Heptachlor 76-44-8 2903 59 90 0 7 Hexachlorobenzene 118-74-1 2903 62 00 0 8 Mirex 2385-85-5 2903 59 90 0 9 Toxaphene (Camphechlor ) 8001-35-2 3808 10 20 0 10 Polychlorinated biphenyls (pcb), except mono- and dichlorinated 1336-36-3 etc. 2903 69 90 0 biphenyls The use, trade, import and export of certain chemicals and preparations, classified as dangerous are severely restricted or banned due to their effects on health and the environment. The following legislative acts introduce a ban for use in the production, import and use of POPs pesticides in plant protection preparations and biocides: Order RD12-28/21.05.2004 of MoAF; RD 09-457/13.07.2004 of MoH; RD 590/15.06.2004 of the MoEW, issued pursuant to Article 15 of the Plant Protection Act concerning the protection of plants and approving of a List of active substances prohibited for use in the Manufacturing of Plant Protection Chemicals. (The POPs pesticides - Aldrin, Dieldrin, DDT,Endrin, Heptachlor, Toxaphene); List of permitted for use in Republic of Bulgaria preparations for disinfection, disinfection and deratization, published annually by MoH List of permitted for marketing and use of plant protection preparations, registered fertilizers and soil improvement chemicals, published annually by MoAF Regulation 44 on the terms and procedures for marketing of biocide preparations, SG

POPs Waste: Consistent with the Basel Convention, nine POPs – DDT, hexachlorbenzene, aldrin, chlordane, dieldrin, endrin, heptachlor, and mirex – have been classified as hazardous waste, and the Stockholm Convention requires that Bulgaria should take measures to restrict the environmental-quality impacts of POP pesticides in storage. Administrative Procedures for POPs Waste Control and Management include classification, registration, permits, licenses and inspection. Data about hazardous waste is collected in Bulgaria only within the system of the MoEW (by the EEPA) by means of information cards documenting the name, quantity, properties, movement, storage and disposal of waste by enterprises whose activity involves hazardous waste generation and/or treatment. Table 26 Administrative Procedures for POPs Waste Control and Management

Collect Temporary Trading/ Administrative procedure Import Transport Recovery Disposal ion storage Use

Classification X X X X X X X

Registration X X X X

Permits X X X X X X License for trading in non- ferrous and ferrous metal X X waste Inspection X X X X X X X Information for workers/the X X X public (X – Adequately regulated in the legislation)

Data gathering conforms to the European Catalogue of Waste and to the current Bulgarian legislation. The national classification of waste conforms to the European classification and the data are comparable. Law on waste management, SG 86/24.09.2003,amend SG 70/10.08.2004,effective 01.01.2005 Regulation 3/01.04.2004 on waste classification, SG 44/25.04.2004. Regulation 6 on the conditions and requirements for construction and operation of waste incinerators and co-incinerators, SG .78/07.09.2004. Regulation 7 on the requirements for the sites for waste treatment facilities, SG 81/17.09.2004 Regulation 8 on the terms and requirements for construction and operation of waste recycling and disposal landfills and other facilities, SG 83/24.09.2004. Regulation on the treatment and transportation industrial and hazardous waste, CM Decree 53/19.03.1999, SG 29/30.03.1999. Regulation on the procedures and manner of import, export and transit of waste and on the cases requiring bank guarantees or insurances, SG 102/26.10.2004. According Article 5 of Stockholm convention “Measures to reduce or eliminate releases from unintentional production” each party shall at a minimum take measures to reduce the total releases derived from anthropogenic sources of each of the chemicals listed in Annex C, with the goal of their continuing minimization and, where feasible, ultimate elimination. Annex С applies to the following persistent organic pollutants: Polychlorinated dibenzo-p-dioxins and dibenzofurans (PCDD/PCDF); Hexachlorobenzene (HCB) and Polychlorinated biphenyls (PCB), when formed and released unintentionally from anthropogenic sources.

The preventive activities aimed to reduce the environmental and human-health risks and to bring compliance with the regulations are stipulated in the Environment Protection Act, and in the regulations on the introduction of EIA procedures and on the issuing of integrated permits for construction and operating of existing plants and facilities of certain categories of industrial activity, and also, in the regulation on protection in the case of emergencies involving dangerous chemical substances: Regulation on the conditions, procedures and methods for environmental assessment of plans and programmes, CM Decree 139/24.06.2004, SG 57/2004, effective 1.07.2004. Regulation on adopting Regulation on carrying out of Environmental Impact Assessments of Investment Proposals for construction, operation and technologies, CM Decree 59/07.03.2003, SG 25/18.03.2003; Regulation № 2 for Protection from accidents in activities with dangerous chemicals, SG 100/1990. Bulgarian legislation for Major Accident Prevention and Control, involving dangerous substances, transposing Council Directive 96/82/EEC Seveso on the Control of major accident hazards includes:

The Environmental Protection Act (Chapter Seven, Section I “Prevention of Major Industrial Accidents”); Regulation on the conditions and procedure for issuing of permits for construction and operation of new Enterprises and Facilities and for operation of existing Enterprises and Facilities implementing a system for the prevention of major accidents involving dangerous substances or the limitation of their consequences, SG 38/23.04.2003.

According Article 103 of the Environmental Protection Act (EPA), At enterprises and facilities where specific dangerous chemical substances and preparations are present in quantities equal to, or in excess of, the quantities listed in Tables 1 of Annex 3 hereto, there shall be introduced a system for prevention of major accidents involving dangerous substances or for limitation of the consequences of such accidents for the environment and for human health. Table 27 indicates the permissible quantity Dioxins (PCDDs) and Furans (PCDFs), recalculated in TCDD equivalent. Table 27 Annex № 3 hereto Article 103 of EPA, ( Table 1under EPA) Dangerous substances Permissible Quantity (tones) Polychlordibensofurans and polychlordibensodioxins 0,001 (incl. TCDD), recalculated in TCDD equivalent Remark: The quantities of ploychlordibenzofurans and polychlordibenzodioxins (PCDFs, PCDDs) are calculated by multiplying the limit quantity in Table 1 by International Toxic Equivalent Rates for Representatives of One Group”.

Building and operation of new and operation of existing enterprises and installations referred to in Article 103 herein shall be admitted after issuance of a permit , Article 104(1) of EPA.

The regulation stated above determines the conditions and procedure for the issuing of a permit as per Art. 104 of the Environmental Protection Act (EPA), and the duties of the operator of the enterprise or facility where a system for the prevention of major accidents involving dangerous substances or for the limitation of their consequences for man’s life and health and the environment has been introduced. The regulation enters into force from: 2004 for New Establishments 2006 for Existing Establishments

The operator of an enterprise or facility where dangerous chemical substances are present in quantities equal to or in excess of the quantities listed in Annex 3 to the Art.103 of EPA shall be obliged to classify the the enterprise or facility as a “Lower Tier” or a “Upper Tier”. The operator submits to the Minister of Environment and Water an application for the issuing of a permit. The operator of an enterprise or facility classified as a “Lower Tier” shall attach to the application the following: an assessment of the major accident risk in accordance; a report on the major accident prevention policy.

The operator of an enterprise or facility classified as a “Upper Tier” shall attach to the application the following: an assessment of the major accident risk ; a safety report in accordance ; an internal emergency plan ; the necessary information for the preparation of an external emergency plan.

The operator of an enterprise or facility , classified as “Upper tier” is obliged in case of accident to submit information about the Planned safety measures. Safety Management System must deal with: 1. Organisation and personnel 2. Identification and evaluation of major hazards 3. Planned Modifications 4. Safe management of technological processes 5. Planning for emergencies 6. Monitoring performance 7. Audit and review

Bulgarian legislation for Integrated Pollution Prevention and Control (IPPC), transposing Directive 96/61EC on integrated pollution prevention and control (IPPC) includes:

The Environmental Protection Act (Chapter Seven, Section II “Integrated Permits”); Regulation on the Conditions and Procedures for Issuing of Integrated Permits for Construction and Operation of New and Existing Industrial Plants and Facilities, CM Decree 62/12.03.2003, SG 26/2003, amended SG 29/2003. According Article 121 of EPA the major goals of Integrated Pollution Prevention and control (IPPC) are: 1. The implementation of all appropriate preventive measures against pollution, in particular through application of the best available techniques (BAT); 2. The implementation of environmental management systems (EMS); 3. The prevention of environmental pollution according to the emission limit values and the environmental quality standards; 4. The avoidance of waste generation; where waste is produced, it shall be recovered; where such recovery is technically and economically impossible, the waste shall be disposed of while avoiding or reducing any impact thereof on the environment; 5. The efficient use of energy; 6. The implementation of all possible measures to prevent industrial accidents and limit the consequences thereof; 7. The undertaking of necessary measures to avoid any possible pollution risks and to return the site of operation to a satisfactory state upon definitive cessation of activities. Various national programs and action plans determine priority activities and other activities aimed to reduce the risks or the harmful impact of the hazardous chemicals and preparations. Such documents are the National Programme for Ozone Depleting Substances aimed at reducing the 79

harmful emissions of sulphuric and nitric oxides, the national programmes for construction of waste landfills and waste water treatment plants, the National Programme for Production of Unleaded Petrol, the National Environmental and Health Action Plan, etc. The highest number of non-regulatory mechanisms is created in relation to the production of chemical substances. Every manufacturer of certain chemicals or preparations operates under a technology regulation. Different manufacturing processes create and adhere to different technological regulations. Other non-regulatory mechanisms related to production are the technological operating instructions for compliance with the labour safety and fire safety regulations. Other mechanisms are the Bulgarian State Standards (BSS) and the international standards (particularly ISO), establishing quality parameters or admissible concentration of admixtures in manufactured chemicals. Product quality systems (ISO 9000), environmental management systems (ISO 14000), product control and certification systems (ISO 45000 and, presently, 17025), and safe working conditions systems (ISО 18000) are being introduced. Regarding EIA and issuance of integrated permits, the companies elaborate programmes for compliance with EU regulations determining also the deadlines for such compliance. Some companies have already implemented such programmes successfully, others continue the implementation. National Voluntary Schemes include: National Ecolabeling Scheme National Ecoenvironment Management and Auditing Scheme The voluntary initiatives Responsible Care and Stewardship Products, introduced by the Bulgarian Chamber of Chemical Industry in some manufacturing companies, also contribute for the reduction of environmental pollution with chemical substances, the reduction of risks from emergencies and the creation of safer working conditions. The Stewardship Products initiative marked the beginning of voluntary manufacturer responsibility during the entire life cycle of chemicals and preparations.

2.3. ASSESSMENT OF THE POPS ISSUE IN THE COUNTRY INTRODUCTION Persistent organic pollutants (POPs) are toxic chemicals that are persistent, bioaccumulate in organisms and food chains, prone to long-range transboundary atmospheric transport and deposition by air, water and, via migrating biological species and likely to cause significant adverse human health or environmental effects near to and distant from their sources.

The group of 12 persistent organic pollutants listed in the Stockholm Convention includes the following: Pesticides Aldrin, Chlordane, , Dieldrin, Endrin, Heptachlor, Mirex, Toxaphene, Hexachlorobenzene (HCB) and Dichlorodiphenyltrichloroethane (DDT) Industrial Chemicals Polychlorinated Biphenyls (PCBs) Unintentionally formed By-Products Polychlorinated Biphenyls (PCBs) , Hexachlorobenzene (HCB) Polychlorinated dibenzo-p-dioxins (dioxins) and Polychlorinated dibenzo-p-furans (furans)

NATURAL RESOURCES Water Resources The water resources represent the utilized part of natural waters. They are formed mainly from precipitation and exist as ground and underground waters. In 2003 the average precipitation quantity over 40 meteorological stations is 596 l/m2 and represents 94,2% of the norm. The outflow from the internal rivers (based on the data from hydrometric stations covering 67.3% of the territory of the country) amounts to 15 174 Mm3 and is about 104,65% of the norm. The available volume of the 53 monitored reservoir dams in this country is 4 578.69 Mm3, their utilizable volume is 3 695.12 Mm3, which shows that the available utilizable volume is 65.1% of their total useful volume. The distribution of the total river outflow by Basin Management Regions (Danubian, Black Sea, Eastern-Aegian and Western-Aegian) during the year repeats the trends from the previous years, the major contribution being of the rivers from the Eastern-Aegian Region - 46.8%.

Surface Waters Water is an important life natural resource for people as well as for social and economic development of the country and at the simultaneously it is a component of te environment and habitat of water eco-systems. Water quality is the most significant indicator for human activity impact on the natural waters. Industry, agriculture, population, transport, etc., generate substantial quantities of different pollutants, major part of which are constantly discharged into surface waters. Part of the pollutants, mainly those of organic origin, decompose to a certain extent under the influence of natural self- purification processes, but the growing load decreases the efficiency of such processes. Some substances are not at all decomposed in the course of the natural processes, which necessitates human interference for their removal or elimination to environmentally admissible values. Water pollution is harmful not only for the water organisms and eco-systems, but it has as well impact on the people using such waters one way or another. The assessment of chemical concentrations allows a direct Environmental and Human Health inpact assessment. Compared to the previous years, negligible improvement with some % of the basic indicators Dissolved oxygen and Biological oxygen need (BON5), while the other indicators do not change for the values, corresponding to I category surface waters. The water quality It is observed trends for reduction of the concentration measured for II & III category. For 2003, the indicators, corresponding to I category with quality “very good” are over 80%, excluding NH3 –N , for which the value is very low - display permanent to values, 0.1 mg/l.During the year the trend is to negligible improvement of basic indicators.

Ground water The monitoring data assessment indicates good condition of groundwater on the whole territory of the country. Pollution threshold’s (PT) exceedings are most considerable for nitrates , but for the past few years a tendency of slight decrease of nitrate concentrations is observed. Elswhere the source of PT exceedings of nitrates in ground water is a result of agricultural activities (including stock-breeding farms), which does not comply with the Good Agriculture Practice (GAP) and in rare cases might be due to the lack of sewerage in some settlements. In isolated water-catchment regions exceedings of PT were found for the indicators – total iron and manganese, which is mainly related to the characteristics of the water receptacle’s rocksq as well as to oxidation/reduction potential of water media.

Coastal sea water

Bulgaria is a party of the Convention on the protection of the Black Sea against pollution. The Black sea is unique concerning its location and water quality exchanging its water only with the Marmara sea through the Bosphorous. From the other hand a big rivers as the Danube, the Dnestar and the Dnepar rivers mouth into the Black sea. The coastal seawater is devided in zones of use and sanitary belts around them. Different levels are stipulated for admiisible pollution values. One of the main pollution source of the Bulgarian part of the Black sea is the water discharge from coastal rivers and lakes. Another source of pollution are the coastal towns and resorts with outlet direct into the sea. Despite sporadic single exceedins of the admissible pollution values for some indicators, a tendency towards improvement and stabilizitation of the coastal seawater quality has been witnessed. Within the zones of use, water quality complies with the legislative requirements. Exceedings of ammonia nitrogen norms were recorded at the point of outflow of the Kamchiya river, due to hydrodynamic processes occuring when sea and river water are mixed and outflow of impurified and incufficiently purified wastewater. The seawater quality in the sanitary zones does not always comply with current applicable standards. The maximum values of bigenic elements ammonium nitrogen and phosphates were recorded at the point of Balchik and that of the Kamchiya river mouth. The increased concentrations were as a result of established sea streams, accomplishing the pollutants transfer from the flowing into the Black sea rivers – the Danube, the Dnestar and the Dnepar rivers. Lands and soils Soil is one of the basic elements of eco-system andan irreplaceable component of the environment. It is characterized by multifunctional ability, providing environmental equilibrium within the eco- system. As an environmental component and resource it is physically limited. According to the data of Agency on Cadastre, as of 31.12.2000 г. the total area of R Bulgaria is 11 100 190.2 ha, distributed into 6 categories (Table 28). Table 28. Balance by land categories according to their intended use 2000. Source: Agency on Cadastre*

Type of territories according their intended use Area,ha % of total area Arable land 6 376 481.7 57.44 Woodland 3 715 753.8 33.47 Population centres and other urban areas 460 341.6 4.15 Rivers and water bodies areas 201 038.5 1.81 Mining areas 271 086.7 2.44 Transport and infrastructure areas 75 487.9 0.68

* The results are obtained under the "Common European Project Corine - Land Cover 2000”, financed by European Environmental Agency and MoEW – Bulgaria.

According to the above balance, the arable land occupies the largest share- about 57%, out of which about 78% is cultivated, incl. about 15% irrigated land . The land cover is identified through reading out of satellite pictures and mapping of land cover classes under unified method in 3 levels by 44 classes . The Land Cover is presented by 36 out of

totally 44 classes in 52252 points (polygons) according Corine Land Cover (CLC)1. More than half of the country territory is included in 2 classes: Non-irrigated cultivated land – 3 909 744 ha (35,15%); Deciduous Woodland – 2 340 436 ha (21,04%).

The classes distribution (Level I) of Land Cover by area is as follows: Arable land – 5 734 854 ha (51,56%); Woodland – 4 721 246 ha (42,45%); Anthropogenic objects – 545 488 ha (4,90%); Water bodies - 109 761 ha (0,99%); Wet areas - 11 621 ha (0,10%).

The soil pollution could be from local (point) source or difussive. The soil contamination from local sources is a result of industrial activities and waste management, identified mainly as wates landfills, spillages and industrial accidents and fertilizer and pesticides storage sites. In diffusion pollution the agriculture practice is the main factor. The diffusion and local point source soil pollution results in damages of surface and underground water. The presence of pollutants, exceeding limit values may lead to negative consequences to all food chain and pose risk to human health , all type of eco-systems and other natural resources. The local (point) soil pollution is not well investigated and registered in the country. National register for local soil pollution and their sources is in the process of establishing, which shall provide efficient monitoring and control over the pollution sources as well as over the management of pollutited sites. Impact of Economic sectors on Environment Industry In 2003 the industrial production and sales showed a considerable growth versus 2002, respectively 15.1% and 17.1%. To a great extend the good development of industrial sector is due to the marked increase of industrial sales for export. Industry is a branch effecting all environmental components - air, water, soils. The environmental pollution is connected with harmful releases emitted into air and water, past local soil contamination and unsolved problems with wastes generated. Currently in Bulgaria the emissions are monitored of more than 120 basic manufacturing processes including burning processes in industry, electric power generation, fossil fuel mining and processing and solvent consumption. Following the considerable decrease in harmful substance emissions after 1988, mostly due to the reduced share of industry in the branches structure of national economy, emissions levels of the main pollutants remain relatively constant. In spite of the measures undertaken in a number of atmospheric air quality evaluation and control regions, problems exist with high levels of air contamination. There are still industrial enterprises having negative effect on atmospheric air quality. Local soil contamination is mainly identified as waste depots, leakages and industrial accidents representing a considerable risk for soils and ground waters. Electric power sector Bulgaria is facing a number of serious challenges in power engineering caused by objective reasons and circumstances and also by the delay of reforms in the years of transition.

1 The results are obtained within the frame of the European project “Corine Land Cover 2000”, funded by EEA and MoEW.

The country is highly energetically dependent, because more than 70% of its primary electric power resources have beem imported. The only significant local power resource is low quality brown coal with high sulfur content. It relies mainly on imported Russian fuel-oil, natural gas, quality coal and nuclear fuel. This energy balance structure causes uneasiness in terms of electric power supply security. In 2003 the highest relative share in the electric power generation in the country holds the thermal electric power stations (TEPSs – 51.64%), followed by Nuclear electric power station (NEPS- 40.61%) and Water electric power stations (WEPSs- 7.75%). The total national electric power generation in 2003 has decreased compared to 2002. In Bulgaria the relative electric power consumption (consumption/gross domestic product) by economy is decreasing within the period 1998-2003, which is a favorable tendency for the country’s development but the indexes are still too high compared to the average consumption by the Western European countries. Electric and thermal electric power generation is the largest harmful substance emission source in Bulgaria. On national scale the power engineering sector, especially TEPSs with local lignite coal, is the main sulfur dioxide, carbon dioxide, dioxins and furans emission source and a relatively large one of nitrogen oxides. The use of non-restorable power resources (coal, oil, etc.) for energy generation is a main source of greenhouse gas emissions. A smaller but not less significant source of harmful substances, related to power engineering development, is the fuel use in households for heating purposes. It has a significant impact on the atmospheric air quality due to the fact that mainly coal, compressed slack and wood are used in burning installations (different types of stoves) with low efficiency. Scattering of atmospheric pollutants emitted from households is down to a minimum and in the specific winter conditions long accumulation periods occur leading to higher ground concentrations. Another fact which is observed in the recent years is the large drop of central heating (TEPS) users and transition to local heating which might increase even more the atmospheric pollutants in the lowermost layer. The relative energy consumption of Bulgarian economy and the related environmental load decreases, but the energy sector impacts on climate change will certainly continue, if energy efficiency improvement is not performed and prevailable use of non-restorable power resource.

The negative consequences of energy resource production and thermal and electric power generation on the environment require measures for their reduction. The Ministry of Power Engineering and Energy Resources (MPEER) pays special attention to emissions form burning organic fuel - coal, black oil and natural gas because of their possible effect on the climate. It is a priority to adequately employ the potential for energy efficiency enhancement and the use of restorable power resources - two of the few feasible environment preservation measures, which under the conditions of market economy prove to be paying-off. With respect to the governmental policy for energy efficiency improvement in 2003 an Energy Efficiency Act has been adopted. The Act aims to stimulate the energy efficiency through a system of measures and activities at national, branch, regional and municipal levels as a basic component of market economy. It has been developed a National programme for energy savings and three yearly Action plan, including measures to decrease energy consumption in all economic sectors. For funding work on enhancement and encouragement of the use of RPR an Energy efficiency fund has been established. The fund will have as an objective the managing of funds, allocated for energy efficiency development investment projects in compliance with the priorities in the year’s energy efficiency programs, adopted by the Council of Ministers. The state policy on energy efficiency enhancement and use of RPR has been carried out on the basis of national long- and short-term programs adopted by the Council of Ministers. The national long- term programs represent a common conception of energy efficiency development and the use of RPR marking the long-term goals and means to achieve those goals, and they are developed by the

Energy Efficiency Agency. The short-term programs are worked out by the Agency on the basis of the national long-term program and programs elaborated at departmental and municipal level. The topic of the day in power engineering is the execution of Directive 2001/80/EC about limitation of emissions of certain atmospheric air pollutants from large burning installations (LBI). With a Council of Ministers Decision a Program for Application of the Requirements of Directive 2001/80/EC has been adopted for emissions limitation of certain ambient air pollutants released from Large Combustion Installations (LCI), under which all LCI, should be in conformity with the Directive until January 1, 2008. By the fulfillment of the EU requirements, through reduction of the harmful sulfur and nitrogen oxide and dust emissions, the atmospheric air quality around LCI and the quality of life of the population shall be improved. Transport After the mid 90s in Bulgaria there is a permanent tendency towards raise of the transport share in the Gross Added Value of economy. Almost 100% from local goods transport is done by land transport with strong prevailing share of motor (88%) compared to railway transport (12%). A growth in public transport (buses and trains) has been recorded. The increased demand in transport services resulted in expansion of coach and automobile park of the country, retaining the negative age ratio. Transport sector pose serious impact on all environmental media. From ecological point of view land transport is the most considerable , which development trends are similar to those in the European Union: motor transport records a serious growth while its main competitor - the railway transport - continues to go down. The increase in the motor-car traffic inevitably leads to ecological and health problems, in particular to climate changes, acidification, increase in the ground ozone level, local atmospheric pollution, noise,etc. The motor-car park in Bulgaria has extremely unfavourable age structure, which affects negatively on environment protection. A large part of the motor-car flow goes through populated areas and because of this it is a decisive factor for the atmospheric air quality in such areas. In the most cases areas with deteriorated atmospheric air quality are large settlements with intensive transport - Sofia, Bourgas, Plovdiv, Varna, Pernik, etc. Nevertheless that air pollution caused by transport is on the decrease due to a combination of technical improvements and legislative measures, theecological advance is however not enough to slow down the effect of the fast growth of the share of transport in the gas emissions (CO, NOx SO2, Dioxins and Furans, etc.) causing greenhouse effect, raise in the ground ozone level, the noise and fragmentation of the environment by the transport infrastructure. Harmful substance emissions from other transport (railway, inland water transport, marine navigation, air transport, etc.) remain unchanged as compared to previous years. The railway transport is the most environmentally harmless, being an effective manner for large share emissions elimination and minimizing the use of natural resources. The development of effective and environmentally conformed transport systems and technologies is a priority for the transport sector, with a view to effectiveness and quality improvement in the passenger and goods transport, reduction of energy consumption of transportation and health and environmental protection from the harmful impact of transport. To reduce the specific fuel consumption and greenhouse gas emissions from transport, measures are required, such as flexible financial policy for transport fleet renovation and technical state improvement of the means of transportation, as well as the creation of a specialized body for energy effectiveness by the Ministry of Transport and Communications.

Agriculture The agricultural sector includes rural economy, forestry, preserve and fish industry. In spite of the increase of the physical volume of the Gross Added Value created by the agricultural sector in 2003, its share in the structure of the GAV in the economy as a whole preserves the tendency towards decrease. The agricultural land is formed by cultivated arable land, farmed durable plantation, permanent lawns, and agricultural lands, uncultivated more than 3 years.The agricultural lands in 2003 is 5782 461 ha or 52.1% of the country’s territory. In 2002 the agricultural land was 5 796 208 ha. Its relative share remains unchanged during the two years. The utilized agricultural land is formed by cultivated arable land, durable plantation, permanent lawns, family gardens and green house areas. . The cultivated arable lands are those, included in the succession of crops ,occupied with annual plants and temporary lawns and the uncultivated lands. The utilized agricultural land in 2003 are 5 326 Kha or 48% of the country’s territory. With the highest share in UAL is the North-West Economic region with 23.6% (1 259 Kha), fo;;owed by South-Central region – 21% and North-Central region – 19.2%. In 2002 the utilized agricultural land was 5 324 Kha – 48,0%. In general for the country no considerable change in the relative UAL share versus total country territory was observed . Arable land in Bulgaria in 2003 was 3 239 Kha and represented 60.8% of the utilized agricultural land. In 2002 was the arable land 3 277 Kha and represented 61.5% of the utilized agricultural land. Negligible decrease of arable land is observed compared to the previous year. Uncultivated land is land not included in the succession of crops and not used for agricultural production for more than two years. Its reclaiming is still possible with minimum funds. The uncultivated lands in 2003 are 455 798 ha or 14,1% of arable land, while in 2002 they were 471 507 ha. A sight decrease of uncultivated lands in 2003 is observed compared with 2002. Fallow land is cultivated land which is not cropped in the year of record. Cultivated or not, these lands remain in this category for no more than two years. In 2003 fallow land is observed upon 273 911 ha or 5.1% of the UAL (utilized agricultural land). In Bulgaria the state of soil resources is monitored by the Executive Agency of Soil Resources (EASR) by carrying out of large-scale soil studies and expertise based on which digital soil surface map is compiled. Usage of fertilizers and plant protection products is a prerequisite for steady high yields but on the other hand they are a main water and soil contamination source. After 1989 a considerable reduction in the amounts of mineral fertilizers used is reported. The gradual increase of nitrogen fertilizers used which are a main soil acidification factor is a fact in the last 5 years. Unbalanced nitrogen fertilization has still unrealized harmful consequences with respect to soil quality, only due to the fact that the total amount of nitrogen fertilizers used is small. Unbalanced fertilization with considerable predomination of nitrogen and with all resulting negative consequences is becoming practice in Bulgaria. In the last years the usage of plant protection products was stabilized but it is still in levels considerably lower than in 1989. The reason for the little increase in the usage is, on one hand, financial (for a major part of the owners prices are a determining factor for the use of fertilizers and plant protection products), and on the other hand - the small land farming. The right choice and usage (dosage, active substances, quarantine schedules observation, etc.) suggests that farmers possess high agrochemical culture and knowledge which is acquired in long years of practice and/or training. Soil contamination is considerably limited. The low fertilizer and plant protection products usage limits the harmful substances distribution but on the other hand unbalanced fertilization is a precondition for soil acidification. The improved quality of water used for irrigation and the limited irrigated land areas in the recent years considerably reduce the transition of contaminants to the soil. 86

In the interval 1997-2002, about 33 pesticides have been studied at part of the monitoring stations of the monitoring network. In the last two years slight exceeding has been reported of the ecological limit value - 0.01 mg/l of triasine pesticides which supports the fact that herbicides are used the in largest quantities in the country. Values recorded everywhere are below the contamination limit values. Heavy-metal contaminated soils constitute an insignificant part of the total arable land area. Nevertheless the Ministry of Agriculture and Forestry has developed a recommendable regime system to limit the cultivation of heavy-metal contaminated soils, according to the contamination level and the potential health risk from the usage of the plant products. Projects for contamination reduction and elimination have been developed, as well as a sustainable control of those lands and their utilization. Agriculture is currently a main methane and ammonia source of air pollution.In 2003 an increase in methane and ammonia emissions is reported as a result of the increased number of the animals - sheep, goat and cattle breeding.

The availability of regulations harmonized with the European legislation and a certifying body are a prerequisite for the development of biological agriculture aiming at environmental preservation.

2.3.1 ASSESSMENT WITH RESPECT TO ANNEX A, PART І CHEMICALS & ANNEX B (POPS PESTICIDES) OF STOCKHOLM CONVENTION The group of persistent organic pollutants that are subject to the Stockholm Convention includes the following pesticides: aldrin, dieldrin, endrin, mirex, toxaphene, hexachlorbenzene, heptachlor, chlordane and DDT.

2.3.1.1. Manufacturing Chloroorganic persistent pesticides subject to the Stockholm Convention have never been manufactured in the Republic of Bulgaria.

2.3.1.2. Use POP pesticides like Aldrin, Dieldrin, Endrin, Chlordane, DDT, Heptachlor, Chlordecone, Mirex, Toxaphene have been produced in large quantities and were extensively used as insecticides for crop and wood protection and for malaria prevention. Large quantities of these POPs have been manufactured and used worldwide during the middle of the past century (Table 29).

Table 29 Use of POPs pesticides Chemical POPs pesticides use

Aldrin Local ectoparasiticide Aldrin:In the 1950s, aldrin was used primarily to treat termites and beetles on a variety of Insecticide CAS № 309-00-2 crops, such as corn, potatoes, and cotton, as well as to guard wood structures. As a pesticide to treat soil insects, it has been frequently used to kill rice-water weevils, corn rootworms, wireworms, and grasshoppers.

Chlordane Local ectoparasiticide Chlordane: Since 1945, chlordane has been used as an insecticide. Its major function was Insecticide CAS № 57-74-9 to control termites and insects birthed from the Termiticide soil. Farmers used chlordane for many years as a pesticide on crops, such corn, small grains, Termiticide in buildings and dams maize, fruits, nuts, cotton, sugarcane, etc. Termiticide in roads Chlordane also is used in livestock, home gardening, and control of fire ants near power Additive in plywood adhesives transformers. Not used in Bulgaria.

Dieldrin In agricultural operations Dieldrin: It was introduced on the market in 1948 after Second World War. This pesticide Insecticide CAS № 60-57-1 has been used on cotton, corn, potatoes, and other crops. It also can be used for vector control, wood treatment, control of termites and textile pests, and mothproofing of wool products.

Endrin In agricultural operations Endrin: This pesticide has been used in agriculture on crops, such as cotton, sugarcane, Insecticide CAS № 72-20-8 grains, apples, and ornamentals. Since its introduction in 1951, Endrin has been used as a rodenticide and insecticides for controlling mice, voles, and insects that invade orchards and fields. Its use has been banned or restricted in many countries since the 1980s.

Heptachlor Termiticide Heptachlor: The main function of heptachlor is to treat termites and soil insects. Other uses Termiticide in structures of houses CAS № 76-44-8 include control of malaria, cotton insects, and Termiticide (subterranean) crop pests. Wood treatment In use in underground cable boxes

Hexacholobenzene Intermediate HCB: When introduced in 1945, it was used as a fungicide for the treatment of the seeds of Solvent in pesticide CAS № 118-74-1 onions, wheat and sorghum. The chemical also Closed system site limited was used as a manufacturing intermediate and intermediate solvent in the production of synthetic rubber, PVC plastics, dyes, etc. While these uses have Fungicide & microbiocide been banned or severely restricted in many countries, HCB is still produced as a byproduct in the manufacturing of industrial chemicals and the burning of municipal waste. Not used in Bulgaria.

Mirex Termiticide Mirex: The application of Mirex started in the middle of 50-ies of XX century as an

CAS № 2385-85-5 insecticide. Dominant uses were for killing fire ants, leaf cutter ants, harvester termites, Western harvester ants, and mealy bug of pineapple. Mirex also has been widely used as a fire retardant in rubber, paper, plastics, and paint. Not used in Bulgaria.

Toxaphene Insecticide Toxaphene: After its introduction to the market in 1949, toxaphene was used as CAS № 8001-35-2 insecticide. Toxaphene has been used mainly to kill insects on cotton, fruits, nuts, cereal grain, and vegetables; control ticks and mites on livestock and poultry. Toxaphene is now banned or severely restricted in many countries.

DDT Insecticide DDT- Perhaps one of the most infamous of the POPs, DDT was hailed by society as an Acceptable purpose: (1,1,1-trichloro-2,2- effective insecticide in the 1930s. It was used bis(4-chorophenyl) Disease vector control in accordance to control vector-borne diseases, such as ethane malaria and typhus, and some countries are still with Part II of Annex B CAS № 50-29-3 dependent upon it. DDT also has been effective Specific exemption: on a variety of crops, especially cotton, but is widely restricted because of its adverse health Production of dicofol and environmental effects. Intermediate

The use of POP pesticides in R Bulgaria has been largest in the 60-s. They had been used on more than 20 million decares of agricultural land, forests, etc. during this period. The negative effects for humans and for the environment evidenced throughout the world, and the prohibitive and restrictive measures, have reduced and almost discontinued the use of POP pesticides in Bulgaria. Irrational planning and overstocking nationwide during the 60-s have resulted in overstocking of pesticides that are now obsolete, and controlled by the authorities of the Ministry of Internal Affairs.

Two stages are characteristic for the use of POP pesticides in Bulgaria: 1950-1970 – a period of intensive supply and use of chlororganic POP pesticides and subsequent ban for most of them in 1969, except for toxaphene, which was banned in 1985 and heptachlor in 1991. 1970 – 1990 – unofficial data show that an insignificant amount of the pesticides used comprise POPs.

The use of POPs pesticides in R Bulgaria is shown on Table 30. Table 30 Use of POPs pesticides in R Bulgaria POPs pesticide POPs pesticides use

Aldrin Insecticide Aldrin had been used early in the 60-s of past CAS № 309-00-2 century primarily to control soil pests (fleas,

beetles, weevils and grasshoppers) on a variety of crops, such as corn, potatoes and cotton in annual quantities of 150-200 tons. Banned for import & use in 1969.

Chlordane Not imported & used in Bulgaria. CAS № 57-74-9

Dieldrin Insecticide Dieldrin had been used early in the 60-s of past CAS № 60-57-1 century to control soil insects(fleas, beetles,

etc.) on cotton, corn, potatoes, and other crops in annual quantities of approx. 100 tons. Banned for import & use in 1969. Endrin Insecticide Endrin had been used early in the 60-s of past CAS № 72-20-8 century to control various agricultural pests on cotton, rice, apples, maize and other crops, and as a rodenticide in annual quantities of approx.100 tons. Banned for import & use in 1969.

Heptachlor Insecticide Heptachlor had been used till the 90-s of past CAS № 76-44-8 century as cotton-infesting insects and to control crop pests. in annual quantities of approx.100 tons. During 1988-1990 it was included in the list of Ministry of Agriculture and Forests`s for plant protection preparations (containing up to 10% technical product), allowed for agricultural use for treatment of seeds of maize, sunflower, wheat and sugar beet. Banned for import & use in 1991. Hexacholobenzene Not imported & used in Bulgaria. CAS № 118-74-1 Mirex Not imported & used in Bulgaria. CAS № 2385-85-5 Toxaphene Insecticide Toxaphene had been used till the 80-s of past CAS № 8001-35-2 century mainly to kill insects – ticks on cotton, fruits, cereal grain, and vegetables in annual quantities of 100-150 tons. Banned for import & use in 1985. DDT Insecticide DDT had been used in the 50-s of past century (1,1,1-trichloro-2,2- in various preparations (technical product Biocide (dicofol) bis(4-chorophenyl) content in the range of 5 ÷ 20%, of 20%, most ethane usually 5,5%). Later DDT was widely applied CAS № 50-29-3 in agriculture to control various pests on cotton. Its use was restricted in the 60-s. DDT was completely banned for import and use in 1969.*

* The are no official statistics data in R Bulgaria for the used quantities of DDT by years, including those after its official ban.

In the WHO report “Health risks of persistent organic pollutants from long-range transboundary air pollution” (2003) are given data for Usage of DDT in former socialist Central and Eastern European Countries (tonnes), including Bulgaria for the period 1970-1990 (Table 31).

Table 31 Usage of DDT in former socialist Central & Eastern European Countries (t) (Pacyna, 1999)2 Country 1970 1975 1980 1985 1990 Albania 90.00 12.00 6.66 3.00 0 Belarus 872.25 95.22 67.19 29.07 12.21 Bulgaria 600.00 63.00 59.20 27.70 0 Czechoslovakia 270.00 33.30 28.00 13.00 Estonia 106.08 11.58 8.17 3.54 1.49 Eastern Germany 1 500.00 33.99 2.78 4.03 Hungary 20.60 0.60 0 0 0 Latvia 306.47 33.46 23.61 10.22 4.29 Lithuania 365.40 39.89 28.15 12.18 5.12 Poland 2 528.00 16.70 8.78 0 0 Moldova 695.44 75.92 53.57 23.18 9.74 Romania 196.00 26.20 12.00 0 0 Russian Federation 6 000.00 654.99 462.22 200.00 83.99 Ukraine 5 150.97 562.31 396.81 171.70 72.11 Yugoslavia 3 150.60 311.40 80.00 50.00 31.56 TOTAL CEE countries 21851.81 1970.56 1237.14 547.62 220.51

2.3.1.3.Import POPs pesticides have been imported in R Bulgaria witjin the period 1960 ÷1990, most intensively in early 60-ies of past century. The first appearance of evidence of their harmful impacts has served as the cause for their banning for import and agricultural use (Table 32).

Table 32 Data about imports, registration and year of ban for POP pesticides POPs pesticides Import/ Imported Year of ban Remark registration quantities, t/y period Aldrin 1960-1969 135 - 220 1969 Dieldrin 1960-1969 100 1969 Endrin 1960-1969 100 1969 Mirex Not imported Toxaphene 1960-1985 100 - 150 1985 Hexachlorobenzene Not imported Heptachlor 1960-1990 100 1991 Chlordane Not imported DDT 1950-1969 1969 Specific exemption Import of dicofol containing less than 78% of p,p’- dicofol or less than 1 g/kg DDT and DDT derivates is permitted under PIC procedure.

2 WHO-Europe,“Health risks of persistent organic pollutants from long-range transboundary air pollution”, World Health Organization 2003, p.41.

After the ban of POPs pesticides for import and use, the country took measures for their replacement in agriculture with registered in Bulgaria insecticides, suitable for application in any specific case. (Table 33). Table 33 Alternatives for replacement of POPs in R Bulgaria

Pesticide Alternatives Aldrin, Organophosphates, synthetic pyrethroids, Dieldrin, phosphides, benzimidazoles, carbamates, Endrin, benzoylphenylureates, etc. Toxaphene, Heptachlor DDT Organophosphates, synthetic pyrethroids, etc. Chlordane, Not imported & used in Bulgaria. Mirex, HCB

2.3.1.4.Export Chlororganic POPs pesticides have never been exported. 2.3.1.5.POPs pesticides stockpiles Since 1990 the banned POPs pesticides issues went deeper due to reduced control over the stored stockpiles in the facilities of former cooperative farms, agro-industrial complexes, etc. and had created prerequisites for carelessness, improper storing, illegal use, increased risks for human health and pollution of the environment. The documentary – based inventories of prohibited and obsolete plant protection preparations carried out in 1993 and in 1995 (without on-site visits and analyses) by the National Plant Protection, Quarantine and Agrochemistry Service (NPPQAS) and in 1996 by Ministry of Agriculture and Forestry showed that in the country approx. 47267 kg of obsolete POPs pesticides stockpiles exist in 1995, the greatest amount being DDT (29234 kg), followed by heptachlor (11156 kg). Probably the available stocks of POPs pesticides in Bulgaria is bigger, due to lack of data, robbering the abandoned old storage places and insufficient control, impossibility for identification because of damaged packages and missing labels. The Invetory in 1996 found out the availability of 77215 kg POPs pesticides with gratest amount being Toxaphene (34954 kg)(Table 34). Table 34 Available POPs pesticides stockpiles in Bulgaria in 1995 & 1996

Declared POPs pesticides by Declared POPs pesticides POPs documentary inventory in by documentary inventory in pesticides 1995, kg 1996, kg Aldrin 4926 1563 Dieldrin 1726 528 Endrin 20 200 Toxaphene 205 34954 Heptachlor 11156 11156 DDT 29234 28814 POPs total 47267 77215

The inventory done by Ministry of agriculture and forestry in 2000 identified 954 storage places with about 5820 t obsolete pesticides stocks in the country. More than 1/3 of them were in bad condition. It is important to notice that 60% (3492 t) of the stock could not be identified due to lack of labels or damaged packages. The major part (89%) of the storehouses was located in rural regions. The inventory found out availability of obsolete POPs pesticides and mixtures, containing or contaminated with POPs, but the amounts differed from those declared in 1995 and 1996.

The total amount of identified POPs pesticides was about 58 t stored in 99 sites on the territory of 22 districts. A part of them- 22.25 t was identified as POPs and the balance of 35.6 t were mixture of pesticides consisting of or contaminated with POPs stored in 38 sites, on the territory of 10 districts. (Table 35). Table 35 POPs pesticides stockpiles in Bulgaria in 2000* POPs pesticides Number of Districts Total quantity, kg Storehouses Aldrin 8 8 1395 Dieldrin 7 6 1595 DDT 22 11 10749 Endrin 3 2 204 Heptachlor 57 16 7592 Toxaphene 2 1 720 POPs total 99 22255 Mixtures 38 10 35591 Total amount 57846 * Inventory, carried out by Ministry of Agriculture and forestry

The greatest amount were the mixtures of POPs pesticides with unknown composition, followed up by DDT and heptachlor.These figures were not considered as definitive due to absence of data on the quantity of banned OC pesticides stored on the territory of 6 districts (Sofia & Sofia district, Burgas, V.Tarnovo, Targovishte & Sliven) and damaged packages and missing labels. In August 2000, samples were taken from 8 warehouses for prohibited or obsolete pesticides in 4 regions of Bulgaria of approximately 41,2 tons of POP pesticides with assumed content of DDT, aldrin, dieldrin, toxaphene and endrin. The sample analysis has proven presence of DDT, aldrin, and dieldrin in approx. 28 t of POP pesticides. The identified POP pesticides have been re-packed in new drums, labelled in compliance with the European requirements, and transported to a base site. Under the project “Destruction of Risk Pesticides from Bulgaria in the Netherlands”, 27680 kg of POP pesticides such as DDT, aldrin and dieldrin from Bulgaria’s regions Sofia, Plovdiv, Shumen and Burgas have been exported to Netherlands, and destroyed in an incinerator in Rotterdam. Table 36 summarizes the date for available the POP pesticide stocks existing in Bulgaria by 1995 , 1996 and 2000 (according to the document-based inventory, without on-site analyses and visits), the POP pesticides exported in July 2000 for disposal abroad and the probable POPs pesticides stockpiles existing by 2003.

Table 36 Assumed POPs stocks and mixtures, consisting of or contaminated with POPs at end of 2003

POPs pesticides Documentary POPs Documentary Assumed total Exported for Assumed stocks of POPs and mixtures declared Pesticides declared POPs POPs pesticides disposal in pesticides and mixtures, after POPs Inventory pesticides in stockpiles in Hollandi, export to Holland, pesticides in 19964 20005 2000, July 2000 December 2003 19953

kg kg kg kg kg kg

ALDRIN 4926 1563 1395 4926 3531 1395 DIELDRIN 1726 528 1595 1726 131 1595

ENDRIN 20 200 204 204 - 204

TOXAPHENE 205 34954 720 720 - 720

HEPTACHLOR 11156 11156 7592 11156 - 7592 22 255÷25 819 DDT 29234 28814 10749 29234 18485 10749

POPs total 47267 77215 22255 47966 22147 22255

Mixture n.a. n.a. 35591 35591 5533 30058 30058

TOTAL 47267 77215 57846 83557 27680 52313 52313÷55877 From the assessment of available data for POPs pesticides stockpiles, collected by the Inventories carried out within the years, it could be assumed the following: The assumed POPs stockpiles at the end of 2003 are in the range of 22.25 t ÷ 25.82 t and the mixtures, consisting of or contaminated with POPs comprise of approx. 30.06 t, totaling the assumed POPs stockpiles between 52.3 t ÷ 55.88 t. Due to different data declared within the POPs Invetories, carried out in 1995, 1996 and 2000 by various authorities, it is strongly required a detailed POPs Inventory to be carried out in Bulgaria. To identify the specific POPs amount in the obsolete stockpiles and mixtures, it is necessary to determine the actual POPs content by sampling and analysis.

Concusions:

The assumed POPs pesticides stockpiles at the end of 2003 in Bulgaria are in the range of 22.25 t ÷ 25.82 t. The obsolete pesticides mixtures, consisting of or contaminated with POPs comprise of approx. 30.06 t. The assumed POPs pesticides stockpiles are totaling between 52.3 t ÷ 55.9 t To identify the specific POPs pesticides it is strongly required a detailed POPs Inventory to be carried out in Bulgaria.

3 Documentary inventory in 1995 (“Analysis and prospects for use of POPs in Bulgaria ,1995 IVECOL Sole Proprietor, Sofia, 1997) 4 Tasheva M, POPs Inventory 1996, National Centre of Hygiene, Medical Ecology & Nutrition,Training Workshop on POPs Inventories regarding NIPdevelopment, Dec.2003,Sofia,Bulgaria 5 Documentary inventory in 2000 (Kamburova V.,“Impact of Obsolete pesticides on rural environment”, Journal of Balkan Ecology, Vol.7, No4, 2004, p.425) 94

2.3.1.6.Obsolete pesticides stockpiles The storage facilities for unusable and obsolete pesticides are a source of local environmental pollution. By initiative of the EEPA at the MOEW, in 2000 the RIEW jointly with the municipal administrations and plant protection services have inspected the number and staus of warehouses and obsolete pesticides stored in them. Using information cards, the RIEW collect every year and submit to the EEA information about the warehouses status and the obsolete pesticides stockpiles. The Interagency Expert Committee at the MoAF, with participation of MOEW’s representatives discusses and takes decisions on all activities regarding the facilities for storage of prohibited and obsolete pesticides. The obsolete and useless pesticides are stored in centralized and municipal storage facilities and BB-cubes (reinforced steel containers 195x195x195 cm in size, hermetically sealed, with an effective storage capacity of 5 m3 ).

2.3.2.6.1.Inventory results for the period 2001-2004 In the period 2001 – 2004 MOEW through its EEA and RIEWs continued the monitoring of the warehouses status and of the obsolete pesticides stored there (fig.12).

Figure 12 Distribution of warehouses and BB-cubes for storage of obsolete and useless pesticides on the territory of R Bulgaria for 2003. At the end of 2003 the total number of storage facilities is 651, located on 618 lands of 198 municipalities.It has been identified totally 72 centralized storages - repaired or new buildings, complying with the requirement of safe storage of hazardous wastes as well as 55 sites with 957 BB-cubes. 579 unrepaired operating since 60-ies of past century storages for obsolete and useless pesticides are located on 550 lands of 154 municipalities. The latter do not comply with the requirements for safe storage and are a potential source of environmental pollution. At the end of 2004 the total number of storage facilities is 561, out of which being 84 centralized and 477 operating unrepaired storehouses.The 477 unrepaired storage facilities for obsolete pesticides are located on 460 lands of 130 municipalities. In 19 districts are located 1255 BB cubes. The number of centralized storages in 2004 compared with 2003 has increased with 12, and that of BB cubes – with 298. At the same time the number of unrepaired warehouses has been reduced with

102. In 2004 113 storages out of 579 unrepared ones in 2003 has been demolished and 24 new obsolete pesticides warehouses has been discovered. At the end of 2003 total stockpiles of obsolete pesticides are 12394 t, as 28% of them are permanently disposed in 957 BB-cubes, and 39% are re-packed and transferred in 72 centralized storage facilities. In 2004 the total stockpiles of obsolete pesticides are 11222 t, as 37,2% of them are permanently disposed in 1255 BB-cubes, and 41,9% arestored safely in 84 centralized storage facilities.Compared to 2003, the total OP stockpiles has been reduced with 1172 t, the repacked and moved to centralized storehouses OP has increased with 47 t, and that in BB cubes – with 652 t. (Fig.13). Obsolete pesticides stockpiles in warehouses and BB cubes by years

7011 2004 4211

8835 2003 3559

6386 2002 2566

5564 2001 1851

0 2000 4000 6000 8000 10000

tones

In BB cubes In warehouses

Figure 13 Obsolete pesticides stockpiles for 2001-2004. The ownership of warehouses is state, municipal, cooperative and private. The largest share in 2003 was held by the cooperative property – 52%, followed by municipal – 30%, private – 14%, and state – 4%. In 2004 the largest share in was held by the cooperative property – 58,17%, followed by municipal – 24,4%, private – 14,6%, and state – 2,8%. In comparison with 2003, it is observed an increase of storage facilities cooperative ownership and decrease of those municipal and state ownership. (fig.14).

Distribution of warehouses for storage of Obsolete pesticides by type of ownership for 2004

2,83% 13 warehouses 14,60% 67 warehouses

24,40% 58,17% 112 w arehouses 267 w arehouses

cooperative municipal private state

Figure 14 Distribution of warehouses for storage of Obsolete pesticides by type of ownership for 2004.

In 2003 approximately 46% of all warehouses are safe-guarded. Approx. 52% of storages are in an unsatisfactory or poor condition. 66% of all obsolete and useless pesticides stockpiles are stored safely in centralised storages and in BB cubes. The remaining 34% are stored in operating unrepaired warehouses which will be repaired and cleaned gradually, and those in poor status will be liquidated, and their sites and buildings sanitated.(fig.15).

Distribution of Obsolete pesticides stockpiles by manner of storage in 2003 4179 t; 34% 3559 t; 29%

4656; 37%

In abandoned warehouses In centralised warehouses In BB cubes

Figure 15 Distribution of Obsolete pesticides stockpiles by manner of storage for 2003 In 2004 the safe-guarded storages has decreased from 46% in 2003 to 38% in 2004, probably because of limited financial resourses of the municipalities, responsible for safe-guarding of warehouses. The total obsolete pesticides stockpiles, stored safely in centralised storages and in BB cubes has increased – from 66% in 2003 to 79% in 2004. The obsolete pesticides stockpiles , stored in operating unrepaired warehouses decreases from 37% in 2003 to 21% in 2004 (fig.16).

Distribution of Obsolete pesticides stockpiles by manner of storing for 2004

37% 42% 4211 t 4703 t

21% 2308 t

centralized storages unrepaired storages BB cubes

Figure 16 Distribution of Obsolete pesticides stockpiles by manner of storing for 2004.

In 2001 were repaired 124 warehouse in municipalities: Smolyan, Veliko Tarnovo, Kirkovo, Ardino, Burgas, Kubrat, Bobov dol, Tryavna, Yambol, Mizia, Svishtov and Targovishte. In 2002 were repaired warehouses in municipalities:Sredets, Kameno, Provadia, Avren, Aksakovo, Krivodol, Yakimovo, Brusartsi, Valche Dram, Chiprovtsi, Georgi Damyanovo, Kneja, Samokov, Krumovgrad, Harmanli and Kardjali. In 2003 were repaired warehouses in municipalities: Hisar, Brezovo, Saedinenie, Loznitza, Kardjali, Rodopi, Samoil, Belene, Haskovo, Dimitrovgrad, Svishtov, Lukovit, Antonovo, Kneja,

Zavet, Kozloduy and Pleven. Obsolete pesticides encapsulated in BB cubes in municipalities: Aksakovo, Sliven, Avren, Krichim, Opaka, Suvorovo, Gorna Malina, Sungurlare, Samokov, Shumen, Veliki Preslav, Nikola Kozlevo, Vidin, Kaspichan and Novi Pazar and Ruse district. More than 80 warehouses have been eliminated and cleaned up in 2003, and due to improved control and better identification more than 90 new storages have been discovered. The problem for safe storage of obsolete pesticides has been completely solved in the following administrative areas: Yambol, Smolyan, Russe, Gabrovo. Almost completely it is solved in Veliko Tarnovo, Kardzhali, Razgrad, Sliven, Targovishte. In 2004 are concluded 7 contracts for repairing of warehouse in municipalities: Saedinenie, Rakovski, Radnevo, Vetrino, Kaloyanovo, Maritza and Asenovgrad. In BB cubes obsolete pesticides are stored in 23 municipalities. The number of centralized storages in 2004 compared with 2003 has increased with 12, and that of BB cubes – with 298. At the same time the number of unrepaired warehouses has been reduced with 102. In 2004,113 storages out of 579 unrepared ones in 2003 has been demolished and 24 new obsolete pesticides warehouses has been discovered. The obsolete pesticides in 100 municipalities have been collected safely, treated with inert materials, re-packed, transported and stored in reinforced concrete containers – BB cubes – or in repaired warehouses . The increased activity towards permanent and environmental sound disposal of obsolete and useless pesticides in newly built or repaired centralized warehouses and BB cubes for the period 2001 ÷ 2004 is shown in comparative Table 37. In 2003 , 15 new sites with 247 new BB cubes with approx. 993 t of obsolete pesticides capsulated, had been established. At the same time the number of centralized newly built or totally repaired warehouses for obsolete pesticides, complying with the requirements for safe storage increases from 37 in 2002 to 72 in 2003. At the same time the number of unrepaired warehouse in bad status decrease respectively from 678 to 579 . In 2004 , 298 new BB cubes with approx. 652 t of obsolete pesticides capsulated had been established. At the same time the number of centralized newly built or totally repaired warehouses for obsolete pesticides, complying with the requirements for safe storage increases from 72 in 2003 to 84 in 2004. The number of unrepaired warehouse in bad status decrease respectively from 579 to 477, representing 18% decline versus 2003. (Fig 17).

Number of warehouses and BB cubes for storage of obsolete pesticides by years

1400 1255 1200

1000 957

800 756 678 710 579 600 number 477 468 400

200 72 84 16 37 0 centralized unrepaired BB cubes warehouses warehouses

2001 2002 2003 2004

Figure 17 Number of warehouses and BB cubes for storage of obsolete pesticides by years

98 MINISTRY OF ENVIRONMENT AND WATER National Implementation Plan for the Management of POPs in the Republic of Bulgaria

Table 37Total obsolete pesticides stockpiles in storages facilities by types of warehouse and BB cubes for the period 2001-2004 in Bulgaria

Year Storage facilities for obsolete “known” “unknown” Obsolete BB cubes BB “unknown” “unknown” Obsolete pesticides Obsolete Obsolete pesticides in sites cubes Obsolete Obsolete pesticides in pesticides in pesticides in warehouses pesticides in pesticides in warehouses warehouses warehouses BB cubes warehouses & BB cubes & BB cubes

TOTAL Centralized Unrepaired Q/ty Q/ty Total Total TOTAL TOTAL operating tones tones numbe number number tones tones tones number number tones r 2001 772 16 756 2138 3427 5565 20 468 1851 5278 7416 2002 715 37 678 1955 4431 6386 40 710 2566 6997 8952 2003 651 72 579 12 8823 8835 55 957 3559 12382 12394 2004 561 84 477 2,8 7008,2 7011 60 1255 4210,5 11218,7 11221,5 MINISTRY OF ENVIRONMENT AND WATER National Implementation Plan for the Management of POPs in the Republic of Bulgaria

The “unknown” obsolete pesticides stockpiles in warehouses and in BB cubes have been increasing constantly in the period 2001-2003, due to annual discoveries of new quantities of obsolete pesticides, being hazardous waste. The “unknown” obsolete pesticides in 2003 have increased to 12382 tonnes (Fig. 17). In 2004 a decline of OP stockpiles have been observed from 12382 t to 11222 t.

"Unknown" OP stockpiles in storage facilities in tones dor 2001-2003.

tones

14000

12000 3559

10000

8000

6000 2566 1851 8823 4000 4431 2000 3427

0 Year 2001 - total 5278 t Year 2002 - total 6997 t Year 2003 - total 12382 t “Unknown” obsolete pesticides stockpiles in BB cubes “Unknown” obsolete pesticides stockpiles in storages

Figure 18“Unknown” Obsolete pesticides stockpiles in storage facilities in tones for 2001 ÷ 2003

The distribution of “unknown” obsolete pesticides stockpiles (in kgs), stored in centralized and operating unrepaired warehouses and capsulated in BB cubes for 2003 and 2004 by administrative districts is shown on Table 38 and 39. In 2003, the obsolete pesticides stored in centralized 72 warehouses, located in 18 administrative districts amount to 4656 tonnes, that encapsulated in 957 BB cubes on 55 sites is 3559 tonnes, located in 15 administrative districts. The total obsolete pesticides stockpiles stored in safe warehouses, conforming to all requirements and in BB cubes is 8215 tonnes. The quantity of “unknown” obsolete pesticides is 4167 tonnes, stored in 579 unrepaired warehouses (table 38).

Table 38 “Unknown” obsolete pesticides in various storage facilities by districts for 2003 in R Bulgaria In Unrepaired In Centralized warehouses In BB cubes operating warehouses Total District BB quantity, Quantity, Quantity, Sites, Quantity, number number cubes, kg kg kg number kg number Blagoevgrad 22 77790 1 4 20000 97790 Bourgas 4 212215 41 140750 3 41 197000 549965 Varna 6 212330 11 80100 4 64 137150 429580 Veliko Tarnovo 7 1043075 6 33863 3 22 60000 1136938

Vidin 22 208930 1 27 108000 316930 Vratzа 1 291185 21 162900 454085 Gabrovo 3 82979 82979 Dobrich 31 266010 2 89 353600 619610 Kardjali 8 316849 4 11335 328184 Kyustendil 1 432371 2 385911 818282 Lovech 1 66400 42 174350 240750 Montana 1 92000 20 103785 7 119 476000 671785 Pazardjik 23 54171 54171 Pernik 11 853150 3 63 252000 1105150 Pleven 3 105951 91 324742 430693 Plovdiv 9 389055 20 128745 517800 Razgrad 5 126417 4 75593 202010 Russe 7 85 190897 190897 Silistra 1 39225 21 78795 118020 Sliven 4 2980 5 175 862000 864980 Smolyan 6 99970 99970 Sofia 40 367414 7 64 256000 623414 Stara Zagora 2 34000 88 300628 334628 Targovishte 3 105745 3 94270 1 8 27000 227015 Haskovo 5 571340 35 80566 1 50 103000 754906 Shumen 1 8054 17 159989 9 100 281300 449343 Yambol 5 426700 1 46 235000 661700 TOTAL 72 4655861 579 4166767 55 957 3558947 12381575

101 MINISTRY OF ENVIRONMENT AND WATER National Implementation Plan for the Management of POPs in the Republic of Bulgaria

Table 39 “unknown” obsolete pesticides stockpiles, stored in centralized and unrepaired operating warehouses and BB cubes by districts for 2004. District In centralized storehouses In unrepaired operating warehouses Total Общо Liquidated In BB cubes TOTAL Warehouses Q/ty Warehouses Q/ty Warehouses Q/ty Warehouses Cubes Q/ty kg kg kg nr nr kg nr kg nr nr Blagoevgrad 17 66340 17 66340 4 11 42300 108640 Burgas 3 152100 27 113033 30 265133 20 123 511240 776373 Varna 6 213330 3 62600 9 275930 8 70 161150 437080 V.Tarnovo 9 1046675 8 41368 17 1088043 0 11 30000 1118043 Vidin 14 66940 14 66940 6 45 174000 240940 Vratza 1 291185 23 176100 24 467285 0 467285 Gabrovo 3 82979 3 82979 82979 Dobrich 23 102760 23 102760 8 131 506600 609360 Kardjali 8 316849 4 11335 12 328184 0 328184 Kyustendil 3 129102 3 129102 129102 Lovech 1 66400 42 174350 43 240750 3 240750 Montana 17 63640 17 63640 10 177 596000 659640 Pazardjik 19 45521 19 45521 4 1 1370 46891 Pernik 12 56636 12 56636 0 49 196000 252636 Pleven 3 105951 89 340712 92 446663 4 446663 Plovdiv 13 585342 3 38600 16 623942 14 6 36600 660542 Razgrad 5 116655 1 6250 6 122905 1 122905 Ruse 4 84187 4 84187 111 235197 319384 Silistra 1 39225 21 85485 22 124710 2 124710 Sliven 4 3455 4 3455 1 176 864400 867855 Smoljan 5 94170 5 94170 1 5000 99170 Sofia 40 367414 40 367414 0 64 256000 623414 Stara Zagora 4 188745 57 229651 61 418396 27 69 341000 759396 Targovishte 4 184145 3 7600 7 191745 1 14 18300 210045 Haskovo 5 571340 35 94766 40 666106 0 50 103000 769106 Shumen 1 8050 15 153624 16 161674 0 100 281300 442974 Yambol 5 426700 5 426700 46 235000 661700 TOTAL 84 4703130 477 2308180 561 7011310 113 1255 4210487 11221797 МИНИСТЕРСТВО НА ОКОЛНАТА СРЕДА И ВОДИТЕ Национален План за действие за управление на Устойчивите Органични Замърсители в Република България

In 2004, the obsolete pesticides stockpiles in the centralized 84 warehouses is 4703 t and that, capsulated in 1255 BB cubes – 4211 t, located on the territory of 19 districts. Total obsolete pesticides stockpiles stored in safe and in conformity to all requirements warehouses and in BB cubes comprises to 8914 t. (table 24).

The amount of “unknown” obsolete pesticides stored in 477 unrepaired and unsafe warehouses is 2308 t.These stockpiles pose risk to the environment. The insufficient information about the assumed available approx. 52.3 t ÷ 55.9 t obsolete POPs pesticides and mixtures, consisting of or contaminated with POPs, due to torn packages, lack of labels and impossibility to identify their composition requires the implementation of detailed inventory of “unknown” OP stockpiles of 2308 t, stored in 477 unrepaired warehouses. The poor status of 53% of unrepaired operating storages requires measures for safe storage of the available there 1223 t obsolete pesticides – repacking and moving in repaired warehouses or export for disposal abroad.

Conclusions: OBSOLETE PESTICIDES STOCKPILES IN 2003

Аt the end of 2003 the total amount of obsolete pesticides stockpiles is 12394 t, stored in 651 warehouses and 957 BB-cubes. The “unknown” obsolete pesticides comprise of 12382 t, out of which 4656 t are stored in 72 centralized warehouses, 4167 t – in 579 unrepaired storages and 3559 t – in BB-cubes. Total obsolete pesticides stockpiles stored in safe warehouses, conforming to all European requirements for safe and environmentally sound storage of hazardous waste and in BB cubes is 8215 t. The amount of “unknown” obsolete pesticides stored in 579 unrepaired and unsafe warehouses is 4167 t.

OBSOLETE PESTICIDES STOCKPILES IN 2004

At the end of 2004 the total amount of obsolete pesticides stockpiles is 11222 t, stored in 561 warehouses and 1255 BB-cubes. The “unknown” obsolete pesticides comprise of 11219 t, out of which 4703 t are stored in 84 centralized warehouses, 2308t – in 477 unrepaired storages and 4211t – in 1255 BB- cubes. Total obsolete pesticides stockpiles stored in safe warehouses, conforming to all European requirements for safe and environmentally sound storage of hazardous waste and in BB cubes is 8914 t. The amount of “unknown” obsolete pesticides stored in 477 unrepaired and unsafe warehouses is 2308 t. The insufficient information about the assumed available approx. 52.3 t ÷ 55.9 t obsolete POPs pesticides and mixtures, consisting of or contaminated with POPs, contained exactly in these 2308t obsolete pesticides requires the implementation of detailed inventory of the “unknown” obsolete pesticides, stored in 477 unrepaired warehouses.

2.3.1.7.Existing policy and regulatory framework

Existing policy The management of POPs pesticides in R Bulgaria is implemented in conformity to the adopted and effective regulations, mechanisms and procedures. Their enforcement guarantees prevention to the maximum extend the negative impact of POPs pesticides on human health and the environment. The storage facilities for obsolete and unusable pesticides are one of the sources for local environmental pollution and pose health risk

To solve the problem of safe storage of obsolete and unusable pesticides in Bulgaria, with Order RD-159/12.05.1998 of the Ministry of Environment and Water and Order RD-09-991/11.05.1998 of the Ministry of Agriculture and Forests it was created an Inter-Agency Expert Committee for the management of “prohibited, obsolete and unusable pesticides stockpiles”. The responsible institutions for POPs pesticides management are the Ministry of Agriculture and Forestry (MoAF), the Ministry of Environment and Water (MoEW), and their regional structures. The main regulatory framework applied are the Waste Management Act (promulgated in the SG 86/24.09.2003, amended SG 70/10.08.2004), Regulation 12 on the Requirements for the Sites for Waste Treatment Facilities, SG 152/22.12.1998 and Regulation 13 on the Conditions and Requirements for Construction and Operation of Waste Landfills, SG 152/22.12.1998 and the National Waste Management Programme. The construction of centralized municipal warehouses and BB cubes conforming to the legislative requirements for safe disposal, liable storage of available obsolete pesticides stockpiles and cleaning up of emptied warehouses are activities that illustrate consistency in environmental protection policy and sustainable management of obsolete pesticides. The funds allocated by the Enterpise for Management of Environmental Protection Activities (EMEPA) and National Plant Protection Service (NPPS) have been increasing constantly during the peirod 1998 - 2004 for safe storage of obsolete & unusable pesticides, repairing of warehouses, cleaning up of premises and sites, collection, re-packing, and shifting of chemicals from warehouses in the small urban centres to municipal and centralised warehouses, or disposal in BB cubes. The decreasing of old warehouses and the environmentally sound storage of obsolete pesticides has reduced the threat of environmental pollution and human health risk (Fig.19).

Funds allocated by MoEW and MoAF for safe storage of Obsolete pesticides by years

2500000

2000000

1500000

1000000

500000

0 1998 1999 2000 2001 2002 2003 2004 2005

Funds allocated by MoEW 80799 780042 899000 657000 1115580 1651683 1915974 377236 Funds allocated by MoAF 468900 61000 308700 Total 1367900 718000 1424280 1651683 1915974 377236

Figure 19 Funds allocated by MоEW and MоAF for safe storage of obsolete pesticides in BGN by years During the period 2001- 2004, steady positive trends toward the management of warehouse for banned and obsolete pesticides and the surrounding areas are observed as a result of: restriction of existing and prevention of future pollution in cosequence of the effective enforcement of national legislation; restriction of negative impact of warehouses and obsolete pesticide stored there upon environmental quality and human health by re-packing, and shifting in centralised municipal warehouses and cleaning up of emptied premises (picture 1 & 2);

104

Picture 1Unrepaired municipal warehouses for obsolete pesticides

permanent disposal of obsolete pesticides in BB cubes with upto 300 years waste storage term (photo 3); maintaining and annual updating of Obsolete pesticides stockpiles data base, stored in warehouse and BB cubes on national (in EEA) and regional (in RIEWs) level; finacing of project proposals /programmes for improvement of storage facilities status and safe and environmentally sound storage of Obsolete pesticides;

Picture 2 Repaired storage for obosolete pesticides Picture 3 BB cube site

public awareness rising and providing public access to the available information.

To improve the storage conditions of obsolete and unusable pesticides, the following measures have been taken:

In 2003 are concluded 18 contracts for repairing of warehouse in municipalities: Hisar, Brezovo, Saedinenie, Loznitza, Kardjali, Rodopi, Samoil, Belene, Haskovo, Dimitrovgrad, Svishtov, Lukovit, Antonovo, Kneja, Zavet, Kozloduy and Pleven. Obsolete pesticides encapsulated in BB cubes in municipalities: Aksakovo, Sliven, Avren, Krichim, Opaka, Suvorovo, Gorna Malina, Sungurlare, Samokov, Shumen, Veliki Preslav, Nikola Kozlevo, Vidin, Kaspichan and Novi Pazar. In 2004 are concluded 7 contracts for repairing of warehouse in municipalities: Saedinenie, Rakovski, Radnevo, Vetrino, Kaloyanovo, Maritza and Asenovgrad. In BB cubes obsolete pesticides are stored in the municipalities: Kula, Boichinovtzi, Pravetz, Varna, Nessebar, Kubrat, Karnobat, Chuprene, Sofia city, Opaka, Sredetz, Montana, Opan, Stara Zagora, Rakitovo, Shabla, Bansko, Kostenetz, Lom, Medkovetz, Isperih, Kavarna and Ruen;

105

In 2005 are concluded 6 contracts for repairing of warehouse in municipalities: Lukovit, Radnevo, Hisar, Nikopol, Haskovo and district Stara Zagora. In BB cubes obsolete pesticides are stored in the municipalities: Gramada, Ardino, Stara Zagora, Kubrat, Berkovitza, Balchik, Novi Pazar, Dolna Mitropolia, Pleven, Boinitza, Karnobat, V.Preslav, Blagoevgrad and Polski Trambej. The total allocated funds by MoEW/EMEPA for safe storage of obsolete pesticides for the period 1998-2005 amount to 7,5 million BGN, as only for 2004 they are almost 2 million BGN. Nevertheless the annually constantly increased funds allocated by state budget for the management of POPs and obsolete pesticides , the Republic of Bulgaria can not cope alone with final solving of POPs and Obsolete pesticides stockpiles without international financial support, due to limited national funding available and the fact that Bulgaria is in Currency Board. To reduce the risk of POPs pesticides impacts on human health and the environment measures should be taken for safe storage and/or environmentally sound disposal abroad, due to absence of appropriate disposal facility in the country. For this purpose the Republic of Bulgaria needs to be supported by providing financial resources from GEF and other international, bilateral, regional and multilateral twinning programmes.

Existing national legislation The observation of existing national legislation in regard with POPs pesticides management guarantee the reducing of POPs negative impacts on environment and human health

1.Standards for POP pesticides in soils

Regulation No 3 on the Admissible Content of Harmful Substances in Soils, SG 36/08.05.1979, amended SG 54/1997, last amendment SG 39/16.04.2002.(Table 40 and 41). Table 40 Half-Life of POP-Pesticides in Soil and Admissible Limit Values (ALV) Pesticide Half-life in soil ALV in the ALV in Republic of Germany*, Bulgaria, mg/kg mg/kg Aldrin 5 years 0,05 Toxaphene 3 months – 12 years Chlordane 2 – 4 years 0,0043 DDT 10 – 15 years 1,5 Dieldrin 5 years 0,05 Endrin up to 12 years 0,029 Hexachlorobenzene 3 – 6 years 0,25 Heptachlor up to 2 years 0,0007 Plassche E., V.Bashkin, R.Guardans, K.Johnson and J.Vrubel (1998).Overview of critical limits for heavy metals and POPs. Proceedings of UN-ECE Convention on long-range transboudary air pollution, Unweltbundesamt, Germany, p.p. 1-25, p.p. 1- 91.

Table 41 Reference Values for Content of Chlororganic Pesticides in Soils Reference Values for the Content of Prohibited Chloroorganic Pesticides in Soils (mg/kg dry soil) No. Name 1* 2** 3*** 4**** 1 Hexachlorobenzene - 0.025 0.25 10 2 Dichlorodiphenykalogenoethane/DDX (sum) DDT,DDD,DDE - 0.3 1.5 4 3 2,4' и 4,4'' –Dichlorodiphenildichloroethylene/ -o,p' p,p'-DDE - 0,1 0,5 - 4 2,4' и 4,4'' –Dichlorodiphenil-2,2- dichloroethane/ -o,p' и p,p'-DDD - 0.1 0.5 - 5 2,4' и 4,4'' –Dichlorodiphenil-2,2,2-trichloroethane/ -o,p' и p,p'-DDT - 0.1 0.5 - * Reference background levels ** Precautionary Levels *** Admissible Limit Values **** Intervention Value

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2.Limit Values for POPs Pesticides in Water Regulation 12 on the Quality Requirements for Surface Water meant for Drinking Water Supply, SG 63/28.06.2002.(Table 42). Table 42 ALVs for POP pesticides in drinking water and the mandatory levels in surface water Mandatory values for Drinking water ALV, surface water, (mg/l)** POP pesticide (µg/l)* Categories

А 1 А 2 А 3 Aldrin 0.03 0.001 0.0025 0.005 Toxaphene 0.1 0.001 0.0025 0.005 Chlordane 0.1 0.001 0.0025 0.005 DDT 0.03 0.001 0.0025 0.005 Dieldrin 0.1 0.001 0.0025 0.005 Endrin 0.1 0.001 0.0025 0.005 Hexachlorobenzene 0.03 0.001 0.0025 0.005 * The ALVs for POP pesticides in drinking water will become effective as of 01.01.2007. ** The categories A1, A2 and A3 relate to different quantities of surface water based on physical, chemical and microbiological parameters.

Regulation 4 on the quality of waters supporting fish and shellfish organisms' life , SG 88/27.10.2000 (Tables 43 & 44). Annex № 1 to Article 2, i 1 Table 43 Quality values for surface fresh water inhabited by fish Parameter Salmonid Cyprinid Reference Minimum Comments waters waters Methods of sampling and analysis analysis frequency Guide Mandatory (G) (M) (G) (M) DDT - total, (µg/l) 10,0 (for para-para-DDT) GC Quarterly - 25,0 (for total DDT) Aldrin, (ng/l) 10,0 GC Quarterly (1) Hexachlorobenzene 0,03 GC Quarterly (1) (µg/l) НСВ

(1) Aldrin & HCB concentration in the sediment and fish should not show significant increase over time.

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Annex № 1 to Article 2, i 2 Table 44 Quality values for surface fresh water inhabited by shellfish organisms

Parameter Guide (G) Mandatory Reference Minimum (M) Methods of sampling analysis frequency The concentration of each substance in The concentration of Chloroorganic shellfish flesh must be so limited in accordance each substance in the GC compounds with Article 1 that it contributes to the high shellfish water or in quality of shellfish products (Regulation on the shellfish flesh must not limit values for concentrations of harmful reach or exceed a level Six-monthly /dangerous/substances in products for human which has harmful consumption based on Article5 of the Foods effects on the shellfish Act) and larvae. 10,0 for para-para-DDT DDT - 25,0 total DDT for estuary, internal and - GC Quarterly total (µg/l) territorial sea waters Dieldrine (ng/l) 10,0 for estuary internal and territorial - GC Quarterly sea waters Endrine (ng/l) 5,0

Regulation No 1 on the Studying, Use and Protection of Ground Water, SG 57/14.07.2000 (Table 45). Table 45 Recommended Parameters for Protection of Ground Water against Pollution with POP Pesticides Pesticide Ecological threshold, Pollution threshold, (µg/l) (µg/l) Aldrin 0.01 0.1 Dieldrin 0.01 0.1 Endrin 0.01 0.1 DDT/DDD/DDE 0.01 0.1 Chlordane 0.01 0.2 Heptachlor 0.01 0.2 Hexachlorobenzene 0.1 5

3. Maximum admissible concentration of POPs pesticides in fodders

Regulation 24 for maximum admissible concentration of unacceptable substances and products in fodders, SG 56/20.06.2003 (Table 46).

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Annex to Article 2, paragraph 2 Table 46 Maximum admissible concentration of POPs pesticides in fodders № Maximum admissible concentration of UNACCEPTABLE unacceptable substances and FODDERS SUBSTANCES OR PRODUCT products , expressed in mg/kg (ppm), referred to fodders with moisture 12 % 17. Aldrin All fodders with exception of 0,01 fats 18. Dieldrin (separately or in All fodders with exception of 0,2 combination with aldrin, expressed fats as dieldrin) 19. Toxaphene (camphechlor) All fodders 0,1 20. Chlordane (sum of cis- and trans- All fodders with exception of : 0,02 isomers of oxychlordane, expressed as chlordane) - fats 0,05 21. ДДТ (sum of DDT-, TDE- and All fodders with exception of : 0,05 DDE-isomers, expressed as DDT) - fats 0,5 23. Endrine (sum of endrin and delta- All fodders with exception of : 0,01 keti-endrine, expresses as endrine) - fats 0,05 24 Heptachlor (sum of heptachlor All fodders with exception of : 0,01 and heptachloroxide, expressed as heptachlor) - fats 0,2 25. Hexachlorobenzene (НСВ) All fodders with exception of : 0,01 - fats 0,2

4.Standards for POP pesticides in food

Regulation No.6 for the control measures on residues of veterinary medicinal products and environmental pollutants in life animals and foodstuffs of animal origin, SG 32/29.03.2002 (Table 47). Annex № 1 to Article 2 Residues groups, subject to control Group B - veterinary medicinal products and environmental pollutants 3. Other substances and environmental pollutants: а) Chloroorganic compounds, including PCBs; Annex № 2 to Article 4, paragraph 1 Table 47 Groups of substances to be detected by animal species and products of animal origin GROUP OF ANIMAL SPECIES AND FOODSTUFFS OF ANIMAL ORIGIN SUBSTANCES Bovine, Ovine, Poultry Fishery and Row Eggs Rabbit meat, Bee Caprine, Swine meat Aquaculture Milk meat from Honey & Horse meat products wild animals*

and farmed game

B (3) а : Chloroorganic Х Х Х Х Х Х Х compounds, including PCBs (*) For the wild animals only the chemical elements are subject to control.

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Regulation 31/29.12.2003 on the maximum admissible quantities of pesticide residue in food, SG 14/2004, effective 20.02.2004 (Table 48).

Table 48 Daily admissible human doses /DDD/ in the Republic of Bulgaria and maximum admissible residual concentrations /MARC/ of pesticides in food No. Pesticide DDD6 MARC Food type mg/day/kg mg//kg b.m.* 1 Aldrin /separately or with 0.0001 0.2 Meat and meat products; dieldrin/ 0.02 Eggs and egg products; 0.01 Cereal crops, vegetables; 0.006 Milk and dairy products 2 Dieldrin /separately or with 0.0001 0.2 Meat and meat products aldrin/ 0.02 Eggs and egg products 0.01 Cereal crops, vegetables 0.006 Milk and dairy products 3 DDT and metabolites 0.01 1.0 Meat and meat products 0.05 Eggs and egg products, vegetables and oil yielding and cereal crops, nuts and seed fruits 0.04 Milk and dairy products 4 Endrin 0.0002 0.05 Meat and meat products 0.01 Cereal crops, fruits, and vegetables 0.0008 Milk and dairy products 0.005 Eggs and egg products

5 Heptachlor 0.0001 0.2 Meat and meat products 0.01 Cereal, citrus, and nut-bearing crops, fruits and vegetables 0.02 Eggs and egg products 0.004 Milk and dairy products 6 Hexachlorobenzene 0.0006 0,01 Milk and dairy products 0,01 Cereal crops, tea, dry and oil yielding plants fruits, vegetables 0,02 Eggs and egg products 0.2 Meat and meat products 7 Toxaphene /camphor 0.1 Citrus crops, nuts and fruits chloriner/ 8 Chlordane 0.0005 0.05 Meat and meat products 0.01 Cereal crops, fruits, and vegetables 0.02 Eggs and egg products 0.006 Milk and dairy products * b.m - body mass

Regulation 31 on the maximum admissible quantities of pollutants in food, SG 88/08.10.2004

Regulation 25 on the establishment of maximum residue limits of veterinary medicinal products in foodstufs of animal origin, intended for human consumption, SG 94/4.10.2002 г.

6 IPCS, WHO/PCS/02.3, Inventory of IPCS and other WHO pesticide evaluations and summary of toxicological evaluations performed by the Joint Meeting on Pesticide Residues, 2002.

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2.3.1.8.POPS PESTICIDES MONITORING

2.3.1.8.1.POPs pesticides Level in the environment

2.3.1.8.1.1. POPs levels in water A National System for Environmental Monitoring operates on national level. The National Water Monitoring System shall be a complex of specific control, measurement, analytical and information activities which make it possible to assess and forecast water quantity and quality. The National Water Monitoring System shall comprehend: 1. the national network for precipitation and surface waters, including firm water yield; 2. the national network for ground waters; 3. the coastal reference network for the Black Sea; 4. a control and information system on the state of waste waters; 5. the operation, maintenance, communication support and laboratory information services under the foregoing items.

The networks include monitoring posts and/or stations. The Ministry of Environment and Water and the Ministry of Transport shall establish and maintain the part of the National Water Monitoring System relating to the River Danube. Any data obtained from observations and assessments as a result of the activity of the National Water Monitoring System, as well as any such data obtained from self-monitoring, shall provide a basis for the exercise of control and for the imposition of sanctions upon violation of regulatory requirements. Surface water The main purposes of the national surface water monitoring network are to: – obtain quantitative and qualitative data on the state of surface waters and assess trends with respect to their past, present and future development; – oversee compliance with national surface water quality standards; – assess the impacts of point sources on the receiving water body; – identify heavily polluted water areas (hot spots) where immediate action is needed; – provide public and private decision makers, academics and the general public with relevant information on the state of surface waters.

Surface waters are divided into three categories, according to their use: water supply; leisure, fishing and industrial; irrigation. The national network for monitoring surface water quality comprises 253 stations covering all major river basins. Three of these stations, located on the rivers Struma, Mesta and Maritza, are automatic. Of the surface water stations, 185 are in rivers (ten in the Danube), eight in lakes, 26 in reservoirs and 24 in the Black Sea. Fresh water measurements are made for some 30 parameters, including quantity, temperature, DO, BOD, COD, NH4, NO2, NO3, total N, PO4, total P, heavy metals, detergents and hydrocarbons. Measurements are taken once a month in rivers and lakes and seven times a year in the Black Sea.7 Within the period 1992-1993 an investigation of Danube river waters had been implemented in the region of town Silistra. From 2 riverside pointя and 6 thalweg points, it had been analyzed samples with broad spectrum of parameters – microbiological and chemical, including POPs pesticides. In 2 of the analyzed samples was found Heptachlor and р,р’- DDЕ residues respectively 0,004 µg/l and 0,003 µg/l, considerably lower than the ALVs (0,01 µg/l). Residues of р,р’-DDТ, о,р’-DDТ and Dieldrin had not been detected.8

7 National automated system for environmental Monitoring /NASEM/, Dimitar Vergiev,Executive Environment Agency, Ministry of Environment and Water, Bulgaria 8 Gopina G.et al., Health-Hygiene Characteristics of the Danube River in the district of Silistra with basic receiver the Black Sea, 1996, Hygiene and Public Health, vol. XXXIX, pp 25-27. 111

During the period of 1995-1997, the “ Danube Pesticide Regional Study”, a project supported by PHARE was completed. The data on the presence of pesticides residues in the water were collected from 10 Danube countries, including Bulgaria. The data indicated that the levels of DDT in Bulgarian section of the Danube dropped considerably between the 70-ties and 90-ies from 0,098 µg/l to 0,001 µg/l.9It was not found presence of other POPs pesticides.

NCHMEN had carried out investigations on pesticides residues in underground and surface water from 68 water bodies ( rivers, wells, irrigation waters, dam lake of drinking water). One to four samples were examined for each water body or totally 176 samples for the period 1993÷1999. Twenty drinking water sources were examined including 3 dams lake for drinking water supply and 17 underground water sources. Forty eight non-drinking water bodies were investigated including 6 of the biggest Bulgarian rivers – Iskar, Ogosta, Yantra, Vit, Maritza and Struma rivers as well as lakes, irrigation dams, drilling wells, etc. One hundred and fifty six samples were examined for POPs pesticides. Table 49 shows the concentrations of POPs pesticides in the analyzed water. Table 49 Concentrations of POPs pesticides found in Bulgarian waters 10 POPs pesticides POPs pesticides concentrations concentrations found in found POPs case of accidents Limit of pesticides No of samples Detection Method Conc.range/Mean No of analyzed/No of Conc.range, µg/l (LOD), µg/l value, µg/l samples positive samples DDT 156/0 - 7 0,06 – 1,63 0,001 GC/ECD 0,01 GC - MS DDE 156/2 0,001 – 0,003 7 0,13 – 0,53 0,001 GC/ECD 0,01 GC - MS Heptachlor 156/2 0,001 – 0,004 0,001 GC/ECD 0,01 GC - MS HCB 156/4 0,01 – 0,04/0,02 0,001 GC/ECD 0,01 GC - MS

No positive samples of POPs pesticides in surface water sources, used for drinking water supply (dam lakes) were found. The classic representative of persistent organochlorine insecticide – DDT and its methabolites showed clear trend for decrease of DDT and its methabolites in hydrosphere of Bulgaria. In 70-ies of past century this POP chemical was found in amount range 0,023÷0,410 µg/l, in 80-ies respectively - 0,013÷0,150 µg/l, while at present DDT is found only at incidental point pollution and DDE – in rare cases (176/2) in non-drinking waters.

No positive samples of POPs pesticides in surface water sources, used for drinking water supply (dam lakes) were found.

.Ground water The main purposes of the national ground water monitoring network are to: – obtain quantitative and qualitative data, as well as assess trends in the state of ground water; – control compliance with national standards for ambient ground water; – provide decision makers and interest groups with up to date information on the state of ground water. The national network for monitoring ground water quality is made up of 225 stations. They are

9 Bratanova Z. et al., A review of Existing data on occurance of Pesticides in water of the River Danube and its tributaries, 1998, Fresenius Envir.Bull.,7:495-501.

10 Bratanova Z, K.Vassilev, Pesticides residues in ground and surface water in Bulgaria, 2000, Hygiene and Public Health, vol. XLIII,1, pp16-18.

112 sampled two or four times a year for about 30 parameters. Bulgaria reports monitoring results from 74 ground water stations to the EUROWATERNET system. Groundwater is assessed on the ground of information, collected by Executive Environmental Agency. The samples are analyzed by the parameter, indicated in article 33 of Regulation 5 on the Procedure and Manner for Establishment of Networks and on the Operation of the National Water Monitoring System (SG 95/21.11.2000). Once per year in some points pesticides are analyzed. The results are compared with the recommended parameters for groundwater pollution protection - ecological threshold (ET) and pollution threshold(PT) fro Annex 3 of of Regulation 1 on the Exploration, Use and Protection of Groundwater (SG 57/14.07.2000). According to the Regulation 1 , the groundwater condition is defined as follows: 1. Groundwater in excellent condition - the values of the indicators (POPs pesticides) are below the ecological threshold (ET); 2. Groundwater in good condition - the values of the indicators(POPs pesticides) are between the ecological threshold (ET) and the pollution threshold(PT); 3. Groundwater in bad condition - the values of the indicators(POPs pesticides) are above the pollution threshold(PT); 4. Groundwater in very bad condition - groundwater which is damaged. In the period 1998-2002 two groups of samples have been taken for analysis of pesticides in ground water – at high ground water level in spring time, and low level by the later summer and early autumn. The sampling points in the spring were selected after analysis of the data from previous years – these are points where at least one pesticide exceeded the drinking water level of 0.1 µg/l. The following POPs pesticides had been analyzed - aldrin, dieldrin, endrin, chlordane, heptachlor, hexachlorbenzene and 6 DDT isomers and metabolites (o,p-DDT, p,p’-DDT, o,p-DDD, p,p’-DDD, o,p-DDE, p,p’-DDE). The samples taken for POP pesticides in ground water were 287, and in the year 2002 they were 70. Table 50 presents data about POP pesticides in ground water for 1998-2002, and Table 51 presents data about DDT content above the pollution threshold (PT). The analysis of data shows that no ground water in the Republic of Bulgaria is polluted with aldrin, dieldrin, endrin, chlordane, heptachlor and hexachlorobenzene. Although HCB had not been imported and used as pesticide in R Bulgaria , HCB residues had been found in single points samples being below ET, probably due to unintentional emission releases. The investigation results of DDT and its metabolites(o,p-DDT; p,p’-DDT; o,p-DDD; p,p’-DDD; o,p-DDE; pp’-DDE) indicate that in 1998 from totally 49 samples, in 8 samples the values exceed the pollution threshold (PT) - 0,1 µg/l and in 26 samples – above ecological threshold (ET) - 0,01 µg/l. The highest levels have been registered in Byala slatina(area of Vratza) - 1,037 µg/l; village of Yakimovo – 0,306 µg/l and village of Septemvriitsi - 0,178 µg/ (area of Montana); the town of Kozloduy(area of Vratsa) – 0,180 µg/l. For 1999 samples exceeding pollution threshold (PT) are registered in the village of Brushlen(area of Russe) - 0,523 µg/l and the town of Petrich (area of Blagoevgrad.)– 0,263 µg/l. The levels measured in the same points in 2002 were already below the minimum detection level (MDL). The analysis and data assessment shows that no groundwater polluted with DDT in the R Bulgaria ehist in 2002. All values were below the minimum detection level (MDL) in 2002 and this classifies the groundwater as ground water in excellent condition.

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Table 50 Analyzed samples for POPs pesticides residues in Groundwater in the RBulgaria for the period 1998 ÷ 2002.

1998 1999 2000 2001 2002 No of samples No ofsamples No ofsamples No ofsamples No ofsamples No ofsamples No ofsamples No ofsamples No ofsamples No ofsamples No of samples No ofsamples No of samples No ofsamples No ofsamples No of samples No ofsamples No ofsamples No ofsamples No ofsamples No ofsamples No ofsamples No of samples No ofsamples No ofsamples No ofsamples No ofsamples No ofsamples No ofsamples No ofsamples > > > > > > > > > ET ET ET ET ET PT PT PT PT POP pesticide PT

Aldrin 49 40 1 8 0 52 46 6 0 0 51 50 1 0 0 65 65 0 0 0 70 70 0 0 0 Dieldrin 49 42 2 5 0 52 50 2 0 0 51 47 4 0 0 65 65 0 0 0 70 70 0 0 0 Endrin 49 46 1 2 0 52 49 3 0 0 51 48 3 0 0 65 65 0 0 0 70 68 2 0 0 Chlordane 49 47 0 2 0 52 52 0 0 0 51 51 0 0 0 65 65 0 0 0 70 70 0 0 0 Heptachlor 49 35 4 10 0 52 40 10 2 0 51 46 5 0 0 65 65 0 0 0 70 66 4 0 0 Hexachlorobenzene 49 35 14 0 0 52 48 4 0 0 51 50 1 0 0 65 62 3 0 0 70 68 2 0 0 DDT Total 49 7 7 26 9 52 5 38 7 2 51 10 37 4 0 65 58 6 1 0 70 64 6 0 0

Table 51 DDT content in groundwater above the pollution threshold DDT content in ground water above the pollution threshold Area Urban cetntre 1998 1999 2000 2001 2002 level in µg/l Blagoevgrad Petrich 0,263 > ET < MDL < MDL Byala Slatina 1,037 < ET < ET < MDL Vratsa Kozloduy 0,180 > ET > ET < ET < MDL Dobrich Tyanevo 0,144 < ET < MDL Septemvritsi 0,178 < MDL Montana Yakimovo 0,306 < MDL Goyam chardak 0,125 Graf Ignatievo 0,158 < MDL Plovdiv Ioakim Gruevo 0,154 < MDL < MDL Russe Brushlen 0,525 < MDL

ET – Ecological threshold(0,01 µg/l) ; PT – Pollution threshold(0,1 µg/l); MDL – Minimum Detection Level(0,001 µg/l)

114 МИНИСТЕРСТВО НА ОКОЛНАТА СРЕДА И ВОДИТЕ Национален План за действие за управление на Устойчивите Органични Замърсители в Република България

In 2003 for the territory of Danube, Black Sea, East Medetiranian and West Medetiranian Basin Regions were analyzed samples for POPs residues in groundwater – aldrin, dieldrin, endrin, HCB, Heptachlor, isomers and metabolites of DDT(o,p-DDT, p,p’-DDT, o,p-DDD, p,p’-DDD, o,p-DDE, p,p’- DDE) . All values are below minimum detection level - MDL (Table 52). Table 52 Analyzed samples for POPs pesticides residues in Groundwater in the RBulgaria for 2003

BASIN No of ALDRIN DIELDRIN ENDRIN HCB HEPTACHLOR DDT samples REGIONS

DANUBE 23 < MDL < MDL < MDL < MDL < MDL < MDL BLACK SEA 15 < MDL < MDL < MDL < MDL < MDL < MDL EAST 23 < MDL < MDL < MDL < MDL < MDL < MDL MEDETIRANIAN WEST 1 < MDL < MDL < MDL < MDL < MDL < MDL MEDETIRANIAN

In 2004 an investigation study for the groundwater pollution with POPs pesticides (aldrin, endrin, heptachlor, р,р’-DDT, р,р’-DDE and р,р’-DDD) has been carried out in selected regions with intensive agriculture.It has been tested 103 groundwater sources from 16 regions in Bulgaria, according to available information about past pollution accidents. The analysis of pesticides were implemented by liquid-liquid extraction with n-hexane and GC/ECD. It was not found POPs pesticides content in any sample (LOD of method 0,001µg/l).11 Bratanova Zl. At al., “Groundwater pollution with pesticides in selected regions in Bulgaria”, 2005, Hygiene and health care, XLVIII.

POPs pesticide monitoring indicates excellent condition of groundwater on the whole territory of the country. The analysis and data assessment show that during 2003 in R Bulgaria there are no groundwater, polluted with POPs pesticides, listed in Annex A, Part I & II of Stockholm Convention.

2.3.1.8.1.2.POPs pesticides level in Soil

Land and soil quality monitoring, managed by the EEA as part of the NASEM, includes the control and protection of soil from pollution with persistent organic pollutants (20 monitoring stations for PAH, PCB and pesticides, and 48 stations for pesticide monitoring). Data on polluted soils are collected by EEA, together with the Institute of Soil Science and Agroecology. Soil contamination of industrial sites is also monitored using EIA procedures and an environmental auditing system. In 1997, the EEPA at the MOEW initiated a systematic study of soils for residues of POP pesticides – DDT, hexachlorbenzene, aldrin, chlordane, dieldrin, endrin, heptachlor, mirex – that are prohibited for use in the Republic of Bulgaria. Within the MoEW’s 4 years soil monitoring programme 277 soil samples had been collected and analyzed , 124 of which were in the year 2000.

11 Bratanova Zl. At al., “Groundwater pollution with pesticides in selected regions in Bulgaria”, 2005, Hygiene and health care, XLVIII.

In 1997, the soil sampling points had been located in sites of expected pollution. The point selection methodology was changed during the period 1998-2000, and the soil samples were equally distributed along the country’s agricultural land. For evaluation of the results the established 3 levels of reference values - Precautionary Levels (PL), Admissible Limit Values (ALV) and Intervention Value (IV) for the Content of Prohibited Chloroorganic Pesticides in Soils.

Table 53 present the results from the soil monitoing carried out during the period 1997-2000.

Table 53 Reference values for the Content of Prohibited for use DDT and HCB DDT Total DDЕ DDT HCB LEVELS mg/kg mg/kg mg/kg mg/kg dry soil dry soil dry soil dry soil Precautionary Levels (PL) 0,3 ÷ 1,5 < 0,5 < 0,5 0,025 ÷0,25 Admissible Limit Values (ALV) 1,5 0,5 0,5 0,25 Intervention Value (IV) > 4 - - > 10

Tables 54 & 55 present the results from the soil monitoing carried out during the period 1997-2000.

Table 54 Analyzed samples for POPs pesticides residues in Soil in the RBulgaria for the period 1997-2000 1997 1998 1999 2000 No of samples No of samples No of samples No of samples No of samples No of samples No of samples No of samples No of samples No of samples No of samples No of samples No of samples No of samples No of samples No of samples No of samples No of samples No of samples > > > AVL AVL AVL AVL POP pesticide

Aldrin 12 11 1 0 52 47 5 08982 7 0 124 120 4 0 Dieldrin 12 10 2 0 52 52 0 08984 5 0 124 109 15 0 Endrin 12 11 1 0 52 46 6 08983 6 0 124 114 10 0 Heptachlor 12 12 0 0 52 48 4 08980 9 0 124 110 14 0 Hexachlorobenzene 12 9 3 0 52 19 33 0 89 67 22 0 124 98 26 0 Total DDT 12 0 8 4 52 0 46 6 89 4 82 3 124 6 118 0

Table 55 Summary of the monitoring data for POPs pesticides levels in soil for the period 1997 - 2000 POPs pesticide Total samples/ % Min/Max Value AVL Positive samples Positive mg/kg dry soil mg/kg samples dry soil Aldrin 277/17 6,13 0,000012 ÷ 0,00514 Dieldrin 277/22 7,94 0,000013 ÷ 0,0513 Endrin 277/23 8,30 0,000015 ÷ 0,0102 Heptachlor 277/27 9,74 0,000003 ÷ 0,00237 Hexachlorobenzene 277/84 30,32 0,00002 ÷ 0,00401 0,25 Total DDT 277/263 94,94 0,00007 ÷ 8,994 1,5

The analysis of data about redisual POP pesticides in soils showed that the registered positive samples of aldrin, dieldrin, endrin and heptachlor towards the total number of tested samples are relatively few, respectively 6.13%, 7.94%, 8.30% and 9.74%. Relatively low maximal values were detected for the 4th POPs pesticides. Although not imported and used as pesticide in Bulgaria, probably as a result of emissions, Hexachlorobenzene (HCB) residues are found in 30.32% of tested soil samples, which are significantly lower than the ALV (0,25 mg/kg in dry soil). On the basis of the analysis and the data about redisual POP pesticides in soils the following conclusions could be made:

116

DDT and metabolites In Bulgaria DDT was banned for import and agriculture and public health use 32 years ago.Out of total 277 tested soil samples, in 14 (5.1%) the DDT total residue level is below the minimum detected level MDL.The data demonstrate that DDT still exists in in the environment of almost all regions of the country (94,94% positive samples – table 55). Most of the positive values (212/76,5%) the level of DDT total was below the precautionary levels (PL 0.3 mg/kg). The DDT total residue level in 38 samples was in the range of 0.3 ÷ 1.5 mg/kg dry soil (13.7%). Residues concentrations of DDT total higher than ALV were registered in 10 soil sampling points (3,6%) and only 3 samples (1.1%) were exceeding the intervention value (IV) of 4 mg/kg dry soil (Table 56). Table 56 Analyzed samples for DDT total and metabolites residues in Soil in Bulgaria for 1997-2000 Total number ALV Pesticide/ >IV of < MDL < 0.3 – DDT Total 0.3-1.5 – DDT Total >1.5- DDT Total Metabolite >4 - DDT Total samples < 0.1 – DDЕ/DDT 0.5 – DDЕ/DDT >0.5- DDЕ/DDT mg/kg dry soil mg/kg dry soil mg/kg dry soil n mg/kg dry soil n % n % n % n % n % DDT Total 277 14 5.1 212 76.5 38 13.7 10 3.6 3 1.1 DDE 277 40 14.4 182 65.7 28 10.1 27 9.8 DDT 277 33 11.9 202 72.9 28 10.1 14 5.1

The distribution of DDT total residues in tested soil samples by reference values are shown on Figure 20.

Distribution of residue concentrations of DDT total in tested soil samples by reference values in %

1,1% 3,6% 5,1% 13,7%

below MDL below PL PL - ALV above ALV above IV

76,5%

Figure 20 Distribution of DDT total residues in tested soil samples by reference values

The data about excessive DDT and metabolite content in soils by urban centres are presented in Tables 57 & 58.

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Table 57 Data about measured excessive content of some DDT metabolites in soils by urban centres

Data about measured excessive content of some DDT metabolites in soils by urban centres Total Total DDT p,pDDD p,pDDE o,pDDD p,pDDT o,pDDE o,pDDT Urban cetntre DDD DDE DDT Year Area

µg/kg dry soil

Blagoevgrad Gotse Delchev 4,900 1197,000 12,000 196,000 1201,900 12,000 196,000 1409,900 2000 Burgas Vetren 9,383 607,500 6,478 44,889 78,638 739,690 616,883 51,367 818,328 1486,578 1999 Vidin Rakovitsa 9,660 496,000 4,510 27,500 45,700 204,000 505,660 32,010 249,700 787,370 2000 Kyustendil Dupnitsa 5,480 500,000 9,100 117,000 505,480 9,100 117,000 631,580 1998 Pazardzhik Pazardzhik 4,360 1038,22012,130 18,480 8,250 7,650 1042,580 30,610 15,900 1089,090 1998 Plovdiv Dolna Mahala 20,010 880,200 8,960 24,850 7,620 12,270 900,210 33,810 19,890 953,910 1998 Parvomai 7,350 911,690 6,160 10,170 8,040 919,040 16,330 8,040 943,410 1998 Tsalapitsa 10,660 882,580 16,540 50,780 1,830 24,030 893,240 67,320 25,860 986,420 1998 Perushtitsa 9,760 1321,100 12,430 35,470 10,270 1330,860 47,900 10,270 1389,030 1999 Sofia-city Chelopechene 9,050 625,000 9,610 839,000 634,050 9,610 839,000 1482,660 1999 Sofia-district Stolnik 7,775 573,000 6,530 203,000 580,775 6,530 203,000 790,305 2000 Elin Pelin 5,500 1139,000 8,100 54,600 1144,500 8,100 54,600 1207,200 1998 Stara Zagora Malka vereia 3,830 573,680 1,650 10,440 19,100 205,160 577,510 12,090 224,260 813,860 1998 Haskovo Brod 18,900 710,730 42,120 47,450 2,090 729,630 89,570 2,090 821,290 1998 Yambol Veselinovo 2,640 808,490 0,940 5,560 2,820 42,210 811,130 6,500 45,030 862,660 ALV 500,000 500,000 500,000 1500,000

The soil monitoring data assessment show that with 250 positive samples in soils, containing DDT total< AVL were registered values of DDE>AVL for metabolites (0,5 mg/kg dry soil) in 27 sample and of DDT – in 14 samples. The ratio of p,p’-DDE to p,p’-DDT was in the range of 0.75 ÷ 349.10, indicating old contamination of soil with DDT. The increased value of the main metabolite p,p’-DDE indicates a cerain trend of breakdown. Table 58 Data for registered excessive content of DDT total and metabolites in soils by urban centres

Data about measured excessive content of DDT total in soils by urban centres p,pDDD p,pDDE o,pDDD p,pDDT o,pDDE o,pDDT Urban cetntre Total Total DDD DDE DDT DDT Year Area

µg/kg dry soil

1997 V. Tarnovo Dzulyunitsa 10,000 817,000 10,000 91,000 65,000 1225,000 827,000 101,000 1290,000 2218,000 1999 Vidin Kiriaevo 23,800 1530,000 17,000 177,000 230,000 1445,000 1553,800 194,000 1675,000 3422,800 1999 Novo selo 10,800 671,000 24,692 128,000 163,000 830,000 681,800 152,692 993,000 1827,492 1997 Vratsa Hairedin 26,000 3756,00023,000 112,000 117,000 556,000 3782,000 135,000 673,000 4590,000 1997 Mizia 40,000 7423,00039,000 205,000 192,000 1095,000 7463,000 244,000 1287,000 8994,000 1997 Montana Azadzhiski dol 66,000 221,000 31,000 2312,000 66,000 221,000 2343,000 2630,000 1998 Pazardzhik Malo Konare 194,310 1013,250 69,110 376,470 105,610 913,500 1207,560 445,580 1019,110 2672,250 1998 Zvanitchevo 7,010 804,170 56,480 136,530 91,010 527,750 811,180 193,010 618,760 1622,950 1998 Septemvri 91,990 1010,760 73,570 229,150 64,880 971,050 1102,750 302,720 1035,930 2441,400 1999 Ognianovo 18,140 2062,200 3,350 11,190 100,500 377,600 2080,340 14,540 478,100 2572,980 1998 St.Zagora Kirilovo 10,430 767,320 6,450 32,940 101,470 1351,770 777,750 39,390 1453,240 2270,380 Bratia 1998 Daskalovi 28,100 1056,450 12,550 42,930 208,250 1558,000 1084,550 55,480 1766,250 2906,280 1998 Gorno Belevo 402,710 1191,860 74,240 195,720 1494,260 1920,370 1594,570 269,960 3414,630 5279,160 ALV 500,000 500,000 500,000 1500,000 Out of all tested 277 soil samples 10 samples (3.6%) contain DDT total>ALV up to 4 mg/kg dry soil, as for 9 samples the level of p,p’-DDE and p,p’-DDT was exceeding ALV (0.5 mg/kg). Higher concentrations were detected in 5 districts as follows – Veliko Tarnovo, Vidin, Montana, Pazardjik and Stara Zagora. The ratio of p,p’-DDE to p,p’-DDT was in the range of 0.53 ÷ 4.35, indicating for increased value of the main metabolite p,p’-DDE, a cerain trend of breakdown and 118 old contamination of soil with DDT. In the soil sample taken from Azadzhiski dol, Montana the ratio of p,p’-DDE to p,p’-DDT was 0.3, indicating a recent soil pollution due to illegal use of DDT after its ban for import and use in 1969.

In 3 soil samples taken from 2 points in Vratza district and in 1 point in Stara Zagora district were registered residue content of DDT total above 4 mg/kg dry soil, amounting 1.1% of total analyzed samples. The ratio of p,p’-DDE to p,p’-DDT was in the range of 0.46 ÷ 5.79 and is an evidence of old soil contamination.

Conclusions:

No soils polluted with the following POPs - aldrin, dieldrin, endrin, heptachlor and hexachlorbenzene exist in all of the studied regions of R Bulgaria.

DDT and its metabolites still exists in in the environment of almost all regions of the country. Most of the positive values (76,5%) of DDT total are below the precautionary levels of 0.3 mg/kg and 13.7% - within the range of 0.3 ÷ 1.5 mg/kg . Despite the ban on DDT use since 1969, residues of DDT total higher than admissible limit value of 1.5 mg/kg are registered in 3,6% of soil samples within the period 1997-1999. Only 1.1% of samples are exceeding the intervention value of 4 mg/kg. Nevertheless the ratio of p,p’-DDE to p,p’-DDT is an evidence of old soil contamination, new sampling at the same points is required and if necessary remediation measures and clean up sites should be taken. The summarized analytical data show that about 95% of soils in the country are not polluted with DDT.

Local soil pollution in the vicinity of old pesticides storages12 The Plant Protection Institute, Kostinbrod had carried out a two years (1994 - 1996) investigation on pesticides soil pollution in the neighborhood of obsolete pesticides storages in Sofia district: The selected sites included 7 storehouses of obsolete pesticide in Kostinbrod, Aldomirovtsi, Vakarel, Bojurishte, Ichtiman and Slivnitsa. Samples were collected from plots in front of the depots and at 50 m distance. Soil drill was used for sampling until 1 m depth at 20 cm layer interval. Individual samples were collected from 10 points at each plot of the selected layers. 27 target pesticides including also the following POPs – heptachlor and DDT metabolites (p, p’DDT, o, p- DDT, p, p’-DDE, o, p’-DDE) were analyzed by GC method. In all cases, soils in the neighborhood of the observed point sources were heavily polluted with complex of different pesticides. 3 of DDT metabolites were determined in the surface soil samples with different maximum concentrations (Table 59).

Table 59 Maximal Concentrations of DDT metabolites in the Surface Soil Maximum concentrations (mg/kg) DDT metabolite Frequency %

p,p’-DDE 85.7 29.4 p,p’-DDT 71.5 700 o,p-DDT 71.5 200

Extremely high concentrations were determined for some metabolites such as p, p’-DDT , o,p-DDT and p,p’-DDE in the surface soil that were hundreds times exceeding the concentrations resulting after normal agricultural practice. The data corresponds to the great quantities of DDT used in agriculture in the past.

12 Balinova A.,”The Obsolete pesticides stocks in Bulgaria – a source of long-term contamination of the environment”, 7th International HCH and pesticides forum, Kiev, Ukraine, 2003, pp 187-190. 119

Characteristic examples of distribution patterns of the DDT metabolites in soil profiles are shown in Figures 21 and 22.

DDT complex distribution in soil profile in front of storage

2500 mg/k g 2097,6

2000

1500 952,9

1000 700 200 500 61,7 7,8 70,2 5,2 20,40 3,9 22,3 2,4 4,8 0,8 0,35 0 0-20 cm 20-40 cm 40-60 cm 60-80 cm 80-100 cm depth, cm

p,p'-DDT o,p'-DDT p,p'-DDE

Figure 21. DDT complex distribution in soil profile in front of storage Results confirmed that the rate of the vertical migration of the investigated DDT metabolites into soil profile is strongly influenced by their concentrations. Compounds characterized as nearly immobile in soil, such as DDT showed remarkable leachability under conditions of permanent extreme concentrations. Residues within a range of about 0.35 ÷5.2 mg/kg were determined at 80- 100 cm depth. .

DDT complex distribution in soil profile at 50 m distance

8 7,6 mg/k g 7

4 2,7

2 1 0,67 0,53 0,43 0,39 0,42 1 0,1 0,15 0,19 0,11 0,12 0,04 0,14 0 0-20 cm 20-40 cm 40-60 cm 60-80 cm 80-100 cm depth, cm

p,p'-DDT o,p'-DDT p,p'-DDE

Figure 22. DDT complex distribution in soil profile at 50 m distance from storage

Contamination at 50 m distance was detected in most cases at similar rates as in vicinity of the depots, although hundreds time decreased in comparison . For example p,p’-DDT in front of storage in the 0-20 cm soil layer depth is 700 mg/kg, while at 50 m distance – 7.6 mg/kg. The results indicate that in vicinity and at 50 m distance of the depots a real hazard exists for the surface waters, agricultural land, crops etc. The distribution of DDT complex in depth 80-100 cm poses no hazardous risk for groundwater.

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The contamination of the investigated sites was mostly a result of accidental events such as spilling of formulations,working solutions etc. The ratio p,p’-DDE/p,p’-DDT is 0.042, and is an evidence of direct soil contamination. The occurrence of high residues many years after the last practices was due to the improper handling and non-compliance with the requirements for save work. Pesticides detected outside the storehouses represent high potential risk of environmental pollution.

Obsolete pesticides impact on rural environment by small-scale incidents13,14 For a period of 8 years (1993 – 2000) eleven cases of fire incidents associates with obsolete pesticides stocks were registered in Bulgaria. All of them occurred in rural areas. As point sources of environmental pollution with POPs were considered storage sites and related accidental events – fires, releases to the environment, illegal entering in storehouses.The study was addressed mainly to POPs pesticides. DDT total, DDT-isomers and metabolites by GC/ECD were analised.5 To assess the pollution impact on the environment, samples were taken after extreme weather accident in the village of Rani list. The roof of the storage was destroyed because of storm and part of the pesticides mainly DDT was spread. The land around the storage place was used as a pasture and capped water spring (40 m away) with a pool for animals’ watering. After the event 2 soil samples were taken in the vicinity (№ 1 , № 2) and 1 (№3) at 60 m distance from the sorage as well as 1 water sample (№4) from the watering pool. The results of DDT and metabolites are presented in Table 60. Table 60. DDT and metabolites content in soil and water after the incident in v.Rani list

DDT & Soil samples, mg/kg Water, µg/l metabolites №1 №2 №3 №4 p,p’- DDT 6.20 6.00 0.60 0.030 o,p’- DDT 0.50 0.40 0.09 0.009 p,p’- DDE 2.70 5.10 0.06 < 0.005 p,p’- DDD 0.90 2.50 0.60 < 0.005 DDT total 10.30 14.00 1.35 0.039

The DDT content in the soil shows high pollution levels in the vicinity of the storehouse (№ 1, № 2) exceeding IL of 4 mg/kg. Considering the DDE/DDT ratio, it might be assumed that it was a result of past contamination. The DDT total in soil collected at the remote site (№3) was close to the admissible limit value ALV (1.5 mg/kg) and above the precautiona level PL (0.3 mg/kg). The DDE/DDT ratio indicates recent contamination and spreading the contamination towards the watering place. This was confirmed by the analysis detecting traces of DDT total (0.039 µg/l ) in the water sample (№4). Immediate measures for safe making and repair of the storage were taken.

The level of pollution was assessed at representative points around 9 storage places being in bad condition. Soil samples were taken from 15 points close to store houses. The results are presented in Table 61.

13 Kamburova V.,”Impact of obsolete pesticides on rural environment”,J.Balkan Ecology, 2004,Vol.7, No 4, pp 422-427. 14 Kamburova V., J.Christova, Zl.Bratanova, “Environmental pollution with organochlorine pesticides by small-scale incidents”, Fresenius Environmental Bulletin, 2005, Vol. 14, No 3,pp 1-4. 121

Table 61. DDT & metabolites contents in soil near storage house of obsolete pesticides POPs content in soil, mg/kg Number Storage location of points p,p’-DDT o,p’-DDT p,p’-DDE p,p’-DDD DDT total 1 Iskrets 2.10 0.03 0.60 0.12 2.85 2 Iskrets 0.80 0.11 0.09 0.09 1.09 3 Iskrets 0.02 < 0.02 0.02 0.03 0.07 4 Iskrets 0.03 0.02 0.03 0.02 0.10 5 Iskrets 0.66 0.06 0.24 0.09 1.05 6 Chepintsi 1.80 0.10 0.50 < 0.02 2.40 7 Chepintsi < 0.02 < 0.02 < 0.02 < 0.02 < 0.02 8 Chepintsi < 0.02 < 0.02 < 0.02 < 0.02 < 0.02 9 Elin Pelin < 0.02 < 0.02 < 0.02 < 0.02 < 0.02 10 Chelopech 0.18 < 0.02 0.30 < 0.02 0.48 11 Pirdop South 1.30 0.09 1.00 0.06 2.45 12 Anton 0.18 < 0.02 0.09 < 0.02 0.27 13 Piperovo 0.03 < 0.02 0.03 0.02 0.08 14 Pancharevo 0.21 0.02 0.21 0.24 0.68 15 Dragovishtitsa 0.80 0.10 0.40 1.00 2.30

The datа indicated that the area close to the storages was mostly contaminated one. In the cases where the storehouses were in bad status due to improper handling and non-observance of sanitary standars in location №№1, 6, 11 and 15 the levels of DDT total in the soil exceeded the ALV of 1,5 mg/kg. The values wеre in the range of 2.30 ÷ 2.85 mg/kg . In the region of village Iskrets (№ 2) the pollution is spread even over the closely situated corn field. The detected content of DDT total – 1.09 mg/kg exceeded the PL of 0.3 mg/kg. It is well understood that the presence of DDT in soil is generally a result from contamination due past use. Two follow-uр studies related to incidents with obsolete pesticides stocks registered 1997 in Bulgaria had been carried out. The contamination of local environment (water and soil) had been assessed immediately after the events and several years later. DDT total and metabolites, heptachlor, heptachlor epoxide were analysed by GC/ECD.13 Two rural places were in the focus of the study. The first incident was registered yearly in spring of 1997 near the village Zvunartsi.By excavation storehouse ruins and sacks labeled as DDT were found out. The sacks wre repacked and transported to safeguarded storage place. An area of 25 m2 was excavated to a depth of 2 m and the contaminated soil was tracked away for disposal. In spite the remedial measures, there were complains from the inhabitants for smell and death of poultry. Samples were taken from the capped spring, located 200 m far from the place of the incident and from 2 microreservoirs, situated 500 m away. Soil was sampled from the place of the store ruins. The second set of sample from the same places was collected in 2000. The analytical results of spring, microreservoirs and soil samples are presented in Table 62.

Table 62. DDT levels in water and soil samples from the region of Zvunartsi DDT & Year 1997 Year 2000 Groundwater samples,µg/l Soil samples, mg/kg metabolites Surfacewater samples,µg/l No 1 No 2 No 3 No 4 No 5 No 6 p,p’- DDT 0.09 0.37 0.27 875 1750 1030 p,p’- DDE 0.02 0.15 0.06 625 1000 20 o,p’- DDT 0.01 0.05 0.14 105 192 140 o,p’- DDE < 0.02 < 0.02 < 0.02 10 28 15 DDT total 0.13 0.57 0.48 1615 2970 1205

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The concentration of total DDT in groundwater sample No 1 was comparable with the pollution threshold level (0.10 µg/l ), but higher the ecological threshold (0.01 µg/l ). Higher levels of DDT residues were detected in the local surfacewater samples 2 and 3, respectively 0.57 and 0.48 µg/l. The low ratio DDE/DDT (between 0.22 and 0.41) indicated recent pollution events. Total DDT up to 2970 mg/kg were detected in soil semples 4 and 5.The values determined in both soil samples exceeded the intervention value of 4 mg/kg. In the water samples, collected in 2000 no DDT total, isomers and metabolites were found. The total concentration of DDT (1205 mg/kg), taken almost 4 years after the incident (sample 6) was several orders of magnitude above the the intervention value.

The second incident occurred at the outskirts of the town Koinare in May 1997. The investigation was initiated due to a fish perish in a breeding pond, fed up by a small river and located 300 m away from an old storehouse for obsolete pesticides.Throwing away of pesticides into the river was supposed. The drinking water source of the town was located about 1 km from the stockpile. Water samples were taken immediately after the incident and a month later from the river, the breeding pond and the drinking water source. In 1999 the pesticides sorage was liquidated. The rests were barried in concrete reservoirs and covered with soil without any waterproof material. A follow-up sampling was performed in January 2001 and soil samples were taken from the surface layer on embankment. Water samples were collected from the pond and the nearest consumer’s tap. The results of the investigation are presented in Table 63.

Table 63. POPs pesticides levels in water and soil samples from the region of Koinare Year 1997(1) Year 2001(2) Soil samples, mg/kg Pesticide Water samples ,µg/l River Breeding pond Drinking water Embankment 1 2 3 4 5 6 7 p,p’- DDT 0.19 < 0.02 0.17 < 0.02 0.83 0.08 1.2 p,p’- DDE 0.06 < 0.02 0.04 < 0.02 0.30 0.19 0.8 o,p’- DDT 0.06 < 0.02 0.08 < 0.02 0.46 0.09 < 0.1 o,p’- DDE < 0.02 < 0.02 < 0.02 < 0.02 < 0.02 < 0.02 < 0.1 DDT total 0.31 0.29 1.59 0.36 2.0 Heptachlor -(3) - - - - - 6.9 Heptachlor epoxide < 0.02 < 0.02 < 0.02 < 0.02 < 0.02 < 0.02 0.45 (1) soil samples were not collected in 1997; (2) no residues were found in the water samples collected in 2001. (3) “-“ the compound was not analyzed. DDT andits main metabolite DDE had been detected in all water sampes in 1997. In the river (No 1), in breeding point (No 3), and in drinking water (NoNo 5,6) the values exceeded the pollution threshold of 0.1µg/l.These values affect adversely the aquatic species. Environmental exposure concentration of 0.1µg/l could cause inhibition of growth and photosynthesis in green algae. DDT is considered to be highly toxic to aquatic invertebrates at concentration as low as 0.3 µg/l. The concentration of DDT total in drinking water was 1.59 µg/l exceeding 3 times the limit (0.5µg/l) laid down from the preventive point of view for human consumption water (Council Directive 98/83 EC), but approaches the WHO guideline value of 2 µg/l for DDT and its metabolites relevant for lifetime exposure via drinking water (WHO, 1993). The low ratio DDE/DDT in all samples point at continuing release of DDT into the water. DDT residues in the drinking water (No 6) were confirmed a month later, but a lower level of 0.36 µg/l. The water analysis carried out two years after the liquidation of the storehouse evidenced no residue of DDT and its metabolites, heptachlor and heptachlor epoxide. DDT total (2,0 mg/kg); p,p’- DDT(1.2 mg/kg) and p,p’-DDE(0.8 mg/kg) were found in soil sample No 7 in 2001. It is evident that the embankment remains as a local hot spot and potential source for additional environmental pollution. Further clean-up activities are necessary in order to eliminate this problem.

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Conclusions:

Obsolete pesticides storehouses are an important point source of pollution, representing a risk for soil and water contamination. The percentage contribution to local soil contamination, caused by 715 storage sites for obsolete pesticides, estimates to 10.5% from all main types of local pollution sources.15 The local environmental consequences after incidents are often neglected, but their contribution to the problem is important because of the improper extent of the actions undertaken. The data obtained from the places of incidents stress the necessity of continuous pollution monitoring and control of the effectiveness of the performed remedial measures on a long-term and broader scale in order to minimize the ecological threat and to avoid the risk for human health.

2.3.1.9.POPS PESTICIDES LEVELS IN FOOD The control over the foods is implemented by Ministry of Agriculture and Ferestry and Ministry of Health.It is carried out by the State Control Authorities under the Health Act, the Law on veterinary and medical activity and the Law on storage and marketing of grains. The Authorities of State Sanitary Control (SSC) exercise control over all foods , excluding the foods from animal origin. From the numerous control analysis of different food stuff from vegetable and animal origin (average 2200 food products for the Year 2003) made by accredited laboratories of Ministry of Health (MoH) in Bulgaria, it was not found food samples, exceeding the maximum admissible residual concentration (MARC) for POPs pesticides residues in foods. The Authorities of State Veterinary Control (SVC) exercise control on foods from animal origin, including their import, transit and export. The National Veterinary Medical Service (NVMS) at the Ministry of Agriculture and Forestry (MoAF) is the national competent authority responsible for the National Monitoring Program for Control on Residues (NMPCR), including POPs in live animals and animal products intendet for human consumption. It is authorised to organize, manage, control and carry out the NMPCR trough the Regional Veterinary Services. The Central Laboratory of Veterinary Control and Ecology (CLVCE) perform the laboratory tests. All animal species, types and products which are subject to control, are specified in the relevant annual plans for control on residues. The National Monitoring Program for Control on Residues (NMPCR) in live animals and animal product includes: live animals and fresh meat – cattle, horses, sheep, lambs, goats, kids and pigs; poultry – ducks, goose and hens; eggs - hen eggs and quail eggs; fish - carp, silver carp, hausen, trout, pike and perch; milk - sheep and cow milk; game - deer and pheasants; farmed game – pheasants and rabbits; bee honey. Individual samples are tested for Residues of antibacterial substances, phosphorus organic or organochlorine compounds - organic substances, including such as PCBs, chemical elements, mycotoxines or radionuclides in Life animals and animal products - red meat; poultry; hen eggs; raw milk; fish; bee honey; farmed and wild game. NVMS publishes annual report on residues detected.

15 Progress in the management of local soil contamination, Soil Contamination 2003 Delivery Report of EEA/MoEW, Bulgaria to EIONET 124

The analysis of the results from the NMPCR for 2003 in regard with POPs pesticides and PCBs are given in Table 64.16

Table 64 POPs Residues in live animals and animal products in Bulgaria for 2003 Animals and B (3) (a) Group of Matrix Laboratory Number of Number of animal products substances: Organochlore Method Samples samples compounds including PCBs above Action Level Aldrin Fat GC 18 cattle /< 2 years/ (S); None DDT tot 35 f.p. (S); 8 sheep (S); FRESH MEAT Heptachlor epoxide 34 lambs (S); PCBs 3 goats(S); 9 kids (S) Aldrin Fat GC 8 ducks None POULTRY DDT tot 4 geese Heptachlor epoxide 27 hens PCBs Aldrin Fat GC 25 fish carp None DDT 21 fish silver carp FISH Heptahlor epoxide 14 fish trout

PCBs 8 sturgeon 4 hausen fish Aldrin Milk GC 12 cows milk None ROW MILK DDT 6 sheep milk Heptahlor epoxide PCBs Aldrin Eggs GC 18 hen eggs None HEN EGGS DDT

Heptahlor epoxide Aldrin Fat GC 9 pheasant None FARMED GAME DDT 2 rabbits Heptahlor epoxide PCBs Aldrin Fat GC 3 partridges None DDT 2 rabbits WILD GAME Heptahlor epoxide PCBs

Aldrin Bee GC 53 None BEE HONEY DDT honey Heptahlor epoxide Explanatory Notes: GC - Gas Chromatography (S) – slaughter animals/ slaughtered cattle / < 2 years / (f.p.) – fattening pigs The analysis of the results from the National Monitoring Programme for control on residues (NMPCR) of POPs in food and foodstuff from animal origin intended for human consumption for 2003, indicated in Table 36, shows the following: Red meat - Out of the total 1231 analyzed individual samples of live or slaughtered animals, 107 samples of slaughtered cattle (18), pigs (35), sheep (8), lambs (34), goats (3) and kids (9) have been tested for POPs residues. There have not been any presence of residues from B (3)(a) group organochlorine compounds – organic substances, including such as Aldrin, DDT,Heptahlor epoxide and PCBs in the tested samples of Bovine, Swine , Ovine, Lamb, Caprine and Kid fresh meat.

16 National Monitoring Programme for Control on Residues from Medicinal products and Environmental pollutions in Live animals and Foodstuffs of animal origin, MoAF, NVMS, 2004, pp 40-63.

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Poultry - There were totally 388 samples of liver, muscle and fat of poultry (ducks, goose and hens) tested. For POPs residues 71 fat saples had been analyzed in 8 ducks, 36 goose and 27 hens. No presence of any residues from B (3)(a) group organochlorine compounds – organic substances, including such as Aldrin, DDT,Heptahlor epoxide and PCBs in all tested samples of ducks’, goose’ and hens’ fat has been detected. Hen eggs - Out of 58 samples of hen eggs, 18 were sampled and tested for POPs pesticides residues. No presence of any residues from B (3)(a) group organochlorine compounds – organic substances, including such as Aldrin, DDT and Heptahlor epoxide in the tested samples of hen eggs has been detected. Fish - Out of the totally 107 analyzed individual samples of fish , 72 samples of trout (14), carp(25), silver carp(21), sturgeon (8) and hausen (4) have been tested for POPs residues. No presence of any residues from B (3)(a) group organochlorine compounds – organic substances, including such as Aldrin, DDT,Heptahlor epoxide and PCBs in the tested samples of trout, carp, silver carp, sturgeon and hausen fish has been detected. Row Milk - There were totally 63 samples from row milk tested and analysed, out of which 18 samples of cow milk (12) and sheep milk (6) had been tested for POPs residues. No presence of any residues from B (3)(a) group organochlorine compounds – organic substances, including such as Aldrin, DDT,Heptahlor epoxide and PCBs in the tested samples of row milk has been detected. Bee Honey - Out of totally 129 samples from bee honey, 53 samples were tested for POPs residues. No presence of any residues from B (3)(a) group organochlorine compounds – organic substances, including such as Aldrin, DDT and Heptahlor epoxide in the tested samples of bee honey has been detected. Farmed Game - Out of the totally 54 samples of farmed game analyzed, 11 fat samples of pheasants (9) and rabbits (2) have been tested for POPs residues. No presence of any residues from B (3)(a) group organochlorine compounds – organic substances, including such as Aldrin, DDT,Heptahlor epoxide and PCBs in the tested samples of farmed pheasants and rabbits has been detected. Wild Game - There were 16 samples of wild game tested , out of which 5 fat samples of rock partridge (3) and wild rabbits (2) had been analysed for POPs residues. No presence of any residues from B (3)(a) group organochlorine compounds – organic substances, including such as Aldrin, DDT,Heptahlor epoxide and PCBs in the tested samples of Rock partridge and wild rabbits has been detected.

Conclusions:

No presence of any residues of POPs pesticides exceeding the maximum admissible residual concentration (MARC) in the tested 2200 foodstuffs from vegetable and animal origin for the Year 2003 has been detected. No presence of any residues from B (3)(a) group organochlorine compounds – organic substances, including such as Aldrin, DDT, Heptahlor epoxide and PCBs in the tested samples of Live Animals, Fresh Meat, Poultry, Fish, Farmed & Wild Game, Raw Milk, Hen Eggs and Bee Honey in Bulgaria for the Year 2003 has been detected.

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2.3.1.10.POPS PESTICIDES LEVELS IN HUMAN BODY Under the international project developed by 19 European countries, “WHO-coordinated Exposure Study on the Levels of PCBs, PCDDs and PCDFs in Human Milk, Organohalogen Compounds, 2003”17, a study was conducted in Bulgaria of the content of persistent and chlororganic pesticides in mothers’ milk from 30 healthy women, in groups of 10 from three regions (Bankya – ecologically clean area and two others – Sofia and Blagoevgrad – polluted in varying degrees). The preliminary results show no presence of endrin, toxaphene and mirex in the mothers’ breast milk in the ecologically clean region of Bankya. The following POPs pesticides were present in breast milk of Bankya region – hexachlorbenzene (0.012 mg/kg lipids), chlordane (0.018 mg/kg lipids), heptachlor (0.013 mg/kg lipids), dieldrin/aldrin (0.004 mg/kg lipids) and ∑ DDT (0.499 mg/kg lipids), presented by pp’-DDE (0.452 mg/kg lipids), op′-DDT (0.003 mg/kg lipids) and pp′-DDT (0.044 mg/kg lipids). The large predominance of pp’ – DDE in samples suggests the general absence of recent DDT sources. The results for POPs pesticides residues in mothers’ breast milk from Sofia and Blagoevgrad region are still in the process of finalizing.

2.3.1.11.HUMAN HEALTH IMPACTS POP pesticides may enter human body by respiratory, dermal and oral pathway, and they accumulate mainly in breast-milk, blood and fat tissue of human organisms. They are eliminated by mothers’ milk and could be dangerous for breast-fed children. The chronic exposure to POP pesticides may lead to negative impacts on central and peripheral nervous system, gastro-intestinal tract, the liver (toxic hepatitis with different extent of functional disturbances), skin irritations and allergic reactions. Representatives of POP pesticides in contact (respiratory, dermal and oral) with living organisms may cause cancer or increase carcinogen sick rate, male and female reproductive functions and hereditary genetic defects. The connection between hazard classification and health risk of POP pesticides has been a subject of lot of research work (Table 65). Table 65 Hazard Classification and health risks of POP pesticides

LD50 (mg/kg b.m.) Class of Category of Harmful effects Pesticides Hazard carcinogenicity to human health * * ** WHO WHO JARC 98 І b 3 Immunotoxicity, chronic liver effect, male reproductive Aldrin system and central nervous system impact 37 І b 3 Immunotoxicity, chronic liver effect, male reproductive Dieldrin system and central nervous system impact 113 ІІ 2В Immunotoxicity, interference with estrogenic system, DDT and metabolites possible endocrine disruption , thyroid, adrenal and retinol effects 7 Іb 3 Allergic reactions, toxic hepatitis , central and Endrin peripheral nervous system damage 100 ІІ 2В Possible endocrine disruption, Heptachlor reproductive disorders

17 WHO-coordinated Exposure Study on the Levels of PCBs, PCDDs and PCDFs in Human Milk, Submitted to Dioxin 2002. Organohalogen Compounds, 2003. 127

LD50 (mg/kg b.m.) Class of Category of Harmful effects Pesticides Hazard carcinogenicity to human health * * ** WHO WHO JARC > 10 000 Іа 2В Effects on nervous, thyroid, immune, reproductive and Hexachlorobenzene endocrine systems , porphyria at humans 80 ІІ 2В Central and peripheral nervous Toxaphene system damage, possible endocrine disruption 460 ІІ 2В Endocrine system impact, Chlordane reproductive disorders and immunotoxicity 306 2В Teratogen, possible endocrine Mirex disruption, immunotoxicity, reproductive and development system impact.

* WHO – Hazard Classification of WHO of POP pesticides ( Class of Hazard: Іа – extremely hazardous; Іb – highly hazardous; ІІ - moderately hazardous; ІІІ – slightly hazardous. ** IARC – Classification of agents, mixtures and exposures according to their carcinogenic risk to humans in accordance with the procedures adopted as standard IARC practice: Group 1 - carcinogenic to humans; Group 2A - probably carcinogenic to humans; Group 2B - possibly carcinogenic to humans; Group 3 - not classifiable as to carcinogenicity to humans; Group 4 - probably not carcinogenic to humans. No studies of POPs pesticides impact on human health have been carried out in the country.

Conclusion:

No cases of acute and chronic intoxication with persistent chlororganic pesticides.have been registered in the Republic of Bulgaria

Risk assessment by modeling of exposure and effects

Although risk assessment is not an exact science, it continues to be the milestone for decision making in regard with environmental and human health protection. Competent Authorities examine human and animal studies to determine the health effects of a particular contaminant. Both carcinogenic and non-carcinogenic health effects were examined. The investigations about the relation between the DDT and aldrin exposures of humans and cancer occurance continue, nevertheless, the human data are controversial. The allowable level of a contaminant in soil and the health-based clean-up criterion were determined, using combined toxicity, exposure data and risk management factor. Of 14 case control studies published in 2000, there is a positive correlation between breast cancer occurance and the levels of DDT or dieldrin in blood or adipose tissues (Simeonov, 200118) only in 5. Estimation of risk for adults and children in 4 diffrenet scenarios (agricultural, industrial, recreational and urban) was performed in 2001 using Human Exposure to Soil Pollutants (HESP) Model. In the monitoring study 15 districts were included. Soil monitoring data (maximum and average concentrations) were used. The HESP model is directed towards assessment of human exposue to chemicals, which are present in the environment as soil pollutant. The main exposure routes are: ingestion, inhalation and dermal

18 Simeonov, J.(2001),”Analysis of studies relating pesticides to breast cancer risk in exposed persons and their offspring.”In:Euroworkshop Proceedings Current Epidemiological Evidence versus Experimental Data on Reproductive and Development Toxicity of pesticides (T.Vergieva and F.Kaloyanova-Simeonova), Sofia, pp 193-216. 128 absorption. These main exposure routes have been devided according to environmental media involved: a. Direct ingestion of small quantities of soil or dust as well as indirect exposure via consumption of drinking water, ingestion of vegetables, fruits, meat and dairy products, poultry, eggs and fish; b. inhalation of vapours, particulates as inhalation of vapours during bathing or showering; c. dermal exposure to soil or dust, as dermal exposure during bathing. The magnitude of exposure is relevant to the particular situation, which can be selected and included in the calculation depending on the use of the land or characteristics of the agricultural land. The model calculates cumulative and maximum intakes for adults and children living at the contaminated site. The calculated total exposure indicates an annual average. Therefore, the calculated results of daily intake (DI) can be compared with tolerable/acceptable daily intake levels (ADI). For example: In the Netherlands, the tolerable daily intake (TDI) of DDT equals 0.0200 mg/kg.day. The USA EA Reference dose (RfD of DDT) equals 0.0005 mg/kg.day. The Risk Quotient represents the ratio of maximum or average DI/TDI or D/RfD. Its levels: > 1 – large(L); 0.1÷1 – moderate(M); 0.01÷0.1 – small(S); and < 1-negligible(N). The input parameter used were: (1) Physical-chemical properties; (2) Polluted areas (length and width of site): 1 hectare; (3) Concentration of the contaminant (in upper, medium and deep layers) assessed according to the quantity of application per hectare; (4) Type and properties of soil: standard soil with 100% organic content; (5) Land use: agricultural; (6) Exposure conditions: (inter alia) time spent on the land in various activities. Fixed values (climate, human food consumption parameters) were also taken from the Netherlands default scenario.

The risk is negligible in all regions if the risk quotient DI/Netherlands TDI is used for the calculation.

In Tables 66 & 67 risk indicating data are given ,calculated using the quotient DI/RfD(US EPA). The data are part of the Case Study on persistent organic pesticides implemented in Bulgaria in 200119.

19 Kaloyanova-Simeonova F., et all, Human exposure and Risk assessment of soil pollution with Persistent Organochlorine Compounds in Bulgaria, 2001, 7(3-4): 263-275. 129

Table 66 Risk for children and adults from DDT soil contamination, based on modeling estimation (HESP model) District Adult Children 1 2 3 4 1 2 3 4 Montana Max.Conc. S S S - M - S S Av. Conc. S ------S Pleven Max.Conc. - - - - S - - - Vratza Max.Conc. - - - - S - - - Burgas Max.Conc. - - - - S - S - Stara Zagora Max.Conc. - - - - S - - S Pazardjik Max.Conc. S - S - M - S S Av. Conc. S - - S S - S S Plovdiv Max.Conc. S - S - M - S S Av. Conc. - - - - S - - S Haskovo Max.Conc. S - - - S - S - Sofia Max.Conc. M S S S L - M M Av. Conc. S - - - - - S S Blagoevgrad Max.Conc. - - - - S - - S Av. Conc. - - - - S - - - Smoljan Max.Conc. S S S - S - S S Av. Conc. S - - - S - S S 1 – Agricultural/Rural; 2 - Industrial; 3 -Recreational; 4 - Urban. Risk: S (small) ; M (medium) ; L (large); The average annual concentrations of DDT in all monitored regions represent no risk for the general population .Only maximum concentrations of DDT represent more than small rick for the rural general population in the polluted sites. For children it is considerable in the Sofia rural (1) district and moderate in Montana, Pazardjik and Plovdiv rural districts (1) and Sofia Recreational district (3). For adults moderat risk exists only in Sofia ruaral district (1).

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Table 67 Risk for children and adults from Dieldrin soil contamination, based on modeling estimation (HESP model) District Adult Children 1 2 3 4 1 2 3 4 Plovdiv M - S M - - S M Veliko Tarnovo S - - S M - S M 1 – Agricultural/Rural; 2 - Industrial; 3 -Recreational; 4 - Urban. Risk: S (small) ; M (medium) ; The average annual concentrations of Dieldrin in all monitored regions represent no risk for the general population Only maximum concentrations of Dieldrin in Plovdiv and Veliko Tarnovo districts represent more than negligible risk according to HESP calculations. For children moderate risk exist in urban Plovdiv district (4) and rural and urban Veliko Tarnovo district (1,4) . For adults the risk is moderate in rural and urban Plovdiv district (1,4). Conclusion:

The health risk is negligible in all regions if the risk quotient DI/Netherlands TDI is used for the calculation. The annual average concentration of DDT and Dieldrin in all monitored districts present no health risk for the general population.

Summary

Current situation with POPs issue in the country The Stockholm Convention includes the following persistent chloroorganic pesticides, listed in Annexes A & B - aldrin, dieldrin, endrin, mirex, toxaphene, hexachlorbenzene, heptachlor, chlordane and DDT.

Manufacturing: POPs pesticides subject to the Stockholm Convention have never been manufactured in the Republic of Bulgaria. Use : In R Bulgaria most POPs pesticides have been applied mainly as pest control preparations to treat termites and soil insects. The use of POP pesticides has been largest in the 60s in quantities 100-200 t annually. Aldrin, dieldrin, endrine and DDT have been banned for import and use in 1969, toxaphene – in 1985 and heptachlor – in 1991. Mirex, hexachlorobenzene and hlordane have not been imported and used in the country. Import : In R Bulgaria POPs pesticides had been imported within the period 1960 ÷1990, most intensively in early 60s of past century. All POPs pesticides are banned for import and use in agriculture. Export : No data exist for POPs pesticides exports. POPs pesticides stockpiles : The assumed POPs pesticides stockpiles at the end of 2003 in Bulgaria are in the range of 22.25 t ÷ 25.82 t. The obsolete pesticides mixtures, consisting of or contaminated with POPs comprise of approx. 30.06 t. The assumed POPs pesticides stockpiles are totaling between 52.3 t ÷ 55.9 t To identify the specific POPs pesticides, a detailed POPs Inventory is required to be carried out in Bulgaria.

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Obsolete pesticides stockpiles : The “unknown” obsolete pesticides stockpiles in warehouses and in BB cubes have been increasing constantly in the period 2001-2003, due to better control and annual discoveries of new quantities of obsolete pesticides. The obsolete pesticides preliminary inventory data for 2004 indicates the following: At the end of 2004 the total obsolete stockpiles equals to 11222 t, stored in 561 warehouses and 1255 BB cubes; The “unknown” obsolete pesticides stockpiles have increased to 11219 tonnes. 4703 t are stored in 84 centralized warehouses, 2308 t – in 477 non-repaired and 4211 t – in 1255 concrete-steel sealed BB-cubes; The total obsolete pesticides stockpiles stored in safe centralized warehouses, conforming to all requirements and in BB cubes are 8914 tonnes; The “unknown” obsolete pesticides stockpiles, stored in 477 non-repaired and unsafe municipal warehouses is 2308 tonnes. The poor status of 53% of the unrepaired operating storages requires immediate measures – repairing and cleaning up. It is necessary urgent measures to be taken for safe storage of the sored in them 1223 t obsolete pesticides- repacking and moving into repaired warehouses or export abroad for disposal . The insufficient information about the assumed available approx. 52.3 t ÷ 55.9 t obsolete POPs pesticides and mixtures, consisting of or contaminated with POPs, contained exactly in these 2308 t obsolete pesticides requires the implementation of detailed inventory of the “unknown” obsolete pesticides, stored in 477 unrepaired warehouses. Existing policy : The storage facilities for obsolete and POPs pesticides are one of the sources for local environmental pollution and may pose health risk The construction of centralized municipal warehouses and BB cubes conforming to the legislative requirements for safe disposal, liable storage of available obsolete pesticides stockpiles and cleaning up of emptied warehouses are activities that illustrate consistency in environmental protection policy and sustainable management of obsolete pesticides. The funds allocated by the Enterprise for Management of Environmental Protection Activities (EMEPA) and National Plant Protection Service (NPPS) have been increasing constantly during the period 1998- 2004 for safe storage of obsolete & unusable pesticides, repairing of warehouses, cleaning up of premises and sites, collection, re-packing, and shifting of chemicals from warehouses in the small urban centres to municipal and centralised warehouses, or disposal in BB cubes. The totally allocated funds by EMEPA for safe storage of obsolete pesticides for the period 1998-2005 equals to approx. 7,5 million BGN as only for 2004 the funds are almost 2 millions BGN. The decreasing of old warehouses and the environmentally sound storage of obsolete pesticides has reduced the threat of environmental pollution and human health risk. Nevertheless the steady positive trends observed during recent years and constantly increased funds allocated by Bulgarian state for the management of POPs and obsolete pesticides , the Republic of Bulgaria can not cope alone with final solving of POPs and Obsolete pesticides stockpiles without international financial support, due to limited national funding available and the fact that Bulgaria is in Currency Board. To reduce the risk of POPs pesticides impacts on human health and the environment measures should be taken for safe storage and/or environmentally sound disposal abroad, due to absence of appropriate disposal facility in the country. For this purpose the Republic of Bulgaria needs to be supported by providing financial resources from GEF and other international, bilateral, regional and multilateral twinning programmes. Existing regulatory framework : The observation of existing national legislation in regard with POPs pesticides management guarantee the reducing of POPs negative impacts on environment and human health. The country has transposed the main provisions under Stockholm convention in the Environment Protection Act, the Law on protection from harmful impact of dangerous substances and preparations, Water Act, the Law on preservation of agricultural lands, the Law on the protection of soil against pollution, the Law of Health,the Law on Fodders, the Law on Foods, Waste Management Act and their sub-legislative acts.

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POPs pesticides Monitoring POPs levels in Surface water : No positive samples of POPs pesticides in surface water sources, used for drinking water supply (dam lakes) were found. The classic representative of persistent organochlorine insecticide – DDT and its metabolites showed clear trend for decrease of DDT and its metabolites in hydrosphere of Bulgaria. At present DDT is found only at incidental point pollution and DDE – in rare cases in non-drinking waters. POPs levels in Groundwater : POPs pesticide monitoring indicates excellent condition of groundwater on the whole territory of the country. The analysis and data assessment show that during 2003 in R Bulgaria there are no groundwater, polluted with POPs pesticides, listed in Annex A, Part I & II of Stockholm Convention. POPs pesticides level in Soil : No soils polluted with the following POPs - aldrin, dieldrin, endrin, heptachlor and hexachlorbenzene exist in all of the studied regions of R Bulgaria. DDT and metabolite residues in soils are still registered in the environment of almost all regions of the country: Most of the positive values (76,5%) of DDT total are below the precautionary levels of 0.3 mg/kg and 13.7% - within the range of 0.3 ÷ 1.5 mg/kg . Despite the ban on DDT use since 1969, residues of DDT total higher than admissible limit value of 1.5 mg/kg are registered in 3,6% of soil samples within the period 1997-1999. Only 1.1% of samples are exceeding the intervention value of 4 mg/kg. Nevertheless the ratio of p,p’-DDE to p,p’-DDT is an evidence of old soil contamination, new sampling at the same points is required and if necessary remediation measures and clean up sites should be taken. The summarized analytical data show that about 95% of soils in the country are not polluted with DDT. POPs pesticides levels in food No presence of any residues of POPs pesticides exceeding the maximum admissible residual concentration (MARC) in the tested 2200 foodstuffs from vegetable and animal origin for the Year 2003 has been detected. No presence of any residues from B (3)(a) group organochlorine compounds – organic substances, including such as Aldrin, DDT, Heptahlor epoxide and PCBs in the tested samples of Live Animals, Fresh Meat, Poultry, Fish, Farmed & Wild Game, Raw Milk, Hen Eggs and Bee Honey in Bulgaria for the Year 2003 has been detected. POPs pesticides levels in human body : Within the frame of a study, conducted in Bulgaria of the content of POPs pesticides in mothers’ milk from 30 healthy women from three regions (Bankya – ecologically clean area and two others – Sofia and Blagoevgrad – polluted in varying degrees), it was found out that no presence of endrin, toxaphene and mirex in the mothers’ breast milk in the ecologically clean region of Bankya exists, but the following POPs pesticides – hexachlorbenzene (0.012 mg/kg lipids), chlordane (0.018 mg/kg lipids), heptachlor (0.013 mg/kg lipids), dieldrin/aldrin (0.004 mg/kg lipids) and DDT total (0.499 mg/kg lipids) were present. The results for POPs pesticides residues in mothers’ breast milk from Sofia and Blagoevgrad region are still in the process of finalizing. Human health impacts: No cases of acute and chronic intoxication with persistent chlororganic pesticides have been registered in the Republic of Bulgaria Risk assessment by modeling of exposure and effects: The health risk is negligible in all regions if the risk quotient DI/Netherlands TDI is used for the calculation. The annual average concentration of DDT and Dieldrin in all monitored districts present no health risk for the general population. 133

2.3.2 ASSESSMENT WITH RESPECT TO ANNEX A, PART II CHEMICALS – PCBS IN EQUIPMENT Polychlorinated biphenyls (PCBs) are organochlorine synthetic compounds that belong to the group of industrial persistent organic pollutants, listed in Annex A, Part II of the Stockholm Convention.

2.3.2.1.Production Manifacture: The main period of manufacture of PCBs occurred from 1930 to the late 1970s in the United States of America; up to 1974 in China; up to the early 1980s in Europe, up to 1993 in Russia; and from 1954 to 1972 in Japan. The transformers are devices that can increase or decrease the voltage level of an electrical current. For most large transformers, the entire unit is filled with dielectric fluid (often an oil, possibly containing PCBs) to increase the insulation between and to cool the electric coils.

Picture 4Typical transformers, containing PCBs The quantities of dielectric contained in the transformers is directly dependant on the transformer’s capacity, kVA The following rule can be applied to estimate this quantity of electricity: 1 kVA = 1 litre of dielectric 1 litre of dielectric = 1.56 kg The quantities of dielectric, contained in a transformer depending on the transformer capacity is shown in table 68. Table 68 Quantities of dielectric Capacity of transformer, Quantity , Volume, kVA ( kg) ( Density: 1.56) 100 140 90 160 215 138 200 295 189 250 295 189 315 300 192 400 450 288 500 425 272 630 615 394 800 575 369 1 000 670 430 1 250 800 513 1 600 1 130 724 2 000 1 300 833

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The Capacitors are devices that store energy in the electric field created between a pair of conductors on which equal but opposite electric charges have been placed. The main structure of a capacitor consists of electrical conducting surfaces(thin metallic foils), separated by a dielectric material, frequently a dielectric fluid that may or may not contain PCBs.

Picture 5 High voltage capacitors and capacitor batteries

Picture 6 Power factor correction capacitors Power Factor Correction Capacitors are large capacitors that are generally of uniform size (60 cm x 30 cm x 15 cm) and may contain about 1.4 kg of 100% PCB fluid. Power factor correction capacitors are usually located near transformers, often in racks at power stations. Capacitors containing PCBs The size of these capacitors varies a great deal, from that of an ice-cube to that of a refrigerator. They can often de identified by the letters “kvar” on their identification plate. These letters show the electrical classification of the capacitor, which usually lies between 5 and 200 kVar. In practice, all capacitors manufactured between 1930 and 1977 as substitutes for dielectric liquid contain PCBs. The main countries - producers of PCBs were USA, former USSR, Italy, France, Germany, Spain, Japan, China, former Czechoslovakia, Poland, etc. Production of these chemicals was banned in 1977, when their ability to accumulate in the environment and to cause harmful effects became apparent. PCBs were gradually withdrawn at the end of 70-ies of past century in Canada, Japan, Sweden and USA and in the beginning of 80-ies – in France, Germany, Spain and England and in Russia in 1993. So, Equipment manufactured after 1979 usually is considered as not containing PCBs. Tables 69 & 70 show the various types of transformers and capacitors20, containing PCBs by manufacturing countries.

20 AMAP Report 2000: 3 “PCB in the Russian Federation: Inventory and Proposals for Priority Remedial Actions” 135

Table 69 Types of transformers, containing PCB by manufacturing country Country Transformer type USSR ТНЗ-25/10; ТНЗ-40/10; ТНЗ-630/10; ТНЗ-1000/10; ТНЗ-1600/10; ТНЗ-2500/10; ТНЗП- 630/10; ТНЗП-1000/10; ТНЗП-1600/10; ТНЗПУ-1000/10 GDR DL800Voltawerke, TDLF West Germany С; ТС Czechoslovakia РТК; РТР; РТN; Poland ТО; ТАО; ТОС; TON; TOH; TOF; TOW; France MiTR; TP

Table 70 Types of capacitors, containing PCB by manufacturing country Country Capacitor type PCB quantity, kg USSR* КШС-6.3-50; КС2-1,05-60-У1; КС-2-10.5-75-2У3; КС-2-10,5-50-2У3; КС- 10 ÷ 23 2-6,3-75-2У3; КСК-2-10,5-150-2У3; КСК-1-10,5-75-2У3; КС-2-0,38-36- 2У3; КС1-0,66-20-1У1; КС1-0,66-20-1У3; КС1-0,66-40-1У1; КСА-0,66- 20; КС2-1,05-60-2У1; КС2-0,38-50-У1; КС2-1,05-60-1У1; КС2-0,66-40- 2У1; КСК2-10,5-125-1У1; КС2-6,3-75; КСА-0,66-20-У1;KM; KЭ; GDR BK; KCI; KP; LKC; LKCA; LKCI; LKP; LKPA;LKPI; LKPF; LPXF; LPXI; LKPH; LKMI;LKUI; NKPT; NKNI; West D, CO, CD, 4RA, 4RL (produced within the period 1950-1975 ); Germany CSR DZ Poland С

* The USSR condensers have average PCB content – TCB (a mixture of trichlorobiphenyl isomers) – 16,5 kg. In the cases where the answers represent only data about the number of condensers, the value given was used for expert assessment of the quantity of PCBs in the condensers. Some of the more common trade names under which PCBs were manufactured for transformers, capacitors and other devices are shown in Table 71 and the Synonyms and trade names for PCBs by manufacturing countries – in Table 72. Table 71 Common trade names under which PCBs were manufactured for transformers, capacitors and other devices Transformers Capacitors Other Devices Aroclor Fenchlor Aroclor Elemex Abestol Nepolin Aceclor Kanechlor Askarel Eucarel Aroclor No-Flamol Apirolio Montar Clorinol Hyvol Askarel Pyranol Clophen Phenoclor Clorphen Inerteen Chlorextol Pydraul Chorextol Pyralene Capacitor21 MCS 1489 Dykanol SAF-T-Kuhl Diaclor Pydraul Diaclor Olex-SF-D EEC-18 Sorol Delor Santotherm Dykanol ТСВ Inerteen Therminol DK Sovol Turbinol Dykanol Sovtol Elemex SAF-T-Kuhl Source: Polychlorinated Biphenyl Inspection Manual, US EPA, 2004

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Table 72 Synonyms and trade names for PCBs by manufacturing countries Manufacturing Some synonyms and trade names of PCBs Country USA Apirorlio, Areclor, Arochlor, Arochlors, Aroclor/Arochlor(s), Arubren, Asbestol, Bakola 131,Biphenyl, Clophen (Germany), Cloresil, Chlophen, Chloretol, Chlorextol, Diaclor, Ducanol, Duconal, Duconol, Dykanol, Electrophenyl, Elemex, Fenocloro, Gilotherm, Hexol, Hivar, Hydelor, Hydol, Hydrol, Hyrol, Hyvol, Inclor, Inerteen, Kenneclor, Leromoll, Magvar, MCS 1489, Montar, Monter, Nepoli, Nepolin, Niren, NoFlamol, No-Flamol, Pyranol, Pyroclor, Pyrochlor, Pyronol, Safe-T-Kuhl, Saft-Kuhl, Saf-T-Kohl, Saf-T-Kuhl, Italy Abestol, Aceclor, Adkarel, ALC, Apirolio, Diarol, Dicolor, Diconal, Disconon, DK, Dykanol , Educaral ,Elinol, Eucarel, Euracel, Fenchlor, Fenclor , Germany Ask/Askarel/Askael, Auxol, Bakola, Biclor, Blacol, Chlorphen, Chorextol, Chorinol, Clophen/Clophenharz, Cloresil, Clorinal, Clorphen, Crophene, DK(deoachlorodiphenyl), Dyknol, Educarel, EEC-18, Elaol, Hydol, GDR CD,Orophene France Elenex ,Hywol, Non-Flamol, Olex-sf-d, Orophene, Pheaoclor, Pheneclor, Phenochlor, Phenoclor, Plastivar, Polychlorinated diphenyl, Polychlorinated diphenyls, Polychlorobiphenyl, Polychlorodiphenyl, Prodelec, Pydraul, Pyraclor, Pyralene, England Aroclor, Askarel ,Pyroclor, Inclor Spain Phenoclor, Pyralene Czechoslovakia Decachlorodiphenyl, Delofet O-2, Delor , Delor/Del, Delorene, Delorit, Delotherm DK/DH, Russia/ USSR Hexol ,Santothern, Santovac, Sat-T-America, Siclonyl, Solvol, Sorol, Soval, Sovol, Sovtol Poland Chlorfin, Chlorinal/Chlorinol, Chlorinated biphenyl, Chlorinated diphenyl, Chlorobiphenyl, Chlorodiphenyl, Chlorofen, Tarnol, Terphenychlore, Therminal, Therminol, Turbinol Japan Electrophenyl, Inertenn, Kanechlor, Kaneclor, Kennechlor, pyralène, Santosol, Santotherm,

Production of Transformers in the Republic of Bulgaria The manufacturers of transformers in the Republic of Bulgaria are: Transformer plant –“Hyundai Elprom Trafo” – Sofia; Transformer plant –“Elprom Trafo NS” – Kyustendil; Transformer plant – town of Godech The first oil transformer manufacturer in Bulgaria is “Hyundai Elprom Trafo” – Sofia, established late in the 50s. The transformers manufactured at that time had been filled with imported oils. After the commissioning of the “Plama” facility in the town of Pleven in 1970 година, “Hyundai Elprom Trafo” started production of transformers with Bulgarian oils, manufactured in Plama. Special transformers are manufactured in the “Hyundai Elprom Trafo” facility, mainly for energy, metallurgy, and mining. In the 80s, part of the manufacturing capacities of “Hyundai Elprom Trafo” – Sofia was moved into “Elprom Trafo NS” facility in the town of Kyustendil, where assemblying of distributing oil transformers with power of up to 1000 kVA was concentrated.

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Picture 7 Power Transformers with up to 1000 kVA 1000 кVA. These transformers are designed for putting into kiosk switchgears from the electrical grid. The main quantities of transformers have been manufactured within the period 1967-1980, and are significantly lower at present. Within the whole period 1950 – 1990 г. in Bulgaria were produced са 216983 transformers. In 1990, the available number of 52492 transformers, Bulgarian production do not contain PCBs. The inventory study showed that none of the three manufacturers produce or have never produced PCBs transformers.

Manufacturers of Capacitors in Bulgaria The manufacturers of capacitors in the Republic of Bulgaria are: Capacitor plant “Konis” JSC – town of Kyustendil Capacitor plant “Amatitza” JSC – village of Kovachevtsi

The first capacitors plant, “Konis” JSC in the town of Kyustendil was commissioned in 1965. This was followed by the establishment of “Amatitsa” JSC in Kovachevtski village, where capacitor batteries are filled with oil in “Konis” JSC in Kyustendil. The result of the inventory study is that these companies do not and have never manufactured PCBs containing capacitors.

Production of Transformer and Capacitor Oils in Bulgaria

The manufacturers of oil (including transformer and condenser oil) are: “Plama” JSC – town of Pleven “Lubrica” JSC – town of Russe “Prista Oil” JSC – town of Russe “INSA” JSC – town of Rakovski “Lukoil Neftochim” JSC – town of Burgas “Verila” JSC – town of Sofia The result of the inventory study is that these companies do not and have never manufactured PCB oils. Conclusion:

Polychlorinated biphenyls (PCBs) and PCBs Equipment (transformers and capacitors) have never been manufactured and are not manufactured in the Republic of Bulgaria.

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2.3.2.2. Use Polychlorinated biphenyls (PCBs) are used intensively in the industry since 1930. Theoretically, a total of 209 possible PCB congeners exist, but only about 130 of these are likely to occur in commercial products. Commercial PCBs are a mixture of about 50 congeners. Their properties (low dielectric constant, chemical and thermal stability, low flammability, low water solubility, high solubility in organic solvents, excellent electrical insulators, low volatility, etc.) made them particularly suitable in multitude of applications such as oil in transformers, dielectrics in capacitors, hydraulic fluids in hydraulic tools and equipment, heat exchange liquids. They also found wide-spread use as lubricants for turbines and pumps, in the formulation of cutting oils for metal treatment and as ingredients in a range of sealants, adhesives, paints and carbonless copying paper. Worldwide about 1 million tons of PCBs (60% of total amount) are used as dielectric fluids in electrical equipment such as transformers, capacitors, circuit-breakers, voltage regulators, etc. The subsections below identify and classify PCBs use area, based on their presence in three types: Closed systems – a closed PCB application is one in which the PCBs are held completely within the equipment, and no PCB exposure to the environment occur under ordinary circumstances (electric capacitors and transformers). Partially closed systems – Partially closed PCB applications are those in which the PCB oil is not directly exposed to the environment, but may become so periodically during typical use. These types of use may also lead to PCB emissions, through air or water discharge. Examples of partially closed systems include heat transfer and hydraulic systems, and vacuum pumps. Open systems – Open PCB applications are those in which PCBs are in direct contact with their surroundings and thereby may be easily transferred to the environment. Plasticizers are the largest group of open applications and are used in PVC, neoprene, and other chlorinated rubbers. In addition, PCBs have been used in a number of other open uses, including paints as flame-retardants, adhesives as plasticizers, and in surface coatings as flame-retardants, inks and insulating materials and pesticides. In Bulgaria PCBs were used mainly dielectric fluids in electrical equipment such as transformers and capacitors. Till 1971 all transformers and capacitors were filled with imported oils, mainly Russian.

2.3.2.3.Import Import of Transformer oils, containing PCBs The transformer oils imported in Bulgaria in the period 1955-1972 amounted to 24120 tonnes, from the USSR, Chechoslovakia, and Hungary as 83% of the transformer oils being imported from the former USSR. The only exporter of Sovtol –10 transformer oil from the USSR is the Orgsintez PO plant in the town of Novomoskovsk, which had exported 39,5 tonnes only for Cuba, Vietnam and Pakistan within 1981 ÷1989. The transformer oil imported from Czechoslovakia is 1946 tons, or 8% of the total oil imports. In the period 1962 ÷ 1984, the only manufacturer- “Chemko – Stražske” – of PCBs transformer oil of the Delor brand there has not made exports for Bulgaria.21 The study results for transformer oil imports showed that: Transformer oils imported from the former USSR do not contain PCBs; Hungary is not among the manufacturers of PCB transformer oils; The transformer oils imported form the former Czechoslovakia do not contain PCBs.

21 Proposal for National Implementation Plan for POPs in Czech Republic,TOCOEN Report No.252, January 2004. 139

Conclusion: The imported 24120 t transformer oils in Bulgaria within the period 1955 ÷1972 do not contain PCBs.

Import of Transformers, containing PCBs The NIS summarized data about import of transformers and substations for the 1950 – 1990 period show: Till 1970 no transformers have been imported in Bulgaria. For the period 1970 г.÷1990 г. in the country 1954 transformers have been imported . Until 1971, all transformers manufactured in Bulgaria were filled with imported oil, mainly from the USSR. Following the start up of production of Bulgarian oils in 1972, the import of oil was stopped and all transformers had been filled with Bulgarian oils, not containing PCBs.. No information exists about any imports of transformers after 1990. Transformers, manufactured after 1988 do not contain PCBs due to ceasing PCBs production on global scale. The most transformers had been imported from Romania – 951, followed by Korea – 378, the USSR – 313, West Germany and East Germany – 238, Czechoslovakia – 55. Romania and Hungary, Corea, are not manufacturers of PCBs and China had stopped PCBs production in 1974. However, this is no reason for 1248 transformers imported from these countries to be classified as “not containing PCBs” due to the possibility that they may have been filled with imported oils containing PCBs.

Conclusions: In Bulgaria the maximum assumed number of transformers, containing PCBs could be only those imported 1954 . Of all transformer import totalling 1954, most likely to contain PCBs are the transformers imported from PCBs manufacturing countries – the USSR, West Germany, East Germany, and Czechoslovakia – total 606 transformers, representing 31% of all imports.

Import of Capacitors, containing PCBs No data available about any imports of capacitors with volume larger than 5 dm3. 2.3.2.4. Export Export of Transformers, containing PCBs The NIS summarized data about export of transformers and substations for the 1950 – 1990 period show: For the entire period of 1950 – 1990, the exports from among the 216983 manufactured transformers (70136 + 146847) were 144475 Out of totally produced 70136 transformers for the period 1950 – 1970 from Bulgaria 20079 transformers have been exported. Out of totally produced 146847 transformers for the period 1971 – 1990 from Bulgaria 11809 transformers and 66333 power substations with a minimum of 2 transformers each have been exported or in total 144475 transformers.

Conclusion: For the entire period of 1950 – 1990, the exports from among the 216983 manufactured transformers were 164554 transformers, not containing PCBs.

Export of Capacitors, containing PCBs No data available about any exports of capacitors with volume larger than 5 dm3.

140

Conclusions:

R Bulgaria is not among the countries – manufacturers of PCBs. The country has never manufactured and does not manufacture PCBs equipment (transformers and capacitors) and oils , containing PCBs. The country did not export equipment and oils, containing PCBs. The imported transformers oils do not contain PCBs. For the period 1970 г.÷1990 г. in the country totally 1954 transformers have been imported . Of all transformer imports, most likely to contain PCBs are the transformers imported from PCBs manufacturing countries – the USSR, West Germany, East Germany, and Czechoslovakia.

2.3.2.5. PCBs in transformers and transformer oils

An inventory of transformers and transformer oils, containing PCBs on the territory of Republic of Bulgaria by 2003 had been carried out based on voluntary submission of data. The 685 letters sent were responded to by 187 companies which represent most of the owners of transformers – power supply companies from the system of the National Electricity Company (NEC); the Bulgarian Railways; Thermal Power Stations; Hydro Power Stations; the chemical industry; metallurgy, etc. in Bulgaria. The transformers with volume above 5 dm3 and the transformer oils are divided into four main groups: Group І – containing > 0,05 % by weight (500 ppm) PCBs; Group ІІ –containing > 0,005 % by weight (50 ppm)< 0,05 % by weight (500 ppm) PCBs; Group III – containing PCBs assumed; Group ІV – not containing PCBs. This grouping is based on a comparison of data received from the owners about the type of transformers; year of production, country-producer and the referеnce list of transformer types and transformer oil brands, containing PCBs. 43644 transformers and 45715 tonnes of transformer oil have been inventoried.

2.3.2.5.1. Group I: Transformers with volume above 5 dm3 and transformer oils, containing > 0,05 % by weight (500 ppm) PCBs The transformers and the transformer oils have been placed in the group with content of PCBs >500 ppm because of the following reasons : The transformers are filled with mineral oils manufactured prior to 1988. The main brands transformer oils are: Sovtol-10; TGL; Pyralene; Pyroclor; Clophen; PCB and С, which contain PCBs >500 ppm and had been imported from countries-manufacturers of PCBs. Most transformers are of the type ТНЗ, ТНПЗ, ТНП, ТНЗПУ and ТНПУ, produced in USSR and TDLF produced in the GDR, classified as containing > 500 ppm PCBs.

Tables 73 & 74 present data about in-use transformers and transformer oils, containing > 500 ppm PCBs and the brand names of the transformer oils, and on fig.23 – their distribution by districs in Bulgaria for 2003.

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Table 73 Transformers and transformer oil containing > 500 ppm PCBs by districts in Bulgaria for 2003 No. Area Operating Oils Used, in Fresh, in Total Transformers storage storage pcs tonnes tonnes tonnes tonnes 1 Burgas 4 4,1 4,1 2 Varna 2 82,4 82,4 3 V. Tarnovo 3 0,615 0,615 4 Vratsa 45 4,26 4,26 5 Pernik 13 23,33 3,85 27,18 6 Pleven 9 9,01 9,01 7 Sofia-city 64 107,74 6,03 113,77 8 Sofia-district 6 13,23 13,23 9 Stara Zagora 4 1,54 1,54 10 Haskovo 8 64,32 6,8 71,12 Total for 158 310,545 9,88 6,8 327,225 Bulgaria The total number of operating transformers,containing > 500 ppm PCBs is 158, located on the territory of 10 districts; The total quantity of transformer oils > 500 ppm PCBs in Bulgaria amounts to 327,225 t.

The biggest number of transformers containing > 500 ppm PCBs is present in the large industrial centres: Sofia-city – 40, 51% (64 pcs), Vratsa – 28,48% (45 pcs) and Pernik – 8,23%(13 pcs), This is due mainly to the fact that the located in these regions large enterprises from electric power, chemical and metallurgical industries have been in operation since 30-40 years ago, and they are owners of Soviet and East German transformers, containing > 500 ppm PCBs, being manufactured prior to 1988. The highes % share in transformer oils is observed in the towns of Sofia city - 34,77%; Varna - 25,18% and Haskovo - 21,73%. The disbalance of % distribution by number of transformers and by oil quantities can be noted. Mainly, that is due to the differences in technical parameters of the equipment. For instance, 2 transformers in Varna district contain 82,4 tonnes of transformer oil, containing PCBs. This is so because of the large TEPS in the area which owns large power transformers with a large volume of dielectri Table 74 Transformer oil containing > 500 ppm PCBs, by commercial brand and by districts in Bulgaria for 2003 № Operating Commercial brand of oil, t District transformers pcs Pyroclor C TGL Sovtol-10 Clophen Pyralene РCB Total 1 Bourgas 4 1,72 2,38 4,1 2 Varna 2 82,4 82,4 3 V.Tarnovo 3 0,615 0,615 4 Vratsa 45 4,26 4,26 5 Pernik 13 27,18 27,18 6 Pleven 9 9,01 9,01 7 St.Zagora 4 1,54 1,54 8 Haskovo 8 39,6 31,52 71,12 9 Sofia city 64 54,98 56,32 2,47 113,77 10 Sofia distr. 6 13,23 13,23 Total 158 1,72 2,38 126,26 127,525 9,01 56,32 4,01 327,225

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The main brands of transformer oils with PCBs > 500 ppm in Bulgaria are: Sovtol-10; TGL; Pyralene; Pyroclor; Clophen; PCB and С. The quantity of PCBs transformer oils brands Sovtol-10; Pyralene; Pyroclor; Clophen; PCB amounts approximately to 198,6 tones equal to 61% of total quantity of PCB oils. The largest share belongs to USSR made transformer oil Sovtol-10:39% (127,525 tonnes); followed by the East German oil TGL – 38%,(126,26 tonnes); the French Pyralene – 17% (56,32 tonnes) and the East-German oil Clophen - 3%(9,01 tonnes). The owners of transformers containing > 500 ppm PCBs are 12 enterprises, mainly from the energy, chemical and metallurgical sectors (fig.23).

Figure 23Distribution of Transformers, containing > 500 ppm PCBs by sectors in Bulgaria for 2003 The highest % share by number of transformers is held by 5 companies from the sector of metallurgy – 58%, possessing 92 transformers filled mainly with transformer oil of the brands Sovtol-10, Pyralene and Clophen. Two metallurgical companies have declared 9,88 tonnes of used transformer oil brand Sovtol -10, USSR production. In the power sector, there are 6 companies within the National Electricity Company which own 53 transformers, representing 34% of all 158 transformers. In the chemical industry sector 3 companies own 13 transformers, representing 8%. The predominant dielectric is oil of the brands Sovtol-10 and Pyroclor.One company has declared 6,8 tonnes of fresh transformer oil Sovtol-10 on stock. 11 enterprises have not declared any used or fresh transformer oil, containing > 500 ppm PCBs. With 110, 845 tonnes of Sovtol -10 are filled 50 transformers of the type TNZ, TNPZ, TNP and TNPU, manufactured by the USSR, and this amounts to 31,65% of the total number of transformers, and 35,69% of the transformer oils in the in-use transformers containing > 500 ppm PCBs in Bulgaria. Conclusions: The total quantity of transformer oils , containing > 500 ppm PCBs in Bulgaria amounts to 327,225 tons, out of which 310,545 in 158 in-use transformers. Only the total quantity of transformer oils, containing > 500 ppm PCB has been identified, unlike the weight of the equipment due to gaps in the declared data. The out-of-use waste transformer oils, containing > 500 ppm PCBs are 9,88 tonnes. The fresh transformer oils on stock, containing > 500 ppm PCBs amount to 6,8 tonnes.

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2.3.2.5.2. Group II: Transformers with volume above 5 dm3 and Transformer oils, containing > 0,005 % by weight (50 ppm)< 0,05 % by weight (500 ppm) PCBs The transformers and the transformer oils have been placed in the group with content of PCBs >50 ppm because of the following reasons : The transformers are filled with mineral oils manufactured prior to 1988 and with unknown PCB concentrations; No data are available about the transformers’ power (КVA), being the main criterion in determining the concentration of PCBs in them; No information about the transformer production dates and equipment-weight is available; Most transformers are of the TDLF type, produced in the GDR, classified as containing PCBs; No information about the dielectric manufacturer and oils production dates is available; All transformer oils are produced in the GDR – a country manufacturing PCBs. Table 75 shows data about in-use transformers and transformer oils, containing >50 ppm PCBs, by districts. Table 75 Transformers and transformer oils with PCB content > 50 ppm by districts in Bulgaria for 2003 Тransformers, Oils , № District Pcs. tons 1. Blagoevgrad 2 66 2. Burgas 6 243,1 3. Varna 5 147,1 4. Veliko Tarnovo 5 211,8 5. Vratsa 4 208 6. Pleven 1 33 7. Plovdiv 2 138 8. Sofia-city 2 40,5 9. Sofia-district 10 453 10. Stara Zagora 4 101,6 Total for Bulgaria 41 1642,1

On the territory of Bulgaria there are totally 41 transformers, containing > 50 ppm PCBs and 1642,1 t transformer oils, located in 10 districts; The owners of these transformers are 2 companies from energy sector. The first company is a holding structure within the system of the National power supply net with 23 branches in 10 districts of Bulgaria, differentiated as independent enterprises. This company owns 37 transformers (90%) with 1434.1 tonnes (87%) of dielectric.The other company is the Nuclear Power Plant “ NPS Kozlodui” SA, owner of 4 transformers (10%) with 208 t (13%) of dielectric; The largest number of equipment is located in Sofia district (10 pcs), followed by Burgas (6 pcs), Varna and V.Tarnovo districts ( 5 pcs each). In regard with transformer oils, the leader is again Sofia district (453 t), followed by Burgas (243,1 t), V.Tarnovo (211,8 t) and Varna (147,1 t). An impression was made that the two transformers located in Plovdiv district are filled with 138 t dielectric, containing > 50 ppm PCBs . Table 76 shows the distribution of in-use transformers in energy sector and transformer oils, containing > 50 ppm PCBs by number of enterprises and districts in Bulgaria for 2003.

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Table 76 Transformers and transformer oils, containing > 50 ppm PCBs in energy sector by number of enterprises and districts in Bulgaria for 2003

Transformers Transformer oils

Number № District of enterprises Type Producer Pcs Type Tons

1 Blagoevgrad 1 ДКДF-A1 GDR 2 GB Nytrafo 11 66 KDRF 30000 GDR 2 TRF-GL 168 TDLF-25000 GDR 1 TRF-G 18 5 2 Burgas TDLF-25000 GDR 1 TRF-GL 18 TDLF-25000 GDR 1 TRF-GL 18 TDLF-40000 GDR 1 TRF-GL 21,1 TDLF40000 GDR 1 TRF-G 21,1 4 TDLF25000 GDR 1 TRF-GL 18 3 Varna KDRF/v300001 GDR 1 TRF-GL 69 TDLF40000 GDR 2 TRF-G 39 DKDF-A1 GDR 1 TRF-G 31,8 3 4 V.Tarnovo TDLF-40000 GDR 2 TRF-G 42 KDRF-300001 GDR 2 TRF-GL 138 5 Pleven 1 DKDF-A1 GDR 1 TRF-G 33 6 Plovdiv 1 KDRF300001 GDR 2 TRF-GL 138 TDLF31500 GDR 1 TRF-G 22,5 7 Sofia-city 2 TDLF25000 GDR 1 TRF-G 18 TDLF25000 GDR 1 TRF-G 18 4 DKDF-A1 GDR 5 ТRF-G 159 8 Sofia-district KDRF300001 GDR 2 TRF-GL 138 KDRF300001 GDR 2 TRF-GL 138 2 TDLF25000 GDR 2 TRF-G 56,6 9 Stara Zagora ТDLF50000 GDR 2 TRF-G 45 10 Vratsa 1 KWE160001 GDR 4 Nitro10TX 208 Total 24 41 1642,1

The identified 41 transformers, containing 1642,1 tonnes of oils are manufactured by the former GDR .Based on the transformer type TDLF, they are classified as equipment, containing > 50 ppm PCBs. Conclusion:

The owners of transformers containing PCBs >50 ppm are 2 companies from the Energy sector. Only the total quantity of transformer oils in Bulgaria, containing PCBs >50 ppm has been identified as 1642.1 t in 41 in-use transformers but not their weight because of gaps in the declared data.

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2.3.2.5.3. Group III: Transformers and transformer oils with PCBs assumed

The transformers and the transformer oils have been placed in this group according to the generally accepted rules for classification of transformers with assumed PCBs content, according to the Basel Convention: Transformers filled with mineral oils manufactured prior to 1988 and with unknown PCBs concentrations; Unknown date of production of the transformers; Unknown date of production and type of the dielectric. Table 77 shows data about in-use transformers and transformer oil with PCBs assumed by districts. Table 77 Transformers and transformer oils with PCBs assumed content in Bulgaria by districts for 2003 Oils on stock № District Enterprises Transformers Oils Oils number pcs tons Waste Fresh Total tons tones tons 1 Burgas 3 44 10,81 10,81 2 Varna 2 3 84 84 3 Veliko 4 884 508,8 4,72 1,2 514,72 Tarnovo 4 Vratsa 3 59 272,96 2,62 20,44 296,02 5 Gabrovo 2 1100 567,1 567,1 6 Kardzhali 1 8 76,86 76,86 7 Kyustendil 2 13 219,05 219,05 8 Lovech 2 10 7,53 7,53 9 Pleven 1 9 0,18 0,18 10 Plovdiv 2 22 164,81 164,81 11 Razgrad 2 21 6,5 6,5 12 Russe 1 1 28,1 28,1 13 Silistra 2 804 232,1 232,1 14 Sliven 1 1 0 15 Sofia-district 1 5 0,74 0,74 16 Stara Zagora 4 94 295,04 2,9 15,2 313,14 17 Targovishte 1 3 9 9 18 Yambol 1 1 0 Total for Bulgaria 35 3082 2483,58 10,24 36,84 2530,66

Owners of transformers and transformer oils with PCBs assumed are 35 companies from the energy sector: Nuclear power station, thermal power stations, Hydro power stations, Power supply companies and to a less extent, chemical, machine building, metallurgy and light industries. 3082 in-use transformers with PCBs assumed, containing 2483,58 t transformer oils have been identified in 18 administrative areas in Bulgaria. Most of these transformers are imported mainly from USSR, GDR, Poland, Czeck Republic and had been manufactured prior to 1988. The type, power and weight are not known about a large portion of the transformers. The composition of most transformer oils is unknown. The largest number of transformers with PCBs assumed is located in 3 of the districts (2788 pcs), comprising 89% of all transformers in this group: respectively in Gabrovo – 35%; Veliko Tarnovo – 28%, and Silistra – 26%. This is due to the fact that the Power supply companies in those district had not presented data for the transformer types and transformer oils brands.

146

There are 10,24 t of out-of-use waste transformer oils with PCB assumed . The fresh transformer oils on stock, with PCBs assumed are 36,84 t.

Conclusion:

These transformers are owned by 35 companies, mainly from the Energy sector. and to a less extent, chemical, machine building, metallurgy and light industries. A total of 3082 transformers with PCBs assumed and 2531 tonnes of transformer oil have been identified in 18 administrative areas in Bulgaria. Fresh transformer oils with PCBs assumed on stock are 36,84 t. Waste transformer oils with PCBs assumed on stock are 10,24 t. Only the total quantity of transformer oils with PCB assumed has been identified, – but not the weight of the equipment, due to insufficient data for the type, producer, power and weight of transformers and for the transformer oils brands.

2.3.2.6. PCBs in capacitors and capacitor oils An Inventory of capcsitors and capacitor oils, containing PCBs on the territory of Republic of Bulgaria by 2003 had been carried out based on voluntary submission of data. Letters-questionaries were sent to the same companies-owners of transformers. The 685 letters sent were responded to by 187 companies owners of capacitors. The capasitors and capacitor oils are divided into three main groups: Group І – containing PCBs; Group II – containing PCBs assumed; Group ІII – not containing PCBs. This grouping is based on a comparison of data received from the owners about the type of capacitors and capccitor oil; year of production, country-producer and the list of capacitor’s types and capacitor’s oil brands, containing PCBs. A total number of 17689 capacitors and a quantity of 26 tonnes totally of capacitor oils have been inventoried. 2.3.2.6.1. Group І – Capacitors and capacitor oils, containing PCBs The capacitors and the capacitor oils have been placed in the group with containing PCBs because of the following reasons : The capacitors are filled with mineral oils manufactured prior to 1988. The main brands capacitor oils are: Orophen, Isokond and CD, which contain PCBs and had been imported from countries-manufacturers of PCBs. Most transformers are of the type KC, КСК and КМ, produced in USSR and LK, LKCI, LKCL, LPXE and LPXF, produced in the GDR, classified as containing PCBs.

Table 78 shows data about the total number of capacitors and the quantity of capacitor oils, containing PCBs by districts in Bulgaria for 2003.

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Table 78 Capacitors and capacitor oils, containing PCBs by districts in Bulgaria for 2003.

Capacitors on stock Capacitors № District Enterprise Capacitors Oils spare Out-of-use TOTAL pcs. pcs. kg pcs. pcs. pcs. 1 Burgas 3 15 721,5 15 2 Veliko Tarnovo 1 100 50 150 3 Lovech 1 319 21 340 4 Pazardzhik 1 348 87 87 5 Plovdiv 3 576 1694 18 594 6 Russe 1 8 8 7 Sofia-city 2 485 4560 456 941 8 Stara Zagora 1 180 180 9 Haskovo 2 86 575 14 100 Total for Bulgaria 15 1769 7898,5 32 614 2415

The owners of PCBs capacitors are 15 enterprises, mainly from the chemical and mining industries, machine building and metallurgy. Many companies have not declared the quantities of oil in the capacitors, and for other - no data is available about the type and number of other capacitors. In total, 2415 capacitors containing PCBs, or 13% of all capacitors in Bulgaria have been identified, located on the territory of 9 administrative areas. There are 1769 in-use capacitors containing PCBs, or 73% of all capacitors containing PCBs, as 59% of which are located in Sofia city and Plovdiv. The in-use PCB capacitors have been imported from the former Eastern Germany and USSR, the % ratio being: GDR – 68% and the USSR – 32%. The Soviet capacitors have average PCBs content оf 16,5 kg. There are 32 spare PCBs capacitors on stock. There are 614 out-of-use PCBs capacitors. The capacitors oils containing PCBs, currently in the equipment are 7,899 tons. As per an expert assessment the actual quantity of capacitors oils containing PCBs, probably is approx. 40 tonnes, i.e. 5 times more than the declared 7,9 tonnes. Again the lack of data about the number of capacitors or about oil quantities makes the distribution by % inaccurate, but it can be noted, however, that machine building industry holds the highest % share by number of capacitors and by oil quantities.(Fig. 24 & 25).

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Distribution of PCB capacitors by sectors in Bulgaria,

refering the number of capacitors 203 pcs- – 8% 662 pcs – 27% 1252 pcs – 53%

298 pcs – 12%

Chemical industry Metallurgy and extraction Food industry Machine building

Figure 24 Distribution of PCB capacitors in Bulgaria by sectors for 2003, referring the number of capacitors

Distribution of PCB capacitors in Bulgaria by sectors, referring the quantity of oil

2415,5 kg – 31% 4560 kg – 58%

575 kg – 7%

348 kg – 4%

Railway Chemical industry Metallurgy and extraction Machine building

Figure 25 Distribution of PCB capacitors by sectors in Bulgaria, referring the oil quantity in kg for 2003 Conclusions: The owners of PCBs capacitors are 15 enterprises, mainly from the chemical and mining industries, machine building and metallurgy. The Machine building sector holds the highest share by number of PCB condensers (53%), and by oil quantity (58%). The total number of PCBs capacitors is 2415, out of which in use are 1769 pcs., containing 7,899 tonnes of capacitor oils. There are 32 spare PCBs capacitors on stock. There are 614 out-of-use PCBs capacitors on stock Many companies have not declared the quantities of oils in their capacitors , and others - no data is available about the type and number of the capacitors. As per an expert assessment the actual quantity of capacitors oils containing PCBs, probably is approx. 40 tonnes, i.e. 5 times more than the declared 7,9 tonnes.

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2.3.2.6.2. Group II – Capacitors and capacitors oils with PCBs assumed Capacitors and capacitors oils are grouped according to the generally accepted rules for classification of PCBs assumed according to the Basel Convention: Capacitors manufactured prior to 1985 and of unknown PCBs concentration; Unknown production date or type of the Capacitors Unknown date of production and type of the dielectric; Table 79 shows data about the total number of capacitors and the quantity of capacitor oils, containing PCBs assumed by districts in Bulgaria for 2003.

Table 79 Capacitors and capacitors oils with PCBs assumed by districts in Bulgaria for 2003. Capacitors on stock Capacitors № District Enterprise Capacitors Oils spare Out-of-use TOTAL pcs. pcs. kg pcs. pcs. pcs. 1 V.Tarnovo 1 54 54 2 Vratsa 2 61 1650 61 3 Lovech 1 9 9 4 Montana 1 24 24 5 Pazardjik 1 36 36 6 Pleven 1 14 14 7 Plovdiv 3 587 1100 151 738 8 Razgrad 1 60 400 60 9 Russe 1 5 5 10 Smoljan 1 114 26,22 114 11 Sofia city 5 50 88 17 46 113 12 Sofia district 5 83 53 48 184 13 StaraZagora 2 1053 24 30 1107 14 Haskovo 1 18 97 115 Total for Bulgaria 26 2159 3264,22 245 230 2634

The owners of PCBs assumed capacitors are 26 enterprises from the following sectors – power industry, chemical and mining industries, machine buildingq metallurgy and food industry; 2634 PCB assumed capacitors have been identified in Bulgaria representing 15% of the total number of capacitors in the country, located in 14 districts; The PCB assumed capacitors currently in use are 2159 or 81% of all PCB assumed condensers, as 75% of them are located in the areas of Stara Zagora and Plovdiv ; There are 245 spare capacitors with PCBs assumed on stock. There are 230 phased - out capacitors with PCBs assumed on stock. The PCBs assumed capacitorr oils currently in the equipment are 3,264 tons.

150

Distribution of Capacitors with PCBs assumed by industry in Bulgaria for 2003

6,6% 5,5% 2,8%

6,9%

13,8% 64,3%

Machine building – 1694 Food industry - 364 Metallurgy - 181 Mining - 175 Chemical industry - 146 Power industry - 74

Figure 26 Distribution of Capacitors with PCBs assumed by industry in Bulgaria for 2003

The Machine building sector holds the highest share by total number of PCBs assumed capacitors (64,3%), followed by food industry – 13,8%. The rest sectors are with almost equal share ranging 3 % ÷ 7% (fig.26). The PCBs assumed capacitors are imported mainly from the USSR, GDR and Italy. Information about the type and manufacturer of the capacitors exists only for 966 out of 2634 PCBs assumed capacitors. No information about the manufacturing country, the type of capacitors or the brand of the oil is available for 1668 capacitors. Conclusions: The owners of PCBs assumed capacitors are 26 enterprises from the following sectors – power industry, chemical and mining industries, machine buildingq metallurgy and food industry; 2634 PCB assumed capacitors have been identified in Bulgaria representing 15% of the total number of capacitors in the country, located in 14 districts; The PCB assumed capacitors currently in use are 2159 containing 3,264 t oils. Machine building sector holds the highest share by total number of PCBs assumed capacitors - 64,3%. PCBs assumed capacitors are imported mainly from the USSR, GDR and Italy. Information about the type and manufacturer of the capacitors exists only for 966 out of 2634 PCBs assumed capacitors. No information about the manufacturing country, the type of capacitors or the brand of the oil is available for 1668 capacitors.

2.3.2.7. Existing policy and regulatory framework Bulgarian legislation for Chemicals Management with relevance to PCBs (Annex D, Part II of Stockholm Convntion) includes: Law on Protection against Harmful Impact of Chemical Substances and Preparations (LPHICSP), promulgated in SG 10/2000, amended and supplemented SG 114/2003. Regulation relating to bans and restrictions on the marketing and use of Dangerous Chemical Substances and Preparations, promulgated in SG 62/2004;

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Regulation on Import and Export of Dangerous Chemical Substances and Preparations on the territory of the Republic of Bulgaria, promulgated in SG 63/2004;

2.3.2.8. Environmental Monitoring Levels Polychlorinated biphenyls (PCBs) are synthetic organic chemicals comprising 209 individual chlorinated biphenyl compounds (known as congeners). Exposure to each of these compounds is associated with different levels of risk for harmful effects. There are no known natural sources of PCBs. Although PCBs are no longer manufactured, people can still be exposed to them. The two main sources of exposure to PCBs are the environment and the workplace. Because of resistance to degradation, PCBs persist in the environment for decades. Once released into the environment, PCBs adsorb strongly to soil and sediment. As a result, these compounds tend to persist in the environment with half-lives for most congeners ranging from months to years. Leaching of PCBs from soil is slow, particularly for the more highly chlorinated congeners, and translocation to plants via soil is insignificant. Cycling of PCBs through the environment involves volatilization from land and water surfaces into the atmosphere. In Bulgaria the existing data on soil, surface and ground water monitoring for PCBs contamination reffer to pollution caused by unintentional release of PCBs emissions (see item 2.3.4. POPs releases). Environment Exposure: All environmental contaminants have “routes of exposure” to living species. Each contaminant may have a different route of exposure based on its human uses, chemical and physical properties and the media into which it is introduced. The basic route of exposure for all compounds however can be simplified into three stages: Direct Release to the Environment – spills, emissions, dumping, fires, etc.; Local Migration – gravity-induced flow, advective flow in surface water, groundwater flow, diffusion in water, dispersion in air, precipitation and settling in water and air, uptake and movement in non-migratory animals, anthropogenic activities, etc.; Long Range Transport – advective flow in water, advective flow in air, uptake and movement in migratory animals, precipitation and settling in water and air. PCBs are all denser than water, semi-volatile or non-volatile, relatively non-water soluble and relatively viscous or solid at ambient temperatures. They are considered “DNAPLs” (dense non- aqueous phase liquids). Therefore these compounds in the environment will not disperse quickly in air or water, will sink in water and will not flow quickly over or through soil. Therefore spills to

152 soil can be contained or cleaned up completely if the spill is discovered and acted upon promptly. However spills and other emissions that are not acted upon in a timely manner result in downward migration to the sediment layers of surface water or to the bedrock and groundwater in a soil-spill situation. The PCBs then move laterally and further downward under the force of gravity and laterally attached to solid particles that are suspended in the water or are moving with bedload. Although there are many convincing studies that support the conclusion that PCBs are associated with specific effects in certain species (i.e. immunosuppression, endocrine disruption, reproductive and developmental disorders in polar bears, beluga whales, narwhal, and some migratory birds such as the peregrine falcon), there is at present still a significant lack of dose-response data for such effects, and there are some studies which support conclusions to the contrary (ATSDR, 2000; Braune et al., 1999; Muir et al., 1999; ACSH, 1997).

No studies has been made in Bulgaria, investigating the PCBs levels in air over industrial sites, where PCBs equipment is located. No studies has been made for the soil contamination cause by PCBs equipment. No studies has been made for the surface water contamination cause by PCBs equipment.

2.3.2.9. Human exposure and PCBs health impacts

General population exposure22 PCBs are present in the environment all over the world, due to their high persistence and lipophilic properties. However, the exposure of the general population via air is very low. Exposure of the general population to PCBs is principally through food chain. The primary route of humans exposure to PCBs appears to involve the consumption of contaminated foods, particularly meat, fish, and poultry. Babies could be indirectly exposed by moyhers’ milk.

Occupational exposure Occupational exposure occurs during PCB use by electrical or other industries. It might also be widespread among mechanics in contact with lubricating oils and hydraulic fluids, among workers who have contact with varnishes and paints. Furthermore, exposures have occurred through accidents and occupational exposure – for example during the repair of transformers and capacitors, PCBs equipment accidents as leakages and spills, or during handling of toxic wastes. Due to recent preliminary PCBs Equipment Inventory, in Bulgaria no studies has been made for occupational exposure cause by PCBs equipment leaks or among mechanics being in long-term contact with lubricating oils and hydraulic fluids, containing PCBs.

Accidental exposure Accute emergency events may cause extremely high concentrations of PCBs in air, particularly in cases when PCBs are burnt or heated (fire,short circuit with electric arching, burning in welding, etc.) In case of extensive leaks of unheated PCBs from capacitors much higher concentrations could be found in workroom air. Very high concentrations of these toxic chemicals may be found in soot emitted in connection with fires and explosions of PCBs transformers and capacitors. When evaluating PCB accidental exposure, it is important to take into account skin absorption from surfaces and tool, in addition to exposure via inhalation. Thus, skin contamination, and the

22 Polychlorinated Byphenils and Terphenyls (2nd edition), IPCS,WHO,Geneva, 1993,pp 26-29. 153 ingestion and inhalation of soot particles, may result in serious exposure in PCBs accidents and emergencies. No accidents with PCBs equipment had been reported by PCB equipment owners in Bulgaria.

Effect to Human health PCBs usually occur as mixtures of many congeners, and many of the data on the toxicity of PCBs are based on the testing of these mixtures. There are great difficulties in assessing human health effects separately for PCBs, since , quite frequently, dioxins (PCDDs) have been present in the PCB mixtures to which humans have been exposed.The presence of PCDDs has occasionally been seen in accidents with certain PCB/chlorobenzene mixtures. Commercial PCBs have been shown to be contaminated with PCDDs and, therefore, in many cases it is unclear whether effects were attributable to the PCBs themselves or to much more toxic PCDDs. Some of the human health effects believed to be, at least in part, associated with PCB exposure are summarized below (ATSDR, 1999): immunotoxicity – immunosuppressant, increased sensitivity towards infectious diseases, increased incidences of ear and upper respiratory tract infections, lower rate of successful immunization; reproductive/developmental effects – failure to conceive, decreased birth weight, impairment of neurological development; neurological/behavioral effects – impaired learning ability, attention and cognitive deficits, deficiencies in psychomotor development, leaning and memory deficits, impaired visual recognition; and cancer – postulated that PCBs may be associated with liver, gastrointestinal, skin and biliary tract cancers. PCBs effects on human health include: liver and thyroid gland damage, skin and eye changes, immunitoxicity, neurobehavioural deviations, reduced body mass of the newly born, reprotoxicity and carcinogenity. PCBs can damage the ductless glands. JARC classified PCBs in 2A group as probably carcinogenic for humens They have also been classified as endocrine disruptors in an intact organism. No purposeful studies on target groups workers or risk groups of population for PCBs exposure assessment by biological monitoringq investigation of negative health impacts on target organs and systems, including also the long-term effects of PCBs on liver, endocrine balance, immune system, reproduction and additional cancer risk have been carried out in Bulgaria.

Conclusions: No cases of acute and chronic intoxication with polychlorinated byphenyls (PCBs) in equipment have been registered in the Republic of Bulgaria . No studies of PCBs effects on human health caused by PCBs equipment leaks or spills have been carried out in the country.

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Summary: Polychlorinated biphenyls (PCBs) are organochlorine synthetic compounds that belong to the group of industrial persistent organic pollutants, listed in Annex A, Part II of Stockholm convention - PCBs

Current situation of PCBs issue in the country PCBs use: In Bulgaria PCBs were used mainly dielectric fluids in electrical equipment such as transformers and capacitors. Transformer manufacturers: The manufacturers of transformers in Bulgaria are 3 transformer plants in the towns of Sofia, Kyustendil and Godech. The transformer plant “Hyundai Elprom Trafo” – Sofia produces special power transformers mainly for electric power sector, metallurgy and minining. In “Elprom Trafo NS” facility in the town of Kyustendil was concentrated the assemblying of distributing oil transformers with power of up to 1000 kVA, designed for equipment in kiosk switchgears from the electrical supply net. For the period 1950 ÷ 1990 in Bulgaria 216983 transformers had been produced. None of the three manufacturers produce or have never produced PCB transformers. By 1990 the available 52492 transformers, manufactured in Bulgaria do not contain PCBs. Capacitors manufacturers: The manufacturers of capacitors in Bulgaria are 2 plants, located in the town of Kyustendil and in the village of Kovachevtsi. These companies do not and have never manufactured PCB containing capacitors. Transformer and Capacitor oils manufacturers: Transformer and capacitor oils are manufactured at 6 companies in Bulgaria, located in the towns of Pleven, Russe, Rakovski, Burgas and Sofia. These companies do not and have never manufactured PCB oils. Import of transformers and transformer oils: For the period 1970 г.÷1990 г. in the country totally 1954 transformers have been imported . Of all transformer imports, most likely to contain PCBs are the transformers imported from PCBs manufacturing countries – the USSR, West Germany, East Germany, and Czechoslovakia – total 606 transformers, representing 31% of all imports. Romania, Hungary, Korea and China are not countries, manufacturing PCBs oils. This fact gives no reason the imported 1248 transformers to be classified as non-PCBs because of probability to be have been filled with imported oils, containing PCBs. The imported 24120 t transformer oils in Bulgaria within the period 1955 ÷1972 do not contain PCBs.

Export of transformers: For the entire period of 1950 – 1990, the exports from among the 216983 manufactured transformers were 164554 transformers, not containing PCBs.

Imports and Exports of Capacitors: No official data about any imports and exports of capacitors larger than 5 dm3 are available

Inventory of PCBs in equipment

PCBs in transformers and transformer oils An inventory of transformers and transformer oils, containing PCBs on the territory of Republic of Bulgaria by 2003 had been carried out, based on voluntary submission of data by the owners of transformers – power supply companies from the system of the National Electricity Company (NEC); the Bulgarian Railways; Thermal Power Stations; Hydro Power Stations; the chemical

155 industry; metallurgy. The transformers and the transformer oils are divided into four main groups: Group І – containing > 500 ppm PCB; Group ІІ – likely to contain > 50 ppm PCBs; Group III – assumed to contain PCBs; Group ІV – not containing PCBs. Group I: Transformers and transformer oils, containing > 500 ppm PCBs

The total quantity of transformer oils , containing > 500 ppm PCBs in Bulgaria amounts to 327,225 tons, out of which 310,545 in 158 in-use transformers. Only the total quantity of transformer oils, containing > 500 ppm PCB has been identified, unlike the weight of the equipment due to gaps in the declared data. The out-of-use waste transformer oils, containing > 500 ppm PCBs are 9,88 tonnes; The fresh transformer oils on stock, containing > 500 ppm PCBs amount to 6,8 tonnes;

Group II: Transformers and Transformer Oils containing PCBs > 50 ppm The owners of transformers containing PCBs >50 ppm are 2 companies from the Energy sector. Only the total quantity of transformer oils in Bulgaria, containing PCBs >50 ppm has been identified as 1642.1 t in 41 in-use transformers but not their weight because of gaps in the declared data.

Group III: Transformers and transformer oils with PCBs assumed These transformers are owned by 35 companies, mainly from the Energy sector. and to a less extent, chemical, machine building, metallurgy and light industries. A total of 3082 transformers with PCBs assumed and 2531 tonnes of transformer oil have been identified in 18 administrative areas in Bulgaria. Only the total quantity of transformer oils with PCB assumed has been identified, – but not the weight of the equipment, due to insufficient data for the type, producer, power and weight of transformers and for the transformer oils brands.

PCBs in capacitors and capacitor oils An Inventory of capacitors and capacitor oils, containing PCBs on the territory of Republic of Bulgaria by 2003 had been carried out based on voluntary submission of data by the same companies-owners of transformers. The capacitors and capacitor oils are divided into three main groups: Group І – containing PCBs; Group II – PCBs assumed; Group ІII – not containing PCBs. Group І – Capacitors and Capacitor oils, containing PCBs The owners of PCBs capacitors are 15 enterprises, mainly from the chemical and mining industries, machine building and metallurgy. The Machine building sector holds the highest share by number of PCB condensers (53%), and by oil quantity (58%). The total number of PCBs capacitors is 2415, out of which in use are 1769 pcs., containing 7,899 tonnes of capacitor oils. There are 32 spare PCBs capacitors on stock.

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There are 614 out-of-use PCBs capacitors on stock Many companies have not declared the quantities of oils in their capacitors , and others - no data is available about the type and number of the capacitors. As per an expert assessment the actual quantity of capacitors oils containing PCBs, probably is approx. 40 tonnes, i.e. 5 times more than the declared 7,9 tonnes.

Group II – Capacitors and capacitors oils with PCBs assumed

The owners of PCBs assumed capacitors are 26 enterprises from the following sectors – power industry, chemical and mining industries, machine buildingq metallurgy and food industry; 2634 PCB assumed capacitors have been identified in Bulgaria representing 15% of the total number of capacitors in the country, located in 14 districts; The PCB assumed capacitors currently in use are 2159 containing 3,264 t oils. Machine building sector holds the highest share by total number of PCBs assumed capacitors - 64,3%. PCBs assumed capacitors are imported mainly from the USSR, GDR and Italy. Information about the type and manufacturer of the capacitors exists only for 966 out of 2634 PCBs assumed capacitors. No information about the manufacturing country, the type of capacitors or the brand of the oil is available for 1668 capacitors.

Environmental Monitoring Levels And Human Exposure

PCBs Levels in the environment Levels in Air: No studies has been made in Bulgaria, investigating the PCBs levels in air over industrial sites, where PCBs equipment is located. Levels in Soils: No studies has been made for the soil contamination cause by PCBs equipment. Levels in Water: No studies has been made for the surface water contamination cause by PCBs equipment. No studies has been made in Bulgaria, investigating the PCBs levels in environmental media over industrial sites, where PCBs equipment is located.

Human exposure and PCBs health impacts General population and occupational exposure:In Bulgaria no studies has been made for general population and occupational exposure cause by PCBs equipment leaks or among mechanics being in long-term contact with lubricating oils and hydraulic fluids, containing PCBs . Accidental exposure: No accidents with PCBs equipment had been reported by PCB equipment owners in Bulgaria. Levels in human body: No studies on PCBs levels in human body, caused by PCBs equipment have been carried out in Bulgaria. Effect to Human health: No purposeful studies on target groups workers or risk groups of population for PCBs exposure assessment by biological monitoring and investigation of negative health impacts on target organs and systems. No cases of acute and chronic intoxication with polychlorinated byphenyls (PCBs) in equipment have been registered in the Republic of Bulgaria . No studies of PCBs effects on human health caused by PCBs equipment leaks or spills have been carried out in the country.

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No studies for general population and occupational exposure cause by PCBs equipment has been made in Bulgaria

2.3.3. ASSESSMENT WITH RESPECT TO ANNEX B CHEMICALS - DDT Bulgaria has never manufactured and does not manufacture DDT. It had been used in the 50-s of past century in various preparations (technical product content in the range of 5 ÷ 20%, most usually 5,5%). Later DDT was widely applied in agriculture to control various pests on cotton and other crops as insecticide. It was used also against mosquitoes. The use of DDT was restricted in the 60-s and completely banned for import and use in agriculture in 1969. Detailed assessment of import, export, use and levels of DDT in environment are shown in item 2.3.1. Assessment with respect to Annex A, part І chemicals & Annex B (POPS pesticides) of Stockholm Convention. Bulgaria has never manufactured and does not manufacture DDT. DDT was completely banned for import and use in agriculture in 1969.

2.3.4. ASSESSMENT OF RLEASES FROM UNINTENTIONAL PRODUCTION OF ANNEX C CHEMICALS (PCDD/PCDF, HCB AND PCBS) Polychlorinated dibenzo-p-dioxins and dibenzofurans (PCDD/PCDF), hexachlorobenzene (HCB) and polychlorinated biphenyls (PCBs) are unintentionally formed and released from thermal processes involving organic matter and chlorine as a result of incomplete combustion or chemical reactions. Polychlorinated dibenzo-p-dioxins and dibenzofurans (PCDD/PCDF), hexachlorobenzene (HCB) and polychlorinated biphenyls (PCBs) are persistent organic pollutants (POPs), formed and released unintentionally from anthropogenic sources. Polychlorinated dibenzo-p-dioxins” and “polychlorinated dibenzofurans” (PCDD/PCDF), known as Dioxins and Furans, are tricyclic, aromatic compounds formed by two benzene rings connected by two oxygen atoms in polychlorinated dibenzo-p-dioxins and by one oxygen atom and one carbon- carbon bond in polychlorinated dibenzofurans and the hydrogen atoms of which may be replaced by up to eight chlorine atoms. Polychlorinated biphenyls (PCBs) are aromatic compounds formed in such a manner that the hydrogen atoms on the biphenyl molecule (two benzene rings bonded together by a single carbon- carbon bond) may be replaced by up to ten chlorine atoms. According to the Stockholm Convention, effective for Bulgaria since 20 March 2005, our country should take measures to reduce the overall releases from such sources, aiming at their lasting reduction and removal from unintentional use.

2.3.4.1. Assessment of sources of POPs emissions into the atmosphere The following categories of industrial sources have the potential for comparatively high formation and release of dioxins/furans(PCDD/PCDF), hexachlorobenzene (HCB) and polychlorinated biphenyls (PCBs) to the environment: a. Waste incinerators, including co-incinerators of municipal, hazardous or medical waste or of sewage sludge; b. Cement kilns firing hazardous waste; c. Production of pulp using elemental chlorine or chemicals generating elemental chlorine for bleaching; d. Thermal processes in the metallurgical industry.

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Polychlorinated dibenzo-p-dioxins (PCDDs)and dibenzofurans(PCDFs), hexachlorobenzene and polychlorinated biphenyls(PCBs) may also be unintentionally formed and released from the following source categories, including: (a) Open burning of waste, including burning of landfill sites; (b) Thermal processes in the metallurgical industry not mentioned yet (c) Residential combustion sources; (d) Fossil fuel-fired utility and industrial boilers; (e) Firing installations for wood and other biomass fuels; (f) Specific chemical production processes releasing unintentionally formed persistent organic pollutants, especially production of chlorophenols and chloranil; (g) Crematoria; (h) Motor vehicles, particularly those burning leaded gasoline; (i) Destruction of animal carcasses; (j) Textile and leather dyeing (with chloranil) and finishing (with alkaline extraction); (k) Shredder plants for the treatment of end of life vehicles; (l) Smouldering of copper cables; (m) Waste oil refineries.

Figure 27 Source categories POPs releases into atmpsphere from unintentional production

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The emissions of PCDD/F, PCB and HCB are released into the environment by means of direct emission and/or transfer by air, water, soil and waste (Figure 27 & Figure 28).

Figure 28 Unintentional production and routes of entry of PCDD/Fs, PCBs and HCB into the environment (air, water, soil and waste).

2.3.4.2. Distribution of POPs source categories in Bulgaria Table 80 Number of facilities by source categories of unintentional POPs releases Source categories Number of facilities Incinerators Municipal solid waste; - Hazardous waste; 25 Medical waste; 52 Cement kilns 3 Metallurgy Thermal processes in metallurgy; 16 Secondary copper production; - Sinter plants in the iron and steel industry; 5 Industrial combustion processes 427 Combustion processes in energy generation and 34 transformation Combustion processes in trading, administrative 644 and household sectors Firing installations for wood 1 Waste oil refineries 2

2.3.4.3. POPs releases from unintentional production in Bulgaria Every year Bulgaria provides to the the UNECE/CLRTAP (Convention on Long-Range Transboundary Air Pollution ) except with main pollutants (SO2, NO2, CH4, NMVOC, CO, NH3, Cd, Pb, Hg, PAH, PCP) emissions data, also with dioxins and furans, PCBs and HCB, emissions data from 11 activity sector groups, such as public power, congeneration and district heating plants; commercial, institutional and residential combustion; industrial combustion; production processes; extraction and distribution of fossil fuels; solvent use; road transport; other mobile sources and machinery; waste treatment and disposal; agriculture and nature.

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The emissions are calculated in relation with National CORINAIR - 94 methodology, approved by the Minister of Environment and Waters. It was developed by adapting the emission inventory Guide - CORINAIR-94, SNAP-94 for the Bulgarian conditions, taking into account the national specificities concerning the respective activity, technologies and equipment. This methodology is used for inventorying and for balance determination of the emissions of harmful substances into the air.The CORINAIR-94, SNAP-94 manual puts the pollutants into three groups. POPs belong to the third group – persistent organic pollutants. 2.3.4.3.1. National annual POPs emissions – Dioxins/Furans, PCBs and HCB The national annual POPs emissions from unintentional production – dioxins and furans, polychlorinated biphenyls and hexachlorbenzene – in the atmosphere for the period 1990 – 2003 are summarized in Table 81 and figures 29 and 30.

Table 81 National annual emissions of POPs releases in the atmosphere for the period 1990-2003 Year 1990 1995 1996 1997 1998 1999 2000 2001 2002 2003 PCDDs/Fs, g I-TEQ/y 554,2 456 340,9 309,7 288,3 245,2 232,5 200,9 218,5 255 PCB, kg/y 258,5 382,3 261,7 226,9 252,8 234,3 228,5 211,9 250,1 260,7 HCB, kg/y 544 79 87 47 76 46 54 42,5 38 45

Dioxin/Furans emissions by years g I-TEQ/year 600

500

400

300

200

100

0 1990 1995 1996 1997 1998 1999 2000 2001 2002 2003 years

Figure 29 Annual PCDDs/PCDFs releases in the atmosphere by years

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kg/y PCBs and HCB emissions by years

600

500

400

300

200

100

0 1990 1995 1996 1997 1998 1999 2000 2001 2002 2003 years

PCBs, kg/y HCB, k g/y

Figure 30Annual PCBs and HCB releases in the atmosphere by years An increase of Ds/Fs releases has been observed in 2003 by 16,7% of the 2002 emissions.In comparison to base year 1990, the annual emissions of dioxin/furans for 2003 a downward trend of 53,9% or 2,2 times had been observed, following the European trend. According to official data for PCDDs/PCDF emissions in Europe within the period 1990 ÷ 2003,the decrease is 2,7 times (63%)23. The annual PCBs emissions for the period 1990-2003 are almost the same. For the period 1990-2003, the HCB emissions in the atmosphere show a signicicant downward trend. Compared to the base year 1990, for the HCB emission in 2003, a sharp decrease with 91,7% or 12,1 times has been registered due to the decline of industrial production.

2.3.4.3.2. National annual sector POPs emissions by category sources The Bulgarian national annual sector POPs emissions – dioxins/furans, PCBs and HCB by category sources in air for the period 2000-2003 are presented in Tables 82.

23 Shatalov V.at al., Modelling of POP contamination in European region: Evaluation of the model performance. EMEP/MSC-E Technical Report 7/2005, August 2005, pp 103-117.

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Table 82 Annual POPs releases in ambient air by emission categories for year 2000 ÷ 2003 in Bulgaria

Emission categories PCDDs/PCDFs, g I-TEQ/y PCBs , kg/y HCB, kg/y

2000 2001 2002 2003 2000 2001 2002 2003 2000 2001 2002 2003 1. Combustion processes in energy generation 109,1974 102.049 105.4 122,6 40,6394 37,799 39,341 46,142 and transformation; 2. Combustion processes in trading, administrative and household sectors, in 58,3389 44.920 59.4 70,9 141,373 124,719 156,7 164,61 agriculture, in agriculture, forestry and fishing; 3. Industrial combustion processes; 16,3823 8.325 7,5 9,7 5,151 1,9849 1,755 2,261 4. Industrial processes; 21,5054 20.464 19,1 23,5 19 18,5 16 21 5. Production and distribution of fossil fuels; 6. Use of solvents; 7. Road transport; 7,226 6.241 9,2 10,5 41,236 35,85 41,27 37,055 8. Other motor vehicles and machines; 9,685 11.494 10,9 10,5 0,076 11,47 10,95 10,514 9. Waste treatment and disposal; 10,193 7.362 6.978 7,283 0,059 0,056 0,137 35 24 22 24 10. Agriculture and forestry, and changes in land-

use 11. Nature Total annual POPs emissions 232,528 200.855 218.592 254,983 228,475 211,882 250,127 260,71 54 42,5 38 45

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The lack of substantial restructuring in the industrial sector and the insignificant changes in the quantity, type and quality of fuel used in power and heat generation explain the upward or downwar change of the emissions of POPs such as dioxins, furans and polychlorinated biphenyls in the last 4 years of anthropogenic activity. Power sector is the main source of dioxins/furans and PCBs emissions into the atmosphere. The increase of dioxins/furans releases with 17,2 g (16%) for 2003 versus 2002 is due to the growing up consumption of lignite coal. For instance, the emission factor of Ds/Fs for black(anthracite) coal is 1.6 µg/t, while for lignite coal - 4.37 µg /t. PCBs emissions from combustion processes in energy generation and transformation also has increased with 6,8 kg (17,4%) versus previous year. In 2003 the largest source of dioxins and furans are the thermal electric power stations (TEPS) with 48,1 % share of the entire releases emitted in Bulgaria from antropogenic activity, followed by fuel combustion in the household sector – 27,8 %. Concerning PCBs , the largest % share is covered by PCBs emissions from combustion processes in trading, administrative and household sectors – 63,1%, followed by releases from road transport and other motor vehicles and machines - totalling to 18,2% and combustion processes in energy generation and transformation – 17,7%. The increased consumption of coal and wood in the household sector has resulted in a growth of PCDD/F and PCB emissions.In 2003 the household sector emitted 11,2 g more PCDD/PCDF and 7,9 kg more PCB in air as compared to the previous year. It could be noticed that the increase of PCDDs/Fs and PCBs emissions is less compared to that for 2002 versus 2001 being respectively 14,5 g for PCDD/PCDF and 32 kg for PCB, emitted in the air. Probably this is due to slight decrease in coal and wood consumption and gradual gasification of big cities in Bulgaria. The main sources of HCB emissions in 2003 are the categories “waste treatment and disposal” and “industrial processes” with lasting downward trend as a decrease with 16,6% versus 2000 was registered. The HCB emissions for the period 2000 – 2003 are within the range 38 ÷ 54 kg/year, being for 2003 – 45 kg. Figures 31 and 32 show the % share of the main category sources, emitting PCDDs/PCDFs in air and PCBs for 2003.

% Share of PCDDs/Fs emissions in the air by source categories for 2003

4,1% 2,9% 4,1% 48,1%

9,2%

3,8%

27,8%

Combustion processes in energy generation and transformation; Combustion processes in trading, administrative and household sectors, in agriculture, in agriculture, forestry and fishing; Industrial combustion processes; Industrial processes; Road transport; Other motor v ehicles and machines; Waste treatment and disposal;

Figure 31 % Share of the PCDDs/Fs releases by source categories for 2003. The main sources of of PCDDs/Fs emissions are the large industrial centres, where the big thermal electric power stations amd industrial manufacturers are located and the main road and railway routes pass by. 164

% share of PCBs releases in the air by source categories for 2003.

4,0% 0,1% 17,7% 14,2%

0,9%

63,1%

Combustion processes in energy generation and transformation;

Combustion processes in trading, administrative and household sectors, in agriculture, in agriculture, forestry and fishing; Industrial combustion processes;

Road transport;

Other motor vehicles and machines;

Waste treatment and disposal;

Figure 32 Share of PCBs releases in the air by source categories for 2003. The biggest source of PCBs emissions in 2003 are the combustion processes in trading, administrative and household sectors, in agriculture, in agriculture, forestry and fishing, representing 63,1% of total PCBs annual sector releases, followed by road transport and other motor vehicles and machines – 18,2% and the combustion processes in energy generation and transformation – 17,7%.

Conclusions: POPs releases, generated in Bulgaria in the past 5 years are within the range as follows: Dioxins/Furans: 200 ÷ 255 g I-TEQ/y, and in 2002 have reached 254,9 g I-TEQ/y. PCBs: 212 ÷ 261 кg/y, and for 2003 have reached 260,7 kg. HCB: 38 ÷ 54 kg/y, and for 2003 being 45 kg. For the period 1990-2003 the POPs emissions in the atmosphere show lasting downward trend.Compared to the base year 1990, PCDDs/PCDFs and HCB note a sharp decline, respectively with 53,9% or 2,2 times and with 91,7% or 12,1 times. The annual PCBs emissions for the same period are almost the same, which could be explained with upward or downward change of the PCBs emissions formed by various category sources. The lack of substantial restructuring in the industrial sector and the insignificant changes in the quantity, type and quality of fuel used in power and heat generation explain the upward or

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downwar change of the emissions of POPs such as dioxins, furans and polychlorinated biphenyls in the last 4 years of anthropogenic activity. The registered decline in PCDDs/Fs emissions into the atmosphere for 2003 compared to base year 1990 is due mainly to the categories “waste treatment and disposal” – 95%, “combustion processes in industry” – 88%; “industrial processes” - 46% and “road transport and other motor vehicles and machines” – 43%. The lowest decline show category sources “combustion processes in trading, administrative and household sectors, in agriculture, in agriculture, forestry and fishing” – 25% and “combustion processes in energy generation and transformation” – 23%. The assessment of data show, that 75,9% of PCDDs/Fs releases are formed by categories “combustion processes in energy generation and transformation” (48,1%) and “combustion processes in trading, administrative and household sectors, in agriculture, in agriculture, forestry and fishing”(27,8%), followed by “industrial processes” and “road transport”. The registered decline in PCBs emissions into the atmosphere for 2003 compared to base year 1990 is due mainly to the categories“road transport and other motor vehicles and machines” – 54% and “combustion processes in energy generation and transformation”- 18%. PCBs emissions from categories “combustion processes in trading, administrative and household sectors, in agriculture, in agriculture, forestry and fishing” have increased considerably with 88,8%, which could be explained mainly with the growth in the consumption of wood and coal in household sector during past 5 years. The main sources of HCB emissions in air for 2003 are the categories “waste treatment and disposal” and “industrial processes” with lasting downward trend. Compared to base year 1990 a sharp decline of HCB emissions with 91% or 11 times is registered for the category “waste treatment and disposal” . The combustion processes are the main source of PCDDs/Fs and PCBs emissions for 2003. Thermal electric power stations emit about 48,1% of total annual dioxinx/furans emissions, followed by combustion processes in household sector – 27,8%, combustion processes in industry – 13% and road transport and other motor vehicles and machines – 8,2%. The biggest source of PCBs emissions in 2003 are the combustion processes in trading, administrative and household sectors, in agriculture, in agriculture, forestry and fishing, representing 63,1% of total PCBs annual sector releases, followed by road transport and other motor vehicles and machines – 18,2% and the combustion processes in energy generation and transformation – 17,7%. The main sources of HCB emissions in 2003 are the categories “waste treatment and disposal”-53,4% and “industrial processes” – 46,7%, being for 2003 – 45 kg.

2.3.4.3.3. POPs emissions – PCDDs/PCDFs, PCBs and HCB- by districts for 2002 The sources of PCDDs/PCDFs and PCBs emissions in the atmosphere are distributed on the whole territory of the country. 2935 industrial sources generate 0,0001 to 8,29 g of PCDDs/Fs annually. The sources emitting 0,0001 g/year have been excluded from the calculations. 973 industrial sources generate 0,0001 to 3,41 kg of PCBs annually. The sources emitting 0,0001 kg/year have been excluded from the calculations. Table 83 and figure 33 present data about PCDDs/Fs, PCBs and HCB emissions from category sources “combustion processesin energy generation and transformation” and “industrial processes” by districts in Bulgaria for 2002.

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Table 83 PCDDs/PCDFs, PCBs and HCB emissions by districts for 2002.

№ District PCDDs/PCDFs, PCBs, HCB, g/y kg/y kg/y

1 Blagoevgrad 0,4641 0,1019 2 Burgas 7,8258 0,9351 3 Varna 2,2349 0,7329 4 Veliko Tarnovo 1,0279 0,8058 5 Vidin 0,0688 0,1499 6 Vratsa 0,0674 0,8018 7 Gabrovo 0,1965 0,0078 8 Dobrich 0,0681 0,0002 9 Kardzhali 0,1980 0,0065 10 Kyustendil 10,5287 0,2432 11 Lovech 0,3032 0,0188 12 Montana 0,0468 0,0311 13 Pazardzhik 0,0940 0,0050 14 Pernik 10,0993 0,0101 11,70 15 Pleven 0,1676 0,0028 16 Plovdiv 2,0649 0,0301 17 Razgrad 0,0255 0,0247 18 Russe 1,1562 0,0628 19 Silistra 0,2481 0,1806 20 Sliven 0,6523 0,0474 21 Smolyan 0,0790 0,5557 22 Sofia-city 16,1232 12,7108 4,30 23 Sofia-district 0,4461 1,9281 24 Stara Zagora 77,1736 6,5007 25 Targovishte 0,0516 1,3828 26 Haskovo 1,0355 12,6443 27 Shumen 0,1946 0,5486 28 Yambol 0,0277 0,0962 Total for Bulgaria 132,6694 40,5655 16,00

167

PCDD/PCDF

PCBs

HCB

Figure 33 Dioxins /Furans, PCBs and HCB emission sources by districts for 2002

The total PCDDs/PCDFs, PCBs and HCB emissions from category sources “combustion processesin energy generation and transformation” and “industrial processes” for 2002 are as follows: PCDDs/PCDFs - 132,67 g, representing 60,1% of annual emissions from all category sourcs (218,48 g); PCBs – 40,56 kg or 16,2% of annual emissions (250,06 kg); HCB – 16 kg or 42,1% of annual emissions (38 kg). The main sources of PCDDs/Fs and PCBs emissions from category sources “combustion processesin energy generation and transformation” and “industrial processes”are the large industrial centres, where the main part of thermal electric power stations and industrial manufacturers are located. 58% of the emissions released from combustion processes in energy and industry sectors have been registered in Stara Zagora, followed by Sofia-city – 12,2%, Pernik – 7,9% and Burgas – 6 %. The surprising 7,9 % share observed in Kyustendil probably is as a result of Yugoslavia war. 168

Table 84 POPs emissions per unit area and per capita in Bulgaria by years Per unit area, POPs Population, Per capita Year Total country area emissions number (110 993 кm2) PCDDs/PCDFs 554,2 g Base year 1990 0,00499 g/кm2 8487317 0,0000653 g 218,5 g 2002 0,00197 g/кm2 7845841 0,0000278 g 254,9 g 2003 0,00230 g/кm2 7801273 0,0000327 g PCBs 258,5 kg Base year 1990 0,00233 kg /кm2 8487317 0,0000305 kg 250,1 kg 2002 0,00225 kg /кm2 7845841 0,0000319 kg 260,7 kg 2003 0,00234 kg /кm2 7801273 0,0000334 kg HCB 544 kg Base year 1990 0,00490 kg /кm2 8487317 0,0000641 kg 38 kg 2002 0,000342 kg /кm2 7845841 0,0000048 kg 45 kg 2003 0,000405 kg /кm2 7801273 0,0000056 kg

Allocated per capita and unit of area, the PCDDs/PCDFs and HCB emission values versus base year 1990 show a lasting downward trend. The decrease of PCDDs/PCDFs emissions is more the 2 times, while for HCB – 11 times as a result of the decrease in industrial production in Bulgaria after 1990. It is noticed, that allocated per unit area the PCBs emissions are within the same range, while per capita they increase, due probably to the growing consumption of wood and coal in household sector after 1990.

Conclusions The sources of PCDDs/PCDFs and PCBs emissions in the atmosphere are distributed on the whole territory of the country. 2935 industrial sources generate 0,0001 to 8,29 g of PCDDs/Fs annually. 973 industrial sources generate 0,0001 to 3,41 kg of PCBs annually. The main sources of PCDDs/Fs and PCBs emissions from category sources “combustion processesin energy generation and transformation” and “industrial processes” for 2002 are thermal electric power stations and industrial manufacturers. The total PCDDs/PCDFs, PCBs and HCB emissions from category sources “combustion processesin energy generation and transformation” and “industrial processes” for 2002 are as follows: PCDDs/PCDFs - 132,67 g, representing 60,1% of annual emissions from all category sourcs (218,48 g); PCBs – 40,56 kg or 16,2% of annual emissions (250,06 kg); HCB – 16 kg or 42,1% of annual emissions (38 kg). The largest share of PCDDs/Fs emissions for 2002 have been registered in Stara Zagora - 58% followed by Sofia-city – 12,2%, Pernik – 7,9% and Burgas – 6 %.The largest PCB emissions have occurred in Sofia-city at 30%, Haskovo area at 30% and Stara Zagora area at 15% .

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The industrial HCB emission sources are metallurgical enterprises concentrated in the areas around Pernik and Sofia city, as 73,1% have been registered in Pernik. PCDDs/PCDFs and HCB emission values, allocated per capita and unit of area, versus base year 1990 show a lasting downward trend in timesq due the decrease in industrial production in Bulgaria after 1990. PCBs emissions values, allocated per unit area are almost the same range, while per capita they increase, due probably to the growing consumption of wood and coal in household sector after 1990.

2.3.4.4. Existing policy and regulatory framework Existing policy The Ministry of Environment and Water conducts the state policy on protection of the atmospheric air. The municipal authorities and the regional environmental inspectorates control and manage the activities aimed to ensure clean air in their territory. The atmospheric air quality is monitored through the national system for monitoring, control and information. The control and monitoring of transboundary transfer of polluting substances, of the background quality of atmospheric air, and of the impact of atmospheric air pollution on the global processes are conducted by the Ministry of Environment and Water and by the National Statistic Institute. The direct control of the state and the operation of the sites that are sources of emissions into the atmospheric air and on the emissions of various sources is performed by: 9 The Minister of Environment and Water, the Regional Inspectorates of Environment and Water and the municipal authorities; 9 The authorities of the Ministry of Internal Affairs and of the Ministry of Transport – for motor vehicles.

Emission inventory system in Bulgaria The involved institutions at national and local (sub-national) levels in Emissions inventory are Ministry of Environment and Water /MEW/ respectively Executive Environment Agency /EEA/ and Regional Environment Inspectorate /REIWs/, and National Institute of Statistics /NSI/ . Two parallel emission inventory programs are conducted in Bulgaria. The first one covers 150 large point sources and it is conducted by REIWs. The second one covers nearly 2000 point sources and it is conducted by National Institute of Statistics. Both are under the guidance of Ministry of Environment and Waters . The data collected are air pollution control facilities and their efficiency, technological and production data, data for fuels used and fines imposed.

The National Institute of Statistics is the responsible organization for assessment of the following air emissions sources: - Combustion in energy production and energy transformation; - Combustion in commercial, institutional and residential sectors and agriculture, forestry, fishing; - Combustion in industry; - Production processes; - Extraction and distribution of fossil fuels; - Agriculture, forestry and land use change; - Nature.

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The Executive Environment Agency is the responsible organization for assessment of the following air emissions sources: - Road transport; - Other mobile sources and machinery; - Waste treatment and disposal. Data from the emission inventory are stored at local and national level. On a national level the Executive Environment Agency is the responsible organization for final preparation of the National air emission inventory and data reporting to the the UNECE/CLRTAP (Convention on Long-Range Transboundary Air Pollution).

Existing regulatory framework The observation of existing national legislation in regard with POPs releases from unintentional production management guarantees the reducing of POPs negative impacts on the environment and human health. Tables 85 – 99 present the approved Bulgarian standards for PCDD/F, PCB and HCB in air, soil, water and food. Standards for PCDD/F, PCB and HCB in air

Regulation № 1/27.06.2005 on Emission Limit Values of harmful substances (pollutants), released into atmosphere from facilities and activities with stationary point sources, SG 64/05.08.2005, in force from 06.08.2006. Table 85 Emission limit value (ELV) of PCDD/F released from stationary sources № Dioxins/Furans (PCDDs/PCDFs) ELV ng TE/m3 1 Total PCDDs/Fs emissions released into atmosphere from 0,1 ng TE/m3 existing and new stationary sources within a single facility or 0,25 µg/h activity, considering their TEQ. 2 PCDDs/Fs emissions from sinter plants in the iron and steel 0,4 ng TE/m3 industry 3 Total PCDDs/Fs emissions released into exhaust gases from 0,4 ng TE/m3 plants for the production of non-ferous metals, excluding aluminium and iron-based alloys 4 PCDDs/Fs emissions released into exhaust gases - in the processes of melting, alloying and refining of non-ferous 0,1 ng TE/m3 metals , excluding aluminium - in the processes of copper melting in shaft furnace 0,4 ng TE/m3

Annex № 6 to article 20, item 1

For the determination of the total concentration (TEQ) of dioxins and furans, the mass concentrations of the following dibenzo-p-dioxins and dibenzofurans shall be multiplied by the following equivalence factors before summing:

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Table 86 Toxicicity Equivalents (TEQ) of dibenzo-p-dioxins and dibenzofurans Toxicity equivalent Chemical TEQ 2,3,7,8 — Tetrachlorodibenzodioxin (TCDD) 1 1,2,3,7,8 — Pentachlorodibenzodioxin (PeCDD) 0,5 1,2,3,4,7,8 — Hexachlorodibenzodioxin (HxCDD) 0,1 1,2,3,6,7,8 — Hexachlorodibenzodioxin (HxCDD) 0,1 1,2,3,7,8,9 — Hexachlorodibenzodioxin (HxCDD) 0,1 1,2,3,4,6,7,8 — Heptachlorodibenzodioxin (HpCDD) 0,01 — Octachlorodibenzodioxin (OCDD) 0,001 2,3,7,8 — Tetrachlorodibenzofuran (TCDF) 0,1 2,3,4,7,8 — Pentachlorodibenzofuran (PeCDF) 0,5 1,2,3,7,8 — Pentachlorodibenzofuran (PeCDF) 0,05 1,2,3,4,7,8 — Hexachlorodibenzofuran (HxCDF) 0,1 1,2,3,6,7,8 — Hexachlorodibenzofuran (HxCDF) 0,1 1,2,3,7,8,9 — Hexachlorodibenzofuran (HxCDF) 0,1 2,3,4,6,7,8 — Hexachlorodibenzofuran (HxCDF) 0,1 1,2,3,4,6,7,8 — Heptachlorodibenzofuran (HpCDF) 0,01 1,2,3,4,7,8,9 — Heptachlorodibenzofuran (HpCDF) 0,01 — Octachlorodibenzofuran (OCDF) 0,001

Regulation No. 2 on Emission Limit Values (Concentrations in Waste Gases) for Harmful Substances, Released into the Atmospheric Air from Stationary Sources, SG 51/06.05.1998, last supplemented in the SG 93/21.01.2003. Table 87 Emission limit value (ELV) of PCDD/F for large stationary sources ELV (applicable to 11% No. Waste incinerators concentraiton of oxygen in the flue gas) ng TE/m3 Solid household waste (at incinerated waste quantities of more than 3 0,1 ng TE/m3 1 tonnes per hour) Solid medical waste (at incinerated waste quantities of more than 1 0,5 ng TE/m3 2 tonnes per hour) Hazardous waste (at incinerated waste quantities of more than 1 tonnes 0,2 ng TE/m3 3 per hour)

Regulation 6 on the Conditions and Requirements for Construction and Operation of Waste Incinerators and Co-Incinerators, SG 78/07.09.2004. Annex № 1 to Article 2 Table 88 Average values for emission limit values of dioxin and furans in air from waste incinerators Harmful sunstances ELV ng /m3 Dioxins and furans 0,1

The emission limit value refers to the total concentration of dioxins and furans calculated using the concept of toxic equivalence in accordance with Annex № 6. (see table 82 above).

Regulation 13 on Workers Protection from Risks, Related to Chemical Agents’ Exposure at Work, SG 8/20.01.2004, effective 31.01.2005.

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Table 89 Limit values of chemical agents in occupational air No. Chemical agent CAS No. Limit values 8 hours 15 Specific effects minutes mg/m3 mg/m3 361. Polychlorinated 11097-69-1 1,0 P biphenyls 0,5 (54% chlorine)* 362. Polychlorinated 53469-21-9 2,0 P biphenyls 1,0 (42% chlorine)* P – toxic for reproduction * - resorption through the skin

Table 90 Limit values of the harmful substances in the occupational environment of working juveniles (15 – 18 years of age) Chemical substance Limit value mg/m3 Polychlorinated biphenyls Not allowed

Standards for PCDD/F, PCB and HCB in soil

Regulation on the Procedures and Manner of Using of Waste-Water Treatment Sludge in Agriculture, SG 112/23.12.2004 Table 91 Admissible Limit Values for POPs in sludge meant for use in agriculture Parameter Value of mg/kg dry substance Polychlorinated biphenyls 1

Regulation 3/1979 on the Admissible Content of Harmful Substances in Soils, SG 36/08.05.1979, amended SG 54/1997, last amendment SG 39/16.04.2002.

Table 92 Admissible limit values for POPs in soil, in mg/kg of dry soil Name 1* 2** 3*** 4**** Polychlorine PCB6 (total) 0.005 0.02 0.2 1 biphenyls 2,4,4' - trichlorobiphenyl PCB-28 0.001 0.001 0.01 - 2,2,5,5' - tetrachlorobiphenyl PCB-52 0.001 0.001 0.01 - 2,2,4,5,5' - pentachlorobiphenyl PCB-101 0.001 0.004 0.01 - 2,2',3,4,4',5' - hexachlorobiphenyl PCB-138 0.001 0.004 0.04 - 2,2',3,4,4',5,5' - hexachlorobiphenyl PCB-153 0.001 0.004 0.04 - 2,2',3,4,4',5,5' - hexachlorobiphenyl PCB-180 0.001 0.004 0.04 - Hexachlorobenzene - 0.025 0.25 10 * reference background levels: ** levels of concerns and concentrations: *** admissible limit values: **** intervention concentration levels:

Standards for PCDD/F, PCB and HCB in water

Regulation 1 on the Studying, Use and Protection of Ground Water, SG 57/14.07.2000, in effect since 14.07.2000, amended in the SG 64/04.08.2000.

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Table 93 Recommended Parameters for Protection of Ground Water against Pollution PARAMETER Unit, international Unit, Bulgarian Ecological threshold Pollution signature signature threshold Polychlorinated biphenyls (1) µg/l mkg/l 0,01 1 Polychlorinated dibenzodioxins µg/l mkg/l 10 50 Polychlorinated dibenzofurans µg/l mkg/l 10 50 Hexachlorobenzene µg/l mkg/l 0,1 5

'0( sum of polychlorinated biphenyls 28, 52, 101, 118, 138, 153 and 180;

Standards for PCDD/F, PCB and HCB in waste

Regulation 8 on the Terms and Requirements for Construction and Operation of Waste Recycling and Disposal Landfills and Other Facilities, SG 83/24.09.2004. Table 94 Limit values for total PCB in waste Chemical substance Value mg/kg Polychlorinated biphenyls, 7 congeners 1

Standards for PCDD/F, PCB and HCB in fodders Regulation 24 for maximum admissible concentration of unacceptable substances and products in fodders, SG 56/20.06.2003.Annex to Article 2, paragraph 2 Table 95 Maximum admissible concentration of PCDDs/Fs and HCB in fodders № Maximum admissible UNACCEPTABLE concentration of unacceptable substances and SUBSTANCES OR FODDERS products , expressed in PRODUCT mg/kg (ppm), referred to fodders with moisture 12 % 1 Hexachlorobenzene (НСВ) All fodders with exception of : 0,01 - fats 0,2 2 Dioxins, expressed by All stuff of vegetable origin in 0,75 ng WHO- Coefficient of Toxic Equivalent fodders, incl. vegetable oils and PCDD/F , defined by WHO derivates TEQ/kg(1) Minerals 1,0 ng WHO- PCDD/F TEQ /kg Animal fat, incl. Fats from milk 2,0 ng WHO-PCDD/F and eggs TEQ /kg Other products from terrestrial 0,75 ng WHO- animals, incl. milk and dairy PCDD/F products, eggs and egg products TEQ /kg Fish oils for human consumption 6 ng WHO-PCDD/F TEQ /kg Fish, other aquatic animals, their 1,25 ng WHO- products and subproducts, PCDD/F excluding fish oil TEQ /kg Mixed fodders, excluding fodders 0,75 ng WHO- for animals with valuable fur, pets PCDD/F and fodders for fish TEQ /kg Fodder for fish, fodder for pets 2,25 ng WHO- PCDD/F TEQ /kg

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Standards for PCDD/F, PCB and HCB in food

Regulation No.6 for the control measures on residues of veterinary medicinal products and environmental pollutants in life animals and foodstuffs of animal origin, SG 32/29.03.2002 (Table90). Annex № 1 to Article 2 Residues groups, subject to control Group B - veterinary medicinal products and environmental pollutants 3. Other substances and environmental pollutants: а) Chloroorganic compounds, including PCBs; Annex № 2 to Article 4, paragraph 1 Table 96 Groups of substances to be detected by animal species and products of animal origin GROUP OF ANIMAL SPECIES AND FOODSTUFFS OF ANIMAL ORIGIN SUBSTANCES

Bovine, Ovine, Poultry Fishery and Row Eggs Rabbit meat, Bee Caprine, Swine meat Aquaculture Milk meat from Honey & Horse meat products wild animals*

and farmed game

B (3) а : Chloroorganic Х Х Х Х Х Х Х compounds, including PCBs (*) For the wild animals only the chemical elements are subject to control. Regulation 31 on the maximum admissible quantities of pollutants in food, SG 88/08.10.2004 Table 97 Limit values for dioxins in some food (pg/g) Product Limit value (PCDD+ PCDF) (pg WHO- PCDD/F-TEQ/g fat or product) Meat and meat products*1 from: ruminants (cattle, sheep) 3 pg WHO- PCDD/F-TEQ/g fat*2 farm raised fowl and game 2 pg WHO- PCDD/F-TEQ/g fat*2 pigs 1 pg WHO- PCDD/F-TEQ/g fat*2 Liver and derivative products from terrestrial animals 6 pg WHO- PCDD/F-TEQ/g fat*2 Meat from fish and fish products, and their products 4 pg WHO- PCDD/F-TEQ/g live weight Milk and dairy products, including butter 3 pg WHO- PCDD/F-TEQ/g live weight*2 Hen eggs and egg products; 3 pg WHO- PCDD/F-TEQ/g live weight*2 Animal fats from: ruminants 3 pg WHO- PCDD/F-TEQ/g live weight farm raised fowl and game 2 pg WHO- PCDD/F-TEQ/g live weight pigs 1 pg WHO- PCDD/F-TEQ/g live weight mixed animal fats 2 pg WHO- PCDD/F-TEQ/g live weight Vegetable oils and animal fats. 0.75 pg WHO- PCDD/F-TEQ/g live weight Fish oils for human consumption 2 pg WHO- PCDD/F-TEQ/g live weight *1 Meat for slaughtering and production, proposing of fresh meat on the market. *2 The dioxin content limit values do not apply to food containing < 1 % fat.

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Table 98 Toxic Equivalence Factors (TEFs) Congener Congener TEF values in food Dioxin-like PCBs PCB 77 0.0001 PCB 81 0.0001 PCB 126 0.1 PCB 169 0.01 Mono-ortho PCBs PCB 105 0.0001 PCB 114 0.0005 PCB 118 0.0001 PCB 123 0.0001 PCB 156 0.0005 PCB 157 0.0005 PCB 167 0.00001 PCB 189 0.0001 Table 99 Toxic Equivalence Factors of 17 isomers (congeners), applied to 2,3,7,8- TCDD Congener Congener TEF values in food Dibenzo-p-dioxins (PCDDs): 2, 3, 7, 8-TCDD 1 1, 2, 3, 7, 8-РеСDD 1 1, 2, 3, 4, 7, 8-НхCDD 0.1 1, 2, 3, 6, 7, 8-НхCDD 0.1 1, 2, 3, 7, 8, 9-НхCDD 0.1 1, 2, 3, 4, 6, 7, 8-НрCDD 0.01 OCDD 0.0001 Dibenzofurans (PCDFs): 2, 3, 7, 8-TCDF 0.1 1, 2, 3, 7, 8-PеСDF 0.05 2, 3, 4, 7, 8-РеСDF 0.5 1, 2, 3, 4, 7, 8-НхCDF 0.1 1, 2, 3, 6, 7, 8-НхCDF 0.1 1, 2, 3, 7, 8, 9-НхCDF 0.1 2, 3, 4, 6, 7, 8-НxCDF 0.1 1, 2, 3, 4, 6, 7, 8-НрCDF 0.01 1, 2, 3, 4, 7, 8, 9-HpCDF 0.01 OCDF 0.0001 Abbreviations: T = tetra; Pe = penta; Hx = hexa; Hp = hepta; O = octa;

2.3.4.5. Environmental Monitoring Levels and Human Exposure The atmosphere pollution from stationary and mobile sources causes direct negative impacts on human health and the environmental media.

Picture 8 POPs releases impacts on human health and the environment

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2.3.4.5.1. Environmental Exposure routes and behaviour of POPs releases The exposure routes and behaviour of dioxins/furans, PCBs and HCB into the environment – air, water and soil are indicated on Tables 100 & 101. Table 100Environmental exposure routes of Dioxins/Fs, PCBs and HCB

Environment Dioxins/Furans Polychlorinated biphenyls Hexachlorobenzene media PCDDs/PCDFs PCBs HCB

AIR Dioxins/ Furans are released PCBs enter the air during their HCB enter the air as by- into the air from combustion use and disposal; from accidental product during the processes in industry; spills and leaks; and from leaks or manufacture of certain accidental fires; uncontrolled fires in products containing PCBs. chemicals. Small amounts can municipal solid waste & tire also be produced during burning; forest fires and combustion of municipal uncontrolled stubble-fields waste. Under ordinary burning; in emissions from conditions HCB not much industrial incinerators and evaporates into the air. Once motor vehicles. in air, it can be carried out long distances. Dioxins/Furans enter water as HCB enter the water from WATER PCBs enter the water during their a result of deposition after contaminated air. Once in disposal and from accidental spills emitted to the atmosphere water, it binds to sediments and leaks. In water, a small from combustion sources. and settles to the bottom. amount of PCBs may remain

dissolved, but most stick to organic particles and bottom sediments. SOIL Dioxins/Furans enter in soil PCBs enter soil during their HCB enter the soil from by atmospheric deposition disposal; from accidental spills contaminated air and water . It from combustion and and leaks. PCBs also bind sticks strongly to soil. manufacturing processes and strongly to soil. disposal of contaminated wastes.

WASTE When released in waste PCBs can still be released to the HCB can be released to the waters, some Dioxins/Furans environment from hazardous environment from hazardous are broken down by sunlight, waste sites; illegal or improper waste sites and during some evaporate to air, but disposal of industrial wastes and combustion of municipal most attach to soil and settle to consumer products; leaks from waste. the bottom sediment in water. old electrical transformers containing PCBs. BIOTA Dioxins/Furans low levels PCBs are taken up by small Low levels of HCB are taken may build up in the food organisms and fish in water. They up in eating contaminated food chain. Low levels of are also taken up by eating (e.g, fish, meat, milk, dairy Dioxin/Furans are taken up by contaminated food (fish, products), drinking eating contaminated food, meat, and dairy products), contaminated water, breathing breathing contaminated air breathing air near hazardous contaminated air and being in and drinking polluted water. waste sites and drinking contact with contaminated contaminated well water. soil.

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Table 101 Behaviour of Dioxins/Fs, PCBs and HCB in the environment

Environme Dioxins/Furans Polychlorinated biphenyls Hexachlorobenzene nt media PCDDs/PCDFs PCBs HCB

AIR Dioxins and furans are emitted as gas or PCBs are heavier than air and Atmospheric air bound to the particulates dispersed in the waste can settle in the ground layer. pollution with HCB gases – drops, dust, soot, ash. In the form of PCB molecules bind to bound to particulate gas, they are photo-degradable. However, their volatile particulates and to fine matter is a serious threat. low vapour pressure means that usually they aerosols of less than 0.05 – 20 Hexachlorobenzene is are emitted into the atmosphere adsorbed onto µm in size, they spread into resistant to ultraviolet various particles and this stops them form the atmosphere, and settle at radiation. disintegrating. This explains their ability to stay long distances, mainly in areas Fotodegradation in the in air for long periods of time and to be carried of cold climate. PCBs half- atmosphere takes along large distances. The Doxins life-times in times in the atmospheric air approximately 2 years the atmosphere , depending on the rate of vary from 3 weeks to 2 years. and the metabolites may chlorination vary from 0,5 to 10 days. The cause the formation of estimated tropospheric lifetimes of furans greenhouse gases or are

depending on the rate of chlorination vary from greenhouse gases 1.9 to 39 days. themselves. HCB has an estimated half-life in air of 0.5-4.2 years in air.

WATER In water, dioxins and furans exhibit extremely PCBs evaporate from ground HCB does not dissolve low solubility but, also, hibh capacity for and water surfaces over in water but is carried by adsorption into sediments and into the biota. several days. They accumulate it, and in this way Scientists have established that more than 90% in the sediments on water pollutes other water of the 2,3,7,8-THDD available in the aquatic basin bottoms and may, basins and, thus, soils. environment exist in adsorbed state. The half- through infiltration, pollute The half-life of HCB in life times of dioxins/furans depending on the ground water. Local pollution rivers varies between 0.3 rate of chlorination in water varies between 2.6 is possible also in result of and 3 days. and 4 days. emergencies, accidents or illegal activities. The half-life of PCBs in water is more than 6 years. SOIL Dioxins and furans enter soils by means of PCBs enter soils by means of HCB is not heavily wet and dry deposits adsorbed onto solid wet and dry deposits adsorbed absorbed in soil. Its half- particles and water drops. The poor waeter onto solid particles and water life in soil is 2,7 – 5,7 solubility of furans and dioxins means that they drops. Increasing chlorine years. do not exfiltrate from soils into the ground atoms increases the adsorption water and does not wash away from surfaces. and resistance to The evaporation of these compounds from the biodegradation in soils, and soil surface is also a limited process because of reduces the speed of their low vapour pressure. The main route for infiltration. The half-life of transition of PCDD/F from the soil surface into PCBs in soil is more than 6 air is by carrying along into the air stream of years. suspended particulates onto which these have adsorbed. Estimates of the half-life of TCDD on the soil surface range from 9 to 15 years, whereas the half-life in subsurface soil may range from 25 to 100 years (Paustenbach et al. 1992). BIOTA PCDDs/PCDFs have a relatively high PCBs have extremely long HCB has a relatively bioaccumulation potential and long half-life in half-lives in biota as for some high bioaccumulation biota (log KOW: 6.60 – 8.20). species it could reach more potential and long half- than 10 years life in biota (log KOW - 4,3-8,26). (log KOW - 3.93-5.73).

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2.3.4.5.2.Levels in the Environment Levels of Dioxins/Furans, PCBs and HCB in air POPs releases into the air are calculated by balance determination with adapted to the EU CORINAIR-94 Inventory Manual (Selected Nomenclature for Air Pollution For CORINAIR 94 Inventory (SNAP 94). There are no international regulatory provisions for implementing of monitoring for Air quality assessment concerning POPs releases. Levels of Dioxins/Furans, PCBs and HCB in soil

Dioxins/Furans (PCDDs/PCDFs) There are no international regulatory provisions for monitoring of soil contamination , concerning PCDDs/Fs releases. Polychlorinated byphenils (PCBs) In the period 1997-2002, the soil-chemistry monitoring of the MOEW covered 231 soil samples distributed uniformly across Bulgaria’s agricultural lands and analysed for content of 8 PCB congeners. Table 102 shows the range of PCBs concentrations for 8 congeners and sum PCB6 in soils for Bulgaria for the period 1997÷2002.

Table 102 PCBs concentration ranges in soils in Bulgaria PCBs congener Range µg/kg PCB 28 0,003 ÷ 4,37 PCB 52 0,007 ÷ 5,76 PCB 101 0,001 ÷ 3,04 PCB 105 0,029 ÷ 0,25 PCB 118 0,004 ÷ 0,71 PCB 138 0,004 ÷ 3,038 PCB 153 0,005 ÷ 2,65 PCB 156 0,031 ÷ 0,41 PCB 180 0,003 ÷ 5,75 PCBs total 0,009 ÷ 12,47

The analysis of the data shows that no PCBs congeners above the admissible limit value (ALV - 0,2 mg/kg) have been measured . Measurements in individual local points have shown levels of PCB congeners above the levels of concern(0,001 ÷ 0,004 mg/kg).

The sum PCBs content in soil is significantly (by a multiple factor) below the levels of concern which allows the assumption that no potential threat exists for pollution of soil with PCBs.

Hexachlorobenzene (HCB) The soil-chemistry monitoring included 4 years of systematic gathering by the MOEW of 277 soil samples for HCB residues analysis, out of which 124 were collected in the year 2000. The soil sampling points in 1997 had been orientated towards places with assumed soil pollution. The point 179 selection methodology was changed during the period 1998-2000 and the soil samples were equally distributed along the country’s agricultural land. The sample analysis was made using gas- chromatograph by means of MS and EC detector, according to ISO/CD 10382.2. The three levels of reference values – levels of concern, admissible limit values and intervention levels – have been used to evaluate the results, according toBulgarian legislation. Table 103 shows the number of samples, analysed for HCB in soils for the period 1997 ÷ 2000 in Bulgaria. Table 103 Number of samples analysed for HCB in soil by years Year 1997 1998 1999 2000 < MDL < MDL < MDL < MDL > > > > < ALV < ALV < ALV < ALV Total Total Total Total Total Total ALV ALV ALV ALV Number of samples

Total for Bulgaria 12 9 3 0 52 19 33 0 89 67 22 0 124 98 26 0 MDL – minimum detection level ALV – admissible limit value 0,25 mg/kg The analysis results from soil monitoring for HCB show the following:

Out of 277 soil samples analyzed for the period 1997 ÷ 2000 only 30,3% (84 samples) show HCB residues below ALV, and the remaining 193 soil samples(69,7%) are below the minimum detection level (MDL); The registered levels of HCB in soil are 0.02 ÷ 4,01 µg/kg, which are significantly below ALV (0,25 mg/kg);

There are no HCB polluted soils in Bulgaria.

Levels of Dioxins/Furans, PCBs and HCB in water

Dioxins/Furans (PCDDs/PCDFs) There are no international regulatory provisions for monitoring of groundwater contamination , concerning PCDDs/Fs releases. Polychlorinated byphenils (PCBs) According to Regulation 1 on the Studying, Use and Protection of Ground Water, SG 57/14.07.2000, amended SG 64 /4.08.2000, the condition of ground water is defined as follows: 1. Ground water in excellent condition – the parameters are below the environmental threshold; 2. Ground water in good condition – the parameters are between the ecological threshold and the pollution threshold; 3. Ground water in poor condition – the parameters are above the pollution threshold; 4. Ground water in a very bad condition – water where damages have occurred. Table 104 presents data for number of samples, analysed for PCBs congeners (PCB 28; PCB 52; PCB 101; PCB 138; PCB 153 and PCB 180) in ground water from the National Ground Water Monitoring Network. PCB 105 and PCB 118 and PCB 156 had not been analyzed.

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Table 104 Number of samplesq analysed PCBs in ground water for 2001 Urban centres Municipalities,

Area samples for samples for samples for samples for samples for samples for Number of Number of Number of Number of Number of Number of PCB 101 PCB 138 PCB 153 PCB 180 PCB 28 PCB 52 Year total

2001 Kardzhali 3 3 4 4 4 4 4 4 2001 Pazardzhik 3 7 8 8 8 8 8 8 2001 Plovdiv 5 6 6 6 6 6 6 6 2001 Haskovo 6 10 8 9 9 10 10 10 TOTAL 17 26 26 27 27 28 28 28

The analysis of total 164 ground water samples in 26 urban places showq that all levels of the six PCB congeners are below the minimum detectable level (< MDL) . In Bulgaria for 2001 there are no ground water polluted with PCBs. All values were below the ecological threshold and this classifies the ground water as ground water in excellent condition. Hexachlorobenzene (HCB) In the period 1998-2002 two groups of samples have been taken for analysis of hexachlorobenzene in ground water – at high ground water level in spring time, and low level by the later summer and early fall. The samples taken for HCB in ground water were totally 287, and in the year 2002 they were 70. Table 105 presents number of ground water samples, analysed for HCB above and below the ecological threshold (ET)in Bulgaria from the National Ground Water Monitoring Network. Table 105 Number of samples analysed for HCB content in ground water in Bulgaria by years

Year 1998 1999 2000 2001 2002

Total Total Total Total Total Number > > > > > of ET ET ET ET ET samples Total 49 35 14 0 52 48 4 0 51 50 1 0 65 62 3 0 70 68 2 0

MDL – minimum detection level ET – ecological threshold 0,1 µg/l The analysis results from monitoring of ground water shows the following:

During the period 1998-2002 no HCB in ground water above the pollution threshold of 5 µg/l and above the ecological threshold of 0,1 µg/l have been registered in Bulgaria. From totally analysed 287 groud water samples 91,6% (263 samples) are below MDL and only 8,4% (24 samples) are below ET.

There is no HCB polluted ground water in Bulgaria for the investigated period. All values were below the minimum detection level in the period 1998 – 2002 and this classifies the ground water as ground water in excellent condition.

2.3.4.6. Levels of PCDD/Fs, PCBs and HCB in food The National Veterinary Medical Service (NVMS) at the MoAF is the national competent authority responsible for the National Monitoring Program for Control on Residues, including POPs in live animals and animal products intendet for human consumption.

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The results of control on Residues of PCBs in life animal and animal products - red meat; poultry; hen eggs; raw milk; fish; bee honey; farmed and wild game in 2003, performed by NVMS at MoAF under the National Monitoring Program for Control on Residues (NMPCR)indicate the following: No presence of any residues from B (3)(a) group organochlorine compounds – PCBs in the tested samples of Live Animals, Fresh Meat, Poultry, Fish, Farmed & Wild Game, Raw Milk, Hen Eggs and Bee Honey in Bulgaria for the Year 2003 has been detected. No investigations for PCDDs/PCDFs and HCB in food had been performed.

The results of control on Residues of PCBs in life animal and animal products are shown in table 36. (Part “POPs pesticides, point 2.3.1.9.).

2.3.4.7. Levels of PCDD/Fs, PCBs and HCB in animal world

The study of PCB in subcutaneous fat of a bear killed in April 2004 in Central Stara Planina, Troyan area, showed 142 ng/g fat of polychlorinated biphenyls (analysis protocol 140 dated 15.06.2004, issued by the Food Chemistry Laboratory at the NCHMEN in the town of Sofia).

2.3.4.8. Human exposure and health impact

Human exposure

Human exposure to background contamination with PCDD/PCDF is possible via several routes: Inhalation of air and intake of particles from air Ingestion of contaminated soil Dermal absorption Food consumption Humans occupy a top position in terrestrial and aquatic foodchains and as a result consume a high proportion of food in which persistent lipophilic compounds can be effectively biomagnified. Once ingested, POPs sequester in body lipids, where they equilibrate at roughly similar levels on a fat-weight basis between adipose tissue, serum, and breast milk. Milk monitoring is far more widely practised due to the relatively easy sample collection. It is possible to document three distinct types of human exposure to POPs compounds:

a. High-dose acute exposure: typically resulting from accidental fires or explosions involving electrical capacitors or other PCB-containing equipment or high dose food contamination. b. Mid-level chronic exposure: predominantly due to the occupational exposure or high consumption of a POPs –contaminated dietary source such as fish or other marine animals. c. Chronic, low-dose exposure: characteristic for the general population as a consequence of theexisting global background levels of POPs with variations due to diet, geography, and level of industrial pollution. People are exposed to multiple POPs during their lifetime and all individuals today carry detectable levels of a range of POPs in their body lipids.

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Levels in human tissue - Human milk A considerable number of studies have been produced on breast milk mainly aimed to characterise breast-fed infant exposure and the associated risk. Mothers’ age, number of breast-fed infants and dietary habits are in fact crucial parameters in determining POPs body burden and hence milk contamination.

Polychlorinated Biphenyls The international project conducted in 19 countries (Brasil, Bulgaria, Croatia, the Czech Republic, Egypt, Finland, Hungary, Ireland, Italy, New Zealand, Norway, Romania, Russia, Slovakia, Spain, Sweden, the Netherlands, the Unkraine) by the WHO – “WHO-coordinated Exposure Study on the Levels of PCBs, PCDDs and PCDFs in Human Milk, Organohalogen Compounds, 2003” carried out a study in Bulgaria of PCDD/PCDF content in mother’s milk of 30 healthy women distributed by 10 of three regions in Bulgaria (Bankya – environmentally clean and two (Sofia and Blagoevgrad) polluted in different degrees. The results show the highest content of PCB in human milk from Blagoevgrad, followed by that of Sofia. Lowest levels were found in the milk from mothers from the environmentally clean region of Bankya (Table 106). Table 106 PCB levels in human milk (pg TEQ/g fat) Bankya Sofia Blagoevgrad WHO - PCB 3.74 4.21 4.70 Sum WHO – PCDD/PCDF + PCB 8.82 10.35 11.81 The data from the study of the three PCB representatives -138, 153 and 180 – follow a similar trend (Table 107). Table 107 Level of the most important PCB markers in human milk (ng/g fat) PCB Bankya Sofia Blagoevgrad PCB 138 9.64 14.06 16.33 PCB 153 11.37 17.42 20.29 PCB 180 6.38 9.40 13.20 PCB levels below 5 pg TEQ/g fat and sum content of the three parameters below 40 ng/g fat have been established in human milk in Brasil, Australia, New Zealand, Hungary and Bulgaria. The highest PCB content was registered in the Ukraine, Italy, the Czech Republic and Russia – higher than 15 pg TEQ/g fat. The highest total content of the three PCB representatives 138, 153 and 180 in Spain, Slovalkia and the Czech Republic (400 – 500 ng/g fat). Dioxins/Furans - PCDD/PCDFs WHO carried out periodically monitoring programmes on the levels of PCDD/PCDFs and dioxin-like PCBs in human milk. The results of the third round of the WHO 2001-2002 co-ordinated exposure study show that the lowest levels of PCDDs/Fs have been found in Bulgaria (median value of 6,14 pg WHO-TEQ/g fat) and of dioxin-like PCBs – being one of the lowest (median value of 4,21 pg WHO-TEQ/g fat) after Hungury. (Table 108).

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Table 108 Levels of PCDD/PCDFs and dioxin-like PCBs in human milk (2001-2002) [pg WHO-TEQ/g fat]24

Country Number of PCDDs/Fs Dioxin-like PCBs pools median range median range Bulgaria 6.14 5.08-7.11 4.21 3.74-4.70 3 Czech Republic 7.78 7.44-10.73 15.24 14.32-28.48 3 Finland 9.44 9.35-9.52 5.85 5.66-6.03 2 Hungary 6.79 5.26-7.46 2.87 2.38-4.24 3 Ireland 6.91 6.19-8.54 4.66 2.72-5.19 3 Norway 7.30 7.16-7.43 8.08 6.56-9.61 2 Romania 8.86 8.37-12.00 8.06 8.05-8.11 3 Russia 8.88 7.46-12.93 15.68 13.38-22.99 4 Slovak Republic 9.07 7.84-9.87 12.60 10.72-19.49 4 The Netherlands 18.27 17.09-21.29 11.57 10.90-13.08 3 Ukraine 10.04 8.38-10.16 19.95 14.10-22.00 3

Industrialised countries like The Netherlands show relatively high levels of PCDD/PCDFs. Elevated levels of dioxin-like PCBs were found in human milk from Ukraine, Russia and the Czech Republic.

Human health effects

Many laboratory experiments have been conducted to test the relationship between POPs exposure and a range of adverse outcomes in animals. Table 109 shows some possible effects that can be produced by some of POPs – dioxins/furans, PCBs and HCB and Category of carcinogenicity by JARC*. Table 109 Potential effects of individual POPs Types of Effects PCDDs PCDFs PCBs HCB

Reproduction and/or development X X X X Cytochrome P450 system X X X X Porphyria X X X X Immune system X X X X Thyroid and retinol effects X X X X Skeletal changes X X X Endocrin disruptor X X X Carcinogenic effects X X X X Category of carcinogenicity Group 1 – carcinogen to Group 3 - Group 2A - Group 2B – JARC* humans : Only for Not classifiable probable possible 2,3,7,8- Cl4DD as carcinogen carcinogen to carcinogen to Group 3 – to humans humans humans not classifiable as carcinogen to humans: For all other PCDDs * IARC – Classification of agents, mixtures and exposures according to their carcinogenic risk to humans in accordance with the procedures adopted as standard IARC practice: Group 1 - carcinogenic to humans; Group 2A - probably carcinogenic to humans; Group 2B - possibly carcinogenic to humans; Group 3 - not classifiable as to carcinogenicity to humans;

24 Regiaonally based assessment of persistent toxic substances,Global Report 2003, UNEP 184

Detailed possible effects of POPs on human healt are shown on Table 110. Table 110 Possible POPs effects on human health

POPs Human health effects of POPs

Dioxins/Furans exposures to humans are associated with: an increased risk of severe skin lesions (chloracne and hyperpigmentation), altered liver function and lipid metabolism, general weakness associated with drastic Dioxins/Furans weight loss, depression of the immune system, and endocrine and nervous system abnormalities.

2,3,7,8-TCDD is a potent teratogenic and fetotoxic chemical in animals and a potent promoter in rat liver carcinogenesis. TCDD also causes cancers of the liver and other organs in animals. The most sensitive groups are fetus and neonatal infants.

PCBs can cause: a skin condition called chloracne, which produces pustules, blackheads and cysts; liver and thyroid gland damage, skin and eye changes, PCBs immunitoxicity, neurobehavioural deviations, reduced body mass of the newly born, reprotoxicity and carcinogenity. PCBs have also been classified as endocrine disruptors in an intact organism.

HCB effects on human health are associated with: alterations in liver enzyme activities and liver and thyroid gland damage, neurobehavioural deviations, depression of the immune system, and endocrine and nervous system HCB abnormalities, reduced body mass of the newly born and reprotoxicity. and carcinogenity. HCB Can produce skin eruptions and colour changes HCB is known to cause liver disease in humans (porphyria cutanea tarda) and cancer of the liver, kidneys and thyroid.

Fifure 14 shows the potential effects on human health of dioxins, furans, polychlorinated biphebyls (PCBs) and Hexachlorbenzene (HCB.).

The PCDDs/PCDFs, PCBs and HCB source category inventory and Environment Pollution assessment give reson to assume that hot spots around industrial and energy generation and transformation sources and landfills for disposal of industrial and municipal waste. No date exists for the level of environment pollution from industrial accidents, forest fires and uncontrolled stubble-fields burning as a source of Dioxin/Furans” No date from health and epidemiological studies of general population exposured to dioxins and furans have been published. No biological monitoring of risk target groups of population had been performed. From the assessment of occupational and environmental pollution with PCBs in Bulgaria it could be suggested that a health risk exists within the regions of thermal electric power stations using coal and mazut , around transformers and capacitors and badly maintained electrical PCBs equipment, near to iligal depot for municipal waste. In Bulgaria no studies has been carried out on the levels of PCBs in human body for target groups of workers and risk groups of general population as well as negative health effects assessment on target organs and systems. No data for acute and chronic intoxications with PCDDs/Fs, PCBs and HCB are available.

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Conclusions:

One of the lowest levels of PCBs and PCDDs/PCDFs in breast milk have been found in Bulgaria for the period 2001 – 2002 within the European countries. No studies have been carried out in the counry for the levels of PCDDs/PCDFs, PCBs and HCB in serum and adipose tissue as well as for HCB levels in breast milk. In Bulgaria no health and epidemiological studies has been carried out on risk groups of general population for negative health effects of PCDDs/Fs, PCBs and HCB on target organs and systems. No data for acute and chronic intoxications with PCDDs/Fs, PCBs and HCB are available.

SUMMARY Assessment of releases from unintentional production of Annex C Chemicals (PCDD/PCDF, HCB and PCBs) The emissions are calculated in relation with National CORINAIR - 94 methodology, approved by the Minister of Environment and Waters. It was developed by adapting the emission inventory Guide - CORINAIR-94, SNAP-94 for the Bulgarian conditions, taking into account the national specificities concerning the respective activity, technologies and equipment. National annual POPs emissions – Dioxins/Furans, PCBs and HCB An increase of Ds/Fs releases has been observed in 2003 by 16,7% of the 2002 emissions.In comparison to base year 1990, the annual emissions of dioxin/furans for 2003 a downward trend of 53,9% or 2,2 times had been observed, following the European trend. According to official data for PCDDs/PCDF emissions in Europe within the period 1990 ÷ 2003,the decrease is 2,7 times (63%). The annual PCBs emissions for the period 1990-2003 are almost the same. For the period 1990-2003, the HCB emissions in the atmosphere show a signicicant downward trend. Compared to the base year 1990, for the HCB emission in 2003, a sharp decrease with 91,7% or 12,1 times has been registered due to the decline of industrial production. National annual sectorPOPs emissions by category sources POPs releases, generated in Bulgaria in the past 5 years are within the range as follows: Dioxins/Furans: 200 ÷ 255 g I-TEQ/y, and in 2002 have reached 254,9 g I-TEQ/y. PCBs: 212 ÷ 261 кg/y, and for 2003 have reached 260,7 kg. HCB: 38 ÷ 54 kg/y, and for 2003 being 45 kg. For the period 1990-2003 the POPs emissions in the atmosphere show lasting downward trend.Compared to the base year 1990, PCDDs/PCDFs and HCB note a sharp decline, respectively with 53,9% or 2,2 times and with 91,7% or 12,1 times. The annual PCBs emissions for the same period are almost the same, which could be explained with upward or downward change of the PCBs emissions formed by various category sources. The registered decline in PCDDs/Fs emissions into the atmosphere for 2003 compared to base year 1990 is due mainly to the categories “waste treatment and disposal” – 95%, “combustion processes in industry” – 88%; “industrial processes” - 46% and “road transport and other motor vehicles and machines” – 43%. The lowest decline show category sources “combustion processes in trading, administrative and household sectors, in agriculture, in agriculture, forestry and fishing” – 25% and “combustion processes in energy generation and transformation” – 23%.

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The assessment of data show, that 75,9% of PCDDs/Fs releases are formed by categories “combustion processes in energy generation and transformation” (48,1%) and “combustion processes in trading, administrative and household sectors, in agriculture, in agriculture, forestry and fishing”(27,8%), followed by “industrial processes” and “road transport”. The registered decline in PCBs emissions into the atmosphere for 2003 compared to base year 1990 is due mainly to the categories“road transport and other motor vehicles and machines” – 54% and “combustion processes in energy generation and transformation”- 18%. PCBs emissions from categories “combustion processes in trading, administrative and household sectors, in agriculture, in agriculture, forestry and fishing” have increased considerably with 88,8%, which could be explained mainly with the growth in the consumption of wood and coal in household sector during past 5 years. The main sources of HCB emissions in air for 2003 are the categories “waste treatment and disposal” and “industrial processes” with lasting downward trend. Compared to base year 1990 a sharp decline of HCB emissions with 91% or 11 times is registered for the category “waste treatment and disposal” . The combustion processes are the main source of PCDDs/Fs and PCBs emissions for 2003. Thermal electric power stations emit about 48,1% of total annual dioxinx/furans emissions, followed by combustion processes in household sector – 27,8%, combustion processes in industry – 13% and road transport and other motor vehicles and machines – 8,2%. The biggest source of PCBs emissions in 2003 are the combustion processes in trading, administrative and household sectors, in agriculture, in agriculture, forestry and fishing, representing 63,1% of total PCBs annual sector releases, followed by road transport and other motor vehicles and machines – 18,2% and the combustion processes in energy generation and transformation – 17,7%. The main sources of HCB emissions in 2003 are the categories “waste treatment and disposal”-53,4% and “industrial processes” – 46,7%, being for 2003 – 45 kg. POPs emissions – PCDDs/PCDFs, PCBs and HCB- by districts for 2002 The sources of PCDDs/PCDFs and PCBs emissions in the atmosphere are distributed on the whole territory of the country. 2935 industrial sources generate 0,0001 to 8,29 g of PCDDs/Fs annually. 973 industrial sources generate 0,0001 to 3,41 kg of PCBs annually. The main sources of PCDDs/Fs and PCBs emissions from category sources “combustion processesin energy generation and transformation” and “industrial processes” for 2002 are thermal electric power stations and industrial manufacturers. The total PCDDs/PCDFs, PCBs and HCB emissions from category sources “combustion processesin energy generation and transformation” and “industrial processes” for 2002 are as follows: PCDDs/PCDFs - 132,67 g, representing 60,1% of annual emissions from all category sourcs (218,48 g); PCBs – 40,56 kg or 16,2% of annual emissions (250,06 kg); HCB – 16 kg or 42,1% of annual emissions (38 kg). The largest share of PCDDs/Fs emissions for 2002 have been registered in Stara Zagora - 58% followed by Sofia-city – 12,2%, Pernik – 7,9% and Burgas – 6 %.The largest PCB emissions have occurred in Sofia-city at 30%, Haskovo area at 30% and Stara Zagora area at 15% . The industrial HCB emission sources are metallurgical enterprises concentrated in the areas around Pernik and Sofia city, as 73,1% have been registered in Pernik. PCDDs/PCDFs and HCB emission values, allocated per capita and unit of area, versus base year 1990 show a lasting downward trend in times, due the decrease in industrial production in Bulgaria after 1990.

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PCBs emissions values, allocated per unit area are almost the same range, while per capita they increase, due probably to the growing consumption of wood and coal in household sector after 1990. Existing policy The control and monitoring of transboundary transfer of polluting substances, of the background quality of atmospheric air, and of the impact of atmospheric air pollution on the global processes are conducted by the Ministry of Environment and Water and by the National Statistic Institute. The direct control of the state and the operation of the sites that are sources of emissions into the atmospheric air and on the emissions of various sources is performed by: 9 The Minister of Environment and Water, the Regional Inspectorates of Environment and Water and the municipal authorities; 9 The authorities of the Ministry of Internal Affairs and of the Ministry of Transport – for motor vehicles. Emission inventory system in Bulgaria The involved institutions at national and local (sub-national) levels in Emissions inventory are Ministry of Environment and Water /MEW/ respectively Executive Environment Agency /EEA/ and Regional Environment Inspectorate /REIWs/, and National Institute of Statistics /NSI/ . Two parallel emission inventory programs are conducted in Bulgaria. The first one covers 150 large point sources and it is conducted by REIWs. The second one covers nearly 2000 point sources and it is conducted by National Institute of Statistics. Both are under the guidance of Ministry of Environment and Waters . The data collected are air pollution control facilities and their efficiency, technological and production data, data for fuels used and fines imposed. Data from the emission inventory are stored at local and national level. On a national level the Executive Environment Agency is the responsible organization for final preparation of the National air emission inventory and data reporting to the the UNECE/CLRTAP (Convention on Long-Range Transboundary Air Pollution). Existing regulatory framework The observation of existing national legislation in regard with POPs releases from unintentional production management guarantees the reducing of POPs negative impacts on the environment and human health. The country has transposed the main provisions under Stockholm convention in the Environment Protection Act, the Law on protection from harmful impact of dangerous substances and preparations, Clean Air Act, Water Act, the Law on the protection of soil against pollution, the Law of Health, the Law on Foods, Waste Management Act and their sub-legislative acts.

Monitoring of POPs releases Levels of Dioxins/Furans, PCBs and HCB in air There are no international regulatory provisions for implementing of monitoring for Air quality assessment concerning POPs releases. Levels of Dioxins/Furans, PCBs and HCB in soil There are no international regulatory provisions for monitoring of PCDD/F in soils. The sum PCBs content in soil is significantly (by a multiple factor) below the levels of concern which allows the assumption that no potential threat exists for pollution of soil with PCBs. There are no HCB polluted soils in Bulgaria.

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Levels of Dioxins/Furans, PCBs and HCB in water

There are no international regulatory provisions for monitoring of PCDD/F in water. In Bulgaria for 2001 there are no ground water polluted with PCBs. All values were below the ecological threshold and this classifies the ground water as ground water in excellent condition. There is no HCB polluted ground water in Bulgaria for the investigated period. All values were below the minimum detection level in the period 1998 – 2002 and this classifies the ground water as ground water in excellent condition.

Levels of PCDD/Fs, PCBs and HCB in food No presence of any residues from B (3)(a) group organochlorine compounds – PCBs in the tested samples of Live Animals, Fresh Meat, Poultry, Fish, Farmed & Wild Game, Raw Milk, Hen Eggs and Bee Honey in Bulgaria for the Year 2003 has been detected. No investigations for PCDDs/PCDFs and HCB in food had been performed.

Levels in human tissue & Human health effects

2.3.5. INFORMATION ON THE STATE OF KNOWLEDGE ON STOCKPILES, CONTAMINATED SITES AND WASTES, IDENTIFICATION, LIKELY NUMBERS, RELEVANT REGULATIONS, QUIDANCE, REMEDIATION MEASURES AND DATA ON RELEASES FROM SITES The storage facilities for unusable and obsolete pesticides are a source of local environmental pollution. The storage facilities are subject to annual inventorying and the statusof warehouses and of pesticides stored there are monitored. The construction of centralized municipal warehouses and BB cubes conforming to the legislative framework, responsible storage of available stockpiles, cleaning up of emptied warehouses are activities that illustrate consistency and sustainable management of the issue of prohibited and obsolete pesticides.

2.3.5.1. POPs pesticides stockpiles The assumed POPs pesticides stockpiles at the end of 2003 in Bulgaria are in the range of 22.25 t ÷ 25.82 t. The obsolete pesticides mixtures, consisting of or contaminated with POPs comprise of approx. 30.06 t. The assumed POPs pesticides stockpiles are totaling between 52.3 t ÷ 55.9 t, stored in 99 sites on the territory of 22 districts.

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2.3.5.2. Obsolete pesticides stockpiles At the end of 2004 the total amount of obsolete pesticides stockpiles is 11222 t, stored in 561 warehouses and 1255 BB-cubes. The “unknown” obsolete pesticides comprise of 11219 t, out of which 4703 t are stored in 84 centralized warehouses, 2308t – in 477 unrepaired storages and 4211t – in 1255 BB-cubes. Total obsolete pesticides stockpiles stored in safe warehouses, conforming to all European requirements for safe and environmentally sound storage of hazardous waste and in BB cubes is 8914 t. The amount of “unknown” obsolete pesticides stored in 477 unrepaired and unsafe warehouses is 2308 t. The insufficient information about the assumed available approx. 52.3 t ÷ 55.9 t obsolete POPs pesticides and mixtures, consisting of or contaminated with POPs, contained exactly in these 2308t obsolete pesticides requires the implementation of detailed inventory of the “unknown” obsolete pesticides, stored in 477 unrepaired warehouses.

2.3.5.3. PCBs waste Waste, containing PCBs are phased-out equipment (capacitors), containing PCBs and waste transformer oils, containing PCBs. The waste, containing PCBs are stored on the territory of 8 districts. (table 111). Table 111 Phased-out equipment and waste, containing PCBs Total PCBs Capacitors Transformer oils, Transformer oils, PCBs Total PCBs Transformer PCBs № 100% PCBs PCBs assumed Capacitors Capacitors DISTRICT oils assumed Waste in stock Waste in stock Waste in stock Out-of-use on Out-of-use on Out-of-use tonnes tonnes tonnes stock stock on stock pieces pieces pieces 1 V.Tarnovo 4,72 4,72 50 50 2 Vratza 2,62 2,62 3 Lovech 21 9 30 4 Pazrdjik 87 5 Pernik 3,85 3,85 6 Sofia-city 6,03 6,03 456 46 502 7 Sofia-distr. 48 48 8 St. Zagora 2,9 2,9 30 30 9 Haskovo 97 97 Total 9,88 10,24 20,12 614 230 844

Total quantity of waste PCBs transformer oils is 20,12 t, out of which 100% PCBs are 9,88 t, and PCBs assumed - 10,24 t. Waste transformer oils, containing PCBs are in transformer holders warehouses, located in 5 districts. Total pieces of PCBs capacitors are 844, out of which PCBs - 614 , and PCBs assumed – 230. Out-of-use capacitors, containing PCBs are in capacitor holders’ warehouses, located in 6 districts.

2.3.5.4.Regions with potential for formation of PCBs emissions (PCDDs/PCDFs, PCBs and HCB) in the environment Regions with potential for formation of POPs emissions (PCDDs/PCDFs, PCBs and HCB) in the environment are the large industrial centres, where the main part of thermal electric power stations and industrial manufacturers are located as well as the large cities, where the main roads and R.W. lines pass by. In 2002, 58% of PCDDs/Fs emissions released from combustion processes in energy and industry sectors have been registered in Stara Zagora, followed by Sofia-city – 12,2%, Pernik – 7,9% and Burgas – 6 %. The surprising 7,9 % share observed in Kyustendil probably is as a result of Yugoslavia war. 190

The largest PCB emissions have occurred in Sofia-city at 30% (predominantly from thermal power plants), Haskovo area at 30% (predominatnly from the textile industries) and Stara Zagora area at 15% (predominantly from thermal power plants and the food industry). The industrial HCB emission sources are metallurgical enterprises concentrated in the areas around Pernik and Sofia city. Their share is 42,1% from total HCB emitted (38 kg) in 2002 . Therefore, regions with potential for formation of POPs emissions (PCDDs/PCDFs, PCBs and HCB) are theregions, close to the big thermal electric power stations, using lignite coal and mazut, the large industrial manufacturers, using mazut as fuel and the large cities, where the main roads and R.W. lines of the country pass by. The risk of air pollution with dioxins/furans and PCBs from forest fires, the municipal waste disposal sites and uncontrolled burning of solid municipal waste, stubbles and tires should not be neglected.

2.3.5.5. Hazardous Waste, containing POPs Data about hazardous waste is collected in Bulgaria only within the system of the MoEW (by the EEPA) by means of information cards documenting the name, quantity, properties, movement, storage and disposal of waste by enterprises whose activity involves hazardous waste generation and/or treatment. Table 112 Type and quantity of POPs containing hazardous waste in 2004 Code Waste type Unit Quantity 02 01 Waste from agriculture (orchards, flowers and gardening), forestry, hunting and fisheries 02.01.08 Agrochemical waste containing hazardous substances tons 11222 (obsolete and expired PPCs): 7011 − in storage; tons 4211 − in BB cubes tons including 52,3÷55 Obsolete POPs pesticides and their mixtures tons 22 ,3÷25 ,9 - Aldrin, Dieldrin, Endrine, Toxaphene, Heptachor and DDT tons 30,06 - Mixtures of POPs pesticides with „unknown“ composition 13 03 Used insulation and heat transferring oils 13.03.01 Processed insulation and heat transferring oils containing tons 20,12 PCBs − transformer oils containing 100% PCBs tons 9,88 − transformer oils with assumed PCB content tons 10,24 16 02 Waste from electrical and electronic equipment 16.02.09 Transformers and condensers containing PCB units 844 − Phased out capacitors, containing PCBs units 614 − Phased out capacitors, containing PCBs assumed units 230 The waste stockpiles of POPs pesticides and mixtures of obsolete pesticides, containing or contaminated with POPs are stored in warehouses and BB-cubes; The pfased out PCBs equipment and waste oils stocks are stored in storehouses of PCBs equipment holders.

2.3.5.6. Potentially contaminated sites The pollution might be caused by a point (local) source or by diffusion. Local pollution is usually associated with operating or closed mining or industrial enterprises, whereas the main contributors to diffusion are agricultural practices. Soil pollution by local or diffusion sources leads to soil functions damage and surface and ground waters pollution. The availability of pollutants, exceeding certain levels, may lead to negative consequences for the whole food chain, and thus – for human health, all kinds of eco-systems and other natural resources.

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Diffusion soil pollution

No new POPs soil pollution levels were recorded in 2003. At all points the measured content of POPs pesticides, PCBs and HCB is considerably below the reference background values and no potential threat exists from POPs soil pollution. Isolated local cases of DDT soil pollution were registered. The monitoring results show that at this stage the agricultural activities do not result in further soil load. That fact is due on the one hand to the reduced fertilizer and pesticides consumption, , but also to the performed programs for environmental-friendly agriculture and biological production.

Local soil pollution

Soil pollution from local sources results from industrial activities and waste management and is mainly identified as waste depots, spills and industrial accidents, fertilizer and pesticide storage sites. The industrial activities (historical or current) result in considerable risk for soils and ground waters.

Local soil pollution are not investigated well and registered in the country. The warehouses for safe storage of obsolete pesticides represent one of the sources of local soil pollution.

2.3.6. SUMMARY OF FUTURE PRODUCTION, USE AND RELEASES OF POPS 2.3.6.1. POPs pesticides POPs pesticides have never been produced in Bulgaria; POPs pesticides import and use are banned. No future production of POPs pesticides is foreseen in the country. 2.3.6.2. PCBs in equipment and oils PCBs and equipment, containing PCBs have never been produced in Bulgaria; PCBs import is banned. The marketing and use of PCBs and preparations, including waste oils with content of PCBs greater than 0,005 % (50 mg/kg) are prohibited. PCBs use is allowed only for electrical equipment in close systems – transformers and capacitors. Equipment with PCBs concentration in the fluid greater than 0.05 % by weight (500 mg/kg) and volume above 5 dm3 - latest by the end of 2010. Equipment with PCBs concentration in the fluid greater between 0,005 % by weight (50 mg/kg) and 0,05 % by weight (500 mg/kg) and volume above 5 dm3 - at the end of their useful lives , but not later than the end of 2025. No future production of PCBs is foreseen in the country. 2.3.6.3. POPs releases from unintentional production – PCDDs/Fs, PCBs and HCB For the projected POPs releases from unintentional production (PCDDs/Fs, PCBs and HCB), MoEW has developed prognosis for the period 2000 – 2020 with two options: pessimistic, and optimistic.

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Table 113 Prognosis of projected annual emission values of PCDDs/PCDFs for the period 2000 ÷ 2020 and current value for 2000 DIOX g/year pessimistic optimistic 2000 232,528 232,528 2007 244,383 263,813 2010 241,357 270,832 2015 264,545 296,443 2020 271,493 323,89

Table 114 Prognosis of projected annual emission values of PCBs for the period 2000 ÷ 2020 and current real value for 2000 PCBs kg/year pessimistic optimistic 2000 228,475 228,475 2007(8) 200 228,967 2010 214,1 262,114 2015 231,024 305,7 2020 246,808 355,348

Table 115 Prognosis of projected annual emission values of HCB for the period 2000 ÷ 2020 and current value for 2000 HCB кg/year pessimistic optimistic 2000 54,3 54,3 2007 64,1 78,3 2010 68,7 91,7 2015 72,9 103,1 2020 77,3 116,06

2.3.7. EXISTING PROGRAMMES FOR MONITORING RELEASES AND ENVIRONMENTAL AND HUMAN HEALTH IMPACTS 2.3.7.1. National environmental monitoring system (NEMS) Environmental Protection Act (EPA), (SG 91/25.09.2002; Corrected, SG No. 96/2002; amended SG 70/10.08.2004) regulates the establishment and management of the National Environmental Monitoring System, covering the entire territory of Bulgaria The National Environmental Monitoring System. (NEMS) is organized and directed by the Minister of Environment and Water. A number of subsystems for monitoring of POPs in the environmental media exists in Bulgaria as a part of NEMS. The National Environmental Monitoring System shall comprehend: 1. The national networks for: a) ambient air monitoring; b) precipitation and surface-water monitoring; c) ground-water monitoring; d) sea-water monitoring; e) geological environment monitoring; f) land and soil monitoring; g) monitoring of waste landfills and of past pollution with waste;

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2. A system for information on, and control of, air emissions and the state of waste waters; For the purposes of the information support of the National Environmental Monitoring System, a National Automated System for Environmental Monitoring (NASEM) is established at national, basin, and regional level. Methodological guidance of the monitoring activity shall be provided by the Executive Environment Agency (EEA). The state of the environment is assessed at regional and national level, respectively, by the RIEWs and the Executive Environment Agency. The data on and assessments of the state of the environment are published in a quarterly and annual Bulletin on the State of the Environment.

2.3.7.1.1. Air

Ministry of Environment and Water The National Environment Monitoring System, Air quality control /AQC/ consists of 53 stationary sampling points, including 26 manual sampling, 9 mobile and 18 automatic stationary stations, located in 33 settlements. The concentrations of the following pollutants are analyzed: dust, PM10, sulphur dioxide, nitrogen dioxide,carbon oxide, hydrogen sulphide, phenol, ozone, ammonia, chlorine and hydrogen chloride, sulphuric acid aerosols, benzene, toluene , styrene, xylene, heavy metals, methane and non-methan hydrocarbons. The national database for AQC includes primary information about pollutants level in the ambient air. With an additional statistical development the primary information is reduced to daily, monthly and annually concentrations used for assessment of air quality control in accordance with European and National legislation. Bulgaria does not have monitoring system for assessment of air quality concerning POPs releases.

National Environment Monitoring System, Emissions control of harmful substances in atmospheric air

The database includes information about: emissions from all the sources of harmful substances, from anthropic activity and nature. They are summarized in 11 basic groups: heat and power stations, domestic combustion, combustion processes in industry, non-combustion production processes, extraction and processing of fuel resources, solvents usage, road transport, other transport, waste treatment and disposal, agriculture and nature resources. The emissions of the following harmful substances are controlled: dust, sulphur dioxide, nitrogen dixide, PAH, PCBs, HCB, PCP, DIOX, methane, non-methane carbons, ammonia, carbon oxide, Hg, Cd and Pb. The institutions,responsible for information,associated with harmful substances emission contol are MOEW, respectively EEA, RIEW and NSI. In Bulgaria there are two paralels for emission control. The first cover 150 major point sources is led by EEA and RIEW.The second covers approximately 2000 point sources and is responsibility of NSI. The both programmes are controlled by MOEW and are on CORINE-94 (SNAP 94) methods. The information is kept on national and local level. The local database are stored in NSI and RIEW. The both organizations send data for emissions in National database of EEA. Every year in EEA, together with RIEW are prepared annual work schedules for the objects-major stationary sources of harmful substances for filling in registration maps and for objects being subject of compulsory control measurements. Information development, assessments and analysis are performed by EEA

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Ministry of Health Concentrations of the ambient air pollutants monitoring Inspectorates of Hygiene and Epidemiology (new name& Regional Inspectorates of protection and control of public health – RIPCPH) are performing monitoring of the ambient air pollutants in the following settlements: Sofia, Zlatica, Pirdop, Pernik, Stara Zagora, Dimitrovgrad, Russe, Silistra, Pleven, Plovdiv, Assenovgrad, Kuklen, Pazardzik, Burgass, Varna, Devnya, Veliko Tarnovo, Vraca, Beli Izvor, Zverino, Zli Dol, Eliseina, Zlatna Panega, Brestnica, Dobrich, Yanbol .

The information consist of mean annual, 24 hours and hourly concentrations of dust, SO2, NO2, PM10 , H2S monitored in 26 settlements. These settlements include as well the so called "hot spots" in the country. In the towns of Vraca, Sofia and Plovdiv PM10 and PM2,5 are monitored as well. There are only few settlements where other specific pollutants are monitored such as: CL2, NH3, H2SO4, HCL, Phenols, As, Cd, HF.

National statistical institute

Air emissions

Emissions in the air from industrial combustion and production processes, road transport, agriculture and households are monitored. Data are aggregated by territorial and industrial region.

State Agency for Energy and Energy Resources - National Electricity Copmany

Air emissions pollution from thermal electric power station NEC

Emissions of SO2, NOx, CO2, CO, dust and fly ash: Maritza East1, Maritza East2 , Maritza East3, Maritza 3, Bobov dol, Russe East and Varna are monitored. Emissions of consumed fuels - coals and fuel oil; fuel characteristics - thermal units, fly ash amount, moisture are determined.

Technological - economic indicators of thermal electric power station NEC

Specific consumptions conditional fuel , others. Hot spots :Maritza Iztok region, Ruse, Varna and Dimitrovgrad region Thermal electric power station sends a monthly report to NEC with the power station technical and economic indicators for the next month. On the base of the data are calculated the emissions about hazardous substances in air.

2.3.7.1.2. Water

Ministry of Environment and Water, Executive Environment Agency

National Environment Monitoring System, Subsystem “Water”, Functional subsystem “Underground water”

The database contains information from sampling site on underground water manitoring of National Environment Monitoring System, RIEWs, dates of sampling, No of protocol, values of physical-chemical parameters determined as well as values for Persistent Organic Pollutants (POPs) found – pesticides, PCBs and HCB. Groundwater samples are analysed for PCBs congeners (PCB 28; PCB 52; PCB 101; PCB 138; PCB 153 and PCB 180). PCB 105 and PCB 118 and PCB 156 congeners are not analyzed. Two groups of samples are taken for analysis of HCB in ground water – at high ground water level in spring time, and low level by the later summer and early fall. National System for Environmental Monitoring, Subsystem: "Water", Functional subsystem “Surface waters”

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National System for Environmental Monitoring, Functional subsystem “Surface waters” consists of 253 stations as follows: 185 river stations (10 of them located on the Danube river), 8 lake stations, 26 dam lake stations and 24 Black sea stations. Measured Indicators are Temperature, Activity reaction /pH/, dissolved oxygen, oxygen saturation, Biochemical oxygen demand (BOD5), COD-Mn, COD-Cr, Electrical conductivity, suspended solids, dissolved solids, Chloride ions, Sulphate ions, Ammonium ion, nitrite and nitrate nitrogen, Phosphates, Total hardness, Cyanides, petroleum products and extractable substances with tetrachlormethane, Iron, Chromium, Lead, Copper, Zinc, Cadmium, Nickel, Sodium, Tin, Arsenic. Surface water samples are taken monthly from rivers and 7 times annually from Black Sea.

Surface water samples are analyzed for POPs pesticides residues only in case of warning for any pollution or accidents.

Ministry of Agriculture and Forestry , National Plant Protection Servise Pesticide residues and heavy metals and nitrates content in irrigation water Pesticide residues and heavy metals and nitrates content in irrigation waters are monitored. NPPS controls regularly or in case of warning for any pollution of irrigation waters or pesticides, including POPs.

Ministry of Transport and Communications Executive Agency Marine Administration

Environmental monitoring on bulgarian blacksea coast

Database includes: - Total amount of carbons and petroleum hydrocarbons in sea water, sediments by marine and coastal stations - Total amount of individual polyaromatic carbons and chlorine content pesticides in sediments and in sea water. - Total amount of individual polyaromatic carbons in mussels

Environmental monitoring on bulgarian blacksea coast 1999/2000

Database includes: - Total amount of carbons and petroleum hydrocarbons in sea water and sediments by coastal and marine stations - Total amount of individual polyaromatic carbons and chlorine content pesticides in sea water and in sediments by coastal and marine stations - Total amount of individual polyaromatic carbons and chlorine content pesticides in mussels

2.3.7.1.3. Soils

Ministry of Environment and Water, Executive Environment Agency

National Automated System for Ecological Monitoring /NASEM/, Subsystem "Lands and soils", Funtional subsystem "Earth bowels protection", Waste

Since January 2004 a new system for soil monitoring ia approved and introduce by MoEW. Level II consists of National sampling points net for monitoring of regional pollution including industrial pollution, soil oxidation and salinification, land critical loading and soil erosion.

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The National Nets for Control and Industrial Soil Pollution Prevention register: - Soil pollution with heavy metals in the vicinity of large industrial polluters – 33 sampling points; measured parameters: рН, Pb, Cu, Zn, Cd and As; - Soil pollution with POPs from 20 sampling points; measured parameters: 16 polyaromatic hydrocarbons and 6 PCBs congeners.

National Automated System for Ecological Monitoring /NASEM/, Subsystem "Lands and soils", Funtional subsystem" Control and soils pollution protection with persistent organic pollutants - pesticides"

The database includes measured residues of organochlorine, phosphorus organic and triazine pesticides in soils. The sampling is performed in regions by 15 regional inspectorates for environment and waters, samples preparation and analysis are performed in 6 basic RIEW. Organization,coordination,quality control and assessment are performed by EEA/Sofia. Measurement technique: ISO /CD 10382.2

Measured indicators:

9 organochlorine pesticides: DDT,heptachlorine,endrine,eldrine,dieldrine, methoxichlorine,cis-heptachloroepoxyde, hexachlorocyclohexane isomers; 9 organophosphorus pesticides-zolone,phenitrotion; 9 and triazine pesticides-atrazine, simazine, propazine.

National Automated System for Ecological Monitoring /NASEM/, Subsystem "Lands and soils", Funtional subsystem" Control and soils pollution protection with persistent organic pollutants - pesticides" - storages and plant protection products, stored in them

Since January 2004 a new system for soil monitoring ia approved and introduce by MoEW. Level III monitors and registers the local soil contamination, including the control and soil protection from mining industry activities and storehouse status and the amounts of obsolete and banned pesticides stockpiles. Using information cards, including 10 indirect indicators the RIEW collect every year data about obsolete pesticides stockpiless ( storehouse status ,owner, localit) and pesticides , stored in them (amount, liquid and solid state, known and unknown type). Data obtained are as a result of expert assessment based on site visits with participation of MOEW’s, Civil Protection Agency and MoAF representatives. discusses and takes decisions on all activities regarding the facilities for storage of prohibited and obsolete pesticides. The collected information is submited to EEA for summarizing and analysis by statistical methods, being a base for assessment of local soil contamination. The established database shall be included in special Register for local soil pollution and contaminated sites, which are localized by settlements on the land of which the obsolete pesticides storage is located. National Automated System for Ecological Monitoring /NASEM/, Subsystem "Lands and soils", Funtional subsystem "Control and and soils pollution protection with persistent organic pollutants - PAH and PCB" The database includes measured background concentration of heavy metals in soils from 20 points for monitoring and control, selected in accordance with pollution source : point (industrial), linear (road transport) and reference background. The information is collected by RIEWs, settlements, municipalities, districts and for the whole country. Measurement technique: ISO /CD 10382.2. Measured indicators: - PAH – 16 compounds in accordance with European classification; - PCBs – 6 congeners in accordance with European classification;

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Sampling is performed by 15 RIEWs and analysis – 4 RIEWs. Organization,coordination,quality control and assessment are performed by EEA/Sofia

Ministry of Agriculture and Forestry National Plant Protection Servise (NPPS)

Pesticide residues and heavy metals and nitrates content in soil

Together with its regional structures and laboratories NPPS controls regularly or in case of warning for any pollution of soils, irrigation waters or plant products regarding the above mentioned pollutants.

Pesticide residues and heavy metals and nitrates content in row materials and products of plant origin

NPPS together with its regional units and laboratories controls regularly or in case of warning for any pollution of plant products and row materials with pesticides residues, heavy metals and nitrates.

National Veterinary Medical Service (NVMS)

National Monitoring Program for Control on Residues (NMPCR), including POPs in live animals and animal products intendet for human consumption. The National Monitoring Program for Control on Residues (NMPCR) in live animals and animal product includes: live animals and fresh meat – cattle, horses, sheep, lambs, goats, kids and pigs; poultry – ducks, goose and hens; eggs - hen eggs and quail eggs; fish - carp, silver carp, hausen, trout, pike and perch; milk - sheep and cow milk; game - deer and pheasants; farmed game – pheasants and rabbits; bee honey.

Individual samples are tested for Residues of antibacterial substances, phosphorus organic or organochlorine compounds - organic substances, including such as PCBs, chemical elements, mycotoxines or radionuclides in Life animals and animal products - red meat; poultry; hen eggs; raw milk; fish; bee honey; farmed and wild game. NVMS publishes annual report on residues detected.

2.3.8. CURRENT LEVEL OF INFORMATION, AWARENESS AND EDUCATION AMONG TARGET GROUPS; EXISTING SYSTEMS TO COMMUNICATE SUCH INFORMATION TO THE VARIOUS GROUPS; MECHANISM FOR INFORMATION EXCHANGE WITH OTHER PARTIES TO THE CONVENTION The efforts to guarantee the environmental protection and sustainable development in Bulgaria require public awareness raising. During recent years the Ministry of Environment and Water carried out a number of national public awareness campaigns on issues such as use of unleaded petrol, European day without automobiles; climates change and ozone-depletion substances; municipal waste reduction; for “Clean environment”, etc.

2.3.8.1. State of knowledge among governmental stakeholders The experts and specialists involved in management and control of chemicals in relevant agencies are highly qualified and experienced, with specific knowledge in their field (chemistry, medicine,

198 pharmaceuticals, economy, mathematics, physics, biology, machine engineering, metallurgy, agrochemistry, agronomy); they are aware of the national and international legislation, and of the global practices in their field, are computer literate and know one or more language (English, German, French, Russian). Table 116 presents data about the administrative capacity available in ministries and government agencies whose activities involve management of chemicals: MOEW; MH; MAF; MLSP; МЕ; MTC; NIS; State Agency “Civil Protection”. Table 116 Available resources at ministries and governmental agencies Ministry/agency Available experts Available experts number type MOEW; Headquarters 2 Managers 1 State experts 3 Chief experts 4 Senior experts 5 Junior experts

RIEW – 15 30 Experts MAF and NPPS – headquarters 7 Experts

Central control laboratory for 23, of which analysis of pesticides, heavy 11 specialists metals and nitrates 12 chemists MH Headquarters 8 Experts

IHE – 28 57 Experts

NCHMEN 15 Toxicologists 36 chemists 12 specialists

Clinics and clinical toxicology 42 Experts departments in Sofia and in larger 20 specialists towns Occupational disease clinic 3 Experts 1 specialists MLSP Chief labour inspectorate 5 Inspectors

Regional labour inspectorates 32 Inspectors МЕ 2 Experts Civil Defence State Agency 2 Managers 5 Experts Regional Civil Protection Directorates 30 Experts NIS 12 Experts Chief experts

Note: The number of experts in management of chemicals is for December 2004, with some experts being entrusted with other responsible, as specified in their job descriptions.

2.3.8.2. State of knowledge among target groups The training programmes aimed to provide technical competence to assess potential risks in the production, use, import, export of chemicals, and the disposal of their waste are mainly used in university-grade education. These are: the University of Chemical Technology and Metallurgy in Sofia, the Asen Zlatarov University in Burgas, the Chemical Department of the Sofia University

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“Kliment Ohridski”, Medical Universities. These are mostly master degree or post-graduate education programmes. In order to increase the competence of specialists for environment protection, many universities teach the subject of Ecology and Environment Protection: University of Chemical Technology and Metallurgy of Sofia, the Mining and Geology University of Ivan of Rila in Sofia, the Forestry University of Sofia, the Sofia University “Kliment Ohridski”, the Thracian University in Stara Zagora, the Technical University in Sofia, the Technical University in Varna, the South-West University of Neophit of Rila in Blagoevgrad, the Plovdiv University, etc. 2.3.8.3.Public state of knowledge According to a national representative sociological survey, more than half of the citizens are interested in environmental issues and state that they receive sufficient information. The other half claims that the information they receive is insufficient but this is caused by lack of interest (27%), lack of persons responsible to this information (8%), lack of such information (7%). The most preferred form of receiving of environmental information by the citizens is the national television stations, followed by central and local newspapers, and the information materials distributed to their homes and on public displays.

2.3.8.4. Public awareness Following the adoption of the NESAP for 2000-2006, the MOEW started a number of important steps for further provision of environmental information to the public. The MoEW, in cooperation with the NIS, has developed progress monitoring indicators, which can be traced from NIS studies. The results will guide the national policy for provision of information to the public for environmental decision making. The collection, processing and distribution of environmental information from the National Environmental Monitoring System (NEMS) are extremely important for the scope, the form and the understanding of the information for the public. A range of problems and weaknesses were analysed in the period 2000-2003 and measures for development of the system were envisioned. In addition, the annual public reports have been prepared in a way that helps better understanding of environment-related events in Bulgaria. The “minimum 5% annual increase in registered knowledge on issues of the environment and sustainable development” will be achieved by means of the following planned activities: Drawing up of a programme for rising of the public awareness on issues of environment and sustainable development. Implementation of the programme. Carrying out of sociological studies for progress monitoring.

2.3.8.5. Workshops for training of experts and public awareness raising GEF POPs 12 Pilot Countries’ NIPs Project – Bulgaria -Sub-project kick-off meetings and Technical Workshop for the Preparation of NIPs for POPs Management with participation of UNEP and UNITAR experts, December 8 to 15, 2002, Sofia. 8th International HCH and Obsolete Pesticides Forum”, organized by MoEW, Bulgaria and IHPA, Denmark, 26-28 May 2005, Sofia. Conference of the Parties of the Stockholm Convention on Persistent Organic Pollutants, COP1, Punta del Este, Uruguay, 2–6 May 2005. 2nd Meeting of the Steering Group - UNEP/DGEF: 12 countries pilot project for the development of National Implementation Plans (NIPs) for the management of Persistent Organic Pollutants (POPs), Geneva, 3-4 October 2005.

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Workshop “Stockholm convention on POPs”, NGO “Ecoglasnost”, 22 April 2005, Sofia. Workshop “Pesticides impacts in the Danube and Black sea region”, IPEN, 13-15 May 2005, Varna, Bulgaria Regional Workshop for CEECA countries on Lessons learnt and Good practice on NIPs development under Stockholm convention, UNEP Chemicals, 15-17 February 2006, Sofia.

Conclusions: The data about administrative capacity and financial resources submitted by these represented state institutions lead to the conclusion that most ministries have the necessary capacity to implement the new legislation on chemicals and POPs.. An additional number of experts should be envisioned for the MoH and for the Civil Protection State Agency and their branches throughout Bulgaria. The chemical-substance management training programmes offered in the Bulgarian universities at present provide very good technical competence that is required for the implementation of environmental conservation management programmes. To increase the competence of officials involved in the management of chemical substances and POPs , short-term courses and post- graduate requalification for bachelor and magistrate degree holders should be intensified.

2.3.9. RELEVANT ACTIVITIES OF NON-GOVERNMENTAL STAKEHOLDERS With their specific structure, financing and expression, non-governmental organizations play an important role in the management of any country. Many NGOs in Bulgaria have ecological issues and environmental protection at the centre of their activities. Considering the activities and the large diversity of non-governmental structures in our country, we could arrange them in a general group, as follows: 9 Industrial organizations – unions, branch chambers, economic associations, economic chambers, companies, manufacturer associations, etc.; 9 Universities, study institutions, colleges, vocational schools, specialized private schools, specialized national and international training courses, re-training, scientific research institutes, scientific-research sectors, associations, foundations, laboratories, etc.; 9 Non-governmental organizations – centres, clubs, movements, user associations; association of carriers, unions etc.; 9 Other organizations – limited liability companies (Ltd), joint stock companies (JSC), sole proprietors (SP), private companies, associations, consulting organizations etc. Despite the diversity of existing non-governmental structures and of the manner of their registration, the above organizations can participate through different types of activities (production, import, export, use of chemical substances, development of new chemical substances and their application) in “the life cycle” of chemical substances. Various non-governmental organizations may aid in the efforts of governmental institutions to manage chemicals and POPs, such as: collection and processing of data about chemicals and POPs; risk assessment; provision of programmes for training in management of chemicals and POPs; public awareness raising campaigns; research for ecological substitutes

2.3.9.1. Management of hazardous waste activities BALBOK ENGINEERING JSC The main activities related to management of chemical substances are: the Method for Detoxification and Decomposition of Unusable or Obsolete Pesticides, Sofia, 2000

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BB Cube steel reinforced concrete container for transportation and storage of hazardous and radioactive waste. Chapter 2 shows such cubes and the location of their sites in Bulgaria where environmentally sound storage of obsolete or expired pesticides, some of which might contain persistent organic pollutants. Management of hazardous waste containing polychlorinated biphenyls and polychlorinated terphenyls – pilot implementation of an action plan in a model region (Research on national production of PCB and import/export of PCB/PCT containing devices in Bulgaria) 2001

2.3.9.2. POPs activities management

BALKAN SCIENCE AND EDUCATION CENTRE OF ECOLOGY AND ENVIRONMENT (BSECEE) The main activities of the centre are: education; scientific research; consulting; expertise; provision of information; designing. The main work and projects of the BSECEE involving chemical substances, including persistent organic pollutants and their environmental impacts are: 1. Participation in the development of a National Profile for the Management of Chemical Substances, 1997. 2. Updating of the National Profile for the Management of Chemical Substances, 2002. 3. Elaboration of the National Action Plan for Management of Persistent Organic Pollutants in relation to the Stockholm Convention.

2.3.9.3. Publications and websites in the country POPs issues and Stockholm convention WEB page , containing various information, text of convention ; National Profile for the management of chemicals in Bulgaria can be found on the web site of Ministry and Environment and Waters (MoEW) – www.moew.government.bg. The POPs web page shall be amended with the NIP for POPs management in Bulgaria, POPs Action plans; POPs Inventories, POPs popular brochures for the awareness raising of general population and other issues related to POPs issues in Bulgaria soon as the final POPs reports have been endorsed by National POPs Coordinating Committee. The endorsement of POPs NIP is forseen for the end of March 2006. The POPs web page shall be updated regularly.

Links to other international stakeholders

Official website of the Stockholm Convention: www.pops.int Official website of the Rotterdam Convention: www.pic.int Official website of the Bazel Convention: www.basel.int Official website of UNEP- Chemicals: www.chem.unep.ch Official website of WHO: www.who.ch Official website of FAO: www.fao.org Official website of UNIDO: www.unido.org Official website of OECD: www.oecd.org Official website of UNITAR: www.unitar.org Official website of IFCS: www.who.int/ifcs/

The University of Chemical Technology and Metallurgy (UCTM) in Sofia teaches chemical engineers jointly with Universities from Germany and France. Three theses have been developed and successfully defended in 2004 in the UCTM on evaluation of the status in Bulgaria of DDT, polychlorinated biphenyls in transformer and condenser oils, and polychlorinated biphenyls in emissions. University of Forestry, Sofia. Seven theses have been defended in 2004 on subjects related to persistent organic pollutants which are subject to the Stockholm Convention. Three of these include

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data about emissions of dioxins, furans, polychlorinated biphenyls, and poly-aromatic hydrocarbons into the atmospheric air in Bulgaria, and environmental conservation possibilities. Three others evaluate the present status of the DDT problem, as well as that of some plant protection preparations, and consider the possibilities for their environmentally sound disposal. One of them is related to inventorying condenser and transformer oils containing polychlorinated biphenyls, and their effect on the environment and on human health.

Conclusions: Regarding POPs, the scientific research institutes and their various forms in the state and private sectors have the potential for human-health risk assessment through studies of POP content in mothers’ milk; and to study POP contents in plants and animals to establish their accumulation or spreading along the food chain. They can elaborate and introduce POP measurement methods and model POP distribution into the environment from emission sources. These institutes can carry out research for improvement of the monitoring technologies and systems, and can study the depositions from emissions, the POP transformation processes and presence, and the synergy in selected ecosystems.

2.3.10. OVERVIEW OF TECHNICAL INFRASTRUCTURE FOR POPS ASSESSMENT, MEASUREMENT, ANALYSIS, ALTERNATIVES AND PREVENTION MEASURES, MANAGEMENT, RESEARCH AND DEVELOPMENT – LINKAGE TO INTERNATIONAL PROGRAMMES AND PROJECTS 2.3.10.1. Laboratory Infrastucture for POPs analysis A number of laboratories in Bulgaria may be involved in the management of chemical substances in the various stages of their life cycle. These laboratories are capable of analysing chemical quality during the manufacturing process, analysing and controlling of waste products, identifying unknown substances, studying of possible harmful effects, etc. These laboratories should be accredited according to Bulgaria’s current legislation. Table 117 Accredited Laboratories for Analysis of POPs № Name/ Location Personnel Laboratory equipment Analysis of: POPs 1 Laboratory for analysis of organic 3 1 GC/MS system “Hewlett Packard Water, POPs pollutants, Executive Agency 5890/5972”, 1 GC/MS system “Termo sediments, pesticides, Environmental Protection, Ministry Finnigan DSQ” 2 HPLC systems with soil, PCB and of Environment and Water, Sofia DAD, FLD, UV, 1 GC/FID/ECD oils HCB system Agilent 2 Regional Laboratory, EA 2 1 GC/MS system “Hewlett Packard”, Water, POPs Environmental Protection, Ministry 1 LC system “Hewlett Packard” sediments, pesticides, of Environment and Water, Russe soil PCB and HCB 3 Regional Laboratory, EA 2 1 GC/MS system “Termo Finnigan Water, POPs Environmental Protection, Ministry DSQ”, 1 GC/MS system “Hewlett sediments, pesticides, of Environment and Water, Plovdiv Packard”, 1 GC/FID system “Perkin soil PCB and Elmer” HCB 4 Regional Laboratory, EA 1 1 GC/FID system “Perkin Elmer”, Water, POPs Environmental Protection, Ministry 1 GC/MS system Agilent sediments, pesticides, of Environment and Water, Varna soil, PCB and oils HCB 5 Regional Laboratory, EA 1 1 GC/MS system “Hewlett Packard”, Water, POPs Environmental Protection, Ministry 1 GC/MS system Agilent sediments, pesticides, of Environment and Water, Burgas soil PCB and HCB 6 Chemical studies, Inspectorate of 5 1 GC system “Perkin Elmer”, 1 UV- food, water POPs Hygiene and Epidemiology, Sofia VIS Specter Photometer “Perkin pesticides Elmer”, Thin-layer Chromatography 7 Toxicology, Inspectorate of Hygiene 3 UV-VIS Specter Photometer “Lomo”, Food POPs and Epidemiology, Sofia Thin-layer Chromatography kit pesticides 8 Laboratory Studies, Inspectorate of 3 VIS Specter Photometer Food POPs Hygiene and Epidemiology, Razgrad pesticides

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9 Toxicology of food, Inspectorate of 3 1 GC system “Perkin Elmer”, Thin- Food, water POPs Hygiene and Epidemiology, Varna layer Chromatography kit pesticides 10 Laboratory Studies, Inspectorate of 5 1 GC system “Perkin Elmer”, Thin- Food, water POPs Hygiene and Epidemiology, Burgas layer Chromatography kit pesticides 11 Laboratory Studies, Inspectorate of 5 1 GC system “Perkin Elmer”, Thin- Food, water POPs Hygiene and Epidemiology, Pleven layer Chromatography kit pesticides 12 Laboratory Studies, Inspectorate of 5 1 GC system “Perkin Elmer”, Thin- Food, water POPs Hygiene and Epidemiology, Plovdiv layer Chromatography kit pesticides 13 Laboratory Studies, Inspectorate of 4 Thin-layer Chromatography kit Food, water POPs Hygiene and Epidemiology, Stara pesticides Zagora 14 Central Laboratory for Monitoring of 10 3 GC systems 2 GC/MS system 1 LC Plant POPs Pesticides, Nitrates, and Heavy system, 2 HPLC, 1 UV-VIS Specter products, pesticides, Metals. Photometer soil, PCB and National Plant Protection Service, sediments HCB Sofia 14 Chemistry of Food, National Centre 24 2 GC systems, 1 HPLC, 1 UV-VIS Food POPs for Hygiene, Medical Ecology, and Specter Photometer pesticides, Nutrition, Sofia PCB and HCB 15 Environmental Chemistry, National 35 2 GC systems, 1 GC/MS system 1 Soil, water, POPs Centre for Hygiene, Medical HPLC system, IR Specter Photometer, air pesticides, Ecology, and Nutrition, Sofia UV-VIS Specter Photometer PCB and HCB

Note: The EABAS has accreditated under the Bulgarian State Standard EN ISO/IEC 17025:2001, BSS ЕN 45000 and ISO/IEC 17000 a number of laboratories working in the field of persistent organic pollutants.

No laboratory infrastructure for PCDDs/PCDFs in air, water, soil and food exists in Bulgaria. There is only two accredited Laboratories for analysis of PCBs in oils. Laboratory capacity for PCBs and HCB is insufficient.

2.3.10.2. National CORINAIR-94 Methodology for POPs emissions estimation The emissions are calculated in relation with National CORINAIR - 94 methodology for Determination of the Emissions of Harmful Substances in Air, approved by the Minister of Environment and Waters. It was developed by adapting the emission inventory Guide - CORINAIR-94, SNAP-94 for the Bulgarian conditions, taking into account the national specificities concerning the respective activity, technologies and equipment. The CORINAIR-94, SNAP-94 manual puts the pollutants into three levels. This nomenclature is based on three different levels of sub-categories and individual activities: - The upper level (11 items) corresponds to the main classical categories generating emissions of pollutants; - The intermediate level reflects the structure of activities according to engineering and socio – economical aspects; - The lowest level enumerates all relevant activities to be included for the CORINAIR 94 inventory. POPs belong to the third group – persistent organic pollutants. This methodology is used for inventorying and for balance determination of the emissions of harmful substances into the air.

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A. Definition of items in CORINAIR 94 methodology (emission sources)

1. Combustion processes in energy generation and transformation (stationary sources) Electricity and heat generation as primary activity, transformation of energy (including district heating). Cogeneration and autoproduction from sources belonging to this sector are included. 2. Combustion processes in trading, administrative and household sectors, in agriculture, in agriculture, forestry and fishing (stationary sources) Heat generation in other sectors than industry and energy production and transformation. Cogeneration and autoproduction from sources belonging to this sector are included. 3. Industrial combustion processes (stationary sources) Electricity and heat generation and production processes whose heat demand is met directly through combustion (non-combustion related emissions excluded). Cogeneration and autoproduction from sources belonging to industry are included. 4. Industrial processes (stationary sources) Non-combustion related emissions only. Heat demand of non-combustion processes is met directly through heat transfer media. Some plants involve processes possibly splitted into different items. 5. Extraction and distribution of fossil fuels Combustion for energy generation or transformation is included in item 1. Off - shore gas and oil installations including loading within EMEP area. Flaring is considered in item 9. 6. Use of solvents Use of solvents through application of solvent containing products, as an agent, and in manufacturing and processing of products. Use of N2O for anesthesia and possibly others. Flaring is considered in item 9. 7. Road transport Vehicles moving and parking, refueling is included in item 5. 8. Other motor vehicles and machines Land based activities in harbours and ground level activities in airports other than aircraft are included either in other groups or elsewhere in items of this group. Fishing boats under national registration within the EMEP area. Ship transport including ferries, irrespective of flags, between ports in the same country, localized within the EMEP area. Landing and take-off operations are differentiated from cruise for as well domestic as international traffic. Regarding machinery, the split is considered in the separate technology component. 9. Waste treatment and disposal Waste incineration with or without heat recovery may be included. If some waste is considered a relevant fuel for energy generation, then this combustion has to be included in items 1 to 3. Cogeneration and autoproduction from sources belonging to this sector are included. 10. Agriculture, forestry and and changes in land-use Combustion for heat generation is included in item 2, operation of vehicles and machinery in item 8 and open burning of waste in item 9. Managed forests are included in this item. Land use change is attached to this group. 11. Nature Processes uncontrolled by man (metabolic, degradation, thermal, etc.).

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B. Emission factors

The emissions of air pollutants are calculated based on the activity data and emission factors, which are set in CORINAIR 94 methodology, taking into account the national specificities concerning the respective activity, technologies and equipment. The CORINAIR-94, SNAP-94 and the Methodology are using the matrix approach. The rows in the matrix cover the sources of emissions. These are the activities (anthropogenic and natural) that generate emissions of the respective pollutants. The columns of the matrix involve the pollutants of air, i.e.the emitted harmful substances. Their emissions are calculated using the formula: Е = EF. Q where E – emission in a certain quantity EF – emission factor – a factor, a relative measure – emission related to a quantitative unit that defines adequately the specific activity. Q – Quantitative charactiristic Depending on the type of the activity, the quantitative characteristic may be: used raw materials, fuel, energy or manufactured produce. The dimensions use the SI system: g – gram, Nm3 – normal cubic meter, J – joules, Wh – watt hours, cal – calories for Q. The dimensions for the PCDD/PCDF emissions are: g – gram, µg – microgram (10-6g), ng – nanogram (10-9g). The emissions of individual congeners may be also in pg – picograms (10-12g) – or in fg – femtograms (10-15g). The emission factor reflects the correlation of quantity emissions of POPs from: • used raw materials: • the process type; • the level of used technology; • the availability and type of treatment facilities; A change of one or more of the four EF determining factors requires recalculation of the quantity of emissions. The emission factor value is not influenced by the geographic location of the activity.

C. Pollutants

The emissions of following air pollutants are estimated by the National CORINAIR 94 Methodology: - sulphur oxides /SOx/; - nitrogen oxides /NOx/; - ammonia /NH3/; - non-methane volatile organic compounds /NMVOC/; - carbon monoxide /CO/; - heavy metals: cadmium /Cd/, lead /Pb/, mercury /Hg/; - Persistent organic pollutants: hexachlorobenzene /HCB/, hexachlorocyclohexane /HCH/, polychlorinated biphenyls /PCBs/, dioxins/furans /DIOX/, polycyclic aromatic hydrocarbons (PAH), pentachlorophenol /PCP/;

The following air pollutants are not covered by the National CORINAIR 94 Methodology: - particulate matter /TSP, PM10, PM2.5/; - heavy metals: arsenic, chromium, copper, nickel, selenium, zink; - Persistent organic pollutants: aldrin, chlordane, chlordecone, DDT, dieldrin, endrin, heptachlor, mirex, toxaphene, hexabromobiphenyl.

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Emission data reporting to UNECE/CLRTAP for year 2003 According to the Revised Guidelines for estimating and reporting emissions data, Each Party should use the reporting format set out in Annex IV for its annual submissions. The reporting format aims at facilitating electronic submissions to simplify the processing of emissions information and the preparation of useful technical analysis and synthesis documentation.

The Bulgarian National annual emissions and national annual sector emissions using NFR are reported in electronic TABLE : National sector emissions: Main pollutants, particulate matter, heavy metals and persistent organic pollutants.

The Appendix provides the corresponding allocation of EMEP NFR source categories into SNAP 94 items of National emission inventory according to CORINAIR 94 methodology for year 2003.

As it is mentioned above the current CORINAIR 94 methodology doesn’t allow estimation of emissions of some harmful substances as particulate matter, some heavy metals and POPs. These pollutants are reported as NE (not estimated) in reporting table. There is not good correlation between the new EMEP NFR source categories and SNAP 94 items of the National CORINAIR 94 emission inventory. As a result some NFR source categories are not estimated in reporting table.

Future improvement in National methodology In order to improve the national emission inventory under the Convention on Long-Range Transboundary Air Pollution and to eliminate all methodological and data gaps in existing CORINAIR-94 inventory, at the moment MEW/EEA is in process of Updating of National Emission Inventory Methodology. The new methodology will be developed by adapting the Third edition of the EMEP/CORINAIR Atmospheric Emission Inventory Guidebook for the Bulgarian conditions, taking into account the national specificities concerning the respective activity, technologies and equipment. The new National CORINAIR methodology will take into account the requirements of the Revised Guidelines for estimating and reporting emissions data.

2.3.10.3. References

1. AMAP Report 2000: 3 “PCB in the Russian Federation: Inventory and Proposals for Priority Remedial Actions” 2. Atanasov, A. Devolopment of monitoring program for PCBs and PAHs soil contamination , graduation paper, UCTM-Sofia, 1999 3. BalBok Engineering Co., Detocsication and destruction method for obsolate pesticides, BalBok Engineering Co., 2000 4. BalBok Engineering Co., Management of dangerous wastes contaminated with PCBs and PCTs - pilot action plan aplly, June 2002 5. BalBok Engineering Co., "BB CUBE"- Reinforced- concrete container for radioactive and hazardous waste, BalBok Engineering Co. 6. BalBok Engineering Co., Envoronmentally sound management of obsolate pesticides as dangerous wastes on the terrytory of Bulgaria, Ecology and Bussiness 7. BalBok Engineering Co., Guideline for inventory, collecting, transport and disposal of PCBs/PCTs wastes, BalBok Engineering Co. 8. BalBok Engineering Co., Insulate techology for obsolete pesticides on the terrytory of Bulgaria, BalBok Engineering Co. 9. BalBok Engineering Co., Leitfaden zur Datenaufnahme( Inventarisierung), Sammlung, Befoerderung und Entsorgung(Beseitigung) PCB-haltiger Abfaelle in Republik Bulgarien, BalBok Engineering Co.

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10. BalBok Engineering Co., Origin, Quantity and Destination of PCB- containing Residues in Bulgaria - Tack VII, Tack IX (Final Report), BalBok Engineering Co., September 2002 11. BalBok Engineering Co., Research on national production of PCB and import/export of PCB/PCT containing devices in Bulgaria (Final Report) revision 1, BalBok Engineering Co., April 2001 12. Balinova A.,”The Obsolete pesticides stocks in Bulgaria – a source of long-term contamination of the environment”, 7th International HCH and pesticides forum, Kiev, Ukraine, 2003, pp 187-190. 13. Bratanova Z, K.Vassilev, Pesticides residues in ground and surface water in Bulgaria, 2000, Hygiene and Public Health, vol. XLIII,1, pp16-18. 14. Bratanova Z. et al., A review of Existing data on occurance of Pesticides in water of the River Danube and its tributaries, 1998, Fresenius Envir.Bull.,7:495-501. 15. Bratanova Zl. At al., “Groundwater pollution with pesticides in selected regions in Bulgaria”, 2005, Hygiene and health care, XLVIII. 16. 16. Broshtilova, M., Soil comtamination and ecosystems impact, University" Prof.Dr.Asen Zlatarov"-Bourgas, 37165 17. Dimova, V. Dioxins and furans emissions invetory in Bulgaria and possibilities for environment protection, graduation paper, FU-Sofia, 2004 18. Documentary inventory in 1995 (“Analysis and prospects for use of POPs in Bulgaria ,1995 ,IVECOL Sole Proprietor, Sofia, 1997) 19. Documentary inventory in 2000 (Kamburova V.,“Impact of Obsolete pesticides on rural environment”, Journal of Balkan Ecology, Vol.7, No4, 2004, p.425) 20. Ecotex Consult, Ltd, Chemicals - Administer, Guideline for consumer,Ecotex Consult, Ltd, 2000 21. Gopina G.et al., Health-Hygiene Characteristics of the Danube River in the district of Silistra with basic receiver the Black Sea, 1996, Hygiene and Public Health, vol. XXXIX, pp 25-27. 22. Gorova, R., Study on the Pesticides Content in the Groundwater in the Republic of Bulgaria: Some Problems and Recommendations, EA at the Ministry of the environment and water, 6th international HCH and pesticides forum, March 2001 23. IPCS, WHO/PCS/02.3, Inventory of IPCS and other WHO pesticide evaluations and summary of toxicological evaluations performed by the Joint Meeting on Pesticide Residues, 2002. 24. Ivanov, G. Assessment of some chlororganic pesticides used in Bulgaria - human health and environment impact, and possibilites for protection, graduation paper, FU-Sofia, 2004 25. Ivecol, Project for combustion of risk pesticides from Bulgaria into Netherland, Ivecol, 2001 26. Jeliazkova, L., R. Anguelova, Balbok Engineering Co, Reliability aspects of treatment and storage of obsolete and banned pesticides. Technologies and practices, 7th international HCH and pesticides forum, June 2003 27. Kaloyanova-Simeonova F., et all, Human exposure and Risk assessment of soil pollution with Persistent Organochlorine Compounds in Bulgaria, 2001, 7(3-4): 263-275. 28. Kamburova V., J.Christova, Zl.Bratanova, “Environmental pollution with organochlorine pesticides by small-scale incidents”, Fresenius Environmental Bulletin, 2005, Vol. 14, No 3,pp 1-4. 29. Kamburova V.,”Impact of obsolete pesticides on rural environment”,J.Balkan Ecology, 2004,Vol.7, No 4, pp 422-427. 30. Kazaldjiev, G. Possibilities for obsolate pesticides disposal, graduation paper, FU-Sofia, 2004 31. Midova, E. PCBs emissions inventory in Bulgaria and possibilities for environment protecion, graduation paper, FU-Sofia, 2004 32. National automated system for environmental Monitoring /NASEM/, Dimitar Vergiev,Executive Environment Agency, Ministry of Environment and Water, Bulgaria

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33. National Monitoring Programme for Control on Residues from Medicinal products and Environmental pollutions in Live animals and Foodstuffs of animal origin, MoAF, NVMS, 2004, pp 40-63. 34. Polychlorinated Byphenils and Terphenyls (2nd edition), IPCS,WHO,Geneva, 1993,pp 26-29. 35. Programme PHARE, Final EIA report of NHWC, Ecology consortium, August 2001 36. Progress in the management of local soil contamination, Soil Contamination 2003 Delivery Report of EEA/MoEW, Bulgaria to EIONET 37. Proposal for National Implementation Plan for POPs in Czech Republic,TOCOEN Report No.252, January 2004. 38. Regiaonally based assessment of persistent toxic substances,Global Report 2003, UNEP 39. Shatalov V.at al., Modelling of POP contamination in European region: Evaluation of the model performance. EMEP/MSC-E Technical Report 7/2005, August 2005, pp 103-117. 40. Simeonov, J.(2001),”Analysis of studies relating pesticides to breast cancer risk in exposed persons and their offspring.”In:Euroworkshop Proceedings Current Epidemiological Evidence versus Experimental Data on Reproductive and Development Toxicity of pesticides (T.Vergieva and F.Kaloyanova-Simeonova), Sofia, pp 193-216. 41. Sokolovski, E., B. Zdravkov, Iv. Dombalov, Y. Pelovski, Emissions of Persistent Organic Pollutions (POPs) and their Influence over Human Health and Environment, Seminar of the Balkan Environmental Association (B.EN.A), Medical Ecology and Human Health Protection, 18 - 22 December, 2003, Bitola, Macedonia – Journal of Environmental Protection and Ecology (in press) 42. Sokolovski, E., Iv. Dombalov, Atmospheric Pollution with POPs – Problems Related with Environment and Possibilities for Protection, Journal of Environmental Protection and Ecology, Vol. 6, № 1, 54 - 63 (2005) 43. Sokolovski, E. V. Hristova, Y. Pelovski, Iv. Dombalov, Romania, Journal of Environmental Protection and Ecology, vol.5, No1, p.29 - 35, 2004 44. Sokolovski, E. POPs inventory in R. Bulgaria, graduation paper, UCTM-Sofia, 2004 45. Sokolovski, E. State of PCBs equipment and oils in Bulgaria - environment impact , MSc thesis, UCTM-Sofia, 2004 46. Sokolovski, E., Dombalov, Y. Pelovski, Polychlorinated Biphenyls (ПХБ) in Transformer’s and Capacitor’s Oils and Their Influence Over Human Health and Environment, Seminar of the Balkan Environmental Association (B.EN.A), Medical Ecology and Human Health Protection, 18 - 22 December, 2003, Bitola, Macedonia – Journal of Environmental Protection and Ecology (in press) 47. Sokolovski, E., Iv. Dombalov, Assessment of the Emissions of Dioxins and Furans in Republic of Bulgaria, Journal of Environmental Protection and Ecology, Vol. 6, № 1, 45-53 (2005) 48. Sokolovski, E., Iv. Dombalov, Assessment of the Emissions of Polychlorinated Biphenyls in Republic of Bulgaria, Seminar of the Balkan Environmental Association (B.EN.A), Environmental Professions of: Eco-agro-tourism, Organic Agriculture, Public Health, Water and Soil Pollution, Sustainable Management, Solid Waste Recycling, 01 - 03 July, 2004, Plovdiv, Bulgaria – Journal of Environmental Protection and Ecology (in press) 49. Sokolovski, E., Zdravkov B.,Dombalov Iv. , Y. Pelovski, Transfer and Degradation of some Persistent Organic Pollutants (POPs) in Water Systems in Bulgaria, Journal of Environmental Protection and Ecology, vol.5, No1, p.16 - 23, 2004 50. Stoianov, S. D. Todorov. Dioxins and Furans, [email protected], 2001 51. Stoianov, S. Pesticides in environment and foods, toxicology, Pensoft, Sofia, 1999 52. Tasheva M, POPs Inventory 1996, National Centre of Hygiene, Medical Ecology & Nutrition,Training Workshop on POPs Inventories regarding NIPdevelopment, Dec.2003,Sofia,Bulgaria 53. The results are obtained within the frame of the European project “Corine Land Cover 2000”, funded by EEA and MoEW. 54. Vassileva, V., Obsolete pesticides and soil overview of Bulgaria, EA at the Ministry of the environment and water

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55. Vuchkova, K., H. Zafirov. Dangerous chemicals, preparation and products (Part 3), Leonardo da Vinci Programme, 2003 56. WHO-coordinated Exposure Study on the Levels of PCBs, PCDDs and PCDFs in Human Milk, Submitted to Dioxin 2002. Organohalogen Compounds, 2003. 57. WHO-Europe,“Health risks of persistent organic pollutants from long-range transboundary air pollution”, World Health Organization 2003, p.41.

2.3.10.4. Participation in international projects and programmes

1. МoEW, “Destruction of Risk Pesticides from Bulgaria in the Netherlands”, July 2000. 2. МoEW , Twinning project BG99IBEN01a " Management of Waste, containing PCBs”- part I. 3. МoEW, Twinning project BG99IBEN01a Management of Waste, containing PCBs”- part II. 4. MoH, PHARE project “ Danube Pesticide Regional Study”, 1995-1997. 5. MoH, Project “Environmental pollution with organochlorine pesticides by small-scale incidents” 1993 – 2000. 2.3.11. IDENTIFICATION OF IMPACTED POPULATIONS OR ENVIRONMENTS, ESTIMATED SCALE ANDMAGNITUDE OF THREATS TO PUBLIC HEALTH AND ENVIRONMENTAL QUALITY AND SOCIAL IMPLICATIONS FOR WORKERS AND LOCAL COMMUNITIES

There are not sufficient data to perform adequate assessment of POPs effects on human health and the environment. Potential sources of human health risks have been identified in in the country - storages for obsolete pesticides and the surrounding areas, PCBs equipment sites as well as “hot spots” of potentially large formation of POPs releases ( large industrial plants and electric power stations). There is a necessity for carrying out more POPs analysis of environmental media and investigations of target groups of population to identify and assess correctly the POPs impacts. 2.3.12. DETALS OF ANY RELEVANT SYSTEM FOR THE ASSESSMENT AND LISTING OF NEW CHEMICALS Each Party that has one or more regulatory and assessment schemes for new pesticides or new industrial chemicals shall take measures to regulate with the aim of preventing the production and use of new pesticides or new industrial chemicals which, taking into consideration the criteria in paragraph 1 of Annex D, exhibit the characteristics of persistent organic pollutants.

2.3.12.1. Notification of new chemicals - ELINCS This online ELINCS Information System provides , through the European List of Notified Chemical Substances (ELINCS), to find general information concerning a chemical substance like ELINCS number, Trade Name or Substance Name. This current ELINCS contains 3 827 chemical substances.

2.3.12.2. European Inventory of Existing Commercial chemical Substances (EINECS) The online EINECS Information System enables to find, through the European Inventory of Existing Commercial chemical Substances (EINECS), general information concerning a chemical substance like CAS number, EINECS number, Substance Name and Chemical Formula. This current EINECS contains 100 204 chemical substances.

2.3.12.3. New system for Registration, Evaluation and Authorisation of Chemicals (REACH) REACH aims to improve the protection of human health and the environment while maintaining the competitiveness and enhancing the innovative capability of the EU chemicals industry. Under REACH enterprises that manufacture or import more than one tonne of a chemical

210 substance per year would be required to register it in a central database. REACH would furthermore give greater responsibility to industry to manage the risks from chemicals and to provide users in the supply chain with safety information on the substances.

2.3.12.4.System for Major Accident Prevention and Control, involving dangerous substances – Seveso I and Seveso II A list of potential Seveso enterprises has been elaborated in 2001. It includes information about the number, type and locations of future enterprises witt Lower Tier or Upper Tier in regard with Seveso Directive. The list indicates that in Bulgaria exist 67 enterprises from chemical industry, Oil refineries, metallurgy, electric power plants, mining, pharmaceutical industry, old depots for pesticides), which are subject of control under Seveso Regulation. Out of these 67 enterprises, 35 are classifies as Upper Tier \large industrial enterprises and storage areas and 32 – Lower Tier ( smaller industrial enterprises, storage facilities for combustible chemicals, pesticides warehouses). From the Seveso reports assessment under this Convention chemicals posing biggest risk for the human health and the environment may be determined.

2.3.12.5. Business initiative : “Responsible care” and “Stuardship products” “Responsible care” is a voluntary initiative, developed and adopted by the Chemical industry Associations aimimg to improve the measures on human health prevention, safity of work and the environment within their production activities as well as for public awareness raising on these issues.

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3. STRATEGY AND ACTION PLAN ELEMENTS OF THE NATIONAL IMPLEMENTATION PLAN 3.1 POLICY STATEMENT The Stockholm convention is signed by the Republic of Bulgaria on 23 May 2001 and ratified on 30 September 2004 (SG № 89/12.10.2004). With its entry into force on 20 March 2005, the Republic of Bulgaria is obliged to comply with Stockholm convention requirements. Recognizing the threats posed by the adverse effects to human health and environment, caused by persistent organic pollutants (POPs) and conscious of the need for global action on persistent organic pollutants, the Republic of Bulgaria undertakes commitments to take necessary measures and activities to: reduce or eliminate releases from intentional production and use, including to prohibit its production, use, import and export (POPs, included in Annex A and B); reduce or eliminate releases from unintentional production (POPs included in Annex C) reduce or eliminate releases from stockpiles and wastes (Annex A, B or C). establish of POPs registrers; participate in the international information exchange regarding POPs; report on the implementation of the Convention. In implementing its obligation to develop an Action plan within 2 years of the date of entry of Stockholm convention for RBulgaria (i.e. 2007), the country has already developed National Implementation plan for management of POPs under GEF project GF/2732-02-4454. 3.1.1. PROJECT ACTIVITIES The project activities follow the step-wise process set out in the GEF “Initial Guidelines for Enabling Activities for the Stockholm Convention on Persistent Organic Pollutants” and the “UNEP-World Bank Guidance Document on the development of National Implementation Plans”. In summary, these are: (a) Determination of coordinating mechanisms and organization of process, public awareness-raising on POPs and other related hazardous substances; (b) Establishment of POPs inventory and assessment of national infrastructure and capacity; (c) Setting of national priorities and determination of objectives for POPs management; (d) Formulation of a national Implementation Plan and specific Action Plans on POPs; and (e) Endorsement of the National Implementation Plan by Stakeholders 3.1.2. ACTION PLAN ELEMENTS The action plan elements of NIP includes the following: 1. An Evaluation of POPs issue in the country: An Assessment with respect to Annex A, part I chemicals POPs pesticides: historical, current and future production, use, import and export; summary of available monitoring data (environment, food, humans) and health impact An Assessment with respect to Annex A, part II chemicals (PCBs); An Assessment with respect to Annex B chemicals (DDT); An assessment of current and future releases from unintentional production of Annex C chemicals (PCCD/PCDF, HCB and PCBs), including the development and maintenance of source inventories and release estimates, taking into consideration the source categories identified in Annex C; An Assessment on the state of knowledge of stockpiles consisting of or containing POPs listed either in Annex A or Annex B; and waste consisting of , containing or contaminated with POPs listed in Annex A, B or C;

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Steps to promote handling, collection, transport, storage and disposal in an environmentally sound manner of wastes consisting of , containing or contaminated with POPs listed in Annex A, B or C; An identification of sites contaminated by chemicals listed in Annex A, B or C; 2. An evaluation of the efficacy of the existing regulatory framework and policies of the R Bulgaria relating to the management of POPs; 3. Existing programmes for monitoring releases and environmental and human health impacts; 4. Strategies to meet the county’s obligations, taking into account the evaluations; 5. Development of Specific Action plans for each POPs, included in Annex A, B and C; 6. Steps to promote education and training with regard to, and awareness of those strategies; 7. A review every five years of those strategies and of their success in meeting the country,s obligations under Stockholm convention; 8. A schedule for implementation of the action plan, including for the strategies and measures identified therein. 3.1.3. NIP OUTCOMES NIP expected outcomes are: 1. Assessment of national capacity to implement the Stockholm Convention; 2. Preliminary inventories of POPs; 3. National Implementation Plan, including ranked and costed Action Plans and strategies required to meet Convention obligations; 4. Strengthened POPs management infrastructure and raised public awareness on POPs; and 5. Capacity to meet reporting obligations under the Stockholm Convention. 3.1.4. INSTITUTIONAL ARRANGEMENT, PARTICIPANTS AND STAKEHOLDERS The Ministry of Environment and Water is the Implementing Agency for the development of NIP in collaboration with a Steering committee comprising of representatives of the Ministries of Health; Agriculture and Forestry; Foreign Affairs; Economy; Transport and Communications; Labour and Social Policy; and Finance; the State Agencies for Civil Defence, and Environment; the National Centre for Hygiene, Medical Ecology and Nutrition; National Plant Protection Service; National Veterinary and Medical Service; Bulgarian Academy of Sciences; Bulgarian Chamber of Commerce, Bulgarian Chamber of the Chemical Industry; University of Chemical Technology and Metallurgy – Sofia; Forestry University, Sofia; and the NGOs “Ecotech Consult”; “Protect the Women”; “For the Earth”.

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3.2. IMPLEMENTATION STRATEGY To meet its obligation under Stockholm convention each Party: (a) Develops and endeavours to implement a plan for the implementation of its obligations under this Convention; (b) Transmits its implementation plan to the Conference of the Parties within two years of the date on which this Convention enters into force for it; and (c) Reviews and updates, as appropriate, its implementation plan on a periodic basis and in a manner to be specified by a decision of the Conference of the Parties.

3.2.1. GUIDING PRINCIPLES OF THE IMPLEMENTATION STRATEGY The implementation strategy of NIP for POPs is based on the following principles: Adherence of Stockholm convention provisions; Adherence to EU directives provisions; Adherence to “the polluter-pays” principle; Adherence to and enforcement of international standards; Integration within overall environmental management and sustainable development policies; Transparency in information sharing and exchange on POPs issues; Provision to the public of available information on POPs and training of professionals on the implementation of measures and activities, included in the NIP for POPs; Public and stakeholder participation and transparency of the decision making process regarding POPs issues;

3.2.2. SWOT – ANALYSIS ON THE POSSIBILITIES TO MEET THE PROVISIONS OF STOCKHOLM CONVENTION IN R BULGARIA SWOT-Analysis (Strengths, Wealnesses, Opportunities and Threats analysis) is of key importance for the strategic planning process. It helps to proritise the results of the environmental scan analysis and to structure them in such a way as to allow for the setting of the strategic goals and specific objectives of the Republic of Bulgaria to be pursued in the coming years. The SWOT analysis has been implemented based on the results obtained to date.The analysis showed that R Bulgaria has good institutional, professional and scientific capacity to meet its obligations under Stockholm convention.

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SWOT- Analysis on the possibilities to meet the provisions of Stockholm convention in R Bulgaria STRENGTHS WEAKNESSES • No POPs production and import; • Shortage of national funding for investment in the field of management • Ban for production, import and use of POPs pesticides; of POPs; • Good Laboratory infrastructure for analysis of POPs • Lack of financial resources for research, monitoring, laboratory pesticides and PCBs in air, water, soils and food; infrastructure and detailed POPs inventory; • Competent administrative, technical and research staff; • Lack of sufficient administrative capacity on municipal level for the • Well developed system for monitoring of POPs enforcement of legislation in respect to POPs, listed in Stockholm pesticides in the environment; convention; • Low level of air, water and soil POPs pollution of the • Lack of trained specialists and managerial personnel for POPs territory of the country; management in the industrial, energy and agriculture sectors; • Developed National Implementation Plan for • Lack of Labs and trained personnel for control and analysis of Dioxins management of POPs; and Furans; • Adopted legislation, harmonized with environment • Insufficient laboratory infrastructure and trained personnel for control acquis communitare in respect to provisions of and analysis of PCBs in air, water, soil, food, oils and waste Stockholm convention; • Incomplete date on the composition of obsolete and out-of-use • Sufficiently developed institutional system on national pesticides in storages; level for enforcement of environmental legal • Insufficient information about the number and distribution of electrical framework for management of POPs; equipment, containing PCBs ; • Lack of data for the impacts of PCBs and Dioxins/Furans on human health; • Lack of integrated monitoring on POPs levels (PCBs and D/Fs) in humans and the environment; • Incomplete data on food contamination with POPs; • In some “hot spots” urban places there are still unsolved problems with regard to POPs po;;ution of ambient air; • Unsolved problems with regard to wastes, containing and/or contaminated with POPs; • Uncontrolled burning of wastes in households and stuble-fields; • Low awareness of the general public about the hazards of POPs; • Lack of information brochures/leaflets and insufficient dissemination of education and publicly accessible awareness materials concerning the impact of POPs on human health and on the environment. • Lack of of decontamination and disposal oils facilities; • Lack of POPs pesticides disposal facility.

OPPORTUNITIES THREATS • Use of EU, GEF and World bank financial toolls for • Risk of exposure to PCBs and D/Fs for humans and the environment; dolving problems related to management of POPs; • Air Pollution resulted from forests fires, uncontrolled burning of • Conformity of national priorities in the management of wastes in householdsand and stuble-fields; POPs with priorities of international bodies – UN, FAO, • Potential for air pollution with Dioxin/Furans from large stationary EU, WHO, etc. point sources in energy sector; • Political will of the Government to make efforts to solve • Potential for air pollution from the intensive transport traffic and the the POPs issue; extremely adverse age structure of the motor vehicles; • Intellectual capacity; • Lack of financial resources from dtate budget for inventory and POPs • Institutional framework for information and public elimination activities; participation in decision taking with regard to • Limited financial and human resources for POPs management on environmentq including POPs issues; regional and municipal level; • Active NGOs;

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3.2.3. STRATEGIC GOAL AND NATIONAL OBJECTIVES OF NIP FOR POPS (OBJECTIVES TREE) Mindful of the precautionary approach as set forth in Principle 15 of the Rio Declaration on Environment and Development, the main strategic objective of Stockholm Convention is to protect human health and the environment from persistent organic pollutants. Based on the SWOT analysis, the major objectives for the future development of the country in the field of management of persistent organic pollutants (POPs). In setting up the strategic goal and specific objectives, the strengths to be preserved; the weaknesses to be solved and the threats, posed by POPs had been taken into consideration. In order to solve this issue the approach was chosen to allow to the maximum extent possible the use of the strengths and the opportunities im the country. Formulated goal and specific objectives express strategic choice and the main priorities of R Bulgaria for the next several years. Strategic goal and specific objectives are presented as a major long-term strategy and specific national objectives in medium-term and short-term, the country is facing out (Objectives tree). The longterm strategic goal of National Implementation Plan for management of POPs in RBulgaria is: Protection of human health and the environment from harmful impact of Persistent Organic Pollutants based on the environmental policy for sustainable development. The identification of national strategic objectives for the future management of POPs in the Republic of Bulgaria has been implemented on the grounds of SWOT analysis of existing problems and difficulties, the national peculiarities as well as taking into account the provisions for comformity with EU asquis and Stockholm convention. The National implementation plan for management of POPs formulates the following 8 major national objectives addressed to: 1. Development and Strengthening of Insititional and Administrative Capacity Building on national, regional and municipal level; 2. Elimination of intentional production and use of POPs; 3. Minimization or prevention releases from unintentional production of POPs (Dioxin/Furans, HCB and PCBs) or source elimination; 4. Reduce or eliminate obsolete pesticides stockpiles, containing and/or contaminated with POPs; 5. Develop and endeavour to apply Action plans for implementation of measures, envisaged in the NIP; 6. Encourage and promote research, development and monitoring pertaining to POPs including on their: • presence and levels in humans and the environment; • effects on human health and the environment. 7. Public awareness raising with regard to POPs; 8. Attract investments and encourage activities with regard to POPs management. 3.2.4. CRITERIA FOR PRIORITY SETTING The following steps have been identified in the process of priority setting: Defining the methodology; Selecting the ranking criteria; Creating the priority list and verifying it; Transferring priority areas to the NIP objectives.

The following Criteria for National priority settings was adopted:

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1. Efficacy and efficiency of possible measures for control and risk reduction for human health and the environment; 2. Technical feasibility, availability and accessibility of alternative products and technologies; 3. Economic aspects, including financial capabilities and costs of implementing possible control measures; 4. Waste and disposal implications (in particular stockpiles of obsolete pesticides and clean-up of contaminated sites); 5. Status of control and monitoring capacity; 6. Access to information and public education] 7. Time - Frame Schedule for implementation; 8. Integration in the existing legislation 3.2.5. IDENTIFIED PRIORITIES OF NATIONAL SIGNIFICANCE The use of above criteria enabled an in-depth analysis, taking into account all significant factors with regard to the provisions of Stockholm convention, the situation in Bulgaria as well as ongoing activities related to POPs management. The significance of priorities and objectives has been ranked under the following coefficients: High Priority Area (H); Moderate Priority Area(M); Low Priority Area(L).

All above provided a ranking list of major priorities of national significance for POPs management on the basis of total scores obtained for problems assessed in a view of different criteria. During the NIP development process, the following 10 priorities of national significance among POPs categories were defined, based on ranking of POPs issues importance: 1. Development and enforcement of plan for environmentally sound management stockpiles and wastes in order to reduce/eliminate obsolete pesticides, containing/contaminated with POPs; 2. Development of plan for identifying and remediation of contaminated sites. 3. Development of strategy for identification, marking and step-by-step phase-out of use of PCBs operating equipment; 4. Development of an action plan for safe storage and environmentally sound disposal of equipment and oils, containing PCBs; 5. Development an action plan for reduction/elimination of releases from unintentional production (D/Fs, HCB and PCBs); 6. Evaluation of negative POPs impacts on human health and monitoring of POPs levels in humans and the environment; 7. Encourage and support research on POPs effect on humans and the environment; 8. Promote and facilitate public awareness raising with regard to POPs; 9. Endeavour to secure financial resources for implementation NIP measures by attracting investments from international finance institutions and donors. 10. NIP integration in the existing National Environmental and Sectoral policies; 3.3. ACTIVITIES, STRATEGIES AND ACTION PLANS The specific action plans deal with the requirements for Parties of the Stockholm Convention in the following four major areas: 9 intentional production and use of POPs (Articles 3 and 4, Annexes A and B). 9 unintentional production of POPs (Article 5 and Annex c, Parts I, II and III) 9 stockpiles and wastes (Article 6) 9 measures related to information exchange (Article 9), public information, awareness and education (Article 10), research, development and monitoring (Article 11) and reporting (Article 15). Bulgaria has undertaken a lot of activities related to the arrangements under the Convention, such as introduction of the general public with the problems caused by POPs; institutional capacity building; development of a National Implementation Plan for POPs Management.

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The implementation of the Bulgarian environmental legislation that is harmonized with the EU one, the National Implementation Plan for POPs Management and the enforcement of other mechanisms (such as strategies, plans, projects, etc.) shall impose the convention requirements in practice. The Convention obliges its Parties to pursue policy and undertake measures to eliminate the production and usages and to prohibit import and export of the POPs or to reduce or eliminate their unintentional production and distribution. Given the fact the inventory of POPs pesticides in Bulgaria has not registered any production, use, import or export of chemicals, listed in Annexes A and B, excluding PCBs use in close systems, it can be concluded that the list of country obligation arising from Articles 3 of the Convention have already been fulfilled. The part common to all POPs and which refers to unintentional production of POPs, to identification of contaminated sites, stockpiles and wastes and use of PCBs in equipment is stated in the strategies and specific action plans. Table 118 gives the list of commitments arising from the Convention with regard to POPs and current status of implementation in R Bulgaria. Table 118 Current status of Bulgarian obligations’ implementation under the provisions of Stockholm Convention Commitment Annexes Current status Article 3.1 a) i Annex A, Part I There is no production or use of POPs pesticides and no PCBs production Annex A, Part I PCBs use in close systems permited Annex A, Part II PCBs equipment use such as transformers and capacitors (a) i 10% PCBs >5 liters permitted for use till 2010 (a) ii 0,05% PCBs >5 liters permitted for use till 2010 (a) iii 0,005% PCBs > 0,05 liters allowed for use till 2025 (c) Export and import is prohibited (d) Not allowed recovery for re-use in other equipment (e) Shall endeavour and undertake measures for environmentally sound waste disposal of equipment and liquids, containing >0,05% PCBs till 2010 equipment and liquids, containing upto 0,005% PCBs not later than 2028 a) ii Annex A, Part I There is no export or import of POPs b) Annex B Production and use of DDT is prohibited Article 3.2 a) i Annex A & B Import for disposal is prohibited a) ii Annex A & B Import for POPs use is prohibited b) i Annex A & B No exceptions for POPs disposal b) ii Annex A & B No exceptions for POPs use 3.5 There are provisions about the use of chemicals for laboratory purposes Article 5 (a) Annex C An action plan is developed (b) Annex C Regulatory measures for IPPC are undertaken (d) Annex C BAT application is legally regulated for existing and new installations Article 6 Annex A and B A strategy for identification of stockpiles of POPs pesticides is not 1.a) i developed. 1 a) ii Annex A,B or C There is no POPs pesticide in use. Annex A or B Preliminary Inventories has been completed. Need for detailed physical b) inventories. Annex A and B Stockpiles of POPs pesticides have not been physically identified due to torn c) packages and lack of labels. Need for additional site analysis. Annex A or B Handling, collection, transportation and storage of hazardous wastes is d) i legally regulated. d) ii Annex A or B No facility for environmentdlly sound POPs disposal. d) iii Annex A or B Not permitted for re-use after disposal. Annex A or B Provisions has been taken to comply with the Basel Convention and d) iv regulations on transport of hazardous substances Annex A,B or C No strategy for identifying of contaminated sites. Remediation of e) demolished obsolete pesticides storage sites has been carried out.

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Commitment Annexes Current status Article 9 As signatory of SC, Bulgaria has undertaken obligations to participate in the international information exchange regarding POPs; Article 10 1 (a), (b) Annex A,B or C Web-site on hazardous chemicals, including info on POPs is is prepared 1(d) Annex A,B or C Active participation of NGO, addressing POPs 1(f) Annex A,B or C POPs brochures and leaflets has been developed. 2. Annex A,B or C National Profile for management of chemicals, including POPs is put on MoEW Web-site for access to the public. 4. Annex A,B or C POPs safety data sheets has been developed. Information centres on national and regional level has been established. All information addressing POPs is available at Info centres. Article 15 1. As signatory of SC, Bulgaria has undertaken commitmets on Reporting on the implementation of the Convention. 2. Annually maintained POPs pedticides data base . PCBs and POPs release category sources date bases shall be developed.

To achieve the main national objectives, three specific Action plans for each POPs were developed: 1. Action plan for POPs - Pesticides 2. Action plan for PCBs in Equipment 3. Action plan for POPs releases from unintentional production (D/Fs, PCBs and HCB). Within the process of formulation and development of specific Action plans for each POPs category the strengths and opportunities of Bulgaria to meet its obligations under Stockholm convention have been considered. The measures and activities to be taken recognize the current status of POPs issue in Bulgaria 9 No POPs production and import; 9 Ban for production, import and use of POPs pesticides; 9 Relatively good Laboratory infrastructure for analysis of POPs pesticides and PCBs in air, water, soils and food; 9 Competent administrative, technical and research staff; 9 Well developed system for monitoring of POPs pesticides in the environment; 9 Low level of air, water and soil POPs pollution of the territory of the country; 9 Developed National Implementation Plan for management of POPs; 9 Adopted legislation, harmonized with environment acquis communitare in respect to provisions of Stockholm convention; 9 Sufficiently developed institutional system on national level for enforcement of environmental legal framework for management of POPs; 3.3.1. POPS SPECIFIC ACTION PLANS The proposed Action plans cover the period 2006-2028 and include the major measures and activities envisaged for the implementation of the NIP for POPs. The structure of the Action plans is in compliance with the objectives and priorities specified in items 3.2.3 and 3.2.5. By the adoption and the implementation of the present plans, it is aimed that optimal balance between the different legislative, institutional, economic and technical measures and implementation of integrated approach for POPs management to be achieved. The plans determine also the responsibilities of the various institutions and organizations related to the implementation of the proposed activities in NIP, the expected costs and the probable sources of funding.

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3.3.1. 1. ACTION PLAN FOR POPS PESTICIDES Aldrin, Chlordane, Dieldrin, Endrin, Heptachlor, Hexachlorobenxene, Mirex, Toxaphene and DDT (Annex А, part I and Annex B ) ACTION PLAN OBJECTIVE IS: To protect the human health and the environment from harmful impact of POPs Pesticides by taking necessary measures to minimize or prevent releases from stockpiles, consisting of or containing chemicals listed either in Annex A or Annex B and manage such stockpiles in a safe, efficient and environmentally sound manner. The specific objectives of a POPs pesticides Action plan are: To review and summarize the production, use, import and export of the POPs chemicals listed in Annex A and Annex B of the Convention; To gather information on stockpiles and wastes containing, or thought to contain POPs pesticides; To assess the national legal and institutional framework for control of the production, use, import, export, safe storage and disposal of the POPs chemicals listed in Annex A and Annex B (excluding PCBs) of the Convention. To identify gaps in information required to complete the assessment.

Anticipated costs Responsible Deadlines (thous.BGN) Sources of № MEASURES ACTIONS Bodies Start-End Exchange rate Financing 1 US $= 1,5 BGN ACTIVITY 1: INSTITUTIONAL AND REGULATORY STRENGTHENING MEASURES 1.1. Evaluation of effectiveness of existing legislation with regard to POPs pesticides 1.1.1 Enforcement of existing legislation, regulating POPs pesticides MoEW, MoAF, permanent - State budget (SB) management . MoH, A”Customs”,

NSPP 1.1.2 Exercising control over observation of existing regulatory bans for MoEW, MoAF, permanent - State budget (SB) import & export of POPs pesticides. A”Customs”, NSPP 1.2. Amendment of Bulgarian legislation in case of including new POPs chemicals in Stockholm Convention 1.2.1 Duly amending and supplementing of legislative acts and regulations MoEW, MoAF permanent - State budget (SB) in case of including new POPs chemicals in Annex A of Stockholm convention.

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Anticipated costs Responsible Deadlines (thous.BGN) Sources of № MEASURES ACTIONS Bodies Start-End Exchange rate Financing 1 US $= 1,5 BGN 1.3. Reference measurement methods for POPs analysis 1.3.1 Reference measurement methods for POPs analysis in waste. MoEW 2006-2007 30 GEF, International International overview on measurement methods for POPs in waste. funding Evaluation of existing measurement methods and proposals in view of European reference methods. 1.3.2 National legal framework review. Assessment of Existing limit values MoEW 2006 20 GEF for POPs pesticides 1.3.3 Application and enforcement of EU Reference measurement MoEW, permanent - MoEW, MoH, methods/Standards for POPs pesticides analysis in the environment, MoH,NCPHP, NCPHP,MoAF levels of accumulation in human body, in food of vegetable and animal MoAF origin 1.4. Administrative capacity strengthening of authorities, responsible for POPs pesticides management 1.4.1 Strengthening of municipal administrative capacity for control and Municipalities permanent - Municipal Budgets save storage of obsolete pesticides’ stockpiles, including appointment (MB) of additional personnel. 1.4.2 Strengthening the laboratory infrastructure for analysis of POPs Interested 2006-2009 Private and state International pesticides in the environmental media, in foods of vegetable and animal institutions and funding findings, SB, origin and the levels in human tissues; including delivery of necessary authorities Interested equipment, personnel training and lab accreditation. institutions and authorities

ACTIVITY № 2: MEASURES TO ENSURE SUFFICIENT AND RELIABLE DATA ON OBSOLETE PESTICIDES, INCLUDING THOSE CONSISTING OF OR CONTAMINATED WITH POPs 2.1. Maintaining of actual and reliable data base for obsolete pesticides 2.1.1 Annual updating of the data base for obsolete pesticides stockpiles MoEW, EEA, annually - MoEW, EEA 2.1.2 Development of a plan for environmentally sound management of MoEW 2006-2009 50 GEF, UNEP, obsolete pesticide stockpiles aiming to reduce/eliminate the obsolete MoEW in-kind co- pesticides consisting of or containing/contaminated with POPs financing

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Anticipated costs Responsible Deadlines (thous.BGN) Sources of № MEASURES ACTIONS Bodies Start-End Exchange rate Financing 1 US $= 1,5 BGN 2.1.3 Development of a Programme for identifying obsolete pesticides MoEW 2006-2007 25 GEF, MoEW in- stockpiles, consisting of or containing/contaminated with POPs kind co-financing 2.1.4 Detailed inventory of 2308 t of “unknown” obsolete pesticides not yet MoEW, EEA, 2006-2009 500 GEF, MoEW, secured, stored in 477 unrepaired in-use warehouses. Detailed field MoAF, NPPS MoAF in-kind co- survey of known sites. Identifying the assumed available between 22.3 financing t ÷ 25.8 t POPs pesticides and approx. 30 t mixtures, consisting of or contaminated with POPs, if international funding is provided. 2.1.5 Development of a plan for identifying and sanitation of contaminated MoEW, 2006-2009 50 GEF, International with POPs pesticides sites and the surroundings areas around the minicipalities Co-financing and obsolete pesticides storehouses. in-kind MoEW financing 2.2. Updating NIP for POPs 2.2.1 Updating NIP for POPs pesticides MoEW 2010 every 5 30 MoEW years ACTIVITY № 3: MEASURES TO REDUCE OR ELIMINATE OBSOLETE PESTICIDES STOCKPILES, INCLUDING THOSE CONSISTING OF OR CONTAMINATED WITH POPs 3.1. Environmentally sound storage and

reduction of Obsolete pesticides stockpiles 3.1.1 Development of Obsolete Pesticides Storage and Stock control Manual MoEW 2006-2007 40 GEF, n-kind and Guidelines for the environmentally sound Management of obsolete MoEW financing and unwanted pesticides” 3.1.2 Handling, collecting, repacking, transporting and storing in an MoEW, MoAF permanent 1 500 MoEW, MoAF, environmentally sound manner of obsolete pesticides in newly Municipalities annually projects financed

constructed or repaired centralized and municipal storages facilities or by EMEPA, Fund capsulation in BB-cubes “Agriculture” 3.1.3 Providing municipal safeguarding of centralized storage houses for Municipalities 2007-2015 - Municipal budgets

obsolete pesticides (MB) 3.1.4 Old storehouses demolishing and sanitation of storage sites, disengaged Municipalities 2008-2015 300÷500 Municipal budgets from old storehouses and remediation of areas and soils around them. annually (MB),projects financed by EMEPA, Fund “Agriculture”

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Anticipated costs Responsible Deadlines (thous.BGN) Sources of № MEASURES ACTIONS Bodies Start-End Exchange rate Financing 1 US $= 1,5 BGN 3.2. Safe and environmentally sound disposal of

obsolete pesticides stockpiles 3.2.1 Review of the existing methods and technologies for POPs pesticides MoEW 2006 10 GEF

reduction and/or elimination 3.2.2 Analyzing & Preliminary Assessment of the technologically & MoEW 2006 10 GEF economically feasible options for elimination/disposal of obsolete pesticides 3.2.3 Study of National capacity for environmentally sound POPs disposal. MoEW 2006-2008 75 GEF, International Feasibility study and investments cost assessment. Co-financing and in-kind MoEW financing 3.2.4 Development of project proposals for Safe removal and municipalities permanent 40 MB

storage/disposal options 3.2.5 Long-term business plan for disposal of obsolete POPs pesticides MoEW, МoAF, 2007-2009 180 GEF, International currently in long-term storage, site remediation Municipalities Co-financing and in-kind MoEW financing 3.2.6 Removal and disposal abroad of 2308 t of “unknown” obsolete MoEW, MoAF, 2007-2010 13927 GEF, International municipalities Co-financing and pesticides, stored in 477 unrepaired in-use warehouses and contaminated soils, if international funding is provided. in-kind MoEW financing 3.2.7. Partial disposal of obsolete pesticides, identified as consisting of or MoEW 2007-2010 332 GEF, International contaminated with POPs abroad, if international funding is provided. Co-financing and in-kind MoEW financing 3.2.8 Gradual disposal/elimination of obsolete pesticides stockpiles . MoEW, МoAF, 2010-2028 - SB, international

Municipalities not yet defined funding ACTIVITY № 4: MEASURES FOR CONTROL, MONITORING AND REPORTING 4.1. Strengthening of the control over the implementation of legal requirements for storage of obsolete and out-of-date pesticides stockpiles

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Anticipated costs Responsible Deadlines (thous.BGN) Sources of № MEASURES ACTIONS Bodies Start-End Exchange rate Financing 1 US $= 1,5 BGN 4.1.1 Exercising permanent control over the implementation of legal MoEW, RIEW, permanent 20 MoEW, MoAF requirements for safe storage of obsolete and unusable pesticides MoAF, NSPP stockpiles and regular inspections of storage facilities status 4.2. Monitoring 4.2.1 Monitoring of soils with local spot POPs pollution (where DDT and MoEW, EEA 2006 -2007 20 MoEW, EEA metabolites values exceeded the maximum admissible concentration and intervention concentration level) by repeated soil sampling and analysis, especially in surrounding areas of obsolete pesticides storehouses and in spot points where residual quantities of DDT[sum] and metabolites were registered. 4.2.2 Monitoring of underground waters for POPs content in the regions MoEW, EEA once per 20 MoEW, EEA close to storages for obsolete and out-of-use pesticides year 4.3. Reporting 4.3.1 Annual reporting of existing obsolete and out-of-date pesticides MoAF,MoEW, MoAF,MoEW, permanent 10 stockpiles, stored in warehouses and BB-cubes EEA EEA 4.3.2 Maintaining of the Functional Subsystem “Control and soil protection MoEW, annually 10 MoEW, EEA from POPs pollution – obsolete pesticides storages”-Preparation of RIEWs, EEA annual enquiries for warehouse status and obsolete pesticides, stored in them. ACTIVITY № 5: MEASURES TO ENCOURAGE RESEARCH AND DEVELOPMENTS (Article 11) 5.1. Risk assessment for the humans from POPs

pesticides impact 5.1.1 Carrying out investigations on POPs level accumulation, population Interested 2006-2009 210 WHO, EU health institutions and funds health status assessment with priority to risky groups of population authorities 5.2. Promoting research activities and developments for POPs pesticides impact on the human health and the environment 5.2.1 Carrying out representative research investigations for POPs levels of MoH, NCPHP 2007-2009 200 WHO, MoH accumulation in risky groups of population, especially women and children in the regions close to storages for obsolete pesticides

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Anticipated costs Responsible Deadlines (thous.BGN) Sources of № MEASURES ACTIONS Bodies Start-End Exchange rate Financing 1 US $= 1,5 BGN 5.2.2 Carrying out representative research investigations for POPs levels in MoAF,MoEW 2007-2009 300 GEF, external co- soils and products of vegetable origin in the rural areas close to OP financing, storage facilities MoAF,MoEW in- kind funding

ACTIVITY № 6: MEASURES FOR PUBLIC INFORMATION, AWARENESS AND EDUCATION (Article 10) 6.1. Development of Educational and Awareness programs on POPs issues 6.1.1 Development and carrying out “round-tables” discussions for public MoEW 2006 30 UNEP Chemicals awareness raising on POPs effects oh human health and the Small grant environment with gender focus on young people and target groups of component, local communities and other counterparts MoEW 6.1.2 Development and implementation of educational and awareness MoH, NCPHP 2006-2008 50 GEF, WHO, MoH programs on POPs as well as on their health effects, especially for in- kind financing women, children and the least educated” 6.2. Raising pupils and students knowledge on

POPs issues 6.2.1 Development of educational programs on POPs MoES, UCTM 2007-2009 50 MoES 6.2.2 Preparing and editing suitable school text books for POPs MoES 2008-2009 30 MoES 6.3 Training of trainers over the implementation of measures envisaged in the NIP for POPs 6.3.1 Development of training materials for the “Training of trainers” MoEW 2006 5 GEF Workshop – specialists and experts from the competent state authorities 6.3.2 Carrying out Seminars and Training Workshops for qualification MoEW 2006 20 GEF raising of experts of relevant state authorities over the NIP implementation.

6.3.3 Carrying out Seminars for industry professionals and NGOs over the MoEW 2006 5 GEF NIP implementation.

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Anticipated costs Responsible Deadlines (thous.BGN) Sources of № MEASURES ACTIONS Bodies Start-End Exchange rate Financing 1 US $= 1,5 BGN 6.3.4 Organizing and carrying out Regional Multinational Workshop with UNEP Chemicals, 2006 - UNEP Chemicals participation of Bulgaria and 23 countries from Central & Eastern MoEW Europe, Asia and Pacific Ocean for experience and skill exchange , lessons learnt and training on POPs NIP implementation.” 6.4 Provision of Public access and awareness

raising on POPs issues 6.4.1 Publication of NIP and Action plan for POPs pesticieds on the POPs MoEW 2006 2 GEF Web page of MoEW. 6.4.2 Updating of POPs Web page on MoEW Web site, including available MoEW permanent - MoEW information on POPs 6.4.3 Publication and dissemination of NIP for POPs МОСВ 2006 22 GEF 6.4.4 Provision access to the public of available information on POPs trough MoEW, EEA, permanent - MoEW Info-centers at MoEW, EEA and RIEWs. RIEWs 6.4.5 Providing opportunities for public input, opinions and statements and MoEW 2006-2007 - МОСВ raise questions & responses , addressing POPs management through the Forum “Green Graphite” on the MoEWs Web site. 6.4.6 Carrying out Information Campaigns by ecological NGOs for POPs NGOs 2006-2008 75 GEF UNDP, Small effects on human health and the environment at regional level through grant programme projects, financed by GEF Small Grants Project 6.4.7 Development and strengthening NGOs public relation in the process of MoEW, MoAF, 2006-2008 - MoEW, MoAF, development of projects, concerning POPs management and for their MoH, MoES, MoH, MoES, effects on human health and the environment. municipalities municipalities 6.5. Development and exchange of educational and public awareness materials at the national for POPs and their health and environmental effects 6.5.1 Development, publication and dissemination of POPs popular MoEW 2006 8 GEF brochures for their human health and environmental effects 6.5.2 Elaboration of a ecological NGOs Project proposal “Development, NGOs 2007-2008 20 IPEN, publication and dissemination of POPs popular brochures and leaflets GEF/UNDP, Small for awareness raising on POPs pesticides and their effects on human grants programme 226

Anticipated costs Responsible Deadlines (thous.BGN) Sources of № MEASURES ACTIONS Bodies Start-End Exchange rate Financing 1 US $= 1,5 BGN health and the environment among the for rural population” 6.5.3 “POPs: Be careful. Strengthening NGOs' capacity in realization of the NGO 2006-2007 12 IPEN, information campaigns and improve communications with local GEF/UNDP, Small community and other counterparts. “ grants programme 6.5.4 NGOs participation in the society awareness raising on POPs Campaign NGO 2006-2007 50 IPEN, GEF/UNDP for raising public awareness by a number of seminars and round tables Small grants and wide information dissemination through mass media and by means Programme of leaflets and booklets 6.5.5 Sharing information about POPs Public awareness campaign on POPs MoEW 2006-2007 - MoEW “Planet without POPs 6.5.6 POPs information dissemination & networking of scientific MoEW, 2006-2007 - MoEW, publications, developed projects, seminars and scientific forums on MoAF,MoH, MoAF,MoH, POPs Web-page of MoEW. MoEE MoEE 6.6. Reporting (Article 15 ) 6.6.1 Report development for the progress on the NIP implementation in MoEW 2010 10 MoeW regard with POPs pesticides

For the implementation of urgent measures and activities, envisaged in NIP under the preliminary financial needs assessment approx. 16 983 000 BGN (about 10 614 000 US $) are required. Due to the limited financial capabilities of the country to provide funding from state budget other sources shall be surched – GEF, international donor programmes and intergovernmental agreements.

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3.3.1.2. ACTION PLAN FOR PCBS IN EQUIPMENT (TRANSFORMERS AND CAPACITORS) (Annex А , Part І and II) ACTION PLAN OBJECTIVE IS: To reduce Exposures and Risk for human health and the environment from the harmful impact of PCBs by taking measures for better management of PCBs in equipment and oils and promotion of early actions for phasing-out of PCBs equipment and environmentally sound disposal of equipment (transformers and capacitors) and oils, containing PCBs. Objectives of a PCBs assessment is to assess current uses of PCBs within the country and to understand the likely quantities, equipment types, holders, operational practices, health and safety management and end-of-life treatment of PCB containing equipment and materials.

Estimated costs Responsible Deadlines (thous.BGN) Sources of № MEASURES ACTIONS Bodies Start-End Exchange rate Financing 1 US $= 1,5 BGN ACTIVITY 1: INSTITUTIONAL AND REGULATORY STRENGTHENING MEASURES FOR MANAGEMENT OF PCBS IN EQUIPMENT Harmonization of Bulgarian legislation for 1.1. management of PCBs in equipment and wastes, containing PCBs in compliance with the provisions of Directive 96/59/EEC for disposal of polychlorinated biphenyls and polychlorinated terphenyls and Stockholm convention 1.1.1 Development and adoption of Regulation on the requirements for MoEW 2006 10 MoEW the order and the manner of inventory, labeling and decontamination of equipment containing PCBs, as well as the treatment and transportation of waste containing PCBs.

1.2. Introducing of regulatory requirements for inventory, phasing out, safe storage and environmentally sound decontamination and disposal of equipment, containing PCBs and waste, containing PCBs. 1.2.1 Development of Plan for ESM of PCBs, equipment, containing MoEW, holders of 2007-2009 120 International PCBs and waste, containing PCBs : equipment, private & state funding, containing PCBs funding holders of 9 Carrying out a detail inventory of equipment, containing equipment, PCBs; containing 9 Measures and terms for phasing out of inventoried equipment, PCBs, MoEW containing PCBs;

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Estimated costs Responsible Deadlines (thous.BGN) Sources of № MEASURES ACTIONS Bodies Start-End Exchange rate Financing 1 US $= 1,5 BGN 9 Measures for safe storage of phased-out equipment, containing PCBs and wastes, containing PCBs – insulating, hydraulic and heat transmission oils; 9 Measures and terms for decontamination and environmentally sound disposal of equipment, containing PCBs and waste, containing PCBs; 9 Financial security of activities; 9 Monitoring and control over the in-use equipment, containing PCBs 9 reporting regimes incorporating incentives and penalties; 1.3. Effective enforcement of existing legislation related to PCBs 1.3.1 Application and enforcement of existing national legislation , MoEW, Customs permanent - State budget regulating PCBs management – observing over the bans for import Agency, importers, (SB) and export of PCBs and permitted uses of PCBs restricted to use in exporters, holders close systems. of PCBs equipment 1.4. Prepare methodological manuals, guidelines, supporting enforcement of existing legislation for equipment , containing PCBs and waste, containing PCBs 1.4.1 Development of technical Manual for carrying out detailed MoEW 2006 20 MoEW inventory of equipment, containing PCBs and Practical Guidelines for decontamination/clean-up and dismantling of equipment, collection and storage of waste, containing PCBs 1.4.2 Development of Practicle Guidelines for ESM of equipment , Holders of 2006-2008 80 Holders of containing PCBs by the owners and handlers of equipment, equipment, Private funding equipment, containing PCBs: containing PCBs, containing MoEW’s PCBs 9 for decontamination or environmentally sound disposal of methodological equipment, containing PCBs and waste, containing PCBs and support deadlines for implementation; 9 for safe storage of phased-out equipment, containing PCBs and wastes, containing PCBs including insulating, hydraulic

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Estimated costs Responsible Deadlines (thous.BGN) Sources of № MEASURES ACTIONS Bodies Start-End Exchange rate Financing 1 US $= 1,5 BGN and heat transmission oils, containing PCBs; 9 for safe operation and maintenance, monitoring and control over the in-use equipment, containing PCBs ; 9 reporting, risk assessment and management; 1.5. Reference measurement methods for POPs analysis 1.5.1 National legal frameworks review. Existing limit values analysis MoEW 2006 20 GEF for PCBs. 1.5.2 Application and enforcement of EU Reference measurement Interested permanent - Interested methods/standards for PCBs measurements in oils - EN ISO 3170; institutions and institutions and EN ISO 3171; EN ISO 60 475; EN 12 766-1; EN 12 766-2; EN 61 authorities authorities 619 1.6. Strengthening of institutional capacity for PCBs management on regional level 1.6.1 Strengthening of administrative capacity of RIEWs for control and MoEW, RIEWs permanent - MoEW inspection of operating PCBs equipment and for the conditions for storage of dismantled equipment and wastes, containing PCBs 1.6.2 Carrying out Seminars and Training Workshops for qualification MoEW 2006 12 GEF raising of industry representatives, personnel, engaged in MoEW in regard to: - Carrying out detailed PCBs equipment inventory; - ES storage, decontamination and disposal; Control of PCBs equipment holders and wastes, containing PCBs; 1.6.3 Feasibility study for country needs for the building up of MoEW, EEA 2006-2008 50 International laboratories for PCBs analysis in oils and strengthening of lab funding, EEA infrastructure for control and analysis of PCBs in air, water, soils, food and wastes. Cost benefits assessment of required funding and investments for construction, equipment and personnel training 1.6.4 Building up laboratory infrastructure for analysis of PCBs in oils, Interested 2007-2011 2 250 External including delivery of necessary equipment, training of personnel authorities, PCBs funding, SB and lab accreditation. equipment holders

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Estimated costs Responsible Deadlines (thous.BGN) Sources of № MEASURES ACTIONS Bodies Start-End Exchange rate Financing 1 US $= 1,5 BGN 1.6.5 Interested Private and state Interested Accreditation of sufficient laboratories for analysis of PCBs oils 2006-2009 authorities funding authorities ATIVITY № 2: MEASURES FOR THE PROVISION OF SUFFICIENT AND RELIABLE DATA ON THE OPERATING AND OUT-OF-USE PCBs EQUIPMENT AND WASTES 2.1. Maintenance of actual and reliable data base for equipment and oils, containing PCBs 2.1.1 Detailed inventory of equipment (in-use and phased out) and oils, MoEW, PCBs 2006-2008 500 PCBs containing PCBs equipment holders equipment holders, MoEW 2.1.2 Establishment of data base for in-use and phased out equipment MoEW 2006-2008 80 External with PCBs concentration above 0,05 % by weight and volume funding, above 5 dm3 and waste, containing PCBs and its regular updating. MoEW, GEF 2.1.3 Software for data-base for PCBs equipment – type, oil trade mark, MoEW 2006 - External year of production, manufacturer and holder. funding, MoEW 2.2. Updating of National Implementation plan for PCBs management 2.2.1 Updating of the National Implementation plan for POPs MoEW 2010 –every 5 70 SB management – PCBs in equipment and oils . years ACTIVITY № 3: MEASURES FOR MINIMIZATION AND DISPOSAL/DESTRUCTION OF PCBs IN EQUIPMENT AND OILS 3.1. Safe operation of equipment, containing PCBs – transformers and capacitors and gradual phasing out . 3.1.1 Prepare short-term plan for labeling of in-use equipment, containing PCBs equipment 2006-2007 private funding PCBs PCBs holders equipment holders 3.1.2 Prepare long-term plans for phase out of in-use PCBs equipment, PCBs equipment 2007-2010 80 External holders funding, PCBs dismantling, decontamination, safe storage, appropriate disposal private funding ahead of national legislation deadlines equipment holders 3.1.3 Develop detailed business plans for environmentally sound end-of- PCBs equipment 2006-2010 20 PCBs life management for highest risk equipment, containing PCBs and holders private funding equipment waste, containing PCBs holders

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Estimated costs Responsible Deadlines (thous.BGN) Sources of № MEASURES ACTIONS Bodies Start-End Exchange rate Financing 1 US $= 1,5 BGN 3.1.4 Labeling of in-use equipment, containing PCBs – transformers PCBs equipment 2006-2007 private funding PCBs and capacitors holders equipment holders

3.1.5 Prepare Plan for monitoring and control of in-use equipment, PCBs equipment 2006-2007 private funding PCBs holders equipment containing PCBs due to be decontaminated and disposed till 2010. holders

3.1.6 Decontamination of transformers with PCBs concentration above PCBs equipment 2007 private funding PCBs 3 holders equipment 0,05 % by weight and volume above 5 dm ; holders 3.1.7 Prepare Plan for monitoring and control of in-use equipment, PCBs equipment After end life- private funding PCBs containing PCBs to be phased out after end life-cycle term holders cycle term equipment holders

3.1.8 Phasing-out of equipment with PCBs concentration above 0,05 % PCBs equipment 2010 private funding PCBs 3 holders equipment by weight and volume above 5 dm ; holders 3.1.9 Phasing-out of Equipment with volume above 5 dm3 and PCBs PCBs equipment Gradually but private funding PCBs concentration between 0,005% and 0,05 % by weight holders not later than equipment 2025 holders 3.2. Safe storage of phased-out equipment, containing

PCBs and waste, containing PCBs 3.2.1 Provision of the necessary storage sites for safe storage of phased PCBs equipment after removal private funding PCBs out equipment, containing PCBs. holders from use equipment holders

3.2.2 Provision of the necessary storehouses for safe storage of wastes PCBs equipment permanent private funding PCBs containing PCBs holders equipment holders 3.3. Disposal of the equipment and wastes, containing PCBs 3.3.1 Review and Evaluation of the existing PCBs destruction MoEW 2005-2006 10 GEF technologies for equipment and oils and elaboration of criteria for choice of PCBs destruction technologies 3.3.2 Analysis and preliminary evaluation of technical and economical MoEW 2005-2006 10 GEF opportunities and options for destruction of waste, containing PCBs

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Estimated costs Responsible Deadlines (thous.BGN) Sources of № MEASURES ACTIONS Bodies Start-End Exchange rate Financing 1 US $= 1,5 BGN 3.3.3 National capacity for phased out equipment and waste oils, MoEW 2006-2007 75 External containing PCBs. Feasibility study, required investments evaluation funding and criteria setting for destruction PCBs technology selection 3.3.4 Export for disposal of 20,12 t waste PCBs transformer oils abroad MoEW 2007-2009 67 GEF, External

funding 3.3.5 Export for disposal of 844 phased out PCBs capacitors abroad MoEW 2007-2009 6350 GEF, External

funding 3.3.6 Construction of National Hazardous waste treatment centre and МoEW 2008-2014 87000 External corresponding infrastructure for hazardous wates landfilling resources, ISPA, SB 3.3.7 Disposal and recycling of highest risk equipment with PCBs PCBs equipment after removal not defined yet PCBs concentration above 0,05 % by weight and volume above 5 dm3 holders from use, but Private funding equipment not later than holders 2010 3.3.8 Disposal and recycling of PCB equipment with volume above 5 dm3 PCBs equipment after removal not defined yet PCBs and PCBs concentration between 0,005% and 0,05 % by weight holders from use, but Private funding equipment not later than holders

2028 ACTIVITY№ 4: MEASURES FOR CONTROL & MONITORING 4.1. Control over equipment and wastes, containing PCBs 4.1.1 Permanent control over the remaining in-use equipment, MoEW, RIEWs permanent - MoEW containing PCBs and over the conditions for storage of waste,

containing PCBs, including dismantled equipment and wastes, containing PCBs 4.2. Monitoring over equipment and wastes,

containing PCBs 4.2.1 Development of a Manual for the procedures and requirements for MoEW 2006-2007 30 GEF, MoEW monitoring, and inspections of equipment, containing PCBs remaining in use.

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Estimated costs Responsible Deadlines (thous.BGN) Sources of № MEASURES ACTIONS Bodies Start-End Exchange rate Financing 1 US $= 1,5 BGN ACTIVITY № 5: MEASURES TO PROMOTE RESEARCH WORK AND DEVELOPMENTS 5.1. PCBs impact risk assessment for the human health 5.1.2 Carrying out investigations on identifying PCBs level accumulation, MoH, NCPHP 2006-2009 210 State budget, population health status assessment with priority to risky groups in WHO, EU the regions with high concentration of PCBs equipment. health funds 5.2. Promote Research And Developments for PCBs

effects on human health 5.2.1 МoH, NCPHP 2006-2009 210 External Carrying out representative investigations of PCBs accumulation financing, levels in breast milk and fat tissue in women – suckling mothers in WHO, EU the regions with high concentration of PCBs equipment Health funds MoH

5.2.2 Undertake research works geared on alleviating the effects of PCBs МoH, NCPHP 2007-2009 200 WHO, EU Health funds on reproductive health. MoH ACTIVITY № 6: MEASURES FOR PUBLIC INFORMATION, AWARENESS AND EDUCTAION ON PCBS ISSUES 6.1. Development of Educational and Awareness programmes on POPs issues 6.1.1 Development and carrying out “round-tables” discussions for public MoEW 2006 30 UNEP awareness raising on POPs effects oh human health and the Chemicals environment with gender focus on young people and target groups Small grant of local communities and other counterparts component, MoEW 6.1.2 Development of educational programs on PCBs, as well as on their 2006-2008 25 WHO, EU health effects , especially for women, children and the least МoH, NCPHP Health funds educated. MoH 6.1.3 Development of awareness programs on POPs, as well as on their NGO 2007-2009 25 GEF small environmental effects, especially for women, children and the least grants educated. programme, IPEN 6.2. Raising pupils and students knowledge on POPs issues 6.2.1 Development of educational programs on POPs МoES, CTMU МoES, External 2007-2009 50 funding

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Estimated costs Responsible Deadlines (thous.BGN) Sources of № MEASURES ACTIONS Bodies Start-End Exchange rate Financing 1 US $= 1,5 BGN 6.2.2 Preparing and editing suitable school text books for POPs МoES, МoES 2008-2009 30 External funding 6.3. Training of trainers over the implementation of measures envisaged in the NIP for POPs 6.3.1 Development of training materials for the “Training of trainers” MoEW 2006 5 GEF Workshop – specialists and experts from the competent state authorities 6.3.2 Seminars and “Training of trainers” Workshops for the experts of MoEW, 2006 20 GEF MoEW, RIEWs on NIP implementation with participation of foreign experts 6.3.3 Training Workshop for the representatives of industry and NGOs MoEW 2006 5 GEF for explanation of POPs management legislation and NIP implementation. 6.3.4 Organizing and carrying out Regional Multinational Workshop with UNEP Chemicals, 2006 - UNEP participation of Bulgaria and 23 countries from Central & Eastern MoEW Chemicals Europe, Asia and Pacific Ocean for experience and skill exchange , lessons learnt and training on POPs NIP implementation.” 6.4. Provision of Public access and awareness raising on PCBs issues 6.4.1 Publication of NIP and Action plan for PCBs in equipment and oils МoEW 2006 2 GEF on the POPs Web page of MoEW. 6.4.2 Updating of POPs Web page on MoEW Web site, including all МoEW permanent - МoEW available information on PCBs 6.4.3 Publication and dissemination of NIP for POPs МoEW 2006 22 GEF 6.4.4 Provision to the public available information on POPs trough EEA, MoEW, permanent - MoEW Information centers at MoEW, EEA and at RIEWs. RIEWs 6.4.5 Providing opportunities for public input, opinions and statements MoEW 2006-2007 - MoEW and raise questions & responses , addressing POPs/PCBs management through the Forum “Green Graphite” on the MoEWs Web site. 6.4.6 Carrying out Information Campaigns by ecological NGOs for POPs NGOs 2006-2008 75 GEF UNDP,

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Estimated costs Responsible Deadlines (thous.BGN) Sources of № MEASURES ACTIONS Bodies Start-End Exchange rate Financing 1 US $= 1,5 BGN effects on human health and the environment at regional level Small grant through projects, financed by GEF Small Grants Project programme 6.4.7 Development and strengthening NGOs public relation in the MoEW, MoH, 2006-2009 - MoEW, MoH, process of development of projects, concerning POPs management municipalities municipal and for their effects on human health and the environment. budget 6.5. Development and exchange of educational and public awareness materials at the national for POPs and their health and environmental effects 6.5.1 Development, publication and dissemination of POPs popular MoEW 2006 8 GEF brochures for their human health and environmental effects 6.5.2 МoH, NCPHP 2007-2008 60 WHO, Development, publication and dissemination of POPs popular MoLSP, MoEE IPEN,МoH, brochures and leaflets for PCBs issues and their effects on human MoLSP, health among operators of PCBs equipment MoEE, EU Health funds 6.5.3 POPs: Be careful. Strengthening NGOs' capacity in realization of NGO 2007-2009 12 GEF/UNDP the information campaigns and improve communications with local Small grants community, governmental departments and other counterparts. Programme 6.5.4 NGOs participation in the society awareness raising on POPs . NGO 2007-2009 50 GEF/UNDP Campaign for raising public awareness by a number of seminars and Small grants round tables and wide information dissemination through mass Programme media and by means of leaflets and booklets. 6.5.5 Sharing information about POPs Public awareness campaign on MoEW 2006-2007 - MoEW POPs “Planet without POPs” 6.5.6 PCBs information dissemination & networking of scientific MoEW, MoAF, 2006-2007 - MoEW, publications, developed projects, seminars and scientific forums on MoH, MoEE MoAF, MoH, POPs Web-page of MoEW. MoEE 6.6. Reporting (Article 15 ) 6.6.1. Report development for the progress on the NIP implementation, in MoeW 2006 every 10 MoEW regard with PCBs in equipment and oils. 5 years For the implementation of urgent measures and activities, envisaged in NIP in regard to PCBs in equipment under the preliminary financial needs assessment approx. 8 698 000 BGN (about 5 346 000 US $) are required. Due to the limited financial capabilities of the country to provide funding from state budget other sources shall be surched – private funding from PCBs equipment holders, GEF, international donor programmes and intergovernmental agreements.

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3.3.1.3. ACTION PLAN FOR POPS RELEASES FROM UNINTENTIONAL PRODUCTION POLYCHLORINATED DIBENZODIOXINS (PCDD) AND POLYCHLORINATED DIBENZOFURANS (PCDF), HEXACHLOROBENZENE (HCB) AND POLYCHLORINATED BIPHENYLS (PCB) (Dioxins/Furans, PCBs and HCB) (Annex C) ACTION PLAN OBJECTIVE IS: To limit the risk for human health and the environment through continuing minimization of total releases derived from anthropogenic sources of Dioxin/Furans, PCBs and HHB listed in Annex C. The specific objectives of the Action plan for unintentionally produced POPs releases are: to carry out a preliminary evaluation of current and projected releases of the chemicals listed in Annex C of the Convention; to detail existing laws and policies relating to the management of releases of these chemicals and to evaluate their effectiveness and deficiencies.

Estimated costs Responsible Deadlines (thous.BGN) Sources of № MEASURES ACTIONS Bodies Start-End Exchange rate Financing 1 US $= 1,5 BGN ACTIVITY 1: INSTITUTIONAL AND REGULATORY STRENGTHENING MEASURES FOR THE MANAGEMENT OF POPS RELEASES FROM UNINTENTIONAL PRODUCTION 1.1. Evaluation of the efficacy of the legislation relating to the management of POPs releases from unintentional production 1.1.1 Application and enforcement of existing legislation, regulating the Norms МoEW, permanent - State budget, for admissible emissions of D/Fs, PCBs & HHB in Atmospheric Air from Companies- Companies- Static Sources . polluters polluters 1.1.2 Application and enforcement of existing legislation for Major Accident МoEW permanent - МoEW Prevention and Control, involving dangerous substances (Seveso Directive) and for Integrated Pollution Prevention and Control (IPPC Directive), relating POPs releases from unintentional production. 1.2 Improvement of the legislation relating to Integrated Pollution Prevention and Control of POPs releases from unintentional production . 1.2.1 Development of Guidelines on Best Available Techniques (BAT) for МoEW, EEA 2007-2009 30 GEF, UNEP, in- restriction and reduction of D/Fs, based on projected Guidelines to be kind MoEW developed by Secretariat of Stockholm Convention financing

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Estimated costs Responsible Deadlines (thous.BGN) Sources of № MEASURES ACTIONS Bodies Start-End Exchange rate Financing 1 US $= 1,5 BGN 1.2.2 Development of Provisional Guidance on Best Environmental Practices МoEW, EEA 2007-2009 30 GEF, UNEP, in- (BEP) for restriction and reduction of D/Fs, based on projected Guidelines kind MoEW to be developed by Secretariat of Stockholm Convention financing 1.3. Comparative analysis of available release modelling methodologies 1.3.1 Desk study comparison of CORINAIR, UNEP toolkit and other methods МoEW, EEA 2007 10 GEF, UNEP, for modelling inventory of unintentional production of POPs MoEW 1.3.2 Adapting of “Methodology for Determination of the Emissions of Dioxin МoEW, EEA 2007-2009 40 GEF, UNEP, in- and Furan Releases in the Air” based on CORINAIR kind MoEW financing 1.3.3 Analysis of existing concentration limits and . National legal framework MoEW 2005-2006 10 GEF review. Existing limit values at national level. 1.3.4 Detailed Dioxin/Furans, PCBs & HCB flows analyses by category sources. MoEW permanent - MoEW 1.3.5 Development and adoption of EU Reference measurement methods for Interested 2008-2011 100 Interested sampling and analysis of Dioxin/Furans in the environmental media and authorities authorities human tissues 1.4. Strengthening of administrative and institutional capacity for the management of POPs releases from unintentional production on local level 1.4.1 Strengthening of the laboratory capacity for the control and analysis of Interested 2006-2009 - External funding PCBs and HCB in waste gases, waste waters, soils, human tissues and and authorities food of vegetable and animal origin. ACTIVITY № 2: MEASURES TO ENSURE SUFFICIENT AND RELIABLE DATA ON POPs RELEASES FROM UNINTENTIONAL PRODUCTION 2.1. Maintain of actual and reliable data base for unintentionally emitted POPs 2.1.1 Annual updating of data base for Dioxins/Furans, PCBs & HCB in МoEW, EEA Every year 10 МoEW emissions . 2.2. Updating NIP for POPs 2.2.1 Updating NIP for POPs – Dioxin/Furans, PCBs & HHB releases МoEW 2010 – 70 МoEW every 5 years

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Estimated costs Responsible Deadlines (thous.BGN) Sources of № MEASURES ACTIONS Bodies Start-End Exchange rate Financing 1 US $= 1,5 BGN ACTIVITY № 3: MEASURES TO REDUCE OR ELIMINATE RELEASES FROM UNINTENTIONAL PRODUCTION 3.1. Promote the enforcement of measures to reduce POPs releases from unintentional production or remove the emissions sources. 3.1.1 Promote the application of available, feasible and practicle measures for a МoEW, 2006-2009 Private financing Companies realistic and meaningful level of POPs release reduction or source Companies polluters elimination by including in the requirement of the issued Imtegrated polluters

permits of BAT and BEP for the facilities from energy, metallurgy, chemical and cement industries and domestic solid waste burning plants, where it deems appropriate. ACTIVITY № 4: MEASURES FOR CONTROL 4.1. Strengthening of the control over the implementation of admissible emission norms for Dioxins/Furans, PCBs & HHB. 4.1.1 Observing of existing admissible emission norms for Dioxins/Furans, МoEW, permanent - МoEW, companies- PCBs and HCB by exercising permanent control over the implementation companies- polluters of the requirements of the issued Integrated permits. polluters 4.1.2 Exercising permanent control over the implementation of existing limit МoLSP, permanent - SB, companies- values of PCBs releases in the air of working media. companies- polluters polluters ACTIVITY № 5: MEASURES TO ENCOURAGE RESEARCH AND DEVELOPMENTS 5.1. Promoting the research activities for dioxin/furans and PCBs effects on human health 5.2.1 Carrying out representative investigations for PCBs levels of accumulation МoH, NCPHP 2007-2009 180 WHO, EU health in breast milk and fat tissue in risky groups of population – suckling funds, mothers especially in the regions of high concentration of industrial МoH sources with potential for comparatively high formation and release of POPs 5.2.2 Undertake research work geared towards alleviating the effects of Dioxins МoH, NCPHP 2007 –2010 210 WHO, EU health and Furans on reproductive health funds,MoH 5.2.3 Carrying out representative investigations for Dioxin/Furans & PCBs content in МoAF, NVMS 2007-2009 180 External funding, chicken eggs in the regions close to the large thermal power stations (TPS) FAO, МoAF

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Estimated costs Responsible Deadlines (thous.BGN) Sources of № MEASURES ACTIONS Bodies Start-End Exchange rate Financing 1 US $= 1,5 BGN 5.2.4 Carrying out investigations for Dioxin/Furans & PCBs concentrations in МoAF, NVMS 2007-2009 300 FAO, EU health food (hen eggs and eggs products, milk and diary products, animal funds, products,reach in fats, sea and river fish). МoAF ACTIVITY № 6: MEASURES FOR PUBLIC INFORMATION, AWARENESS AND EDUCATION (Article 10) 6.1. Development of Educational and Awareness programs on POPs issues 6.1.1 Development and carrying out “round-tables” discussions for public MoEW 2006 30 UNEP Chemicals awareness raising on POPs effects oh human health and the environment Small grant with gender focus on young people and target groups of local communities component and other counterparts 6.1.2 Development of educational programs on POPs – DIOX/Fs, PCBs and NGO 2007-2009 25 GEF, UNDP HCB, as well as on their health effects, especially for women, children and Small grants the least educated. programme 6.1.3 Development of awareness programs on POPs, as well as on their NGO 2007-2009 25 GEF, UNDP environmental effects, especially for the least educated. Small grants programme 6.2. Raising pupils and students knowledge on

POPs issues 6.2.1 Development of educational programs on POPs MoES, CTMU 2007-2009 50 MoES 6.2.2 Preparing and editing suitable school text books for POPs MoES 2007-2009 30 MoES 6.3. Training of the trainers over the implementation of measures envisaged in the NIP for POPs 6.3.1 Development of training materials for the “Training of trainers” MoEW 2006 5 GEF Workshop – specialists and experts from the competent state authorities 6.3.2 Seminars and “Training of trainers” Workshops for specialists and experts MoEW, 2006 20 GEF from the competent state authorities on NIP implementation. 6.3.3 Training Workshop for the representatives of industry and NGOs on NIP MoEW 2006 8 GEF implementation.

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Estimated costs Responsible Deadlines (thous.BGN) Sources of № MEASURES ACTIONS Bodies Start-End Exchange rate Financing 1 US $= 1,5 BGN 6.3.4 Organizing and carrying out Regional Multinational Workshop with UNEP 2006 - UNEP Chemicals participation of Bulgaria and 23 countries from Central & Eastern Europe, Chemicals, Asia and Pacific Ocean for experience and skill exchange , lessons learnt MoEW and training on POPs NIP implementation.” 6.4. Provision of Public access and awareness

raising on POPs issues 6.4.1 Publication of NIP and Action plan for POPs releases from unintentional MoEW 2006 2 GEF production on the POPs Web page of MoEW. 6.4.2 Updating of POPs Web page on MoEW Web site, including all available MoEW permanent - MoEW information on D/Fs, PCBs & HCB. 6.4.3 Publication and dissemination of NIP for POPs MoEW 2006 22 GEF 6.4.4 Provision to the public of available information on POPs trough EEA, MoEW, permanent - MoEW Information centers at MoEW, EEA and Information centre s at RIEWs. RIEWs 6.4.5 Providing opportunities for public input, opinions and statements and raise MoEW 2006-2007 - MoEW questions & responses , addressing POPs management through the Forum “Green Graphite” on the MoEWs Web site. 6.4.6 Carrying out Information Campaigns by ecological NGOs for POPs effects NGOs 2006-2008 75 GEF UNDP, on human health and the environment at regional level through projects, Small grant financed by GEF Small Grants Project programme 6.4.7 Development and strengthening NGOs public relation in the process of MoEW, MoH, 2006-2008 - MoEW, MoH, development of projects, concerning POPs management and for their municipalities municipal budget effects on human health and the environment. 6.5. Development and exchange of educational and public awareness materials at the national for POPs and their health and environmental effects 6.5.1 Development, publication and dissemination of POPs popular brochures MoEW 2006 8 GEF for their human health and environmental effects 6.5.2 Development, publication and dissemination of POPs popular brochures МoH, NCPHP, 2007-2008 60 WHO, ,МoH, and leaflets for dioxin/furans, PCBs and HCB issues and their effects on MoLSP, MoEE MoLSP, MoEE. human health among worker of energy and industry sectors.

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Estimated costs Responsible Deadlines (thous.BGN) Sources of № MEASURES ACTIONS Bodies Start-End Exchange rate Financing 1 US $= 1,5 BGN 6.5.3 Carrying out NGOs information campaign among least educated NGO 2007-2009 25 GEF/UNDP population for raising public awareness on human health threats from Small grants uncontrolled domestic waste & tire and stubble-fields burning as a source programme, of persistent organic pollutants (POPs) – Dioxin/Furans”. IPEN 6.5.4 POPs: Be careful. Strengthening NGOs' capacity in realization of the NGO 2007-2009 12 GEF/UNDP information campaigns and improve communications with local Small grants community, governmental departments and other counterparts. Programme 6.5.5 NGOs participation in the society awareness raising on POPs . Campaign NGO 2007-2009 50 GEF/UNDP for raising public awareness by a number of seminars and round tables and Small grants wide information dissemination through mass media and by means of Programme leaflets and booklets. 6.5.6 Sharing information about POPs Public awareness campaign on POPs MoEW 2006-2007 - MoEW “Planet without POPs” 6.5.7 POPs information dissemination & networking of scientific publications, MoEW, MoAF, 2006-2007 - MoEW, MoAF, developed projects, seminars and scientific forums on POPs Web-page of MoH, MoEE MoH, MoEE MoEW. 6.7. Reporting (Article 15 ) Report development for the progress on the NIP implementation in regard MoEW 2006 every 10 MoEW with to prevemtion/reduction of POPs releases from unintentional 5 years production

For the implementation of urgent measures and activities, envisaged in NIP in regard to POPs releases under the preliminary financial needs assessment approx. 1 774 000 BGN (about 1 109 000 US $) are required. Due to the limited financial capabilities of the country to provide funding from state budget other sources shall be surched – private funding from companies-polluters, GEF, international donor programmes and intergovernmental agreements.

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3.4. DEVELOPMENT AND CAPACITY-BUILDING PROPOSALS AND PRIORITIES

The implementation of the POPs NIP will require capacity strengthening in both technological/ laboratory infrastructure and human resources/qualification raising as wll as management capacity building. The high priority areas for NIP implementation resources needs are summarized below: 3.4.1. TECHNOLOGICAL & LABORATORY INFRASTRUCTURE Construction of National Centre for treatment of hazardous waste Taking into account the requirement for establishment of adequate system of disposal facilities and installations the necessity of construction of National Centre for treatment of hazardous waste is corroborated. The centre will be composed of installation for incineration, facility for physical and chemical treatment, facility for solidification, recycling, landfill for hazardous waste, landfill for asbestos, laboratories, facilities for waste acceptance and storage. The national infrastructure for disposal of hazardous waste will include also regional landfill and transfer stations for hazardous waste serving the National centre. Construction of laboratory infrastructure for analisis and determination of Dioxins/Furans in environment media and delivery of necessary equipment, personnel appointment, and training and accreditation of laboratories. Strengthening capacity of accredited laboratories for PCBs & HCB control in waste gases & waters, soils and food. Accreditation of Laboratory for carryng out determination of PCBs/PCTs in oils within the MoEW’s system. Construction of new centralized warehouses for storage of obsolete pesticides - Minimization of the risk to the environment and human health arising from old unrepaired warehouses for obsolete and out-of-date pesticides is a high priority task. This necessitates undertaking of permanent measures for improvement of the conditions for storage of these wastes and for their subsequent appropriate final disposal. Handling, collecting, repacking, transporting and storing in an environmentally sound manner of obsolete pesticides in newly constructed or repaired centralized and municipal storages facilities or capsulation in BB-cubes is a priority activity for risk reduction to the environment. The export of the obsolete pesticides, especially those consisting of or contaminated with POPs pesticides, also can be acceptable solution due to the lack of appropriate facility for disposal in the country. The financing of the activities for sanitation of abandoned sites for storage of obsolete pesticides constituting highest risk will be provided by the Enterprise for Management of Environmental Protection Activities, the funds of the Ministry of Agriculture and Forestry and the municipalities on whose territory the sites are located. Providing necessary storage sites for safe storage of phased out PCBs equipment and waste, containing PCBs. The limited use of polychlorinated byphenyls (PCB), the lack of production of PCBs in the country and the ban on the import of PCBs containing materials and equipment since 1985 significantly reduced the scale of the problem for management of these waste. Nevertheless PCBs should be considered as a priority waste stream, which even in small quantities could cause significant damages to the environment and to the human health in case of improper management. With the adoption of Regulation on the requirements for the order and the manner of inventory, labeling and decontamination of equipment containing PCBs, as well as the treatment and transportation of waste containing PCBs(SG 24/21.03.2006), the harmonization of the national legislation with the requirements of Directive 96/59/EC and Stockholm convention had been implemented on the remove from use disposal of PCBs and the rules for management of these

243 waste streams had been laid down. The measures set in the PCBs regulation aim to ensure inventory of PCBs contaminated equipment in the country, its appropriate operation, phasing out such equipment within the deadlines fixed in the national legislation and the Stockholm convention and the subsequent storage and disposal of the waste. Inventory of in-use and phased out PCBs contaminated equipment. Establishment and processing data base on PCBs/PCTs waste The complete detailed inventory of PCBs contaminated equipment will be of significant importance for the planning and organisation of decontamination, collection, storage, and disposal. For this purpose a detailed inventory of PCBs in equipment – in-use and phased out and of fresh and waste oils, containing PCBs should be carried out. The achievement of this objective requires the persons engaged in the inventory to be qualified and properly trained. The information about PCBs contaminated equipment obtained from the inventory and the subsequent activities for collection and disposal of the waste will be included in a specialized database for equipment and for fresh and used oils, containing PCBs . Drawing up of plan and time schedule for disposal of PCBs waste The inventory of the PCBs contaminated equipment will be a base for development of a plan for gradual disposal of this type of waste. This plan should propose a schedule for phasing out the equipment and for disposal of the waste and to determine the responsibilities and the necessary funds for its implementation. Provision of technical capacity for treatment and disposal of PCBs containing waste It is envisaged that the construction of the National Hazardous waste disposal centre will finish in 2009-2014. Incinerations in the existing facilities after their proper reconstruction, construction of specialized facilities and the export of PCB for disposal in other countries are possible options for the period till 2014. The final decision requires detail planning and evaluation of the different possibilities in the context of the risks to the environment and the expenditures for disposal and looking for possibilities for external funding.

3.4.2. STRENGTHENING OF THE ADMINISTRATIVE CAPACITY OF THE INSTITUTIONS RESPONSIBLE FOR MANAGEMENT OF POPS The institutional and organizational frameworks at different levels of the POPs management are of high priority for the implementation of the legislation and the NIP. The MOEW will continue to coordinate at national level the POPS management activities including by establishment of procedures for effective interaction between the institutions engaged in the implementation of the different measures. The National Focal Point of the Stockholm convention shall be responsible for reporting on the NIP progress implementation every 5 years to the Secretariat of the Stockholm convention . Successful implementation of NIP activities will depend on proper coordination among different stakeholders.

3.4.3. PERSONNEL QUALIFICATION RAISING & TRAINING AND TECHNICAL RESOURCES FOR THE COPMPETENT INSTITUTIONS RESPONSIBLE FOR POPS MANAGEMENT The planning, regulation and enforcement of the POPs management legislation depend on the existing human resources in the responsible institutions. In order to support the implementation of the legislation, the competent authorities at national, regional, and municipal level need enough and well-trained personnel engaged with: - development and implementation of legislation, technical standards and guidelines for POPs management activities; - development of the long-term POPs management plan as a part of National Waste Management Programme ( NWMP), planning and implementation on national and regional level; - issuance of permits for activities with POPs waste and construction and operation of facilities for environmentally sound disposal;

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- control, inspections and monitoring of the installations that generate POPs releases and/or operate PCBs equipment; - initiation and enforcement of the measures for implementation of the legislation and the NIP for POPs; - collection, processing, analyzing and reporting of data; - preparation, development, assessment, realization and supervision of projects for NIP implementation activities set up in each POPs category Action plan, financed by GEF, EU funds and other bilateral and multilateral donor programmes. The implementation of the NIP for POPs will require improvement of the administrative capacity on national, regional, and local level. In order to ensure the supervision and control of the fulfilment of the NIP for POPs management, it is necessary the experts in RIEW and EEA to be trained on the NIP implementation measures and if required additional personnel in RIEW and EEA as well as in the other institutions engaged in the implementation of the NIP to be appointed. At the same time the experts working in the administration should have the necessary qualification. A couple of training workshops shall be organized for the experts at different levels. Seminars and workshops with wide participation of competent authorities for the enforcement of measures laid out in NIP and implementation assessment ; “Training of trainers” Workshops for the experts of state authorities responsible for the NIP implementation ; Training Workshop for the representatives of interested state authorities, municipal eco- experts, private sector professionals and NGOs for NIP implementation. The implementation of the legislation will require also provision of appropriate equipment for the state institutions necessary for performance of their functions. In medium term aspect an assessment of the available equipment should be carried out and the priorities and the funds for supply of new equipment have to be determined. Special attention should be paid to the equipment for sampling and monitoring, the laboratories, the collection and processing of the POPs data. The improvement of the administrative capacity will require provision of additional funds for the training personnel and provision of the necessary equipment and techniques.

3.4.4. PUBLIC PARTICIPATION AND AWARENESS RAISING ON POPS ISSUES The necessity of continuation of the intensive dialogue between the competent authorities and the stakeholders that has been involved in the NIP development during the last years is corroborated. This will contribute to overcome a variety of social and institutional barriers to the information exchange and to reach consensus for the implementation of the measures envisaged in the NIP for management of POPs. The campaigns for rising of the public awareness and the consultations with the stakeholder in POPs management activities will contribute to make correct decisions for the implementation of the NIP. Dialogue with the industry and the authority responsible on POPs management To achieve an exchange of information and a transfer of the knowledge in order to improve the effectiveness of the POPs management, the dialogue with the private sector is indispensable. It is of primary importance to: 9 inform the population and the industries on a regular basis and to involve them in the decision-making processes for POPs management issues; 9 the organization of training courses in POPs management; Development and implementation of long term communication and consultation with all stakeholders in POPs management The National campaign “For clean environment” and the competitions organized between municipalities, schools and NGO’s concerning the cleaning up of polluted sites, as well as the

245 regular dissemination of information materials, lead to raising of public awareness in the waste management issues. The present NIP for POPs management envisages the gradual extension of the scope of this well- applied programme and its development in the directions of provision of environmental training in schools on POPs issues with active participation of NGOs, involvement of the industry to participate in development of best ecological practices, conducting of information campaigns, etc. 9 Publication and wide dissemination of NIP for POPs ; 9 Publication of NIP for POPs on the WEB site of MoEW 9 Provision to the public of the available information on POPs/PCBs trough the information centre at Executive Environmental Agency and the existing Information centres at RIEWs; 9 Providing opportunities for public input, opinions and statements and raise questions & responses , addressing POPs/PCBs management through the Forum “Green Graphite” on the MoEWs Web site 9 Carrying out Information Campaigns by ecological NGOs for POPs effects on human health and the environment at regional level through projects, financed by GEF Small Grants Project 9 “POPs: Be careful”. Strengthening NGOs' capacity in realization of the information campaigns and improve communications with local community and other counterparts through projects, financed by GEF Small Grants Project; 9 NGOs participation in the society awareness raising on POPs Campaign for raising public awareness by a number of seminars and round tables and wide information dissemination through mass media and by means of leaflets and booklets. 9 Development of a Program to Disseminate Information and to Raise Public Awareness and carrying out “round-tables” discussions for public awareness raising on POPs effects oh human health and the environment with gender focus on young people and target groups of local communities and other counterparts; 9 Development of educational programs on POPs, preparing and editing suitable school text books for POPs; 9 Preparing of information materials for training the trainers – experts from competent state authorities; 9 Development, publication and dissemination of POPs popular brochures and leaflets for public awareness raising on POPs issues and their effects on human health and the environment; 9 POPs information dissemination & networking of scientific publications, developed projects, seminars and scientific forums on POPs on Web-page of MoEW. 9 Development and strengthening NGOs public relation in the process of development of projects, concerning POPs management and for their effects on human health and the environment. 9 Development and implementation, especially for women, children and the least educated, of educational and awareness programs on POPs, as well as on their health and environmental effects; 9 Sharing information about POPs Public awareness campaign on POPs “Planet without POPs”; The communication objectives can be split up in two categories: awareness raising and stakeholders’ training and communication. The awareness raising has a long-term objective to achieve change in the behaviour of the population by awakening of the environmental risks related to the POPs issue, and their effects on human health and the environment;

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The communication and the training are a process by which on the one hand, information is provided to the stakeholders and on the other hand ideas and actions, concerning POPs management are exchange and assessed. The education and the consultation with the stakeholders, participating in POPs management activities will be important for the next years in the following directions: 9 facilitation of the consultations on the implementation and the subsequently updating of the NIP for POPs; 9 provision of information concerning the POPs management; 9 obtaining of information, feedback and support by the stakeholders concerning the POPs management; 9 facilitation of the formulation, consultation, approval, and implementation of the activities included in the NIP concerning the financing and reimbursement of the costs.

3.4.5. DRAW UP PROJECT PROPOSALS AND APPLY FOR PROVIDING FUNDING FROM GLOBAL ENVIRONMENT FACILITY In the country, good prerequisites for integration of NIP for POPs in various fields of the general state policy exist. It is necessary definite evaluations and activities for its practical implementation, for example planning and enforcement of heterogeneous actions by various state and public organizations, producers, traders and consumers. To achieve the convention’ objectives, of essential importance shall be the implementation of measures over the control of POPs and the accomplishment of some investment projects for POPs disposal and destruction in an environmentally sound manner. Efforts shall be put to use the existing financial mechanism for providing funding from Global Environment Facility (GEF) and bilateral, regional and multilateral twinning programmes to support various activities and measures set up in the NIP. For this purpose with priority Project Proposals shall be drawn up and Bulgaria shall apply for providing funding from Global Environment Facility (GEF) and external co-financing.

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3.5. TIMETABLE OF THE POPS ACTION PLAN IMPLEMENTATION AND MEASURES OF SUCCESS

TIMETABLE BY YEARS, STARTING FROM 2006 POPS ACTION PLAN IMPLEMENTATION

YEARS Short term by 2010 Middle term by 2020 Long term by 2028 ACTIVITIES 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 1. Institutional management and coordination ♦ ♦ ♦ 1.1. Reporting and where appropriate updating the Action plan ♦ ♦ ♦ ♦ ♦ 2. Regulatory strengthening measures ♦ ♦ ♦ ♦ ♦ 2.1. Duly amending and supplementing of legislative acts and regulations in case of including new POPs pesticides in Annex A of Stockholm convention. 2.2. Development of adapted “Methodology for Determination of the Emissions of Dioxin and Furan Releases in the Air” 3 Efficacy enforcement of existing legislation 3.1. Application and enforcement of EU Reference measurement methods/Standards for POPs pesticides analysis. 3.2. Application and enforcement of existing legislation in the country, regulating the management PCBs 3.3 Exercising permanent control over the implementation of existing admissible emission norms for Dioxins/Furans released from large stationary sources. 4. Development of strategies and plans ♦ ♦ 4..1 Updating of NIP ♦ ♦ ♦ ♦ 4.2. Development of appropriate Programme for identifying obsolete pesticides stockpiles, consisting of or contaminated with POPs 4.3. Development of a plan for environmentally sound management of obsolete pesticide stockpiles 4.4. Development of Plan for ESM of PCBs: phasing out in-use PCBs equipment; safe storage of phased-out PCBs equipment and wastes, containing PCBs – insulating, hydraulic and heat transmission oils; ES disposal of PCBs equipment and waste; 4.5. Prepare short-term plan for labeling and retrofilling of in-use PCB equipment 4.6. Prepare long-term plans for phase out of in-use PCBs equipment, dismantling, decontamination, safe storage, appropriate disposal ahead of national legislation deadlines 4.7. Development of a Plan for the reduction/prevention of the releases from unintentional production of Dioxins/Furans, PCBs and HCB. 4.8 Implementation of Action plan for gradual elimination/disposal of obsolete pesticides 4.9 Implementation of Action plan for PCBs in equipment and oils 5. Methodical and technical support ♦ ♦ 5.1. Development of Obsolete Pesticides Storage and Stock control Manual and Guidelines for the environmentally sound Management of obsolete and unwanted pesticides

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5.2. Development of technical Manual for carrying out detailed inventory of PCBs equipment and Practical Guidelines for decontamination/clean-up and dismantling of equipment, collection and storage of PCBs waste oils 6. Institutional strengthening and improvement of technological and laboratory infrastructure 6.1. Evaluation of costs, required for NIP implementation ♦ ♦ ♦ ♦ ♦ 6.2. Building up laboratory infrastructure for analysis of PCBs in oils, including delivery of necessary equipment, training of personnel and lab accreditation. 6.3. Strengthening of laboratory infrastructure for control and analysis of PCBs in air, water, soils, food, and wastes, and accreditation of sufficient number of labs, including delivery of necessary equipment, training of personnel. 6.4. Accreditation of laboratories for analysis of PCBs in oils 6.5. Construction of new centralized and municipal storages facilities for storage of obsolete pesticides or capsulation in BB-cubes 6.6. Construction of National hazardous waste disposal centre and corresponding ♦ ♦ infrastructure for hazardous waste landfilling 6.7 Provision of the necessary storage sites for safe storage of out-of-use PCBs equipment and oils 7. Ensuring sufficient and reliable data for POPs management 7.1. Annually updating of the data base for obsolete pesticides stockpiles 7.2. Carrying out detailed inventory by Sampling and analysis for POPs content ♦ determination of 2308 t “unknown” obsolete pesticides, stored in 477 operating unrepaired storages to ensure identifying of assumed stockpiles of approx. 22,3 - 22,8 POPs pesticides and 30 t mixtures, containing or contaminated with POPs 7.3. Carrying out of detailed inventory of PCBs in equipment – operating andphased out ♦ equipment and oils, containing PCBs. 7.4. Establishment of data base for in-use and phased out equipment with PCBs ♦ concentration above 0, 05 % by weight and volume above 5 dm3 andwaste, containing PCBs and its regular updating. 7.5. Sofware for data-base for PCBs equipment – type, oil trade mark, year of production, ♦ manufacturer and holder. 7.6. Annual updating of data base for Dioxins/Furans, PCBs & HCB in emissions . 8. Gradual phasing out of in-use equipment – transformers and capacitors , safe storage and disposal of equipment and oils,containing PCBs 8.1. Phasing-out of equipment with PCBs concentration above 0,05 % by weight and ♦ volume above 5 dm3 ; 8.2. Phasing-out of Equipment with volume above 5 dm3 and PCBs concentration ♦ between 0,005% and 0,05 % by weight 8.3. Export for disposal of 20,12 t waste PCBs transformer oils abroad ♦ 8.4. Export for disposal of 844 phased out PCBs capacitors abroad ♦ 8.5. Disposal and recycling of highest risk equipment with PCBs concentration above ♦ 0,05 % by weight and volume above 5 dm3 8.6. Disposal and recycling of PCB equipment with volume above 5 dm3 and PCBs ♦ concentration between 0,005% and 0,05 % by weigh

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9. Safe storage and environmentally sound disposal/elimination of POPs pesticides 9.1. Repairing of old and construction of new centralized storage houses for obsolete pesticides 9.2. Old storehouses demolishing and sanitation of storage sites, disengaged from old ♦ storehouses and remediation of areas and soils around them. 9.3 Removal and disposal abroad of 2308 t of “unknown” obsolete pesticides, stored in ♦ 477 unrepaired in-use warehouses and contaminated soils 9.4. Partial disposal of obsolete pesticides, identified as consisting of or contaminated ♦ with POPs abroad. 9.5. Gradual disposal/elimination of obsolete and out-of-date pesticides stockpiles ♦ 10 Identifying and sanitation of contaminated sites with POPs pesticides 10.1. Sanitation of storage sites, disengaged from old storehouses and remediation of areas ♦ and soils around them. 10.2. Sanitation of sites, where PCBs equipment was located. ♦

11 Reduce Dioxin/Furans releases from unintentional production or remove the emissions sources. 11.1. Including within the provisions of Integrated Pollution Prevention and Control ♦ permits the requirements of Best available techniques (ВАТ) and Best environmental practice (ВЕР) with the goal to reduce and limit the POPs releases from unintentional production in energy, metallurgy, chemical & cement industry, existing firing installations for burning of solid municipal wastes , etc., where it is possible. 12 Research, development and monitoring ♦ 12.1. Carrying out representative investigations of PCBs accumulation levels in breast ♦ milk and fat tissue in women – suckling mothers in the regions with high concentration of PCBs equipment 12.2. Carrying out representative investigations for D/Fs and PCBs levels of accumulation ♦ in breast milk and fat tissue in risky groups of population – suckling mothers especially in the regions of high concentration of industrial sources with potential for comparatively high formation and release of POPs 12.3 Carrying out representative investigations for Dioxin/Furans & PCBs content in ♦ chicken eggs in the regions close to the large thermal power stations (TPS) 13. Public Information, Awareness & Education 13.1. Development of Communication Strategy for public awareness raising for POPs ♦ effects on human health and the environment 13.2. Development of Educational and Awareness programs on POPs issues especially for ♦ women, children and the least educated 13.3 Raising students knowledge on POPs issues 13.4 Seminars and “Training of trainers” Workshops for the experts of MoEW, RIEWs on ♦ NIP implementation with participation of foreign experts 13.5 Training Workshops for state & municipal environment experts, industry ♦ professionals and NGOs over the implementation of measures envisaged in the NIP for POPs

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14 Provision of Public access and awareness raising on PCBs issues 14.1 Publication of NIP on the POPs Web page of MoEW. 14.2 Updating of POPs Web page on MoEW Web site, including all available information on POPs 14.3 Publication and dissemination of NIP for POPs 14.4 Provision to the public available information on POPs trough Information centers at MoEW, EEA and at RIEWs. 14.5 Providing opportunities for public input, opinions and statements and raise questions & responses , addressing POPs/PCBs management through the Forum “Green Graphite” on the MoEWs Web site. 14.6 Carrying out Information Campaigns by ecological NGOs for POPs effects on human health and the environment at regional level through projects, financed by GEF Small Grants Project 14.7 Development of a Project proposal “A Program to Disseminate Information and to Raise Public Awareness on the Effects of Persistent Organic Pollutants (POPs) on human health and the environment, with a Gender Focus on students from Universities in Bulgaria” 14.8 Development and strengthening NGOs public relation in the process of development of projects, concerning POPs management and for their effects on human health and the environment. 15 Development and exchange of educational and public awareness materials at the national for POPs and their health and environmental effects 15.1 Development, publication and dissemination of POPs popular brochures for their human health and environmental effects 15.2 Development, publication and dissemination of POPs popular brochures and leaflets for PCBs issues and their effects on human health among operators of PCBs equipment 15.3 POPs: Be careful. Strengthening NGOs' capacity in realization of the information campaigns and improve communications with local community, governmental departments and other counterparts. 15.4 NGOs participation in the society awareness raising on POPs Campaign for raising public awareness by a number of seminars and round tables and wide information dissemination through mass media and by means of leaflets and booklets. 15.5 Sharing information about POPs Public awareness campaign on POPs “Planet without POPs” 15.6 PCBs information dissemination & networking of scientific publications, developed projects, seminars and scientific forums on POPs Web-page of MoEW.

Legend: ♦ Progress report

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3.6. PRELIMINARY ASSESSMENT OF THE FINANCIAL RESOURCES OF THE NATIONAL POPS MANAGEMENT ACTION PLAN A preliminary assessment of the financial resources required for the implementation of the present NIP for the management of POPs has been made, detailed in Annex 3. 3.6.1. FINANCIAL COST OF THE MINIMISATION AND NEUTRALISATION OF PESTICIDES AND PESTICIDE WAREHOUSES Different pesticide disposal and destruction methods exist, which explains the various processes and facilities, and their different construction and operating costs. Table 119 presents the destruction options under consideration, with a more detailed review in Annex 4. Table 119Comparison of the methods for neutralisation and destruction of obsolete and POPs pesticides Options Collection, Operating Total, Total Total Plant Total Total costs transportion, costs BGN/t OP, treatment construction costs, US $ neutralization of BGN/t t costs, costs, BGN Exchange rate warehouses, BGN BGN cleaning up of 1 US$ = 1.6 BGN sites, BGN/ t Destruction of Obsolete pesticides by five methods – Incinerator 1000 kg/h 680 1030,4 1710 7011 11988810 10345000 22333810 13958631 – Incinerator 300 kg/h 680 840,85 1521 7011 10663731 6808600 17472331 10920206 Physicochemical treatment 680 3067,8 3748 7011 26277228 8868100 35145328 21965830 – the Balbok AD company 234 1000 1234 7011 8651574 8651574 5407233 - incineration abroad 234 5800 6034 7011 42304374 42304374 26440233 - incineration abroad of OP stored in 477 unrepaired warehouses 234 5800 6034 2308 13926472 13926472 8704045 - incineration abroad of OP stored in unrepaired warehouses of bad status 234 5800 6034 1223 7379582 7379582 4612238 Neutralisation of Obsolete pesticides from BB cubes by three methods – Incinerator 1000 kg/h 427 1030,4 1457 4211 6135427 6135427 3834642 – Incinerator 300 kg/h 427 840,85 1268 4211 5339548 5339548 3337217 Physicochemical treatment 427 3067,8 3495 4211 14717445 14717445 9198403

3.6.2. FINANCIAL COSTS TO MINIMISE AND NEUTRALISE PCBS IN EQUIPMENT There are different methods for disposal and destruction of PCBs in equipment. The PCBs destruction technologies differ depending on the method chosen , which explains the various processes and plants, and their different construction and operating costs. Table 120 presents the destruction options under consideration, with a more detailed review in Annex 4.

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Table 120 Comparison of methods for neutralisation equipment and oils containing > 50 ppm PCBs Options Collection, Operating Total Total Total Plant Total costs, Total costs transporting, costs BGN/t quantity of treatment constructio BGN US $ draining of oil, BGN/t transformers/ costs, n cost, Exchange rate untwining, capacitors, BGN BGN crushing and and oils 1 US$ = 1.6 BGN scrapping, t levs/t

Disposal/distruction of equipment and oil containing > 50 ppm of PCBs Physico- chemical destruction + incineration 270 150 420 7955 3341100 15290800 18631900 11644937 Disposal abroad 375 2925 3300 7955 26251500 26251500 16407188 Disposal abroad of waste transformer oils 375 2925 3300 9,88 32604 32604 20378 Disposal abroad of 614 phased out capacitors 375 2925 3300 1400 4620000 4620000 2887500

3.6.3. FINANCIAL COSTS TO MINIMISE AND ELIMINATE POPS IN EMISSIONS Regarding the costs necessary for the minimization of POPs in emissions, and the need for specific data and different equipment prices for each particular case, no examples are available, but Annex 3 considers the existing processes for reduction of POPs in emissions.

3.6.4. FINANCIAL COSTS FOR SOIL REMEDIATION AND POLLUTED SITES DECONTAMINATION Table 121 presents a review of several different processes applicable for the treatment of sites polluted with pesticides. They are presented in more detail in Annex 3.

Table 121 Comparison of existing processes for treatment of sites polluted with pesticides Treatment Cost (per square Efficiency of Process period Treated medium1 yard)1 removal1 (months)2 Low-temperature 100-400 $ 0.75 soil, mud, sludge 82-98% desorption Incineration 300-1000 1 soil, mud, sludge >99.8% Biological 8.4-197 3.1 (ex situ) soil, mud, sludge, up to 99.8% restoration and groundwater Phytorestoration approximately 80 or no data soil, mud, sludge, 80% 60000-10000 $/acre and groundwater 1 for treatment of pesticide polluted environments 2 for treatment of 1,000 cubic yards of soil polluted with various organic substances

3.6.5. FINANCIAL COSTS FOR CONTROL AND MONITORING LABORATORIES The funds necessary to construct laboratory infrastructure, monitoring, and constant control of POPs in Bulgaria vary widely due to the direct dependency on the number of laboratories.

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However, funds have been provided for and are presented in POPs specific AP. The funds required for a lab to be equipped with necessary technics amount in average 2,5 – 3 million US $.

3.6.6. ALTERNATIVE SOURCES OF FINANCING The sources of financing are presented for each particular case in the ‘proposed funding sources’ section of the Specific action plans for each POPs category. 3.6.7. REQUIRED FUNDS TO IMPLEMENT THE NIP FOR POPS IN BULGARIA Based on the measures and activities envisaged in the NIP for the management of POPs, a preliminary assessment of the funds required for the successful implementation of NIP has been performed. The total budget required to implement all activities planned under the NIP exceeds 50 millions BGN (approx. 30 millions US $), excluding the costs needed for the construction of the National centre for treatment of hazardous waste (87 million BGN) and lab infrastructure for DIOX/Fs determination in environmental media (approx. 6 million BGN). To implement the most urgent activities related to reduce the negative impacts of POPs on human health and the environment , the Republic of Bulgaria requires funds amounting to 27 455 000 BGN (approx. 17 069 000 US $). The state budget could cover about 10%, mostly as contribution in-kind, providing necessary experts support, offices, technics (computer and copy equipment), communications (Internet, telephone, fax, mail services), office supplies, etc.

The Republic of Bulgaria can not cope alone with final solving of POPs and to meet the full incremental costs of NIP enforcement without international financial support, due to limited national funding available and the fact that Bulgaria is in Currency Board. To reduce the risk of POPs stockpiles impacts on human health and the environment urgent measures should be taken for safe storage and/or environmentally sound disposal abroad, due to absence of appropriate disposal facility in the country. For this purpose the Republic of Bulgaria needs to be supported by providing financial resources from GEF and other international, bilateral, regional and multilateral twinning programmes. The Republic of Bulgaria requires urgently funding amounting to 21,7 million BGN (approx. 13,6 million US $) for the following activities: For carrying out a detailed inventory and disposal abroad of 2308 t obsolete pesticides stored in 477 unrepaired operating warehouses – 14,7 million BGN (approx. 9,2 million US $); For carrying out a detailed inventory of PCBs equipment and wastes, containing PCBs and disposal abroad of 844 phased out PCBs capacitors and 20,12 t waste transformer oils, containing PVBs - 7 million BGN (approx. 4,4 million US $). For the implementation of the NIP for the management of POPs, it should endeavour to provide financial resources by attracting investments on international and national source funding scale, as well as to promote taking measures by the enterprises’ operators, intentionally or unintentionally producing and/or using POPs [construction of facilities for treatment and destruction of POPs, introducing the best available techniques (BAT) & the best environmental practices (BEP), etc. To enable Bulgaria fulfill its obligations under this Convention to meet the full incremental costs of NIP enforcement, potential financial resources to implement the measures set up in POPs Action plans shall be searched by attracting international financing by promotion of multiple-source funding approaches & arrangements, twinning programs and through other bilateral, regional and multilateral sources and channels . Efforts shall be put to use the existing financial mechanism for providing funding from Global Environment Facility (GEF) and bilateral, regional and multilateral finance resources. Project proposals on persistent organic pollutants shall be developed with priority and MoEW shall apply for providing funding by GEF.

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THIS WEB PUBLICATION IS EDITED BY MINISTRY OF ENVIRONMENT AND WATER WITH THE FINANCIAL SUPPORT OF UNITED NATION ENVIRONMENTAL PROGRAMME (UNEP) AND GLOBAL ENVIRONMENT FACILITY (GEF)

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